Sorry, forgot to state my previous comment was in regards to a ground-mount. 

Brian

> On Feb 1, 2022, at 12:19 PM, William Miller <will...@millersolar.com> wrote:
> 
> 
> Ray:
>  
> Thanks for that input.  I was hoping I was wrong.  I looked for that 
> discussion in the archives but could not find it.
>  
> William
>  
> Miller Solar
> 17395 Oak Road, Atascadero, CA 93422
> 805-438-5600
> www.millersolar.com
> CA Lic. 773985
>  
>  
> From: RE-wrenches [mailto:re-wrenches-boun...@lists.re-wrenches.org] On 
> Behalf Of Ray
> Sent: Tuesday, February 1, 2022 10:11 AM
> To: re-wrenches@lists.re-wrenches.org
> Subject: Re: [RE-wrenches] Rapid Shutdown for Off-grid systems
>  
>  Ground mounts do NOT require RSS.  We hashed this out years ago on the 
> Wrenches list, when NEC 2017 came out.
> 
> See Figure 690.1(B) Note (2): " The PV system disconnect in these diagrams 
> separates the PV system from all other systems".
> 
> Thus, the PV disconnect is defined as the transition point from the PV system 
> to all other systems, like battery or inverter systems. The installer/ 
> designer decides where to put that disconnect.  I usually put it on the wall 
> before it goes into the building, and I have never had an inspector question 
> that.
> 
> Thanks,
> 
> Ray Walters
> Remote Solar
> 303 505-8760
> On 2/1/22 10:06 AM, William Miller wrote:
> Jay:
>  
> Here is the text from 2017:
>  
> 690.12 Rapid Shutdown of PV Systems on Buildings. PV
> system circuits installed on or in buildings shall include a rapid
> shutdown function to reduce shock hazard for emergency
> responders in accordance with 690.12(A) through (D).
>  
> Exception: Ground mounted PV system circuits that enter buildings, of
> which the sole purpose is to house PV system equipment, shall not be
> required to comply with 690.12.
>  
> The wording is interesting.  The requirement is directed at “PV system 
> circuits…”, not PV arrays.  The passage does not specify where the PV feeding 
> those circuits is located, it just addresses where the circuits are, 
> specifically “in or on a building.”
>  
> The only circuits that are exempt are those feeding a building that serves 
> only one purpose, to house PV equipment.  For circuits that enter building 
> with other uses—homes, garages, barns, workshops, etc.-- it would seem there 
> is a requirement to have rapid shutdown systems (RSS).
>  
> Reading through the rest of the section, I don’t see any language that gets 
> us out of the requirement to reduce voltages to less than 80 volts within 30 
> seconds inside the array boundary, as in module level shutdown, regardless of 
> roof-top or ground-mount.  Although the 2020 code includes some differing 
> language, I don’t see it as exempting ground mount systems.
>  
> The moral of the story is this:  For ground-mounts:  either install RSS or 
> put your equipment (inverters, charge controllers, batteries, BOS) in a 
> separate building housing only that equipment.
>  
> I don’t necessarily like the requirement, but I think it exists.  Jay, or 
> anyone, please, please tell me I am reading this incorrectly. 
>  
> By the way, regarding battery circuits, here is a quote from a post by Bill 
> Brooks on March 16, 2016:
>  
> In the 2017 NEC, we were very careful to carve out all batteries and loads,
> that were previously part of PV systems, and place them in their own
> articles.
>  
> I have not read through the battery sections of the code to verify this, I am 
> taking Bill at his word.
>  
> William Miller
>  
> Miller Solar
> 17395 Oak Road, Atascadero, CA 93422
> 805-438-5600
> www.millersolar.com
> CA Lic. 773985
>  
>  
> From: Jay [mailto:jay.pe...@gmail.com] 
> Sent: Tuesday, February 1, 2022 6:07 AM
> To: will...@millersolar.com; RE-wrenches
> Subject: Re: [RE-wrenches] Rapid Shutdown for Off-grid systems
>  
> 2017 code has a specific exception/clarification for ground mount solar that 
> it does not need RS. 
> It’s in the first line after 690.12
>  
> Jay
>  
> 
> On Feb 1, 2022, at 12:13 AM, William Miller <will...@millersolar.com> wrote:
> 
> 
> Jerry:
>  
> Yes it is required.  Rapid Shutdown:  NEC 690.12.  All buildings except 
> dedicated solar buildings.  Read it and weep.
>  
> William
>  
> Miller Solar
> 17395 Oak Road, Atascadero, CA 93422
> 805-438-5600
> www.millersolar.com
> CA Lic. 773985
>  
>  
> From: Jerry Shafer [mailto:jerrysgarag...@gmail.com] 
> Sent: Monday, January 31, 2022 7:21 PM
> To: William Miller; RE-wrenches
> Subject: Re: [RE-wrenches] Rapid Shutdown for Off-grid systems
>  
> William
> Are you sure RSD is required on a non habitable building, historically its 
> not required. Now that being said we use fire raptor with the best results, 
> yes it takes an extra conduite and might require a button and power supply 
> depending on inverter application.
> Jerry
>  
> On Mon, Jan 31, 2022, 9:57 AM William Miller <will...@millersolar.com> wrote:
> Friends:
>  
> It is quite rare for us to install off-grid systems on roof-tops.  We have 
> one coming up with about 20kW on a large barn roof.  This will be our first 
> off-grid with a module-level rapid shutdown requirement.  I see no exemptions 
> from RSS for off-grid systems in the code.  I have looked at the options and 
> this is what I have found:
>  
> 1.   Fire Raptor
> 
> 2.   Tigo TS4-F
> 
> 3.   AC coupling with micro-inverters or optimizers
> 
>  
> No one of these approaches seems ideal.  The fire raptor requires extra 
> wiring for control leads.  The Tigo requires a wireless control system which 
> worries me about reliability.  With AC Coupling systems floating the proposed 
> AGM batteries may be awkward.  Furthermore, with AC coupled systems one 
> cannot charge batteries unless the mini-grid is operational, a big problem.
>  
> Have any of you implemented module-level RSS on a battery-based inverter 
> system?  I looked in the archives and found no threads that apply.  Thank in 
> advance.
>  
> William Miller
>  
>  
>  
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