William,

            I STILL fee like RSS is, as implemented by code and product development is a lousy solution to a very small problem. There are other simple safer less expensive, lower maintenance measures than can be taken to protect first responders from danger. Just one example with string inverters and thus higher voltages on the roof is mandate that after the combiner box that's located within a foot of the array route the metal conduit off the roof directly behind it into the attic straight down to the joists perpendicular to the roof plane.

            And then train, if even necessary, the fire responder on the roof anxious to plunge his saw into the roof to not vent through the array. I believe this is referred to as common sense. Has this ever happened anyway?  Has anyone ever been electrocuted in any type of first responding situation due to contact with voltages produced from an array?  If so, we have to also consider damage or harm done by the RSS excess wiring and equipment failures.  Of course micros are inherently "safe" from an RSS standpoint though there are more connections and equipment failure points on the roof and in our mountainous territory that means more often steeper metal roofs. Whew, another whole issue.

        I realize that the DC run from the array combiner to the inverter is still hot...maybe require that run to be in red metal conduit labelled "Danger, Always energized"? Yes, I'm still a string inverter guy.

            With NEM3 in full swing and the federal government now on the solar warpath we certainly won't have to 'worry' about a big rush of installs in PG&E/California area which is most of the state.  You thought resi rooftop solar was just for the well-off before, NEM3 insured that it will remain that way. Maybe this will give the regulators time to reconsider RSS.

Bill


Feather River Solar Electric
Bill Battagin, owner
4291 Nelson St. (Shipping)
5575 Genesee Rd. (USPS, UPS)
Taylorsville, CA  95983
530-284-7849, 258-1641(cell)
CA. C10 Lic # 874049
Solar Powered since 1982
Home of the Sunny Side Up

On 3/27/2025 5:05 PM, William Miller via RE-wrenches wrote:

Wally, Todd:

I have been pondering this discussion since it first appeared.  My conclusion is that you both have valid points to make:

·There are forces at work to make it harder for people to generate their own power and take revenue away from established corporations.  Large utilities did not initiate net metering, they were forced to do so by legislation and I am sure they would like to go back to being the only energy producers in their service area.

·Not every new hurdle we face is a product of these forces.  Some are driven by legitimate safety concerns.

If we lump these two points together and don’t offer reasoned, evidence-supported claims to our arguments, we can look like conspiracy theorists.

The solution, in my humble opinion, is to look carefully and dispassionately at the problems we face, back our conclusions with facts, and communicate our concerns clearly and effectively to the public, to our customers and to legislators and decision makers.

If there is a legitimate safety concern, we need to ask ourselves: Are the proposed solutions realistic?  If the solutions are draconian, unreasonably difficult or ineffective, then we are not resolving the safety issue. This does not always mean dark forces are conspiring against us.  It may be that we need to rethink a given solution.

The original discussion was about RSS.  My view has been changed by the discussion.  I have limited experience with RSS systems that are not part of an optimizer or micro-inverter system.  I have been fortunate that none of my RSDs have burst into flames, but there is credible evidence this has happened.  We have seen first-hand testimony that fire responders have not been adequately trained to activate RSS, making it useless.

I disagree with the need to put RSS on ground mounted arrays. They are required if the feeder enters a building that has any use other than to house solar power equipment.  If you provide an external disconnect, requiring RSS seems totally unnecessary.

Furthermore, UL3741 has me really scratching my head.  The original RSS requirements specified any voltage above 30 as being hazardous.  Then it became 80 volts.  Now with UL3741, up to 160 volts is safe?  I am reading an article <https://www.mayfield.energy/technical-articles/ul3741/> that says 1,000 VDC may be allowed.

It seems we have a huge credibility problem here.  There is no consensus on what voltages are unsafe and we have safety equipment not up to the task.  This credibility problem looks like a conspiracy but it be more accurate to call it a competency issue.  The regulators have been quick to mandate without a clear understanding of the safety thresholds and manufacturers have been quick to fill a market gap with inadequate products.

It is a shame Ms. Hren did not respond to my questions about how this all came about.  I don’t mean to put her on the spot but she offered her credentials as a member of the code making panel.

Getting back to my main point, it is frustrating navigating the complicated regulatory and technical landscape that PV contracting has become.  If we want to advocate for ourselves, we need to communicate clearly and calmly supported by facts.  Labeling the problems as a conspiracy won’t win any arguments.

Sincerely,

William Miller

Miller Solar

17395 Oak Road, Atascadero, CA 93422

805-438-5600

www.millersolar.com <http://www.millersolar.com/>

CA Lic. 773985

*From:*RE-wrenches [mailto:[email protected]] *On Behalf Of *Wallace Stahle via RE-wrenches
*Sent:* Wednesday, February 19, 2025 10:12 AM
*To:* RE-wrenches
*Cc:* Wallace Stahle
*Subject:* Re: [RE-wrenches] No Mistake Conspiricy?

So Todd,

What part of the idea or premise that an industry which produces, distributes and sells electric energy to end users at great profit, in PG&E's case at least, desires to exclude self generators from their grid and plans, lobbies and in fact conspires with other industry stakeholders to tilt the ground rules in their favor by way of the CA PUC is ”IDIOTIC”?

To think an investor owned utility selling energy to end users is not working to limit those same end users from benefiting from self generation is naive at least. Or even idiotic maybe.

Can you further define what part of this idea is idiotic vs rational on the utilities part to limit self generation?

I understand this topic is not specific to wrenching and may not belong on this list but given that getting interconnection agreements seems to be critical to the list it may be a topic worth considering.

Respectfully

Wallace Stahle

Future Electric Energy Co

PO Box 236

Willits, CA 95490

707-459-0474

Lic.#C10-762093

[email protected]

    On Feb 18, 2025, at 9:38 AM, Todd Cory via RE-wrenches
    <[email protected]> wrote:

    *Can we please keep these idiotic conspiracy theories off this list.*

    *Thank you...**


    *

    On Tuesday, February 18, 2025 7:13am, "Drake Chamberlin via
    RE-wrenches" <[email protected]> said:

    Hi David,

    RSS is no mistake. The War on Solar is real. Due to a recent
    computer crash, I am having problems finding my links documenting
    the intentional attack on PV from the Koch Brothers and the
    utility industry in general. I will check on another computer that
    may still have the information. It is at a different location.

    I went on the Wrench list with my concerns when this was first
    proposed, until I was told to stop. Individual homeowner solar is
    viewed as a big problem for utility profits. There are other ways
    to safeguard firefighters.

--
    Cheers,

    Drake

    /Drake Chamberlin/

    /Athens Electric LLC/

    /Ohio Electrical Contractor’s License 44810/

    /NABCEP Certified PV Installation Professional/

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