To change this, we need to recognize we are "fighting City Hall", and I doubt the CMP will be motivated to make changes on their own.  Maybe this has always been more political than technical, but it seems that those who are opposed to the current requirements need to make it known through the formal processes. The CMP is required to respond and in that response we can learn of their reasons for not accepting any changes, or the changes they would be willing to consider.  I just don't see things changing otherwise.

On 5/7/2020 10:18 AM, James Jarvis wrote:
If first responders are the point of all the rapid shutdown, there needs to be better exemptions. I personally have a 20kW solar array on a 100 year old unused barn at my farm. The roof is at 50 degrees slope and needs a 60ft boom lift to access. There was significant extra expense and effort for the rapid shut down. And there is absolutely zero chance that a first responder would do anything other than watch the barn burn. And now I have an array that needs a $1,000 piece of rental equipment to get to the back of any module.

There is a big difference between the stuff that is in big cities and what is in rural and what is in remote locations. For my telecom customers in Alaska and Antarctica, what is the point of decreasing reliability by putting module level electronics on solar arrays that require a multiple hour helicopter flight to get to. That's not protecting anybody other than the MLPE manufacturer's profit.


-James Jarvis
APRS World, LLC
+1-507-454-2727
http://www.aprsworld.com/


On Thu, May 7, 2020 at 8:43 AM Christopher Warfel <cwar...@entech-engineering.com <mailto:cwar...@entech-engineering.com>> wrote:

    I believe Rapid Shutdown was mostly a solution looking for a
    problem.   The only way I see this becoming "reasonable" is to
    present "grievances" to the Code Making Panel WITH a solution for
    their consideration.  Based on experience from being part of an
    outreach program that taught approximately 10k firefighters over
    four years, I have asked that they add to the Directory, the
    language that states what type of solar electric system is on site
    (Microinverter, dc optimizer, string, multimode, grid isolated) so
    that First Responders don't have to guess.  I realize this is
    different than MLPE, but it targets the person who Rapid Shutdown
    came into being for, and that was the First Responder.   Chris


    On 5/6/2020 10:37 PM, Ray wrote:

    Spending more time on the roof, while putting more equipment and
    parts to meet MLPE, means more trips up the ladder, which
    increases, not decreases the #1 worker safety danger: Falls. 
    Please correct me if I have somehow misunderstood this, but MLPE
    is not making installers safer based on OSHA information
    provided. Also after installation, which system is more likely to
    require workers to return to work on the roof, pulling up
    modules, trying to find problem equipment?  More connections is
    More safe?  Really?  I haven't had to climb back up on the roof
    on any of my older, lower voltage off grid work in almost a decade.

    Once again, MLPE has its place, (larger systems, multiple
    subarrays, higher voltage) but we should have sensible exemptions
    as have been mentioned already.  We are endangering ourselves and
    our employees needlessly, to comply with 690.12.

    Ray Walters
    Remote Solar
    303 505-8760
    On 5/6/20 8:41 PM, drake.chamber...@redwoodalliance.org
    <mailto:drake.chamber...@redwoodalliance.org> wrote:

    Interestingly enough, the data on the link
    
<https://www.osha.gov/pls/imis/AccidentSearch.search?p_logger=1&acc_description=&acc_Abstract=solar&acc_keyword=&sic=&naics=&Office=All&officetype=All&endmonth=05&endday=05&endyear=2002&startmonth=05&startday=05&startyear=2021&InspNr=>
 provided
    shows accidents from gas explosions, falls, health problems and 
    industrial injuries. None of these incidents could have been
    prevented by module level power electronics. This is typical of
    the data that I've seen so far.

    ---


    On 2020-05-06 17:22, Martin Herzfeld wrote:

    There could be an issue of encouraging MLPE for worker safety?
    1.  This is data involving incidents with workers in the OSHA
    Fatalities and Catastrophe Investigation Summaries found here:
    
https://www.osha.gov/pls/imis/AccidentSearch.search?p_logger=1&acc_description=&acc_Abstract=solar&acc_keyword=&sic=&naics=&Office=All&officetype=All&endmonth=05&endday=05&endyear=2002&startmonth=05&startday=05&startyear=2021&InspNr=
    2.  In the past I've observed an arc fault at the module level
    with traditional string systems without a listed arc-fault
    circuit interrupter NEC/CEC 690.11. The function in NEC/CEC
    690.12 would be - to _reduce the shock hazard _- for /emergency
    responders/ or /firefighters? (NEC 2020)./  However, I've
    observed thermal events in the panelboard with plans and
    workmanship issues.
    On the other hand, falls are the #1 reason for incidents in the
    construction industry.
    All the best,

    Martin Herzfeld, Interstate Renewable Energy Council (IREC)
    Certified Master Trainer ™ for Photovoltaics (PV) Installation
    Professional #IREC 10037
    Contract Training Provider (CTP)
    Adjunct Professor, Energy

    California Solar & Electrical Contractor License  #00833782 
    C46, C10, D56, D31, C-7 - Since 2004
    Solar, Electrical, Trenching, Pole Installation & Maintenance,
    Instrumentation

    Contract Solar (PV) Technical Inspector - 3rd Party Inspections
    Underwriters Laboratories (UL) Certified PV Installer #17, OSHA 30
    OSHA-Authorized Construction Trainer #32-0105338
    CompTIA Certified Technical Classroom Trainer (CTT+)
    #T3NSZCNBBKB4QTQG

    * Professional Member, International Association of Electrical
    Inspectors #7035507 - Since 2006
    * Accredited and Registered North American Board of Certified
    Energy Practitioners (NABCEP) Continuing Education (CE)
    Training Provider

    On Thu, Apr 30, 2020, 8:29 AM
    <drake.chamber...@redwoodalliance.org
    <mailto:drake.chamber...@redwoodalliance.org>> wrote:


        I would like to see real data on the fire risk of string
        inverters. Anecdotal problems are not data.
        The industry is definitely heading toward MLPE due to the
        rapid shutdown requirements. In many cases MLPE makes
        sense, in other cases it doesn't.
        Systems that are more cost effective and reliable can often
        be built by using string inverters.
        ---


        On 2020-04-29 22:05, Jason Szumlanski wrote:

            "Rapid Shutdown does not prevent fires."

            Not true. If the effect of RS is to steer the market to
            MLPE, I believe it has a significant impact on reducing
            fire risk. As one who has watched a DC conductor fire
            smolder out of control, I am sold on an AC module or
            microinverter architecture. While RS on a DC array
            doesn't necessarily reduce fire risk within the array,
            it still has the potential to reduce severity and
            spread. Nothing is going to prevent all fires. I get
            that. We're talking about risk mitigation when it comes
            to RS.
            As for "dependable string inverters," the one
            dependable feature is failure at least once in the
            module lifetime, accompanied by a shocking repair bill.
            I'm not a shiny object following kind of guy, but the
            writing is on the wall. MLPE is the future. Modular,
            serviceable, disposable if you will. Like it or not,
            Edison is going to lose this battle to Tesla (Tom vs
            Nikola). And I live less than 5 minutes away from Tommy
            E's winter home in Fort Myers, FL. And I "grew up" in
            the industry living off-grid in DC power. But AC
            distribution wins for safety at various scales.



            On Wed, Apr 29, 2020, 9:42 PM
            <drake.chamber...@redwoodalliance.org
            <mailto:drake.chamber...@redwoodalliance.org>> wrote:

                Rapid Shutdown does not prevent fires; it was
                originally drafted to allow firefighters to vent a
                roof without being hindered by energized PV arrays.
                This rule was expanded to include other DC wiring
                from PV sources.

                As for PV safety, I'd like to see some significant,
                statistical evidence that shows there is a major
                fire danger from PV relative to other sources. A
                fire from a solar array gets a lot more press than
                one from a gas leak, bad wiring or an ash tray
                emptied into a wastepaper basket.

                Large public buildings should have all the
                protection that is available. Does one size fit all?

                Would it be reasonable to allow residential
                installations under 12 kW, with 1/4 of the roof
                adjacent to the array available for venting, to be
                excepted from 690.12? What about sparsely occupied
                commercial buildings with ample roof area open for
                ventilation?

                Many of us have chosen to work with renewable
                energy technology to lessen the harms caused by
                fossil fuel extraction and combustion. The need for
                non-carbon based energy sources has become
                extremely clear.

                The old string inverters still chug along year
                after year, with little or no maintenance. Someone
                must pay for the ongoing maintenance of module
                level electronics. Dependable string inverter
                systems should be allowed unless statically
                significant danger can be demonstrated.

                Drake

                ---


                On 2020-04-29 16:01, Jason Szumlanski wrote:

                    I have been to several PV fires for string
                    inverter systems, both commercial and
                    residential, and have seen many DC systems at
                    serious risk of fires or in various stages of
                    melted insulation and connectors. Most of these
                    systems have exhibited good to excellent
                    workmanship. Things just went wrong. Some
                    were traceable to animal damage, wind, or other
                    unmitigated factors, and some were unexplained.
                    I disagree that there isn't justification for
                    rapid shutdown.
                    In my opinion, what we need is some additional
                    innovation and competition in the MLPE space.
                    Reliability is clearly a key factor, but there
                    is no denying that MLPE has added safety
                    benefits among other benefits. And if you do
                    enough volume and set up your business for
                    efficiency (standardization of product
                    offerings), MLPE isn't much more expensive. It
                    becomes a negligible cost relative to the
                    benefit. The value proposition is easy to
                    convey. There are limits to this, but for the
                    majority of residential and small commercial
                    installations, MLPE has become the de facto
                    standard around here. String inverters are
                    dinos, and replacing 8-12 year old transformer
                    based inverters is many times more annoying
                    than some MLPE swaps. I will admit that the
                    roofs around here are pretty easy to walk, so
                    that is a factor that might not apply to you.
                    If you go under due to manufacturer product
                    failures, you are not writing your contracts
                    right or not charging enough for service issues
                    beyond your control. I believe that's a red
                    herring. You might suffer some reputation
                    damage, but for someone that has been
                    installing MLPE for over a decade, that is
                    totally manageable. Consumers find a service
                    call to replace MLPE a LOT more palatable than
                    a surprise inverter replacement that could cost
                    thousands of dollars. People just don't plan
                    for that.
                    Regarding rapid shutdown devices, I have also
                    come across a few that "someone" has bypassed
                    around here. I don't know if they were never
                    installed properly or disabled/bypassed due to
                    failure. It seemed suspicious to me at the
                    time. I remember that it made me wonder what
                    good is a rapid shutdown device if it is easily
                    defeated? That's another argument for MLPE. It
                    has pretty failsafe MLPE functionality.
                    Jason Szumlanski
                    Florida Solar Design Group

                    On Wed, Apr 29, 2020 at 10:59 AM
                    <drake.chamber...@redwoodalliance.org
                    <mailto:drake.chamber...@redwoodalliance.org>>
                    wrote:

                        Clearly, rapid shutdown increases cost and
                        reduces reliability. Given the excellent
                        safety record of PV, prior to rapid
                        shutdown being required, it is unnecessary.
                        The few anecdotal incidents of PV fires
                        were not enough to justify the requirement,
                        especially on smaller systems.

                        According to a friend who worked for a
                        local installation company that went under,
                        a big part of the reason for their failure
                        was the chronic replacement of
                        microinverters and optimizers.

                        What steps can be taken to create some
                        balance in the rapid shutdown requirements
                        that are in the NEC?


                        ---


                        On 2020-04-29 07:27, Sky Sims wrote:

                            So far rapid shutdown has been a
                            nightmare. It's added a lot of cost for
                            no measurable benefit.
                            Using always off devices like midnight
                            solar and Tigo makes it impossible to
                            test open circuit voltages. Which opens
                            the door to tons of problems when
                            commissioning systems.
                            Also we've been trying out midnight
                            Solar's product and have had an absurd
                            failure rate. Which means lots of truck
                            rolls and troubleshooting and system
                            downtime. They send replacement product
                            but they aren't paying for the lost
                            weeks of productivity.
                            We have Tigo product in hand and are
                            deciding which project to try it on.
                            But our big concern about using it is
                            not only the inability to confirm open
                            circuit voltage of the strings but also
                            the way panels bypass if the device
                            doesn't allow the panel to connect
                            properly. Both of these features are a
                            recipe for problems and potential
                            troubleshooting nightmares. The
                            warranty from Tigo doesn't cover our
                            expense if the product fails. And
                            that's really what our reservations
                            about the product boil down to right
                            now. If we're on a job with 50 units
                            and one fails, the contractor or the
                            homeowner will be the ones eating the
                            expense of finding it and replacing it.
                            There has to be a better option.

                            Sky Sims
                            Https://EcologicalSystems.biz

                                On Apr 28, 2020, at 7:46 PM, Corey
                                Shalanski <coreso...@gmail.com
                                <mailto:coreso...@gmail.com>> wrote:

                                Now that 690.12 of the /NEC/ 2017
                                has been in effect for several
                                years, I am curious how designers
                                and installers are meeting the
                                associated requirements with string
                                inverter-based systems (*not*
                                considering microinverters or DC
                                optimizers). I am generally a fan
                                of the KISS principle, and as best
                                I can determine the /Tigo/ TS4-F
                                device is one of the simplest
                                options currently available on the
                                market. What are others finding?
                                I'd love to hear about favored
                                options for complying with rapid
                                shutdown. Any success stories? or
                                better yet, any early failures?
                                --
                                Corey Shalanski
                                Jah Light Solar
                                Portland, Jamaica
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