Statement of Problem and Substantiation for Public Comment...Public Comment No. 710-NFPA 70-2018 [...

352
Public Comment No. 2209-NFPA 70-2018 [ Global Input ] The Correlating Committee directs Panel 4 to review all references to Article 310 under their purview. Article 310 has been divided into Article 310, Conductors for General Wiring, and Article 311, Medium Voltage Conductors and Cables for usability and clarity. Panel 4 shall appoint a task group to review all necessary references to verify their accuracy and submit Public Comments where necessary. This action instructs Panel 4 to submit a Public Comment(s) within the time frame required in the NEC schedule. This action shall be considered as a public comment. Additional Proposed Changes File Name Description Approved CN_270.pdf CN _270 Statement of Problem and Substantiation for Public Comment NOTE: This Public Comment appeared as CC Note No. 270 in the First Draft Report. The Correlating Committee directs Panel 4 to review all references to Article 310 under their purview. Article 310 has been divided into Article 310, Conductors for General Wiring, and Article 311, Medium Voltage Conductors and Cables for usability and clarity. Panel 4 shall appoint a task group to review all necessary references to verify their accuracy and submit Public Comments where necessary. This action instructs Panel 4 to submit a Public Comment(s) within the time frame required in the NEC schedule. This action shall be considered as a public comment. Related Item • Correlating Committee Note No. 270 Submitter Information Verification Submitter Full Name: CC on NEC-AAC Organization: NEC Correlating Committee Street Address: City: State: Zip: Submittal Date: Fri Sep 07 13:50:17 EDT 2018 Committee: NEC-P04 Committee Statement Committee Action: Rejected Resolution: CMP4 has no direct references to Article 310 that would be impacted by the reorganization. National Fire Protection Association Report https://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPar... 1 of 323 12/19/2018, 1:29 PM

Transcript of Statement of Problem and Substantiation for Public Comment...Public Comment No. 710-NFPA 70-2018 [...

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Public Comment No. 2209-NFPA 70-2018 [ Global Input ]

The Correlating Committee directs Panel 4 to review all references to Article 310 under their purview.Article 310 has been divided into Article 310,

Conductors for General Wiring, and Article 311, Medium Voltage Conductors and Cables for usability andclarity. Panel 4 shall appoint a task group

to review all necessary references to verify their accuracy and submit Public Comments where necessary.This action instructs Panel 4 to

submit a Public Comment(s) within the time frame required in the NEC schedule.

This action shall be considered as a public comment.

Additional Proposed Changes

File Name Description Approved

CN_270.pdf CN _270

Statement of Problem and Substantiation for Public Comment

NOTE: This Public Comment appeared as CC Note No. 270 in the First Draft Report.

The Correlating Committee directs Panel 4 to review all references to Article 310 under their purview. Article 310 has been divided into Article 310,

Conductors for General Wiring, and Article 311, Medium Voltage Conductors and Cables for usability and clarity. Panel 4 shall appoint a task group

to review all necessary references to verify their accuracy and submit Public Comments where necessary. This action instructs Panel 4 to

submit a Public Comment(s) within the time frame required in the NEC schedule.

This action shall be considered as a public comment.

Related Item

• Correlating Committee Note No. 270

Submitter Information Verification

Submitter Full Name: CC on NEC-AAC

Organization: NEC Correlating Committee

Street Address:

City:

State:

Zip:

Submittal Date: Fri Sep 07 13:50:17 EDT 2018

Committee: NEC-P04

Committee Statement

Committee Action: Rejected

Resolution: CMP4 has no direct references to Article 310 that would be impacted by the reorganization.

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Correlating Committee Note No. 270-NFPA 70-2018 [ Global Input ]

Submitter Information Verification

Submitter Full Name: Sarah CaldwellCommittee: Submittal Date: Fri May 11 17:54:55 EDT 2018

Committee Statement and Meeting Notes

Committee Statement:

The Correlating Committee directs all panels to review all references to Article 310 under their purview. Article 310 has been divided into Article 310, Conductors for General Wiring, and Article 311, Medium Voltage Conductors and Cables for usability and clarity. Each panel shall appoint a task group to review all necessary references to verify their accuracy and submit Public Comments where necessary. This action instructs the referenced panels to submit a Public Comment(s) within the time frame required in the NEC schedule.

This action shall be considered as a public comment.

Ballot Results

This item has passed ballot

12 Eligible Voters0 Not Returned

12 Affirmative All0 Affirmative with Comments0 Negative with Comments0 Abstention

Affirmative AllBrunssen, James E.

Dressman, Kevin L.

Hickman, Palmer L.

Hittinger, David L.

Holub, Richard A.

Johnston, Michael J.

Kovacik, John R.

Manche, Alan

McDaniel, Roger D.

Pierce, James F.

Saporita, Vincent J.

Williams, David A.

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Public Comment No. 2226-NFPA 70-2018 [ Global Input ]

The Correlating Committee directs Panel 4 to review all Articles, within their purview, that supplement ormodify (90.3) GFCI requirements in 210.8 for correlation, clarity, usability and standardized format. ACorrelating Committee Task Group will be appointed and will submit comments where necessary.

This action shall be considered as a public comment.

Additional Proposed Changes

File Name Description Approved

CN_152.pdf CN_152

Statement of Problem and Substantiation for Public Comment

NOTE: This Public Comment appeared as CC Note No. 152 in the First Draft Report.

The Correlating Committee directs Panel 4 to review all Articles, within their purview, that supplement or modify (90.3) GFCI requirements in 210.8 for correlation, clarity, usability and standardized format. A Correlating Committee Task Group will be appointed and will submit comments where necessary.

This action shall be considered as a public comment.

Related Item

• Correlating Committee Note No. 152

Submitter Information Verification

Submitter Full Name: CC on NEC-AAC

Organization: NEC Correlating Committee

Street Address:

City:

State:

Zip:

Submittal Date: Fri Sep 07 14:40:13 EDT 2018

Committee: NEC-P04

Committee Statement

Committee Action: Rejected

Resolution: The articles within CMP-4 purview are is not impacted by changes to 210.8.

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Correlating Committee Note No. 152-NFPA 70-2018 [ Global Input ]

Submitter Information Verification

Submitter Full Name: Erik Hohengasser

Committee:

Submittal Date: Thu May 10 18:00:52 EDT 2018

Committee Statement

CommitteeStatement:

The Correlating Committee directs each panel to review all Articles, within their purview, thatsupplement or modify (90.3) GFCI requirements in 210.8 for correlation, clarity, usability andstandardized format. A Correlating Committee Task Group will be appointed and will submit commentswhere necessary.

This action shall be considered as a public comment.

Ballot Results

This item has passed ballot

12 Eligible Voters

0 Not Returned

12 Affirmative All

0 Affirmative with Comments

0 Negative with Comments

0 Abstention

Affirmative All

Brunssen, James E.

Dressman, Kevin L.

Hickman, Palmer L.

Hittinger, David L.

Holub, Richard A.

Johnston, Michael J.

Kovacik, John R.

Manche, Alan

McDaniel, Roger D.

Pierce, James F.

Saporita, Vincent J.

Williams, David A.

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Public Comment No. 832-NFPA 70-2018 [ Global Input ]

The Correlating Committee directs Panel 4 to correlate inconsistent duplicate definitions as seen inFR-9008, FR-8983, and FR-8984.

The Correlating Committee advises that CMP-13 has purview over these definitions.

This action will be considered as a public comment.

Additional Proposed Changes

File Name Description Approved

CN_206_-_Global.pdf 70_CN 206

Statement of Problem and Substantiation for Public Comment

NOTE: This Public Comment appeared as CC Note No. 206 in the First Draft Report on First Revision No. 9008.

The Correlating Committee directs Panel 4 to correlate inconsistent duplicate definitions as seen in FR-9008, FR-8983, and FR-8984.

The Correlating Committee advises that CMP-13 has purview over these definitions.

This action will be considered as a public comment.

Related Item

• FR 9008

Submitter Information Verification

Submitter Full Name: CC on NEC-AAC

Organization: NEC Correlating Committee

Street Address:

City:

State:

Zip:

Submittal Date: Mon Aug 20 10:34:46 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected

Resolution: CMP4 disagrees with the correlating committee to assign the definitions of inverter input circuit andinverter output circuit to CMP13. CMP4 uses these terms far more than the articles related toCMP13 and the terms need to be broadly applicable in the NEC. There is nothing substantiallydifferent about these circuits in ESS. Both of these terms (originated in Article 690 (1996 edition ofthe NEC). In 2017, they were copied into Article 706. Each term is used once in Article 706 andeight times in Article 690, once in Article 692, three times in Article 694, and three times in Article705.

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Correlating Committee Note No. 206-NFPA 70-2018 [ Global Input ]

Submitter Information Verification

Submitter Full Name: Erik Hohengasser

Committee:

Submittal Date: Fri May 11 12:54:51 EDT 2018

Committee Statement

CommitteeStatement:

The Correlating Committee directs CMP-4 and CMP-13 to correlate inconsistent duplicatedefinitions as seen in FR-9008, FR-8983, and FR-8984.

The Correlating Committee advises that CMP-13 has purview over these definitions.

This action will be considered as a public comment.

First Revision No. 9008-NFPA 70-2018 [Global Input]

Ballot Results

This item has passed ballot

12 Eligible Voters

0 Not Returned

12 Affirmative All

0 Affirmative with Comments

0 Negative with Comments

0 Abstention

Affirmative All

Brunssen, James E.

Dressman, Kevin L.

Hickman, Palmer L.

Hittinger, David L.

Holub, Richard A.

Johnston, Michael J.

Kovacik, John R.

Manche, Alan

McDaniel, Roger D.

Pierce, James F.

Saporita, Vincent J.

Williams, David A.

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Public Comment No. 710-NFPA 70-2018 [ Definition: Generating Capacity, Inverter. ]

Generating Capacity, Inverter.

The sum of parallel-connected inverter maximum continuous output power at 40°C in watts or kilowatts.(CMP-4)

Statement of Problem and Substantiation for Public Comment

This change is largely editorial. Small inverters are rated in watts while larger inverters are more commonly rated in kilowatts (though could also be rated in watts).

Related Item

• FR-8532

Submitter Information Verification

Submitter Full Name: Jason Fisher

Organization: Tesla Inc.

Affiliation: Solar Energy Industries Association (SEIA)

Street Address:

City:

State:

Zip:

Submittal Date: Thu Aug 16 13:19:23 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Accepted

Resolution: SR-7862-NFPA 70-2018

Statement: The words “watts or” are added before kilowatts to allow for this term to be used for items lessthan one kilowatt.

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Public Comment No. 1563-NFPA 70-2018 [ Definition: Inverter. ]

Inverter.

Equipment Electronic equipment that changes dc to ac. (CMP-4)

Statement of Problem and Substantiation for Public Comment

Adding the term "electronic" will ensure that synchro-converters or other electromechanical devices are not considered in this definition. Some historic devices have been developed that were modified mechanical generators that could potentially fall under this simplified definition. This equipment would have different dynamics for controls than this general definition intends.

Related Item

• FR-8982

Submitter Information Verification

Submitter Full Name: Jason Fisher

Organization: Tesla Inc.

Affiliation: Solar Energy Industries Association (SEIA)

Street Address:

City:

State:

Zip:

Submittal Date: Wed Aug 29 11:50:58 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected

Resolution: The words “electronic equipment” substituted for “equipment” is unnecessary with the advent of thenew definition in Article 690 for Electronic Power Converter. It may be too limiting and products andtest procedures exist for other than electronic inverters.

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Public Comment No. 714-NFPA 70-2018 [ Definition: Multimode Inverter. ]

Inverter, Multimode Inverter .

Equipment having the capabilities of both the interactive inverter and the stand-alone inverter. (CMP-4)

Statement of Problem and Substantiation for Public Comment

This change would improve the ability of users of the Code to lookup this definition as it will place it in order with other inverter-related definitions.

Related Item

• FR 8551

Submitter Information Verification

Submitter Full Name: Jason Fisher

Organization: Tesla Inc.

Affiliation: Solar Energy Industries Association (SEIA)

Street Address:

City:

State:

Zip:

Submittal Date: Thu Aug 16 13:36:49 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Accepted

Resolution: SR-7867-NFPA 70-2018

Statement: This aligns the definition with other parallel definitions in Article 100 for ease of reference to keepit near the basic definition of inverters in Article 100.

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Public Comment No. 1774-NFPA 70-2018 [ Definition: Power Production Equipment. ]

Power Production Equipment.

The generating source and all associated distribution equipment to the source system disconnectingmeans that generates electricity from a source other than a utility supplied service. (CMP-4)

Informational Note: Examples of power production equipment include such items as generators,solar photovoltaic systems, and fuel cell systems.

Statement of Problem and Substantiation for Public Comment

The applicability of this language would be improved by adding the word "system" between "source" and "disconnecting means". In some power production systems there may be a source, such as a battery, that utilizes an equipment disconnect between the battery and an inverter. In that power production system all three of those components would be considered part of the power production equipment. Therefore, clarifying that the power production equipment is all equipment up to the system disconnect, would be an improvement.

Related Item

• FR-8598

Submitter Information Verification

Submitter Full Name: Jason Fisher

Organization: Tesla Inc.

Affiliation: Solar Energy Industries Association (SEIA)

Street Address:

City:

State:

Zip:

Submittal Date: Wed Aug 29 22:36:35 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected but see related SR

Resolution: SR-8125-NFPA 70-2018

Statement: This revised language clarifies the demarcation point between power production equipment andother equipment such as utility sources and distribution equipment for loads.

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Public Comment No. 1214-NFPA 70-2018 [ Definition: Stand-Alone System. ]

Stand-Alone System.

A system that is capable of supplying power independent of an electric power production and distributionnetwork.(CMP-4)

Informational Note: Though stand-alone systems are capable of operating independent of a utilitysupply they may include a connection to a utility supply for use when not operating in stand-alonemode.

Additional Proposed Changes

File Name Description Approved

CN_212.pdf 70_CN 212

Statement of Problem and Substantiation for Public Comment

NOTE: This Public Comment appeared as CC Note No. 212 in the First Draft Report on First Revision No. 8728.

The Correlating Committee directs the panel to reconsider the text of the informational note to remove permissive language. The use of the word “may” makes this permissive.

This action will be considered as a public comment.

Related Item

• FR 8728

Submitter Information Verification

Submitter Full Name: CC on NEC-AAC

Organization: NEC Correlating Committee

Street Address:

City:

State:

Zip:

Submittal Date: Fri Aug 24 13:16:49 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected but see related SR

Resolution: SR-8218-NFPA 70-2018

Statement: The informational note is removed to eliminate language that could be perceived as beingpermissive or confusing.

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Correlating Committee Note No. 212-NFPA 70-2018 [ Definition: Stand-Alone System. ]

Submitter Information Verification

Submitter Full Name: Sarah CaldwellCommittee: Submittal Date: Fri May 11 14:54:32 EDT 2018

Committee Statement and Meeting Notes

Committee Statement:

The Correlating Committee directs the panel to reconsider the text of the informational note to remove permissive language. The use of the word “may” makes this permissive. This action will be considered as a public comment.

First Revision No. 8728-NFPA 70-2018 [Definition: Stand-Alone System.]

Ballot Results

This item has passed ballot

12 Eligible Voters0 Not Returned

12 Affirmative All0 Affirmative with Comments0 Negative with Comments0 Abstention

Affirmative AllBrunssen, James E.

Dressman, Kevin L.

Hickman, Palmer L.

Hittinger, David L.

Holub, Richard A.

Johnston, Michael J.

Kovacik, John R.

Manche, Alan

McDaniel, Roger D.

Pierce, James F.

Saporita, Vincent J.

Williams, David A.

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Public Comment No. 306-NFPA 70-2018 [ Definition: Stand-Alone System. ]

Stand-Alone System.

A system that is capable of supplying power independent of an electric power production and distributionnetwork.(CMP-4)

Informational Note: Though stand-alone systems are capable of operating independent of a utilitysupply they may include a connection to a utility supply for use when not operating in stand-alonemode.

Statement of Problem and Substantiation for Public Comment

CMP-4 has added the Informational Note to the definition of Stand-Alone System in Article 100. In addition, the changes made to the definition of Stand-Alone (Islanded) Mode in Article 710 causes confusion with the definition of Microgrid System in Article 705.

To remedy the confusion, the Informational Note after the definition of Stand-Alone System should be deleted. A premises wiring system with a connection to a primary source (electric utility) is a Microgrid system as defined in Article 705.

The term in 710.2 for Stand-alone (Islanded) Mode should be changed to Island Mode. These changes are consistent with IEEE 1547-2018 - IEEE Standard for Interconnection and Interoperability of Distributed Energy Resources with Associated Electric Power Systems Interfaces.

Related Public Comments for This Document

Related Comment Relationship

Public Comment No. 308-NFPA 70-2018 [Definition: Stand-Alone (Islanded) Mode. ] Same Issue

Public Comment No. 308-NFPA 70-2018 [Definition: Stand-Alone (Islanded) Mode. ]

Public Comment No. 318-NFPA 70-2018 [Section No. 705.150]

Related Item

• FR8728

Submitter Information Verification

Submitter Full Name: Timothy Croushore

Organization: FirstEnergy

Affiliation: Edison Electric Institute - Electric Light and Power Task Force.

Street Address:

City:

State:

Zip:

Submittal Date: Fri Jul 27 11:38:54 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected but see related SR

Resolution: SR-8218-NFPA 70-2018

Statement: The informational note is removed to eliminate language that could be perceived as beingpermissive or confusing.

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Public Comment No. 1978-NFPA 70-2018 [ Definition: AC Module System. ]

AC Module System.

An assembly of ac modules that is engineered, field-assembled, and field-installed using subassembliesand wiring methods supplied , wiring methods, materials and subassemblies that are matched andengineered as a listed system. The AC Module system shall be listed by a singular entity that are matchedand intended to be assembled entity and field assembled and installed as defined in the installationinstructions.

Statement of Problem and Substantiation for Public Comment

The approved text was edited for clarity. The original text referred to "an assembly of ac modules" in the first sentence, but an AC Module System includes wiring, materials and other sub-assemblies. Putting these terms in the first sentence clarifies the definition of this new definition.

Related Item

• FR-8520

Submitter Information Verification

Submitter Full Name: Christopher Fox

Organization: SunPower

Street Address:

City:

State:

Zip:

Submittal Date: Thu Aug 30 13:28:33 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected but see related SR

Resolution: SR-7876-NFPA 70-2018

Statement: The definition was edited for clarity. The original text referred to "an assembly of ac modules" in thefirst sentence, but an AC module system includes wiring, materials and other sub-assemblies.Putting these terms in the first sentence clarifies the definition. The information about a “singularentity” is removed as it may be confusing for the AHJ who may see multiple listing labels onequipment versus the system listing that also may come from more than one entity. Installationinstructions are covered well in 110.3(B) and the second sentence language related to installationinstruction could be viewed as putting a requirement in a definition.

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Public Comment No. 262-NFPA 70-2018 [ Definition: Alternating-Current (ac) Module

(Alternating-Cu... ]

Alternating-Current (ac) Module (Alternating-Current Photovoltaic Module).

A complete, environmentally protected unit consisting of solar cells, inverter, and other components,designed to generate provide ac power.

Statement of Problem and Substantiation for Public Comment

This definition needs to be clarify, you can only generate DC power with a PV solar cell. The inverter Converts this DC power and transforms this energy to AC.Can we please be technically correct in this subject. The PV module or the inverter does not generate AC power. It is like saying a battery with and inverter generates AC power.

Related Item

• Public Input No. 851-NFPA 70-2017

Submitter Information Verification

Submitter Full Name: Alfio Torrisi

Organization: electricain

Street Address:

City:

State:

Zip:

Submittal Date: Sun Jul 22 11:34:23 EDT 2018

Committee: NEC-P04

Committee Statement

Committee Action: Rejected but see related SR

Resolution: SR-7873-NFPA 70-2018

Statement: This substitutes the term “produce” for “generate” for clarity.

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Public Comment No. 1559-NFPA 70-2018 [ Definition: Bipolar Circuits. ]

Bipolar Circuits Circuit .

A dc circuit that is comprised of two monopole subarray circuits, each having an opposite polarityconnected to a common reference point.

Statement of Problem and Substantiation for Public Comment

This action is tied to our comment to remove the term "subarray" from the definition of "monopole subarray circuit" in FR 8549. The definition for "Subarray" was removed in the First Revision by CMP-4. Removing this term from this definition does not change the meaning and will improve the application of the Code. The removal of the "s" and the addition of "an" is advised for editorial purposes.

Related Public Comments for This Document

Related Comment Relationship

Public Comment No. 1555-NFPA 70-2018 [Definition: Monopole Subarray Circuit.] Change in definition

Related Item

• FR-8521

Submitter Information Verification

Submitter Full Name: Jason Fisher

Organization: Tesla Inc.

Affiliation: Solar Energy Industries Association (SEIA)

Street Address:

City:

State:

Zip:

Submittal Date: Wed Aug 29 11:45:36 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Accepted

Resolution: SR-7885-NFPA 70-2018

Statement: This revision is related to the SR-7903 to remove the term "subarray" from the definition of"monopole subarray circuit". The definition for "subarray" was removed in the First Revision.Removing this term from this definition does not change the meaning and will improve theapplication of the Code. The removal of the "s" and the addition of "an" is for editorial purposes.

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Public Comment No. 1553-NFPA 70-2018 [ Definition: DC-to-DC Converter Output

Circuit. ]

DC-to-DC Converter Output Circuit.

The dc circuit conductors between from the dc output of dc -to-dc converter source circuit(s) and theinverter or the dc PV system disconnecting means dc combiners connected to other equipment .

Statement of Problem and Substantiation for Public Comment

This change aligns this definition with the first draft changes to PV output circuits and further differentiates this definition from the definition of Dc-to-dc converter source circuit.

Related Item

• FR-8522

Submitter Information Verification

Submitter Full Name: Jason Fisher

Organization: Tesla Inc.

Affiliation: Solar Energy Industries Association (SEIA)

Street Address:

City:

State:

Zip:

Submittal Date: Wed Aug 29 11:37:39 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected but see related SR

Resolution: SR-7887-NFPA 70-2018

Statement: This aligns the definition with the changes to PV output circuits and further differentiates thisdefinition from the definition of dc-to-dc converter source circuit.

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Public Comment No. 1178-NFPA 70-2018 [ Definition: Direct-Current (dc) Combiner. ]

Direct-Current (dc) Combiner.

A device used to connect two or more dc PV system dc circuits in parallel, providing one or more dc circuitoutput(s).

Additional Proposed Changes

File Name Description Approved

CN_214.pdf 70_CN214

Statement of Problem and Substantiation for Public Comment

NOTE: This Public Comment appeared as CC Note No. 214 in the First Draft Report on First Revision No. 8525.

The Correlating Committee directs that the panel clarify the panel action with respect to the multiple usage of “dc” on FR 8525. The CorrelatingCommittee directs that the parentheses be removed around the letter "s". This action will be considered as a public comment.

Related Item

• First Revision No. 8525

Submitter Information Verification

Submitter Full Name: CC on NEC-AAC

Organization: NEC Correlating Committee

Street Address:

City:

State:

Zip:

Submittal Date: Fri Aug 24 10:09:30 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected but see related SR

Resolution: SR-7892-NFPA 70-2018

Statement: The revision clarifies that a combiner is an enclosure that includes the devices for parallelingcircuits. The previous language could be used to claim that a wire nut was a dc combiner. This alsodeletes the final phrase from the definition as the output is not relevant to this definition.

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Correlating Committee Note No. 214-NFPA 70-2018 [ Definition: Direct-Current (dc) Combiner. ]

Submitter Information Verification

Submitter Full Name: Sarah CaldwellCommittee: Submittal Date: Fri May 11 15:00:56 EDT 2018

Committee Statement and Meeting Notes

Committee Statement:

The Correlating Committee directs that the panel clarify the panel action with respect to the multiple usage of “dc” on FR 8525. The Correlating Committee directs that the parentheses be removed around the letter "s". This action will be considered as a public comment.

First Revision No. 8525-NFPA 70-2018 [Definition: Direct-Current (dc) Combiner. ]

Ballot Results

This item has passed ballot

12 Eligible Voters0 Not Returned

12 Affirmative All0 Affirmative with Comments0 Negative with Comments0 Abstention

Affirmative AllBrunssen, James E.

Dressman, Kevin L.

Hickman, Palmer L.

Hittinger, David L.

Holub, Richard A.

Johnston, Michael J.

Kovacik, John R.

Manche, Alan

McDaniel, Roger D.

Pierce, James F.

Saporita, Vincent J.

Williams, David A.

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Public Comment No. 165-NFPA 70-2018 [ Definition: Direct-Current (dc) Combiner. ]

Direct-Current (dc) Combiner.

A device used to connect two or more dc PV system dc circuits in parallel, providing one or more dc circuitoutput(s) .

Statement of Problem and Substantiation for Public Comment

The deleted wording is unnecessary to the defination. The purpose of a DC combiner is to combine input circuits together, what happens at the output is not relevant to the defination.

Related Item

• First Revision No. 8522-NFPA 70-2018

Submitter Information Verification

Submitter Full Name: MARVIN HAMON

Organization: HAMON ENGINEERING INC

Street Address:

City:

State:

Zip:

Submittal Date: Tue Jul 03 21:38:41 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected but see related SR

Resolution: SR-7892-NFPA 70-2018

Statement: The revision clarifies that a combiner is an enclosure that includes the devices for parallelingcircuits. The previous language could be used to claim that a wire nut was a dc combiner. This alsodeletes the final phrase from the definition as the output is not relevant to this definition.

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Public Comment No. 1180-NFPA 70-2018 [ Definition: Electronic Power Converter. ]

Electronic Power Converter.

A device that uses power electronics to convert one form of electrical power into another form of electricalpower. These devices have limited current capabilities based on the device ratings at continuous ratedpower.

Informational Note: Examples of electronic power converters include, but are not limited to,inverters, dc-to-dc converters, and electronic charge controllers.

Additional Proposed Changes

File Name Description Approved

CN_213.pdf 70_CN213

Statement of Problem and Substantiation for Public Comment

NOTE: This Public Comment appeared as CC Note No. 213 in the First Draft Report on First Revision No. 8526.

The Correlating Committee directs the Code-Making Panel to consider moving the second sentence from the definition into the informational note.This action will be considered as a public comment.

Related Item

• First Revision No. 8526

Submitter Information Verification

Submitter Full Name: CC on NEC-AAC

Organization: NEC Correlating Committee

Street Address:

City:

State:

Zip:

Submittal Date: Fri Aug 24 10:10:51 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected but see related SR

Resolution: SR-7893-NFPA 70-2018

Statement: This revision moves the second sentence of the definition into the informational note. Thesecond sentence was informational.

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Correlating Committee Note No. 213-NFPA 70-2018 [ New Definition after Definition: Electrical Production and ... ]

Submitter Information Verification

Submitter Full Name: Sarah CaldwellCommittee: Submittal Date: Fri May 11 14:55:49 EDT 2018

Committee Statement and Meeting Notes

Committee Statement:

The Correlating Committee directs the Code-Making Panel to consider moving the second sentence from the definition into the informational note. This action will be considered as a public comment.

First Revision No. 8526-NFPA 70-2018 [New Definition after Definition: Electrical Production and ...]

Ballot Results

This item has passed ballot

12 Eligible Voters0 Not Returned

12 Affirmative All0 Affirmative with Comments0 Negative with Comments0 Abstention

Affirmative AllBrunssen, James E.

Dressman, Kevin L.

Hickman, Palmer L.

Hittinger, David L.

Holub, Richard A.

Johnston, Michael J.

Kovacik, John R.

Manche, Alan

McDaniel, Roger D.

Pierce, James F.

Saporita, Vincent J.

Williams, David A.

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Public Comment No. 186-NFPA 70-2018 [ Definition: Electronic Power Converter. ]

Electronic Power Converter.

A device that uses power electronics to convert one form of electrical power into another form of electricalpower. These devices have limited current capabilities based on the device ratings at continuous ratedpower.

Informational Note: Examples of electronic power converters include, but are not limited to, inverters,dc-to-dc converters, and electronic charge controllers.

Statement of Problem and Substantiation for Public Comment

The second sentence of the definition is true, but only one of several EPC attributes, and not necessary or beneficial towards the goal of clarity. CMP 4 has done a great job eliminating Article 690 language that seemed to be more focused on education of the uninformed as opposed to clear and concise installation requirements. I would encourage the panel to continue on that path.

Related Item

• FR 8526

Submitter Information Verification

Submitter Full Name: Pete Jackson

Organization: City of Bakersfield, Californi

Street Address:

City:

State:

Zip:

Submittal Date: Mon Jul 09 11:43:51 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected but see related SR

Resolution: SR-7893-NFPA 70-2018

Statement: This revision moves the second sentence of the definition into the informational note. Thesecond sentence was informational.

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Public Comment No. 429-NFPA 70-2018 [ Definition: Electronic Power Converter. ]

Electronic Power Converter.

A device that uses power electronics to convert one form of electrical power into another form of electricalpower.

Informational Note: These devices have limited current capabilities based on the device ratings atcontinuous rated power.

Informational Note: Examples of electronic power converters include, but are not limited to,inverters, dc-to-dc converters, and electronic charge controllers.

Statement of Problem and Substantiation for Public Comment

Revised to address the concerns of the correlating committee.

Related Item

• CN 213

Submitter Information Verification

Submitter Full Name: William Brooks

Organization: Brooks Engineering

Street Address:

City:

State:

Zip:

Submittal Date: Mon Aug 06 15:58:09 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected but see related SR

Resolution: SR-7893-NFPA 70-2018

Statement: This revision moves the second sentence of the definition into the informational note. Thesecond sentence was informational.

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Public Comment No. 1137-NFPA 70-2018 [ Definition: Grounded, Functionally. ]

Grounded, Functionally.

A system that has an electrical ground reference for operational purposes that is not solidly grounded.

Informational Note: Examples of operational reasons for functionally grounded systems includeground-fault detection and performance-related issues for some power sources.

Additional Proposed Changes

File Name Description Approved

CN_35.pdf 70_CN35

Statement of Problem and Substantiation for Public Comment

NOTE: This Public Comment appeared as CC Note No. 35 in the First Draft Report on First Revision No. 8735.

The Correlating Committee directs that this first revision be rewritten to comply with theNEC Style Manual, section 2.2.2. This action shall be considered as a public comment.

Related Item

• First Revision No. 8735

Submitter Information Verification

Submitter Full Name: CC on NEC-AAC

Organization: NEC Correlating Committee

Street Address:

City:

State:

Zip:

Submittal Date: Thu Aug 23 14:50:18 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected

Resolution: This definition does not necessarily violate the style manual as it is a two-word term that is differentfrom the two-word term that is being defined. This definition is provided to specifically differentiateitself from solidly grounded systems. It includes but is not limited to resistive, capacitive, and fusegrounded systems.

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Correlating Committee Note No. 35-NFPA 70-2018 [ New Definition after

Definition: Wet-Niche Luminaire. ]

Submitter Information Verification

Submitter Full Name: Sarah Caldwell

Committee:

Submittal Date: Wed May 09 14:31:04 EDT 2018

Committee Statement and Meeting Notes

CommitteeStatement:

The Correlating Committee directs that this first revision be rewritten to comply with theNEC Style Manual, section 2.2.2. This action shall be considered as a public comment.

First Revision No. 8735-NFPA 70-2018 [New Definition after Definition: Wet-Niche Luminaire.]

Ballot Results

This item has passed ballot

12 Eligible Voters

0 Not Returned

12 Affirmative All

0 Affirmative with Comments

0 Negative with Comments

0 Abstention

Affirmative All

Brunssen, James E.

Dressman, Kevin L.

Hickman, Palmer L.

Hittinger, David L.

Holub, Richard A.

Johnston, Michael J.

Kovacik, John R.

Manche, Alan

McDaniel, Roger D.

Pierce, James F.

Saporita, Vincent J.

Williams, David A.

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Public Comment No. 1532-NFPA 70-2018 [ Definition: Grounded, Functionally. ]

Grounded, Functionally.

A system that has an electrical ground reference for operational purposes that is not solidly grounded.

Informational Note: Examples of operational reasons for functionally grounded systems includeground-fault detection and performance-related issues for some power sources.

Func onal Ground ‐  A grounded conductor which is connected to a device which serves to connect theconductor to ground under normal condi ons, but may cease to connect the conductor to ground because ofits opera on in response to an abnormal condi on such as a fault condi on. 

Statement of Problem and Substantiation for Public Comment

Currently, the definition of a "Functional Grounded PV System" is very deceiving. A functional ground may cease to be connected if there is a faulted situation. This could create an unsafe condition for anyone working on the system if the system lacks a ground. A functional ground includes a fused ground which could have operated but continues to allow the PV system to continue to be in operation. This is very different than a solidly or resistively grounded system.

Related Item

• PI3865

Submitter Information Verification

Submitter Full Name: Robert Jordan

Organization: Alabama Power Company

Affiliation: EL&P Committee

Street Address:

City:

State:

Zip:

Submittal Date: Wed Aug 29 10:30:48 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected

Resolution: This definition is intended to clarify and differentiate these types of systems from commonlyinstalled solidly grounded systems.

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Public Comment No. 1565-NFPA 70-2018 [ Definition: Grounded, Functionally. ]

Grounded, Functionally.

A system that has an electrical ground reference for operational purposes that is not solidly grounded.

Informational Note: Examples of operational reasons for functionally grounded systems includeground-fault detection and performance-related issues for some power sources.

Need to provide a figure as a visual example to better explain what this is and how it works.

Statement of Problem and Substantiation for Public Comment

Providing a figure would help the user to understand what "functionally grounded" means and how it would be used in a PV system.

Related Item

• PI 3524; PI 3595 PI 3518

Submitter Information Verification

Submitter Full Name: Wendell Whistler

Organization: IBEW 280

Street Address:

City:

State:

Zip:

Submittal Date: Wed Aug 29 11:55:19 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected

Resolution: This PC does not meet the requirements of 4.4.4.4 of the Regulations Governing the Developmentof NFPA Standards. Specific requirements have not been provided. This request is more suitableas an addition to the NEC Handbook for reference.

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Public Comment No. 167-NFPA 70-2018 [ Definition: Grounded, Functionally. ]

Grounded, Functionally.

A system that has an electrical ground reference for operational purposes that is not solidly grounded.

Informational Note: A functional grounded PV system is often connected to ground through a fuse,circuit breaker, resistance device, non-isolated grounded ac circuit, or electronic means that is partof a listed ground-fault protection system. Conductors in these systems that are normally at groundpotential may have voltage to ground during fault conditions. Examples of operational reasons forfunctionally grounded systems include ground-fault detection and performance-related issues forsome power sources.

Statement of Problem and Substantiation for Public Comment

The information in the IN that is being deleted is still relevant and points out a major change to system grounding that occurred in the 2017 NEC revision that changed the definition of PV systems grounding that was used over several previous revisions of the NEC. I feel it would be worthwhile to keep this in for at least one more cycle.

Related Item

• First Revision No. 8734-NFPA 70-2018

Submitter Information Verification

Submitter Full Name: MARVIN HAMON

Organization: HAMON ENGINEERING INC

Street Address:

City:

State:

Zip:

Submittal Date: Tue Jul 03 22:08:18 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected but see related SR

Resolution: SR-8127-NFPA 70-2018

Statement: The language was edited to clarify that most functionally grounded systems are grounded insidethe inverter or charge controller. The note also clarifies the operational purposes for functionallygrounding a system.

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Public Comment No. 712-NFPA 70-2018 [ Definition: Module. ]

Module.

A complete, environmentally protected unit consisting of solar cells and other components designed togenerate produce dc power.

Statement of Problem and Substantiation for Public Comment

PV cells within modules do not "generate" power, they convert sunlight to electricity so it would be more accurate to say that these devices "produce" power when exposed to sunlight.

Related Item

• FR 8550

Submitter Information Verification

Submitter Full Name: Jason Fisher

Organization: Tesla Inc.

Affiliation: Solar Energy Industries Association (SEIA)

Street Address:

City:

State:

Zip:

Submittal Date: Thu Aug 16 13:33:45 EDT 2018

Committee: NEC-P04

Committee Statement

Committee Action: Accepted

Resolution: SR-7902-NFPA 70-2018

Statement: The word generate is replaced with “produce” for clarity.

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Public Comment No. 1555-NFPA 70-2018 [ Definition: Monopole Subarray Circuit. ]

Monopole Subarray Circuit.

An electrical subset of a PV system that has two conductors in the output circuit, one positive (+) and onenegative (−).

Statement of Problem and Substantiation for Public Comment

The defined term "subarray" was removed in the First Revision by CMP-4 in FR-8566. Removing this term from this definition does not change the meaning and will improve the application of the Code. Other PCs are being submitted to update the use of this term throughout the Article.

Related Public Comments for This Document

Related Comment Relationship

Public Comment No. 1559-NFPA 70-2018 [Definition: Bipolar Circuits.]

Public Comment No. 1766-NFPA 70-2018 [Section No. 690.31(E)]

Related Item

• FR-8549, FR-8521, FR-8566

Submitter Information Verification

Submitter Full Name: Jason Fisher

Organization: Tesla Inc.

Affiliation: Solar Energy Industries Association (SEIA)

Street Address:

City:

State:

Zip:

Submittal Date: Wed Aug 29 11:42:15 EDT 2018

Committee: NEC-P04

Committee Statement

Committee Action: Accepted

Resolution: SR-7903-NFPA 70-2018

Statement: The term “subarray” is removed from the title for consistency with action on SR-7885.

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Public Comment No. 2149-NFPA 70-2018 [ Definition: Photovoltaic Output Circuit. ]

Photovoltaic Output Circuit.

The dc circuit conductors from the output of dc combiners connected to other equipment and dc circuitdisconnection means .

Statement of Problem and Substantiation for Public Comment

This definition does not define the end point. If feeding a dc microgrid, the definition implies that the PV output circuit, and hence the PV system extends to utilization equipment, invoking 690 marking requirements etc. The output circuit should terminate at the PV system disconnect

Related Item

• 3607 - defintion of PV output circuit

Submitter Information Verification

Submitter Full Name: Robert Wills

Organization: Intergrid, LLC

Affiliation: AWEA

Street Address:

City:

State:

Zip:

Submittal Date: Thu Aug 30 20:42:36 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected but see related SR

Resolution: SR-7910-NFPA 70-2018

Statement: The revised definition provides both the beginning point and ending point of the PV outputcircuit.

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Public Comment No. 718-NFPA 70-2018 [ Definition: Photovoltaic Output Circuit. ]

Photovoltaic (PV) Output Circuit.

The dc circuit conductors from the output of dc combiners connected to other equipment.

Statement of Problem and Substantiation for Public Comment

Adding "(PV)" to the term to align with its common use through the article.

Related Item

• FR-8559

Submitter Information Verification

Submitter Full Name: Jason Fisher

Organization: Tesla Inc.

Affiliation: Solar Energy Industries Association (SEIA)

Street Address:

City:

State:

Zip:

Submittal Date: Thu Aug 16 13:50:30 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected but see related SR

Resolution: SR-7910-NFPA 70-2018

Statement: The revised definition provides both the beginning point and ending point of the PV outputcircuit.

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Public Comment No. 721-NFPA 70-2018 [ Definition: Photovoltaic Power Source. ]

Photovoltaic Power Source.

An array or aggregate of arrays that generates dc power.

Statement of Problem and Substantiation for Public Comment

This definition is no longer necessary and contains potentially confusing terminology (since PV arrays could be AC as well). Deletion of this term will not impair the ability of users to apply the Code. With the changes made to Article 690 in the First Draft, this term will only remain in three places, in the informational note diagrams in 690.2, in 690.8(C) used in a general manner that doesn't perfectly align with the original definition anyway, and in 690.31(D)(2) in the acceptable label text. We believe all of these uses are self-explanatory and do not require this definition. We have also submitted a PC to make a small change to 690.8(C) to improve the application of this section by specifying "dc" in the sentence that used this old term.

Related Item

• FR-8563

Submitter Information Verification

Submitter Full Name: Jason Fisher

Organization: Tesla Inc.

Affiliation: Solar Energy Industries Association (SEIA)

Street Address:

City:

State:

Zip:

Submittal Date: Thu Aug 16 13:56:12 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Accepted

Resolution: SR-7920-NFPA 70-2018

Statement: The term is generally self-explanatory and no longer commonly used with the revisions to Article690. It may be insufficient to properly describe a PV system. It also could be confused with the useof the term Power Source in Article 705.

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Public Comment No. 716-NFPA 70-2018 [ Definition: Photovoltaic Source Circuit. ]

Photovoltaic (PV) Source Circuit.

The dc circuit conductors between modules and from modules to dc combiners, electronic powerconverters, or the a dc PV system disconnecting means.

Statement of Problem and Substantiation for Public Comment

The applicability of this definition would be improved by changing "the dc PV system disconnecting means" to "a dc PV system disconnecting means" since some dc PV system disconnecting means may be on the output side of a dc combiner, which would therefore be in an Photovoltaic Output Circuit, not a source circuit. Additional editorial change to add "(PV)" to the term to align with its common use through the article.

Related Item

• FR 8555

Submitter Information Verification

Submitter Full Name: Jason Fisher

Organization: Tesla Inc.

Affiliation: Solar Energy Industries Association (SEIA)

Street Address:

City:

State:

Zip:

Submittal Date: Thu Aug 16 13:43:49 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected but see related SR

Resolution: SR-8129-NFPA 70-2018

Statement: The revision changes the term to "PV Source Circuit" to align with the use of the term throughoutthe Article. The change from "the" to "a" is to make the definition more general.

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Public Comment No. 722-NFPA 70-2018 [ Definition: Photovoltaic System DC Circuit. ]

Photovoltaic (PV) System DC Circuit.

Any dc conductor of a PV system, including PV source circuits circuit , PV output circuits circuit , dc-to-dcconverter source circuits circuit , and dc-to-dc converter output circuits circuit in a PV system .

Statement of Problem and Substantiation for Public Comment

Editorial change to add "(PV)" to the term to align with its common use through the article. Additionally, since this term is strictly limited to the four types of circuits identified in this definition, they are not examples of circuits that fall within this term. This modified language will ensure that this term is used as intended and not erroneously applied to another dc circuits that may be part of a PV system such as a dc control or signaling circuits.

Related Item

• FR-8557

Submitter Information Verification

Submitter Full Name: Jason Fisher

Organization: Tesla Inc.

Affiliation: Solar Energy Industries Association (SEIA)

Street Address:

City:

State:

Zip:

Submittal Date: Thu Aug 16 13:58:29 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected but see related SR

Resolution: SR-8130-NFPA 70-2018

Statement: The revision restricts the defined term to only these four circuits. The defined term revised to beconsistent with its use throughout the article.

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Public Comment No. 1490-NFPA 70-2018 [ Section No. 690.4(B) ]

(B) Equipment.

Inverters, motor generators, PV modules, ac modules and ac module systems, dc combiners, dc-to-dcconverters, rapid shutdown equipment, dc circuit controllers, and charge controllers intended for use in PVsystems shall be listed or field labeled evaluated for the application.

Statement of Problem and Substantiation for Public Comment

The process of how “field labeled” is accomplished is not defined or set in the NEC. The definition of “field labeled” does not set any requirement or statement that a “serialized” label is provided as stated in the panel resolution statement. The process that leads to a field label is a function of the “field evaluation” process requirements found in NFPA 790 and NFPA 791. It has been stated that the term “field labeled” infers that a field evaluation would be completed. This may be the intent of the panel, but it is poor code writing to set a requirement that infers a process instead of stating the process, field evaluation, that is to be completed.

The NFPA style manual section 2.3.2.3 prohibits definitions from having requirements in the definition and therefore definitions cannot be used as establishing requirements.

It is noted that the field evaluation process is under the purview of the NFPA Electrical Equipment Evaluation (EEE) Technical Committee.A product or equipment can achieve a “field label” where a field evaluation is completed which has five distinct steps. A brief summary of these procedures includes selection of the correct nationally recognized standard, conducting a complete evaluation of construction, performing applicable non-destructive field testing, and documentation in formal engineering reports to both the client and the Authority having jurisdiction. When the process is completed with satisfactory results, then the serialized “field label” of the FEB is applied.

Please see the related comments for the definition of "field evaluation (field evaluated)" and the new section 110.3(D) that sets the process requirement and FEB qualification criteria.

To permit only the “field label” as suitable evidence for “approval” has allowed and will continue to allow unqualified entities to give a false sense of adequacy when they are in fact not performing the necessary rigorous evaluation that is provided in the requirement of the NFPA 790 and NFPA 791 documents.If the panel believes the term “field labeled” is still the correct term, it is requested this item be referred the Correlating Committee for correlation between the NEC and the documents under the purview of the NFPA EEE committee.

Related Public Comments for This Document

Related Comment Relationship

Public Comment No. 1353-NFPA 70-2018 [New Definition after Definition: FestoonLighting.]

Public Comment No. 1489-NFPA 70-2018 [New Section after 110.3(C)]

Public Comment No. 1353-NFPA 70-2018 [New Definition after Definition: FestoonLighting.]

Public Comment No. 1489-NFPA 70-2018 [New Section after 110.3(C)]

Related Item

• PI 2601

Submitter Information Verification

Submitter Full Name: Charles Mello

Organization: Cdcmello Consulting Llc

Affiliation: Self

Street Address:

City:

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State:

Zip:

Submittal Date: Tue Aug 28 23:32:43 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected but see related SR

Resolution: SR-8144-NFPA 70-2018

Statement: Stating that equipment has a field evaluation does not guarantee that a field label is applied. NFPA791 includes a recommendation for a label to be applied but does not mandate it as quoted below.The process of applying a field label for field evaluated equipment is extremely important for AHJs.

“8.1 Label application after all identified issues have been fully resolved, all electrical testing hasbeen satisfactorily completed, and the evaluation has determined that the equipment meets theapplicable requirements of the standard(s), a label should be affixed to the equipment.”

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Public Comment No. 1182-NFPA 70-2018 [ Section No. 690.6 ]

690.6 Alternating-Current (ac) Modules and Systems.

(A) Photovoltaic Source Circuits.

The requirements of Article 690 pertaining to PV source circuits shall not apply to ac modules or acmodule systems. The PV source circuit, conductors, and inverters shall be considered as internalcomponents of an ac module or ac module system. The PV source circuit, conductors, and inverters shallbe considered as internal wiring of an ac module.

(B) Output Circuit.

The output of an ac module or ac module system shall be considered an inverter output circuit.

(C) Flexible Harnesses and Cables.

Flexible wiring harnesses and cables in ac module and ac module systems shall be installed inaccordance with the instructions included with the listed or labeled equipment. Where not otherwisespecified in their instructions, they shall be installed in accordance with the following:

(1) Where not protected by raceways they shall be limited to rooftop locations

(2) Shall closely follow the surface(s) to which they are adjacent

(3) Shall be protected from physical damage where necessary

(4) Shall be secured or supported, at a minimum, every 1.4 m (41⁄2 ft) and within 300 mm (12 in.) of everyconnector. Sections of cords or cables protected from physical protection by raceways shall not berequired to be secured within the raceway

Exception: Larger support spacings are permitted as defined elsewhere in this Code for the specificwiring method.

Additional Proposed Changes

File Name Description Approved

CN_216.pdf 70_CN216

Statement of Problem and Substantiation for Public Comment

NOTE: This Public Comment appeared as CC Note No. 216 in the First Draft Report on First Revision No. 8152.

The Correlating Committee directs that the panel clarify the panel action with regard to the beginning of list items (2) to (4) which do not seem to benecessary and do not make sense with the text introducing the list. This action will be considered as a public comment.

Related Item

• First Revision No. 8152

Submitter Information Verification

Submitter Full Name: CC on NEC-AAC

Organization: NEC Correlating Committee

Street Address:

City:

State:

Zip:

Submittal Date: Fri Aug 24 10:14:26 EDT 2018

Committee: NEC-P04

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Committee Statement

CommitteeAction:

Rejected but see related SR

Resolution: SR-7921-NFPA 70-2018 The term physical protection is changed to physical damage in690.31(C).

Statement: Section 690.6(C) is deleted. The relevant items in 690.6(C) are included in 690.31(C) includingthe text that incorporates wording related to direct burial cables.

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Correlating Committee Note No. 216-NFPA 70-2018 [ Section No. 690.6 ]

Submitter Information Verification

Submitter Full Name: Sarah CaldwellCommittee: Submittal Date: Fri May 11 15:06:04 EDT 2018

Committee Statement and Meeting Notes

Committee Statement:

The Correlating Committee directs that the panel clarify the panel action with regard to the beginning of list items (2) to (4) which do not seem to be necessary and do not make sense with the text introducing the list. This action will be considered as a public comment.

First Revision No. 8152-NFPA 70-2018 [Section No. 690.6]

Ballot Results

This item has passed ballot

12 Eligible Voters0 Not Returned

12 Affirmative All0 Affirmative with Comments0 Negative with Comments0 Abstention

Affirmative AllBrunssen, James E.

Dressman, Kevin L.

Hickman, Palmer L.

Hittinger, David L.

Holub, Richard A.

Johnston, Michael J.

Kovacik, John R.

Manche, Alan

McDaniel, Roger D.

Pierce, James F.

Saporita, Vincent J.

Williams, David A.

Page 1 of 1National Fire Protection Association Report

8/23/2018https://submittals.nfpa.org/TerraViewWeb/FormLaunch?id=/TerraView/Content/70-2017....

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Public Comment No. 1443-NFPA 70-2018 [ Section No. 690.6 ]

690.6 Alternating-Current (ac) Modules and Systems.

(A) Photovoltaic Source Circuits.

The requirements of Article 690 pertaining to PV source circuits shall not apply to ac modules or acmodule systems. The PV source circuit, conductors, and inverters shall be considered as internalcomponents of an ac module or ac module system. The PV source circuit, conductors, and inverters shallbe considered as internal wiring of an ac module.

(B) Output Circuit.

The output of an ac module or ac module system shall be considered an inverter output circuit.

(C) Flexible Harnesses and Cables.

Flexible wiring harnesses and cables in ac module and ac module systems shall be installed inaccordance with the instructions included with the listed or labeled equipment. Where not otherwisespecified in their instructions, they shall be installed in accordance with the following:

(1) Where not protected by raceways they shall be limited to rooftop locations

(2) Shall closely follow the surface(s) to which they are adjacent

(3) Shall be protected from physical damage where necessary

(4) Shall be secured or supported, at a minimum, every 1.4 m (41⁄2 ft) and within 300 mm (12 in.) of everyconnector. Sections of cords or cables protected from physical protection by raceways shall not berequired to be secured within the raceway

Exception: Larger support spacings are permitted as defined elsewhere in this Code for the specificwiring method.

Statement of Problem and Substantiation for Public Comment

SafeConnect Solar is supportive of the Committee's First Revision No. 8152-NFPA 70-2018 to Section 690.6. AC Module Systems are being developed in the marketplace and their differences from traditional PV systems should be recognized in the Code.

Related Item

• First Revision No. 8152-NFPA 70-2018

Submitter Information Verification

Submitter Full Name: Tyler McNish

Organization: SafeConnect Solar

Street Address:

City:

State:

Zip:

Submittal Date: Tue Aug 28 15:46:43 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected

Resolution: This PC does not meet the requirements of 4.4.4.1 of the Regulations Governing theDevelopment of NFPA Standards. Specific requirements have not been provided.

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Public Comment No. 1985-NFPA 70-2018 [ Section No. 690.6 ]

690.6 Alternating-Current (ac) Modules and Alternating-Current (ac) Systems.

(A) Photovoltaic Source Circuits.

The requirements of Article 690 pertaining to PV source circuits shall not apply to ac modules or ac modulesystems. The PV source circuit, conductors, and inverters shall be considered as internal components of anac module or ac module system. The PV source circuit, conductors, and inverters shall be considered asinternal wiring of an ac module.

(B) Output Circuit.

The output of an ac module or ac module system shall be considered an inverter output circuit.

(C) Flexible Harnesses and Cables.

Flexible wiring harnesses and cables in ac module and ac module systems shall be installed in accordancewith the instructions included with the listed or labeled equipment. Where not otherwise specified in theirinstructions, they shall be installed in accordance with the following:

(1) Where not protected by raceways they shall be limited to rooftop locations

(2) Shall closely follow the surface(s) to which they are adjacent

(3) Shall be protected from physical damage where necessary

(4) Shall be secured or supported, at a minimum, every 1.4 m (4 1 ⁄ 2 ft) and within 300 mm (12 in.) ofevery connector. Sections of cords or cables protected from physical protection by raceways shall notbe required to be secured within the raceway

Exception: Larger support spacings are permitted as defined elsewhere in this Code for the specificwiring method.

Statement of Problem and Substantiation for Public Comment

The requirements for multiconductor cables or harnesses should not be limited to AC module systems. The proposal to remove all the text in subsection 3 in this public comment relates to our public comment to FR 8940 where we proposed moving this text to Part IV of Article 690 covering wiring methods.

Related Public Comments for This Document

Related Comment Relationship

Public Comment No. 1995-NFPA 70-2018 [New Section after 690.31(C)(3)]

Related Item

• FR-8152

Submitter Information Verification

Submitter Full Name: Christopher Fox

Organization: SunPower

Street Address:

City:

State:

Zip:

Submittal Date: Thu Aug 30 13:40:12 EDT 2018

Committee: NEC-P04

Committee Statement

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CommitteeAction:

Rejected but see related SR

Resolution: SR-7921-NFPA 70-2018 The term physical protection is changed to physical damage in690.31(C).

Statement: Section 690.6(C) is deleted. The relevant items in 690.6(C) are included in 690.31(C) includingthe text that incorporates wording related to direct burial cables.

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Public Comment No. 1025-NFPA 70-2018 [ Section No. 690.6(A) ]

(A) Photovoltaic Source Circuits.

The requirements of Article 690 pertaining to PV source circuits shall not apply to ac modules or ac modulesystems. The PV source circuit, conductors, and inverters shall be considered as internal components of anac module or ac module system. The PV source circuit, conductors, and inverters shall be considered asinternal wiring of an ac module.

Statement of Problem and Substantiation for Public Comment

The revision was not recorded properly in TerraView. The proposed change is simply removing the duplicative sentence.

Related Item

• FR 8152

Submitter Information Verification

Submitter Full Name: William Brooks

Organization: Brooks Engineering

Street Address:

City:

State:

Zip:

Submittal Date: Tue Aug 21 20:30:55 EDT 2018

Committee: NEC-P04

Committee Statement

Committee Action: Rejected but see related SR

Resolution: SR-7930-NFPA 70-2018

Statement: The last sentence was mistakenly not removed in the first draft and is removed.

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Public Comment No. 1400-NFPA 70-2018 [ Section No. 690.6(A) ]

(A) Photovoltaic Source Circuits.

The requirements of Article 690 pertaining to PV source circuits, other than 690.11 and 690.12 (B)(2)where such circuits use exposed wiring methods, shall not apply to ac modules or ac module systems.The PV source circuit, conductors, and inverters shall be considered as internal components of an acmodule or ac module system. The PV source circuit, conductors, and inverters shall be considered asinternal wiring of an ac module.

Statement of Problem and Substantiation for Public Comment

Public Inputs No. 4217-NFPA 70-2017 and No. 4127-NFPA 70-2017 included the consideration of PV Arc Fault Protection, 690.11, and PV Rapid Shutdown, 690.12, but the changes made to 690.6 (A) and the new section (C) do not address this. Instead, this clause, as currently written, continues to exempt all PV source circuits of AC modules from requirements in 690. These circuits pose the same risk to first responders as any other PV system circuits internal to the array. As an example, typical AC modules have exposed conductors that, if insulation is damaged, can pose a shock hazard to first responders.

Related Item

• PI No. 4217-NFPA 70-2017 • PI No. 4127-NFPA 70-2017

Submitter Information Verification

Submitter Full Name: Thomas A. Wegener

Organization: SMA Solar Technology AG

Street Address:

City:

State:

Zip:

Submittal Date: Tue Aug 28 05:06:30 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected

Resolution: The proposed text may cause confusion in applying requirements to listed alternating currentmodules or systems that would not otherwise be required to have dc arc-fault protection. Thesubmitter's concerns regarding arc-fault protection and rapid shutdown should be considered forinclusion in the product standard.

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Public Comment No. 26-NFPA 70-2018 [ Section No. 690.6(A) ]

(A) Photovoltaic Source Circuits.

The requirements of Article 690 pertaining to PV source circuits shall not apply to ac modules or ac modulesystems. The PV source circuit, conductors, and inverters shall be considered as internal components of anac module or ac module system. The PV source circuit, conductors, and inverters shall be considered asinternal wiring of an ac module.

Statement of Problem and Substantiation for Public Comment

Seems like the last two sentences were pulled from separate sources and added here but they mean the same thing. Delete the duplicate information.

Related Item

• 4217-NFPA 70-2017

Submitter Information Verification

Submitter Full Name: MARVIN HAMON

Organization: HAMON ENGINEERING INC

Street Address:

City:

State:

Zip:

Submittal Date: Mon Jun 25 18:18:19 EDT 2018

Committee: NEC-P04

Committee Statement

Committee Action: Rejected but see related SR

Resolution: SR-7930-NFPA 70-2018

Statement: The last sentence was mistakenly not removed in the first draft and is removed.

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Public Comment No. 1568-NFPA 70-2018 [ Section No. 690.6(C) ]

(C) Flexible Harnesses and Cables.

Flexible wiring harnesses and cables in ac module and ac module systems shall be installed in accordancewith the instructions included with the listed or labeled equipment. Where not otherwise specified in theirinstructions, they shall be installed in accordance with the following:

(1) Where not protected by raceways they shall be limited to rooftop locations

(2) Shall closely follow the surface(s) to which they are adjacent

(3) Shall be protected from physical damage where necessary

(4) Shall be secured or supported, at a minimum, every 1.4 m (4 1 ⁄ 2 ft) and within 300 mm (12 in.) ofevery connector. Sections of cords or cables protected from physical protection by raceways shall notbe required to be secured within the raceway

Exception: Larger support spacings are permitted as defined elsewhere in this Code for the specificwiring method.

Statement of Problem and Substantiation for Public Comment

These modules and systems, including their cable systems, should be permitted to be used in ground mounted systems provided the materials and methods used are consistent with other Code requirements. Since some wiring harnesses and cable types are unique to PV systems and not covered in other Articles, the addition of specific rules to Article 690 is sensible. The requirements for multiconductor cables or harnesses should not be limited to AC module systems however. The proposal to remove all the text in subsection 3 in this public comment relates to our public comment to FR 8940 where we proposed moving this text to Part IV of Article 690 covering wiring methods.

Related Public Comments for This Document

Related Comment Relationship

Public Comment No. 1786-NFPA 70-2018 [Section No. 690.31(C)(3)]

Related Item

• FR-8152

Submitter Information Verification

Submitter Full Name: Jason Fisher

Organization: Tesla Inc.

Affiliation: Solar Energy Industries Association (SEIA)

Street Address:

City:

State:

Zip:

Submittal Date: Wed Aug 29 11:59:23 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected but see related SR

Resolution: SR-7921-NFPA 70-2018 The term physical protection is changed to physical damage in690.31(C).

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Statement: Section 690.6(C) is deleted. The relevant items in 690.6(C) are included in 690.31(C) includingthe text that incorporates wording related to direct burial cables.

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Public Comment No. 1728-NFPA 70-2018 [ Section No. 690.6(C) ]

(C) Flexible Harnesses and Cables.

Flexible wiring harnesses and cables in ac module and ac module systems shall be installed in accordancewith the instructions included with the listed or labeled equipment. Where not otherwise specified in theirinstructions, they Cables and harnesses buried in the earth shall be rated “Direct Burial”. Harnesses andcables not rated for direct burial and not provided with specific installation instructions, shall be installedin accordance with the following:

(1) Where not protected by raceways they shall be limited to rooftop locations

(2) Shall closely follow the surface(s) to which they are adjacent

(3) Shall be protected from physical damage where necessary

(4) Shall be secured or supported, at a minimum, every 1.4 m (41⁄2 ft) and within 300 mm (12 in.) of everyconnector. Sections of cords or cables protected from physical protection by raceways shall not berequired to be secured within the raceway

Exception: Larger support spacings are permitted as defined elsewhere in this Code for the specific wiringmethod.

Statement of Problem and Substantiation for Public Comment

Some harnesses and DG cables are rated for direct burial applications, which includes additional requirements for this application. This proposal would require that cables and harnesses buried in the earth be rated “direct burial”.

Related Item

• First Revision No. 8152-NFPA 70-2018

Submitter Information Verification

Submitter Full Name: Timothy Zgonena

Organization: UL LLC

Street Address:

City:

State:

Zip:

Submittal Date: Wed Aug 29 18:37:24 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected but see related SR

Resolution: SR-7921-NFPA 70-2018 The term physical protection is changed to physical damage in690.31(C).

Statement: Section 690.6(C) is deleted. The relevant items in 690.6(C) are included in 690.31(C) includingthe text that incorporates wording related to direct burial cables.

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Public Comment No. 431-NFPA 70-2018 [ Section No. 690.6(C) ]

(C) Flexible Harnesses and Cables.

Flexible wiring harnesses and cables in ac module and ac module systems shall be installed in accordancewith the instructions included with the listed or labeled equipment. Where not otherwise specified in theirinstructions, they shall be installed in accordance with the following:

(1) Where not protected by raceways they shall be limited to rooftop locations

(2) Shall closely follow the surface(s) to which they are adjacent

(3) Shall be protected from physical damage where necessary

(4) Shall be secured or supported, at a minimum, every 1.4 m (41⁄2 ft) and within 300 mm (12 in.) of everyconnector. Sections of cords or cables protected from physical protection damage by raceways shallnot be required to be secured within the raceway

Exception: Larger support spacings are permitted as defined elsewhere in this Code for the specific wiringmethod.

Statement of Problem and Substantiation for Public Comment

This PC simply fixes a mistake in the text of item 4. Also, the CC made a PC that does not make sense unless the wording fix that I am proposing is what was causing them confusion. Recommend keeping all 4 items and fixing the one word.

Related Item

• CN 216

Submitter Information Verification

Submitter Full Name: William Brooks

Organization: Brooks Engineering

Street Address:

City:

State:

Zip:

Submittal Date: Mon Aug 06 17:56:55 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected but see related SR

Resolution: SR-7921-NFPA 70-2018 The term physical protection is changed to physical damage in690.31(C).

Statement: Section 690.6(C) is deleted. The relevant items in 690.6(C) are included in 690.31(C) includingthe text that incorporates wording related to direct burial cables.

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Public Comment No. 1183-NFPA 70-2018 [ Section No. 690.7(A) ]

(A) Photovoltaic Source and Output Circuits.

In a dc PV source circuit or output circuit, the maximum PV system voltage for that circuit shall becalculated in accordance with one of the following methods:

Informational Note: One source for lowest-expected, ambient temperature design data for variouslocations is the chapter titled Extreme Annual Mean Minimum Design Dry Bulb Temperature foundin the ASHRAE Handbook — Fundamentals, 2013. These temperature data can be used tocalculate maximum voltage.

(1) Module instructions: The sum of the PV module–rated open-circuit voltage of the series-connectedmodules corrected for the lowest expected ambient temperature using the open-circuit voltagetemperature coefficients in accordance with the instructions included in the listing or labeling of themodule.

(2) Table for crystalline and multicrystalline modules: For crystalline and multicrystalline silicon modules,the sum of the PV module–rated open-circuit voltage of the series-connected modules corrected forthe lowest expected ambient temperature using the correction factor provided in Table 690.7(A).

(3) Engineered industry standard method: For PV systems with an inverter generating capacity of 100 kWor greater, a documented and stamped PV system design, using an industry standard method andprovided by a licensed professional electrical engineer, shall be permitted.

Informational Note: One industry standard method for calculating maximum voltage of a PVsystem is published by Sandia National Laboratories, reference SAND 2004-3535, PhotovoltaicArray Performance Model.

Table 690.7(A) Voltage Correction Factors for Crystalline and Multicrystalline Silicon Modules

Correction Factors for Ambient Temperatures Below 25°C (77°F). (Multiply the rated open-circuitvoltage by the appropriate correction factor shown below.)

Ambient Temperature (°C) Factor Ambient Temperature (°F)

24 to 20 1.02 76 to 68

19 to 15 1.04 67 to 59

14 to 10 1.06 58 to 50

9 to 5 1.08 49 to 41

4 to 0 1.10 40 to 32

–1 to –5 1.12 31 to 23

–6 to –10 1.14 22 to 14

–11 to –15 1.16 13 to 5

–16 to –20 1.18 4 to –4

–21 to –25 1.20 –5 to –13

–26 to –30 1.21 –14 to –22

–31 to –35 1.23 –23 to –31

–36 to –40 1.25 –32 to –40

Additional Proposed Changes

File Name Description Approved

CN_217.pdf 70_CN217

Statement of Problem and Substantiation for Public Comment

NOTE: This Public Comment appeared as CC Note No. 217 in the First Draft Report on First Revision No. 8165.

The Correlating Committee directs the panel to revise the text to remove the titles of list items in accordance with

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2.1.5.1 of the NEC StyleManual. This action will be considered as a public comment.

Related Item

• First Revision No. 8165

Submitter Information Verification

Submitter Full Name: CC on NEC-AAC

Organization: NEC Correlating Committee

Street Address:

City:

State:

Zip:

Submittal Date: Fri Aug 24 10:15:53 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected but see related SR

Resolution: SR-7944-NFPA 70-2018

Statement: The reference to the ASHRAE Handbook was updated to the current edition.

This action is consistent with 2.1.5.1. of the NEC Style Manual and no titles are allowed. An “s” wasmissing from correction factor as this table has more than one factor. Item 3 is edited to bettermatch the format of items 1 and 2. It is not necessary to say that item 3 is permitted since it is oneof three items that are permitted.

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Correlating Committee Note No. 217-NFPA 70-2018 [ Section No. 690.7(A) ]

Submitter Information Verification

Submitter Full Name: Sarah CaldwellCommittee: Submittal Date: Fri May 11 15:10:48 EDT 2018

Committee Statement and Meeting Notes

Committee Statement:

The Correlating Committee directs the panel to revise the text to remove the titles of list items in accordance with 2.1.5.1 of the NEC Style Manual. This action will be considered as a public comment.

First Revision No. 8165-NFPA 70-2018 [Section No. 690.7(A)]

Ballot Results

This item has passed ballot

12 Eligible Voters0 Not Returned

12 Affirmative All0 Affirmative with Comments0 Negative with Comments0 Abstention

Affirmative AllBrunssen, James E.

Dressman, Kevin L.

Hickman, Palmer L.

Hittinger, David L.

Holub, Richard A.

Johnston, Michael J.

Kovacik, John R.

Manche, Alan

McDaniel, Roger D.

Pierce, James F.

Saporita, Vincent J.

Williams, David A.

Page 1 of 1National Fire Protection Association Report

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Public Comment No. 430-NFPA 70-2018 [ Section No. 690.7(A) ]

(A) Photovoltaic Source and Output Circuits.

In a dc PV source circuit or output circuit, the maximum PV system voltage for that circuit shall becalculated in accordance with one of the following methods:

Informational Note: One source for lowest-expected, ambient temperature design data for variouslocations is the chapter titled Extreme Annual Mean Minimum Design Dry Bulb Temperature foundin the ASHRAE Handbook — Fundamentals, 2013. These temperature data can be used tocalculate maximum voltage.

(1) Module instructions: The sum of the PV module–rated open-circuit voltage of the series-connectedmodules corrected for the lowest expected ambient temperature using the open-circuit voltagetemperature coefficients in accordance with the instructions included in the listing or labeling of themodule.

(2) Table for crystalline and multicrystalline modules: For crystalline and multicrystalline silicon modules,the sum of the PV module–rated open-circuit voltage of the series-connected modules corrected forthe lowest expected ambient temperature using the correction factor provided in Table 690.7(A).

(3) Engineered industry standard method: For PV systems with an inverter generating capacity of 100 kWor greater, a documented and stamped PV system design, using an industry standard method andprovided by a licensed professional electrical engineer, shall be permitted.

Informational Note: One industry standard method for calculating maximum voltage of a PVsystem is published by Sandia National Laboratories, reference SAND 2004-3535, PhotovoltaicArray Performance Model.

Table 690.7(A) Voltage Correction Factors for Crystalline and Multicrystalline Silicon Modules

Correction Factors for Ambient Temperatures Below 25°C (77°F). (Multiply the rated open-circuitvoltage by the appropriate correction factor shown below.)

Ambient Temperature (°C) Factor Ambient Temperature (°F)

24 to 20 1.02 76 to 68

19 to 15 1.04 67 to 59

14 to 10 1.06 58 to 50

9 to 5 1.08 49 to 41

4 to 0 1.10 40 to 32

–1 to –5 1.12 31 to 23

–6 to –10 1.14 22 to 14

–11 to –15 1.16 13 to 5

–16 to –20 1.18 4 to –4

–21 to –25 1.20 –5 to –13

–26 to –30 1.21 –14 to –22

–31 to –35 1.23 –23 to –31

–36 to –40 1.25 –32 to –40

Statement of Problem and Substantiation for Public Comment

The correlating committee or the technical editor added these titles to the 2017 Second Revision. CMP4 fixed the titles as they were lengthy and not all that accurate. Now the CC claims that 2.1.5.1. of the style manual applies here and that no titles are allowed. CMP4 did not start this so we need stop having mixed signals. I recommend that we leave it as revised in the 2020 First Revision.

Related Item

• CN 217

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Submitter Information Verification

Submitter Full Name: William Brooks

Organization: Brooks Engineering

Street Address:

City:

State:

Zip:

Submittal Date: Mon Aug 06 17:50:30 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected but see related SR

Resolution: SR-7944-NFPA 70-2018

Statement: The reference to the ASHRAE Handbook was updated to the current edition.

This action is consistent with 2.1.5.1. of the NEC Style Manual and no titles are allowed. An “s” wasmissing from correction factor as this table has more than one factor. Item 3 is edited to bettermatch the format of items 1 and 2. It is not necessary to say that item 3 is permitted since it is oneof three items that are permitted.

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Public Comment No. 1371-NFPA 70-2018 [ Section No. 690.7 [Excluding any Sub-

Sections] ]

The maximum voltage of PV system dc circuits shall be the highest calculated voltage between any twocircuit conductors or any conductor and ground. The maximum voltage shall be used to determine thevoltage and voltage to ground of circuits in the application of this Code. Maximum voltage shall be used forconductors, cables, equipment, working space, and other applications where voltage limits and ratings areused.

PV system dc circuits on or in one- and two-family dwellings shall be permitted to have a maximum voltageno greater than 1000 volts. PV source and output circuits on or in one- and two-family dwellings shall bepermitted to have a maximum voltage no greater than 600 volts. Where not located on or in buildings, listeddc PV equipment, rated at a maximum voltage no greater than 1500 volts, shall not be required to complywith Parts II and III of Article 490.

Statement of Problem and Substantiation for Public Comment

The wording for maximum system voltage appears to be conflicting. PV system dc circuits are allowed up to 1000V while PV source and output circuits are allowed up to 600V. However, aren't source and output circuits also system dc circuits?

Related Item

• FR-8158

Submitter Information Verification

Submitter Full Name: Joseph Felker

Organization: GAF

Street Address:

City:

State:

Zip:

Submittal Date: Mon Aug 27 14:55:07 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected but see related SR

Resolution: SR-8132-NFPA 70-2018

Statement: Additional editorial changes are made to the first paragraph for clarity. This revision essentiallyreturns the language to that of the 2017 edition. Buildings are permitted with systems no greaterthan 1000V and one- and two-family dwellings to no greater than 600V.

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Public Comment No. 1394-NFPA 70-2018 [ Section No. 690.7 [Excluding any Sub-

Sections] ]

The maximum voltage of PV system dc circuits shall be the highest calculated voltage between any twocircuit conductors or any conductor and ground. The maximum voltage shall be used to determine thevoltage and voltage to ground of circuits in the application of this Code. Maximum voltage shall be used forconductors, cables, equipment, working space, and other applications where voltage limits and ratings areused.

PV system dc circuits on or in one- and two-family dwellings shall be permitted to buildings shall have amaximum voltage no greater than 1000 volts. PV source and output circuits on or in one- and two-familydwellings shall be permitted to have a maximum voltage no greater than 600 volts. Where not located on orin buildings, listed dc PV equipment, rated at a maximum voltage no greater than 1500 volts, shall not berequired to comply with Parts II and III of Article 490.

Statement of Problem and Substantiation for Public Comment

The most important comment is to address the error in the first draft that changed the term "buildings" to "one- and two family dwellings" in the first sentence. As was pointed out in my comment on my affirmative note, this was not what was voted on.

The second set of revisions is a simple refinement of the first draft. The old construction had "be permitted to" because the old language worked with that. We can remove those words and the meaning is the same and even clearer. There were many comments about the concern with allowing dc-to-dc converter circuits to operate up to 1000V on dwellings. These comments did not address the main substantiation in PI3850 that shows that 1000V circuits are already permitted in dwellings in accordance with 600.32(I). Dc-to-dc converters only operate at 1000V, but return to the voltage of a single module when not operating. The intent is to allow a single dc-to-dc converter string to be mounted on a rooftop PV system to simply wiring for these systems that are safer than 600V PV source circuits.

Related Item

• PI 3850

Submitter Information Verification

Submitter Full Name: William Brooks

Organization: Brooks Engineering

Street Address:

City:

State:

Zip:

Submittal Date: Tue Aug 28 01:15:53 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected but see related SR

Resolution: SR-8132-NFPA 70-2018

Statement: Additional editorial changes are made to the first paragraph for clarity. This revision essentiallyreturns the language to that of the 2017 edition. Buildings are permitted with systems no greaterthan 1000V and one- and two-family dwellings to no greater than 600V.

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Public Comment No. 1401-NFPA 70-2018 [ Section No. 690.7 [Excluding any Sub-

Sections] ]

The maximum voltage of PV system dc circuits shall be the highest calculated voltage between any twocircuit conductors or any conductor and ground. The maximum voltage shall be used to determine thevoltage and voltage to ground of circuits in the application of this Code. Maximum voltage shall be used forconductors, cables, equipment, working space, and other applications where voltage limits and ratings areused.

PV system dc circuits on or in one- and two-family dwellings shall be permitted to have a maximum voltageno greater than 1000 volts 600 volts . PV source and output system dc circuits on or in one- and two-familydwellings other types of buildings shall be permitted to have a maximum voltage no greater than 600volts 1000 volts . Where not located on or in buildings, listed dc PV equipment, rated at a maximum voltageno greater than 1500 volts, shall not be required to comply with Parts II and III of Article 490.

Statement of Problem and Substantiation for Public Comment

The FR change leads to ambiguity in the code by changing what was already clear in the 2017 code. These changes created the following issues: 1. The voltage level for other buildings has been eliminated. This needs to be added back. 2. It allows higher than 600V on one and two family dwellings for dc-dc circuits only without any justification regarding safety.The proposed edits to the First Revision align with the requirements of the original 2017 NEC language, which is: "PV system dc circuits on or in one- and two-family dwellings shall be permitted to have a maximum voltage of 600 volts or less. PV system dc circuits on or in other types of buildings shall be permitted to have a maximum voltage of 1000 volts or less. Where not located on or in buildings, listed dc PV equipment, rated at a maximum voltage of 1500 volts or less, shall not be required to comply with Parts II and III of Article 490."

Related Item

• FR No. 8158-NFPA 70-2018

Submitter Information Verification

Submitter Full Name: Thomas A. Wegener

Organization: SMA Solar Technology AG

Street Address:

City:

State:

Zip:

Submittal Date: Tue Aug 28 05:33:00 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected but see related SR

Resolution: SR-8132-NFPA 70-2018

Statement: Additional editorial changes are made to the first paragraph for clarity. This revision essentiallyreturns the language to that of the 2017 edition. Buildings are permitted with systems no greaterthan 1000V and one- and two-family dwellings to no greater than 600V.

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Public Comment No. 1536-NFPA 70-2018 [ Section No. 690.7 [Excluding any Sub-

Sections] ]

The maximum voltage of PV system dc circuits shall be the highest calculated voltage between any twocircuit conductors or any conductor and ground. The maximum voltage shall be used to determine thevoltage and voltage to ground of circuits in the application of this Code . Maximum voltage shall be used forconductors, cables, equipment, working space, and other applications where voltage limits and ratings areused.

PV system dc circuits on or in one- and two-family dwellings buildings shall be permitted to have amaximum voltage no greater than 1000 volts. PV source and output circuits on or in one- and two-familydwellings shall be permitted to have a maximum voltage no greater than 600 volts. Where not located on orin buildings, listed dc PV equipment, rated at a maximum voltage no greater than 1500 volts, shall not berequired to comply with Parts II and III of Article 490 . (A) Photovoltaic Source and Output Circuits.

PV source and output circuits on or in one- and two-family dwellings shall be permitted to have amaximum voltage no greater than 600 volts

Statement of Problem and Substantiation for Public Comment

The current first draft language does not appear to have been recorded correctly and is not comprehensible.

Related Item

• FR-8158

Submitter Information Verification

Submitter Full Name: Rebekah Hren

Organization: IPPNC LLC

Street Address:

City:

State:

Zip:

Submittal Date: Wed Aug 29 10:46:50 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected but see related SR

Resolution: SR-8132-NFPA 70-2018

Statement: Additional editorial changes are made to the first paragraph for clarity. This revision essentiallyreturns the language to that of the 2017 edition. Buildings are permitted with systems no greaterthan 1000V and one- and two-family dwellings to no greater than 600V.

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Public Comment No. 1569-NFPA 70-2018 [ Section No. 690.7 [Excluding any Sub-

Sections] ]

The maximum voltage of PV system dc circuits shall be the highest calculated voltage between any twocircuit conductors of a circuit or any circuit conductor and ground. The maximum voltage shall be used todetermine the voltage and voltage to ground of circuits in the application of this Code. Maximum voltageshall be used for conductors, cables, equipment, working space, and other applications where voltage limitsand ratings are used.

PV system dc circuits on or in one- and two-family dwellings shall be permitted to have a maximum voltageno greater than 1000 volts. PV source and output circuits on or in one- and two-family dwellings shall bepermitted to have a maximum voltage no greater than 600 volts. Where not located on or in buildings, listeddc PV equipment, rated at a maximum voltage no greater than 1500 volts, shall not be required to complywith Parts II and III of Article 490.

Statement of Problem and Substantiation for Public Comment

This change is editorial but would improve the applicability of the Code by preventing potential confusion when applying these overall requirements in systems with multiple circuits, such as bipolar systems.

Related Item

• PI 3596 • FR-8158

Submitter Information Verification

Submitter Full Name: Jason Fisher

Organization: Tesla Inc.

Affiliation: Solar Energy Industries Association (SEIA)

Street Address:

City:

State:

Zip:

Submittal Date: Wed Aug 29 12:01:41 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected but see related SR

Resolution: SR-8132-NFPA 70-2018

Statement: Additional editorial changes are made to the first paragraph for clarity. This revision essentiallyreturns the language to that of the 2017 edition. Buildings are permitted with systems no greaterthan 1000V and one- and two-family dwellings to no greater than 600V.

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Public Comment No. 1748-NFPA 70-2018 [ Section No. 690.7 [Excluding any Sub-

Sections] ]

The maximum voltage of PV system dc circuits shall be the highest calculated voltage between any twocircuit conductors or any conductor and ground. The maximum voltage shall be used to determine thevoltage and voltage to ground of circuits in the application of this Code. Maximum voltage shall be used forconductors, cables, equipment, working space, and other applications where voltage limits and ratings areused.

PV system dc circuits on or in one- and two-family dwellings shall be permitted to have a maximum voltageno greater than 1000 volts. PV source and output circuits on or in one- and two-family dwellings shall bepermitted to have a maximum voltage no greater than 600 volts. Where not located on or in buildings, listeddc PV equipment, rated at a maximum voltage no greater than 1500 volts, shall not be required to complywith Parts II and III of Article 490.

Statement of Problem and Substantiation for Public Comment

There is no sound rationale to increase the voltage levels above 600 volts phase to phase on dwellings due mostly due to their limited size. On larger commercial systems higher voltages can be used and effectively reduce the required size of the conductors and the lack of accessibility by unqualified personnel lowers the potential threshold for personal injury. On dwellings access is less limited and the potential for inadvertent contact with conductors and parts is increased. This requirement should not be limited to one or two family dwellings but rather should apply to all dwelling type occupancies.

Related Item

• FR8158

Submitter Information Verification

Submitter Full Name: James Rogers

Organization: Towns Of Oak Bluffs, Tisbury,

Street Address:

City:

State:

Zip:

Submittal Date: Wed Aug 29 20:07:51 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected but see related SR

Resolution: SR-8132-NFPA 70-2018

Statement: Additional editorial changes are made to the first paragraph for clarity. This revision essentiallyreturns the language to that of the 2017 edition. Buildings are permitted with systems no greaterthan 1000V and one- and two-family dwellings to no greater than 600V.

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Public Comment No. 2177-NFPA 70-2018 [ Section No. 690.7 [Excluding any Sub-

Sections] ]

The maximum voltage of PV system dc circuits shall be the highest calculated voltage between any twocircuit conductors or any conductor and ground. The maximum voltage shall be used to determine thevoltage and voltage to ground of circuits in the application of this Code. Maximum voltage shall be used forconductors, cables, equipment, working space, and other applications where voltage limits and ratings areused.

PV system dc circuits on or in one- and two-family dwellings shall be permitted to have a maximum voltageno greater than 1000 600 volts. PV source and output circuits on or in one- and two-family dwellings shallbe permitted to have a maximum voltage no greater than 600 volts. Where not located on or in buildings,listed dc PV equipment, rated at a maximum voltage no greater than 1500 volts, shall not be required tocomply with Parts II and III of Article 490.

Statement of Problem and Substantiation for Public Comment

"As mentioned in CMP members comments in FR8158, there are significant safety concerns regarding personel working on 1000V DC circuits. PV systems on one and two family dwellings are distributed across all regions in large volumes. Conductors operating up to 1000V will be present in homes that change owners and are subject to other electrical and remodeling projects that will expose workers and homeowners to these voltages. The concern is for workers who don't use the right tools and safety protocol that is required to work on these circuits. Also, many DIY homeowners will encounter these circuits while doing upgrade and maintenance work. Residential systems are not in the same type of controlled environment that exists on commercial and industrial sites, with trained personnel familiar with the safety protocol for working on these circuits, and the general public generally restricted from having access.

Additionally, there will be a burden placed on the AHJ to approve and inspect all BOS components to assure 1000V rating. With the volume of PV projects in many AHJs , there is a risk of 600V components getting installed on 1000V circuits, which is an unacceptable risk.

WIth a change this impactful with safety implications, a measured approach and plan that engages stakeholders in the industry, NRTLs, building officials and manufacturers is warranted. "

Related Item

• FR-8158

Submitter Information Verification

Submitter Full Name: Christopher Fox

Organization: SunPower

Street Address:

City:

State:

Zip:

Submittal Date: Thu Aug 30 21:59:53 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected but see related SR

Resolution: SR-8132-NFPA 70-2018

Statement: Additional editorial changes are made to the first paragraph for clarity. This revision essentiallyreturns the language to that of the 2017 edition. Buildings are permitted with systems no greaterthan 1000V and one- and two-family dwellings to no greater than 600V.

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Public Comment No. 173-NFPA 70-2018 [ Section No. 690.8(A) ]

(A) Calculation of Maximum Circuit Current.

The maximum current for the specific circuit shall be calculated in accordance with 690.8(A)(1) through(A)(5) or where supplying an Electronic Power Converter , as permitted in accordance with 690.8(A)( 6) .

(1) Photovoltaic Source Circuit Currents.

The maximum current shall be as calculated in 690.8(A)(1)(1), or where meeting the associated restrictions,as permitted in accordance with either 690.8(A)(1)(2) or 690 . 8(A)(2).

(1) The sum of parallel-connected PV module–rated short-circuit currents multiplied by 125 percent

(2) For PV systems with an inverter generating capacity of 100 kW or greater, a documented andstamped PV system design, using an industry standard method and provided by a licensedprofessional electrical engineer, shall be permitted. The calculated maximum current value shall bebased on the highest 3-hour current average resulting from the simulated local irradiance on the PVarray accounting for elevation and orientation. The current value used by this method shall not be lessthan 70 percent of the value calculated using 690.8(A)(1)(1).

Informational Note: One industry standard method for calculating maximum current of a PV systemis available from Sandia National Laboratories, reference SAND 2004-3535, Photovoltaic ArrayPerformance Model. This model is used by the System Advisor Model simulation program providedby the National Renewable Energy Laboratory.

(2) Photovoltaic Output Circuit Currents .

The maximum current shall be the sum of parallel source circuit maximum currents as calculated in690.8(A)(1) .

(3) Inverter Output Circuit Current.

The maximum current shall be the inverter continuous output current rating.

(4) DC-to-DC Converter Source Circuit Current.

The maximum current shall be the dc-to-dc converter continuous output current rating.

(5) DC-to-DC Converter Output Circuit Current.

The maximum current shall be the sum of parallel connected dc-to-dc converter source circuit currents ascalculated in 690.8(A)(4).

(6) Currents of Circuits Connected to the Input of Electronic Power Converters.

The maximum current for a PV system dc circuit connected to the input of an electronic power convertershall be permitted to be the lesser of the rated input current of the converter, or the current as calculated in690.8(A)(1)

and

through (A)(

3

5 ). Where the rated input current of the converter is not provided in the manufacturer’s instructions, therated input current shall be the current at the lowest input voltage in which the device converts continuousrated output power.

Where multiple PV system dc circuits are connected to a single electronic power converter input, themaximum current per circuit shall be the rated input current of the converter divided by the number ofcircuits connected to the input.

(3) Photovoltaic Output Circuit Currents.

The maximum current shall be the sum of parallel source circuit maximum currents as calculated in690.8(A)(1) or (A)(2).

(4) Inverter Output Circuit Current.

The maximum current shall be the inverter continuous output current rating.

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(5) DC-to-DC Converter Source Circuit Current.

The maximum current shall be the dc-to-dc converter continuous output current rating.

(6) DC-to-DC Converter Output Circuit Current.

The maximum current shall be the sum of parallel connected dc-to-dc converter source circuit currents ascalculated in 690.8(A)(2) or (A)(5).

Statement of Problem and Substantiation for Public Comment

As written this section is hard to follow. There are rules for calculating circuit max currents and then in the middle this variation for converters is dropped. It's more straight forward to renumber the rules, make the converter variation the last one and provide instructions accordingly. I feel my revised wording is easier to follow and will be easier to apply by the user.

Related Item

• First Revision No. 8756-NFPA 70-2018 • Public Input No. 4025-NFPA 70-2017

Submitter Information Verification

Submitter Full Name: MARVIN HAMON

Organization: HAMON ENGINEERING INC

Street Address:

City:

State:

Zip:

Submittal Date: Fri Jul 06 13:47:21 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected but see related SR

Resolution: SR-8133-NFPA 70-2018

Statement: This SR rectifies the style manual issues with the list in 690.8(A)(1). Small editorial changes aremade in the now 690.8(A)(1)(a)(1) to make it a sentence and with (2) to align with edits in690.7(A)(3). The SR also provides a reorganization of section 690.8(A) to improve theunderstanding of the section. Inverter Output Circuit Current, is moved to 690.8(A)(1)(e) to comeafter all the PV system dc circuit items. Section 690.8(A)(2) includes clarifying language to requirean overcurrent device in accordance with 240.4(B) to address the allowance to round up to the nextstandard size. The second paragraph of the original 690.8(A)(2) is deleted.

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Public Comment No. 1184-NFPA 70-2018 [ Section No. 690.8(A)(1) ]

(1) Photovoltaic Source Circuit Currents.

The maximum current shall be as calculated in 690.8(A)(1)(1), or where meeting the associatedrestrictions, as permitted in accordance with either 690.8(A)(1)(2) or 690.8(A)(2).

(1) The sum of parallel-connected PV module–rated short-circuit currents multiplied by 125 percent

(2) For PV systems with an inverter generating capacity of 100 kW or greater, a documented andstamped PV system design, using an industry standard method and provided by a licensedprofessional electrical engineer, shall be permitted. The calculated maximum current value shall bebased on the highest 3-hour current average resulting from the simulated local irradiance on the PVarray accounting for elevation and orientation. The current value used by this method shall not be lessthan 70 percent of the value calculated using 690.8(A)(1)(1).

Informational Note: One industry standard method for calculating maximum current of a PV systemis available from Sandia National Laboratories, reference SAND 2004-3535, Photovoltaic ArrayPerformance Model. This model is used by the System Advisor Model simulation program providedby the National Renewable Energy Laboratory.

Additional Proposed Changes

File Name Description Approved

CN_218.pdf 70_CN218

Statement of Problem and Substantiation for Public Comment

NOTE: This Public Comment appeared as CC Note No. 218 in the First Draft Report on First Revision No. 8756.

The Correlating Committee directs that this first revision be rewritten to comply with the NEC Style Manual. (Because the revision removed the introtext to list items (1) and (2), these should now be renumbered as subdivisions (a) and (b), but (a) needs to be written as a requirement in a completesentence.). This action will be considered as a public comment.

Related Item

• First Revision No. 8756

Submitter Information Verification

Submitter Full Name: CC on NEC-AAC

Organization: NEC Correlating Committee

Street Address:

City:

State:

Zip:

Submittal Date: Fri Aug 24 10:17:24 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected but see related SR

Resolution: SR-8133-NFPA 70-2018

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Statement: This SR rectifies the style manual issues with the list in 690.8(A)(1). Small editorial changes aremade in the now 690.8(A)(1)(a)(1) to make it a sentence and with (2) to align with edits in690.7(A)(3). The SR also provides a reorganization of section 690.8(A) to improve theunderstanding of the section. Inverter Output Circuit Current, is moved to 690.8(A)(1)(e) to comeafter all the PV system dc circuit items. Section 690.8(A)(2) includes clarifying language to requirean overcurrent device in accordance with 240.4(B) to address the allowance to round up to the nextstandard size. The second paragraph of the original 690.8(A)(2) is deleted.

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Correlating Committee Note No. 218-NFPA 70-2018 [ Section No. 690.8(A)(1) ]

Submitter Information Verification

Submitter Full Name: Sarah CaldwellCommittee: Submittal Date: Fri May 11 15:12:21 EDT 2018

Committee Statement and Meeting Notes

Committee Statement:

The Correlating Committee directs that this first revision be rewritten to comply with the NEC Style Manual. (Because the revision removed the intro text to list items (1) and (2), these should now be renumbered as subdivisions (a) and (b), but (a) needs to be written as a requirement in a complete sentence.). This action will be considered as a public comment.

First Revision No. 8756-NFPA 70-2018 [Section No. 690.8(A)(1)]

Ballot Results

This item has passed ballot

12 Eligible Voters0 Not Returned

12 Affirmative All0 Affirmative with Comments0 Negative with Comments0 Abstention

Affirmative AllBrunssen, James E.

Dressman, Kevin L.

Hickman, Palmer L.

Hittinger, David L.

Holub, Richard A.

Johnston, Michael J.

Kovacik, John R.

Manche, Alan

McDaniel, Roger D.

Pierce, James F.

Saporita, Vincent J.

Williams, David A.

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Public Comment No. 248-NFPA 70-2018 [ Section No. 690.8(A)(1) ]

(1) Photovoltaic Source Circuit Currents.

The maximum current shall be as calculated in 690.8(A)(1)(1), or where meeting the associated restrictions,as permitted in accordance with either 690.8(A)(1)(2) or 690.8(A)(2).

(1) The sum of parallel-connected PV module–rated short-circuit currents multiplied by 125 percent

(2) For PV systems with an inverter a DC generating capacity of 100 kW or greater, a documented andstamped PV system design, using an industry standard method and provided by a licensedprofessional electrical engineer, shall be permitted. The calculated maximum current value shall bebased on the highest 3-hour current average resulting from the simulated local irradiance on the PVarray accounting for elevation and orientation. The current value used by this method shall not be lessthan 70 percent of the value calculated using 690.8(A)(1)(1).

Informational Note: One industry standard method for calculating maximum current of a PV systemis available from Sandia National Laboratories, reference SAND 2004-3535, Photovoltaic ArrayPerformance Model. This model is used by the System Advisor Model simulation program providedby the National Renewable Energy Laboratory.

Statement of Problem and Substantiation for Public Comment

Since this section is about calculating the DC current values the AC rating of the PV system is immaterial and the change proposed by the PI would radically change the power requirement for this provision. With DC/AC ratios of 1.2 to 1.5 being standard this would mean that PV array would have to have a DC rating of 120-150kW before this section could be used instead of the current interpretation of 100kW. My change would make it explicitly the DC rating.

Related Item

• First Revision No. 8756-NFPA 70-2018

Submitter Information Verification

Submitter Full Name: MARVIN HAMON

Organization: HAMON ENGINEERING INC

Street Address:

City:

State:

Zip:

Submittal Date: Fri Jul 20 14:38:23 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected

Resolution: The size of the inverter(s) is the criteria for when the calculation is permitted. The only availablecriteria is the ac rating of the inverter. It is understood that the dc system may be larger or smallerthan the inverter.

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Public Comment No. 432-NFPA 70-2018 [ Section No. 690.8(A)(1) ]

(1) Photovoltaic Source Circuit Currents.

The maximum current shall be as calculated in 690.8(A)(1)(

1a ) , or where meeting the associated restrictions, as permitted in accordance with either 690.8(A)(1)(

2b ) or 690.8(A)(2)

.

(a) The calculated maximum current shall be the sum of

parallel-connected PV module–ratedthe short

-circuit currentscircuit current ratings of the PV modules connected in parallel multiplied by 125 percent .

(b) For PV systems with an inverter generating capacity of 100 kW or greater, a documented and stampedPV system design, using an industry standard method and provided by a licensed professional electricalengineer, shall be permitted. The calculated maximum current value shall be based on the highest 3-hourcurrent average resulting from the simulated local irradiance on the PV array accounting for elevation andorientation. The current value used by this method shall not be less than 70 percent of the value calculatedusing 690.8(A)(1)(1) .

Informational Note: One industry standard method for calculating maximum current of a PV systemis available from Sandia National Laboratories, reference SAND 2004-3535, Photovoltaic ArrayPerformance Model. This model is used by the System Advisor Model simulation program providedby the National Renewable Energy Laboratory.

Statement of Problem and Substantiation for Public Comment

The CC in CN 218 recommended that we change the numbering to subdivision lettering. This does read less confusing, but we were trying to follow the style manual.The first items was turned into a sentence to match the style manual. Very difficult sentence to write as source circuits can contain paralleled modules, but often do not.

Related Item

• CN 218

Submitter Information Verification

Submitter Full Name: William Brooks

Organization: Brooks Engineering

Street Address:

City:

State:

Zip:

Submittal Date: Mon Aug 06 18:06:04 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected but see related SR

Resolution: SR-8133-NFPA 70-2018

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Statement: This SR rectifies the style manual issues with the list in 690.8(A)(1). Small editorial changes aremade in the now 690.8(A)(1)(a)(1) to make it a sentence and with (2) to align with edits in690.7(A)(3). The SR also provides a reorganization of section 690.8(A) to improve theunderstanding of the section. Inverter Output Circuit Current, is moved to 690.8(A)(1)(e) to comeafter all the PV system dc circuit items. Section 690.8(A)(2) includes clarifying language to requirean overcurrent device in accordance with 240.4(B) to address the allowance to round up to the nextstandard size. The second paragraph of the original 690.8(A)(2) is deleted.

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Public Comment No. 1574-NFPA 70-2018 [ Section No. 690.8(A)(2) ]

(2) Currents of Circuits Connected to the Input of Electronic Power Converters.

The maximum current for a PV system dc circuit connected to the input of an electronic power convertershall be permitted to be the lesser of the rated input current of the converter, or the current as calculated in690.8(A)(1) and (A)(3). Where the rated input current of the converter is not provided in the manufacturer’sinstructions or label , the rated input current shall be the current at the lowest input voltage in which thedevice converts continuous rated output power.

Where multiple PV system dc circuits are connected to a single electronic power converter input, themaximum current per circuit shall be the rated input current of the converter divided by the number ofsource circuits or output circuits connected to the input.

Statement of Problem and Substantiation for Public Comment

This changes adds an option to use the equipment label instead of just the instructions to determine the equipment's current rating. This should help enforcement. Additionally specifying the circuits to be used in the "number of" scenario is important since it should be either of these two types of circuits, not the sum of both.

Related Item

• FR-8194

Submitter Information Verification

Submitter Full Name: Jason Fisher

Organization: Tesla Inc.

Affiliation: Solar Energy Industries Association (SEIA)

Street Address:

City:

State:

Zip:

Submittal Date: Wed Aug 29 12:11:11 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected but see related SR

Resolution: SR-8133-NFPA 70-2018

Statement: This SR rectifies the style manual issues with the list in 690.8(A)(1). Small editorial changes aremade in the now 690.8(A)(1)(a)(1) to make it a sentence and with (2) to align with edits in690.7(A)(3). The SR also provides a reorganization of section 690.8(A) to improve theunderstanding of the section. Inverter Output Circuit Current, is moved to 690.8(A)(1)(e) to comeafter all the PV system dc circuit items. Section 690.8(A)(2) includes clarifying language to requirean overcurrent device in accordance with 240.4(B) to address the allowance to round up to the nextstandard size. The second paragraph of the original 690.8(A)(2) is deleted.

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Public Comment No. 171-NFPA 70-2018 [ Section No. 690.8(A)(2) ]

(2) Currents of Circuits Connected to the Input of Electronic Power Converters.

The maximum current for a PV system dc circuit connected to the input of an electronic power convertershall be permitted to be the lesser of the rated input current of the converter, or the current as calculated in690.8(A)(1) and (A)(3). Where the rated input current of the converter is not provided in the manufacturer’sinstructions, the rated input current shall be the current at the lowest input voltage in which the deviceconverts continuous rated output power.

Where multiple PV system dc circuits are connected to a single electronic power converter input, themaximum current per circuit shall be permitted to be the rated input current of the converter divided by thenumber of circuits connected to the input.

Statement of Problem and Substantiation for Public Comment

This should be permissive. It's possible for the sources to be smaller than the rating of the converter divided by the number of input circuits, in that case the conductors can be rated less than the rating of the converter divided by the number of input circuits. It's also possible that the designer chooses to fully rate the input conductors for the source output. So let's write this as an option and not a requirement.

Related Item

• First Revision No. 8194-NFPA 70-2018

Submitter Information Verification

Submitter Full Name: MARVIN HAMON

Organization: HAMON ENGINEERING INC

Street Address:

City:

State:

Zip:

Submittal Date: Thu Jul 05 23:40:10 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected but see related SR

Resolution: SR-8133-NFPA 70-2018

Statement: This SR rectifies the style manual issues with the list in 690.8(A)(1). Small editorial changes aremade in the now 690.8(A)(1)(a)(1) to make it a sentence and with (2) to align with edits in690.7(A)(3). The SR also provides a reorganization of section 690.8(A) to improve theunderstanding of the section. Inverter Output Circuit Current, is moved to 690.8(A)(1)(e) to comeafter all the PV system dc circuit items. Section 690.8(A)(2) includes clarifying language to requirean overcurrent device in accordance with 240.4(B) to address the allowance to round up to the nextstandard size. The second paragraph of the original 690.8(A)(2) is deleted.

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Public Comment No. 1753-NFPA 70-2018 [ Section No. 690.8(A)(2) ]

(2) Currents of Circuits Connected to the Input of Electronic Power Converters.

The maximum current for a PV system dc circuit connected to the input of an electronic power convertershall be permitted to be the lesser of the rated input current of the converter, or the current as calculated in690.8(A)(1) and (A)(3) . Where the rated input current of the converter is not provided in the manufacturer’sinstructions, the rated input current shall be the current at the lowest input voltage in which the deviceconverts continuous rated output power.

Where multiple PV system dc circuits are connected to a single electronic power converter input, themaximum current per circuit shall be the rated input current of the converter divided by the number ofcircuits connected to the input.

Statement of Problem and Substantiation for Public Comment

The reference to (A)(3) is not necessary and actually creates confusion for the application of this permissive language

Related Item

• FR8194

Submitter Information Verification

Submitter Full Name: James Rogers

Organization: Towns Of Oak Bluffs, Tisbury,

Street Address:

City:

State:

Zip:

Submittal Date: Wed Aug 29 20:25:12 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected but see related SR

Resolution: SR-8133-NFPA 70-2018

Statement: This SR rectifies the style manual issues with the list in 690.8(A)(1). Small editorial changes aremade in the now 690.8(A)(1)(a)(1) to make it a sentence and with (2) to align with edits in690.7(A)(3). The SR also provides a reorganization of section 690.8(A) to improve theunderstanding of the section. Inverter Output Circuit Current, is moved to 690.8(A)(1)(e) to comeafter all the PV system dc circuit items. Section 690.8(A)(2) includes clarifying language to requirean overcurrent device in accordance with 240.4(B) to address the allowance to round up to the nextstandard size. The second paragraph of the original 690.8(A)(2) is deleted.

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Public Comment No. 611-NFPA 70-2018 [ Section No. 690.8(A)(3) ]

(3) Photovoltaic Output Circuit Currents.

The maximum current shall be the sum of parallel source circuit maximum currents as calculated in690.8(A)(1) or (A)(2) .

Statement of Problem and Substantiation for Public Comment

The inclusion of (A)(2) creates a circular reference. (A)(2) includes a reference to current calculated in (A)(1) and (A)(3). Including (A)(2) also does not make much sense since a PV output circuit will not have as a source an electronic power converter. That is what we call a DC-DC Converter output circuit.

Related Item

• First Revision No. 8202-NFPA 70-2018

Submitter Information Verification

Submitter Full Name: MARVIN HAMON

Organization: HAMON ENGINEERING INC

Street Address:

City:

State:

Zip:

Submittal Date: Mon Aug 13 23:18:01 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected but see related SR

Resolution: SR-8133-NFPA 70-2018

Statement: This SR rectifies the style manual issues with the list in 690.8(A)(1). Small editorial changes aremade in the now 690.8(A)(1)(a)(1) to make it a sentence and with (2) to align with edits in690.7(A)(3). The SR also provides a reorganization of section 690.8(A) to improve theunderstanding of the section. Inverter Output Circuit Current, is moved to 690.8(A)(1)(e) to comeafter all the PV system dc circuit items. Section 690.8(A)(2) includes clarifying language to requirean overcurrent device in accordance with 240.4(B) to address the allowance to round up to the nextstandard size. The second paragraph of the original 690.8(A)(2) is deleted.

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Public Comment No. 1754-NFPA 70-2018 [ Section No. 690.8(B) [Excluding any Sub-

Sections] ]

Circuit conductors shall be sized to carry not less than the larger of larger ampacity calculated inaccordance with 690.8(B)(1) or (B)(2).

Statement of Problem and Substantiation for Public Comment

The added language adds clarity for the application of this requirement

Related Item

• FR8213

Submitter Information Verification

Submitter Full Name: James Rogers

Organization: Towns Of Oak Bluffs, Tisbury,

Street Address:

City:

State:

Zip:

Submittal Date: Wed Aug 29 20:30:30 EDT 2018

Committee: NEC-P04

Committee Statement

Committee Action: Accepted

Resolution: SR-7949-NFPA 70-2018

Statement: The added language provides clarity for the application of this requirement.

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Public Comment No. 1187-NFPA 70-2018 [ Section No. 690.9(A) ]

(A) Circuits and Equipment.

PV system dc circuit and inverter output conductors and equipment shall be protected against overcurrent.Circuits sized in accordance with 690.8(A)(2) are required to protected against overcurrent withovercurrent protective devices. Each circuit shall be protected from overcurrent in accordance with690.9(A)(1), (A)(2), or (A)(3).

(1) Circuits Where Overcurrent Protection Not Required.

Overcurrent protective devices shall not be required where both of the following conditions are met:

(1) The circuits have sufficient ampacity for the maximum circuit current.

(2) The currents from all sources do not exceed the maximum overcurrent protective device ratingspecified for the PV module or electronic power converter.

(2) Circuits Connected to Source of Overcurrent on One End.

Circuits connected to current-limited supplies (e.g., PV modules, electronic power converters, interactiveinverter output circuits) and also connected to sources having higher current availability (e.g., parallelstrings of modules, utility power), that are a source of overcurrent, shall be protected at the higher currentsource connection.

Informational Note: Photovoltaic system dc circuits are current-limited circuits and may not needovercurrent protection. When connected in parallel to higher current sources, such as parallel-connected PV system dc circuits, batteries, or backfeed from inverters, the overcurrent device isoften installed at the higher current source end of the circuit.

(3) Circuits Connected to Sources of Overcurrent on Both Ends.

Circuits that do not comply with 690.9(A)(1) or (A)(2) and with sources of overcurrent on both ends of aconductor shall be protected with one of the following methods:

(1) Conductors not greater than 3 m (10 ft) in length and protected from overcurrent on one end

(2) Conductors protected from overcurrent on both ends

(3) Conductors not installed on or in buildings are permitted to be protected from overcurrent on one endof the circuit where the circuit complies with all of the following conditions:

a. The conductors are installed in metal raceways or metal-clad cables, or installed in enclosedmetal cable trays, or underground, or where directly entering pad-mounted enclosures.

b. The conductors for each circuit terminate on one end at a single circuit breaker or a single set offuses that limit the current to the ampacity of the conductors.

c. The overcurrent device for the conductors is an integral part of a disconnecting means or shall belocated within 3 m (10 ft) of conductor length of the disconnecting means.

d. The disconnecting means for the conductors is installed outside of a building, or at a readilyaccessible location nearest the point of entrance of the conductors inside of a building, includinginstallations complying with 230.6.

Additional Proposed Changes

File Name Description Approved

CN_219.pdf 70_CN219

Statement of Problem and Substantiation for Public Comment

NOTE: This Public Comment appeared as CC Note No. 219 in the First Draft Report on First Revision No. 8226.

The Correlating Committee directs the panel to reconsider the text of the informational note to remove permissive language. The use of the word“may” makes this permissive. This action will be considered as a public comment.

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Related Item

• First Revision No. 8226

Submitter Information Verification

Submitter Full Name: CC on NEC-AAC

Organization: NEC Correlating Committee

Street Address:

City:

State:

Zip:

Submittal Date: Fri Aug 24 10:22:30 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected but see related SR

Resolution: SR-7959-NFPA 70-2018

Statement: This section is revised for clarity. This rewritten section removes the parenthetical language fromthe text and places similar language in the informational note. The title is changed to moreaccurately differentiate this item from (1) and (3).

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Correlating Committee Note No. 219-NFPA 70-2018 [ Section No. 690.9(A) ]

Submitter Information Verification

Submitter Full Name: Sarah CaldwellCommittee: Submittal Date: Fri May 11 15:13:59 EDT 2018

Committee Statement and Meeting Notes

Committee Statement:

The Correlating Committee directs the panel to reconsider the text of the informational note to remove permissive language. The use of the word “may” makes this permissive. This action will be considered as a public comment.

First Revision No. 8226-NFPA 70-2018 [Section No. 690.9(A)]

Ballot Results

This item has passed ballot

12 Eligible Voters0 Not Returned

12 Affirmative All0 Affirmative with Comments0 Negative with Comments0 Abstention

Affirmative AllBrunssen, James E.

Dressman, Kevin L.

Hickman, Palmer L.

Hittinger, David L.

Holub, Richard A.

Johnston, Michael J.

Kovacik, John R.

Manche, Alan

McDaniel, Roger D.

Pierce, James F.

Saporita, Vincent J.

Williams, David A.

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Public Comment No. 1573-NFPA 70-2018 [ Section No. 690.9(A)(1) ]

(1) Circuits Where Overcurrent Protection Not Required.

Overcurrent protective devices shall not be required where both of the following conditions are met:

(1) The circuits have conductors have sufficient ampacity for the maximum continuous circuit current.

(2) The currents from all sources do not exceed the maximum overcurrent protective device ratingspecified for the PV module or electronic power converter.

Statement of Problem and Substantiation for Public Comment

Editorial changes to improve the applicability of this section.

Related Item

• FR-8226

Submitter Information Verification

Submitter Full Name: Jason Fisher

Organization: Tesla Inc.

Affiliation: Solar Energy Industries Association (SEIA)

Street Address:

City:

State:

Zip:

Submittal Date: Wed Aug 29 12:07:56 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected but see related SR

Resolution: SR-7952-NFPA 70-2018 Circuit currents are continuous by definition and it is not necessary torestate this.

Statement: The editorial change to 690.9(A)(1) to improves clarity for applying this section.

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Public Comment No. 1756-NFPA 70-2018 [ Section No. 690.9(A)(2) ]

(2) Circuits Connected to Source of Overcurrent on One End.

Circuits connected to current-limited supplies (e.g., PV modules, electronic power converters, interactiveinverter output circuits) and also connected to sources having higher current availability (e.g., parallelstrings of modules, utility power), that are a source of overcurrent, shall be protected at the higher point ofconection to the higher current source connection.

Informational Note: Photovoltaic system dc circuits are current-limited circuits and may not needovercurrent protection. When connected in parallel to higher current sources, such as parallel-connected PV system dc circuits, batteries, or backfeed from inverters, the overcurrent device isoften installed at the higher current source end of the circuit.

Statement of Problem and Substantiation for Public Comment

This is intended to add clarity to this language

Related Item

• FR8226

Submitter Information Verification

Submitter Full Name: James Rogers

Organization: Towns Of Oak Bluffs, Tisbury,

Street Address:

City:

State:

Zip:

Submittal Date: Wed Aug 29 20:48:36 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected but see related SR

Resolution: SR-7959-NFPA 70-2018

Statement: This section is revised for clarity. This rewritten section removes the parenthetical language fromthe text and places similar language in the informational note. The title is changed to moreaccurately differentiate this item from (1) and (3).

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Public Comment No. 433-NFPA 70-2018 [ Section No. 690.9(A)(2) ]

(2) Circuits Connected to Source of Overcurrent on One End.

Circuits connected to current-limited supplies (e.g., PV modules, electronic power converters, interactiveinverter output circuits) and also connected to sources having higher current availability (e.g., parallelstrings of modules, utility power), that are a source of overcurrent, shall be protected at the higher currentsource connection.

Informational Note: Photovoltaic system dc circuits are current-limited circuits and may in somecases do not need overcurrent protection. When connected in parallel to higher current sources,such as parallel-connected PV system dc circuits, batteries, or backfeed from inverters, theovercurrent device is often installed at the higher current source end of the circuit.

Statement of Problem and Substantiation for Public Comment

Apparently we MAY not use the word "may" in an inforMAYtional note. This removes the may.

Related Item

• CN 219

Submitter Information Verification

Submitter Full Name: William Brooks

Organization: Brooks Engineering

Street Address:

City:

State:

Zip:

Submittal Date: Mon Aug 06 18:22:48 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected but see related SR

Resolution: SR-7959-NFPA 70-2018

Statement: This section is revised for clarity. This rewritten section removes the parenthetical language fromthe text and places similar language in the informational note. The title is changed to moreaccurately differentiate this item from (1) and (3).

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Public Comment No. 475-NFPA 70-2018 [ Section No. 690.9(A)(2) ]

(2) Circuits Connected to Source of Overcurrent on One End.

Circuits A conductor connected at one end to a current-limited supplies (e.g., PV modules, electronicpower converters, interactive inverter output circuits) and also connected to sources having higher currentavailability (e.g., parallel strings of modules, utility power), that are a source of overcurrent, supply wherethe conductor is rated for the maximum current available from that supply and connected on the other endto a source having an available current larger than the conductor is rated for shall be protected at thehigher point of connection to the larger current source connection .

Informational Note: Photovoltaic system dc circuits are current-limited circuits and may not needovercurrent protection. When connected in parallel to higher current sources, such as parallel-connected PV system dc circuits, batteries, or backfeed from inverters, the overcurrent device isoften installed at the higher current source end of the circuit.

Statement of Problem and Substantiation for Public Comment

The description seemed overly wordy and confusing. Revised wording simplifies it to the basics that the OCPD goes on the end with the available current that is higher than the conductor is rated for. The inclusion of example current sources in the original text could be confusing and limiting.

Related Item

• First Revision No. 8226-NFPA 70-2018

Submitter Information Verification

Submitter Full Name: MARVIN HAMON

Organization: HAMON ENGINEERING INC

Street Address:

City:

State:

Zip:

Submittal Date: Wed Aug 08 19:07:26 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected but see related SR

Resolution: SR-7959-NFPA 70-2018

Statement: This section is revised for clarity. This rewritten section removes the parenthetical language fromthe text and places similar language in the informational note. The title is changed to moreaccurately differentiate this item from (1) and (3).

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Public Comment No. 476-NFPA 70-2018 [ Section No. 690.9(A)(3) ]

(3)

Circuits Circuits Connected to Sources of Overcurrent on Both Ends.

Circuits that do not comply with 690.9(A)(1) or (A)(2) and with sources of overcurrent on both ends of aconductor shall be protected with one of the following methods:

(1) Conductors not greater than 3 m (10 ft) in length , enclosed in raceway, and protected fromovercurrent on one end

(2) Conductors protected from overcurrent on both ends

(3) Conductors not installed on or in buildings are permitted to be protected from overcurrent on one endof the circuit where the circuit complies with all of the following conditions:

(4) The conductors are installed in metal raceways or metal-clad cables, or installed in enclosedmetal cable trays, or underground, or where directly entering pad-mounted enclosures.

(5) The conductors for each circuit terminate on one end at a single circuit breaker or a single set offuses that limit the current to the ampacity of the conductors.

(6) The overcurrent device for the conductors is an integral part of a disconnecting means or shall belocated within 3 m (10 ft) of conductor length of the disconnecting means.

(7) The disconnecting means for the conductors is installed outside of a building, or at a readilyaccessible location nearest the point of entrance of the conductors inside of a building, includinginstallations complying with 230.6.

Statement of Problem and Substantiation for Public Comment

The allowance for load end only OCPD in conductors 10ft or less in length without a raceway requirment will result in having exposed unprotected conductors on roofs and in buildings. This is not safe even in such a short length. Not even the tap rules in 240.21(B) allow this without putting the conductors in raceway.

Related Item

• First Revision No. 8226-NFPA 70-2018

Submitter Information Verification

Submitter Full Name: MARVIN HAMON

Organization: HAMON ENGINEERING INC

Street Address:

City:

State:

Zip:

Submittal Date: Wed Aug 08 19:25:49 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected but see related SR

Resolution: SR-7966-NFPA 70-2018

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Statement: The title of the section is changed to simply “other circuits” to capture all remaining options coveredunder this section. Item (1) adds the words “and not in buildings” to further limit when a conductor ofno greater than 10’ can be protected from overcurrent on one end. Item (2) permits conductors of10’ or less in buildings in raceway or metal clad cable in buildings which is similar to therequirement in 240.21.

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Public Comment No. 1571-NFPA 70-2018 [ Section No. 690.9(A) [Excluding any Sub-

Sections] ]

PV system dc circuit and inverter output conductors and equipment shall be protected against overcurrent.Circuits sized in accordance with 690.8(A)(2) are required to be protected against overcurrent withovercurrent protective devices. Each circuit shall be protected from overcurrent in accordance with690.9(A)(1), (A)(2), or (A)(3).

Statement of Problem and Substantiation for Public Comment

Editorial

Related Item

• FR-8226

Submitter Information Verification

Submitter Full Name: Jason Fisher

Organization: Tesla Inc.

Affiliation: Solar Energy Industries Association (SEIA)

Street Address:

City:

State:

Zip:

Submittal Date: Wed Aug 29 12:06:11 EDT 2018

Committee: NEC-P04

Committee Statement

Committee Action: Rejected but see related SR

Resolution: SR-7951-NFPA 70-2018

Statement: The word “be” was missing from the second sentence of 690.9(A).

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Public Comment No. 1189-NFPA 70-2018 [ Section No. 690.9(B) ]

(B) Device Ratings.

Overcurrent devices used in PV system dc circuits shall be listed for use in PV systems. Electronic devicesthat are listed to prevent backfeed current in PV system dc circuits shall be permitted to preventovercurrent of conductors on the PV array side of the device. Overcurrent devices, where required, shallbe rated in accordance with one of the following:

(1) Not less than 125 percent of the maximum currents calculated in 690.8(A).

(2) An assembly, together with its overcurrent device(s), that is listed for continuous operation at100 percent of its rating shall be permitted to be used at 100 percent of its rating.

(3) Where a PV system dc circuit is connected to the input of an electronic power converter and theampacity of the conductor is less than the current calculated in 690.8(A)(1), the conductor shall beprotected with an overcurrent protective device rated or set not greater than the ampacity of theconductor. Conductor lengths of 3 m (10 ft) or less are permitted to be protected with a singleovercurrent device located on one end of the conductor.

Informational Note: Some electronic protective devices prevent backfeed current, which may be theonly source of overcurrent in some PV system dc circuits.

Additional Proposed Changes

File Name Description Approved

CN_220.pdf 70_CN220

Statement of Problem and Substantiation for Public Comment

NOTE: This Public Comment appeared as CC Note No. 220 in the First Draft Report on First Revision No. 8232.

The Correlating Committee directs the panel to reconsider the text of the informational note to remove permissive language. The use of the word“may” makes this permissive.The Correlating Committee directs that the last sentence of 690.9(B)(3) be rewritten to comply with the NEC Style Manual. Only mandatory language ispermitted in the body of the code, which is characterized by the use of the word “shall.” Or “shall be permitted.” The Correlating Committee directs thatthe panel reconsider the structure relative to list format to comply with the NEC Style Manual.This action will be considered as a public comment.

Related Item

• First Revision No. 8232

Submitter Information Verification

Submitter Full Name: CC on NEC-AAC

Organization: NEC Correlating Committee

Street Address:

City:

State:

Zip:

Submittal Date: Fri Aug 24 10:24:40 EDT 2018

Committee: NEC-P04

Committee Statement

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CommitteeAction:

Rejected but see related SR

Resolution: SR-7981-NFPA 70-2018 RESPONSE TO PC 427: This section is about device ratings under theovercurrent protection Section 690.9 so there is no need to repeat the term “overcurrentprotection” in the heading.

Statement: This revision removes 690.9(B)(3) as it is repetitive with the new 690.8(A)(5) and 690.9(A). Thereference to rounding up to standard device ratings is added for clarity. The informational note isedited for clarity and to comply with the style manual.

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Correlating Committee Note No. 220-NFPA 70-2018 [ Section No. 690.9(B) ]

Submitter Information Verification

Submitter Full Name: Sarah CaldwellCommittee: Submittal Date: Fri May 11 15:16:22 EDT 2018

Committee Statement and Meeting Notes

Committee Statement:

The Correlating Committee directs the panel to reconsider the text of the informational note to remove permissive language. The use of the word “may” makes this permissive.

The Correlating Committee directs that the last sentence of 690.9(B)(3) be rewritten to comply with the NEC Style Manual. Only mandatory language is permitted in the body of the code, which is characterized by the use of the word “shall.” Or “shall be permitted.” The Correlating Committee directs that the panel reconsider the structure relative to list format to comply with the NEC Style Manual.

This action will be considered as a public comment.

First Revision No. 8232-NFPA 70-2018 [Section No. 690.9(B)]

Ballot Results

This item has passed ballot

12 Eligible Voters0 Not Returned

12 Affirmative All0 Affirmative with Comments0 Negative with Comments0 Abstention

Affirmative AllBrunssen, James E.

Dressman, Kevin L.

Hickman, Palmer L.

Hittinger, David L.

Holub, Richard A.

Johnston, Michael J.

Kovacik, John R.

Manche, Alan

McDaniel, Roger D.

Pierce, James F.

Saporita, Vincent J.

Williams, David A.

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Public Comment No. 1584-NFPA 70-2018 [ Section No. 690.9(B) ]

(B) Device Ratings.

Overcurrent devices used in PV system dc circuits shall be listed for use in PV systems. Electronic devicesthat are listed to prevent backfeed current in PV system dc circuits shall be permitted to prevent overcurrentof conductors on the PV array side of the device. Overcurrent devices, where required, shall be rated inaccordance with one of the following:

(1) Not less than 125 percent of the maximum currents calculated in 690.8(A).

(2) An assembly, together with its overcurrent device(s), that is listed for continuous operation at100 percent of its rating shall be permitted to be used at 100 percent of its rating.

(3) Where a PV system dc circuit is connected to at any point on the input side of an electronic powerconverter and the ampacity of the conductor is less than the current calculated in 690.8(A)(1), theconductor shall be protected with an overcurrent protective device rated or set not greater than theampacity of the conductor. Conductor lengths of 3 m (10 ft) or less are permitted to be protected with asingle overcurrent device located on one end of the conductor.

Informational Note: Some electronic protective devices prevent or electronic powerconverters prevent backfeed current, which may be the only source of overcurrent in some PVsystem dc circuits.

Where calculations in 690.9(B) do not correspond to a standard rating of a fuse or nonadjustablecircuit breaker, and the calculated current is 9 amperes or more, the next higher standard ratingdescribed in 240.6 shall be permitted.

Statement of Problem and Substantiation for Public Comment

Clarifying language is recommended to be added to (B)(3) to make clear that these are not just the conductors connected to the terminals of EPCs. A change to the IN is suggested to refer to the defined term. Language addressing standard overcurrent protection device ratings is being added. This language is based on similar language used in 450.4(A). Note that the formatting used by TerraView is incorrect. the new suggested language on standard sized OCPDs is not intended to be included in the IN but rather become part of the mandatory text.

Related Item

• FR-8232

Submitter Information Verification

Submitter Full Name: Jason Fisher

Organization: Tesla Inc.

Affiliation: Solar Energy Industries Association (SEIA)

Street Address:

City:

State:

Zip:

Submittal Date: Wed Aug 29 12:27:28 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected but see related SR

Resolution: SR-7981-NFPA 70-2018 RESPONSE TO PC 427: This section is about device ratings under theovercurrent protection Section 690.9 so there is no need to repeat the term “overcurrentprotection” in the heading.

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Statement: This revision removes 690.9(B)(3) as it is repetitive with the new 690.8(A)(5) and 690.9(A). Thereference to rounding up to standard device ratings is added for clarity. The informational note isedited for clarity and to comply with the style manual.

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Public Comment No. 427-NFPA 70-2018 [ Section No. 690.9(B) ]

(B) Overcurrent Device Ratings.

Overcurrent devices used in PV system dc circuits shall be listed for use in PV systems. Electronic devicesthat are listed to prevent backfeed current in PV system dc circuits shall be permitted to preventovercurrent of conductors on the PV array side of the device. Overcurrent devices, where required, shall berated in accordance with one of the following:

(1) Not less than 125 percent of the maximum currents calculated in 690.8(A).

(2) An assembly, together with its overcurrent device(s), that is listed for continuous operation at100 percent of its rating shall be permitted to be used at 100 percent of its rating.

(3) Where a PV system dc circuit is connected to the input of an electronic power converter and theampacity of the conductor is less than the current calculated in 690.8(A)(1), the conductor shall beprotected with an overcurrent protective device rated or set not greater than the ampacity of theconductor. Conductor lengths of 3 m (10 ft) or less are permitted to be protected with a singleovercurrent device located on one end of the conductor. Adjustable electronic overcurrent protectivedevices rated or set in accordance with 240.6.

Informational Note: Some electronic overcurrent protective devices prevent backfeed current, whichmay be the only source of overcurrent in some PV system dc circuits .

Statement of Problem and Substantiation for Public Comment

This change returns this section back to its previous text.

The title of the section must remain as overcurrent device ratings as it accurately reflects the content of this section. The very first sentence of the parent text begins with "Overcurrent protective devices used in PV system dc circuits . . . "

The added sentence referring to electronic devices that are listed to prevent backfeed current in PV systems is removed as those devices are not listed to provide overcurrent protection and should not be included in a section that specifically addresses overcurrent protective devices.

The modifications to Item 3 are also being removed as the determination of overcurrent protection for conductors within the PV system are included elsewhere in Article 690. The intent of this section is to address the characteristics of the overcurrent protective device and not specify levels of protection to be provided.

The informational note is returned back to its original language to align with above changes. Devices listed to prevent back feeding are not overcurrent protective devices and should not be substituted for overcurrent protective devices.

Related Item

• FR 8232

Submitter Information Verification

Submitter Full Name: Thomas Domitrovich

Organization: Eaton Corporation

Street Address:

City:

State:

Zip:

Submittal Date: Mon Aug 06 12:35:58 EDT 2018

Committee: NEC-P04

Committee Statement

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CommitteeAction:

Rejected but see related SR

Resolution: SR-7981-NFPA 70-2018 RESPONSE TO PC 427: This section is about device ratings under theovercurrent protection Section 690.9 so there is no need to repeat the term “overcurrentprotection” in the heading.

Statement: This revision removes 690.9(B)(3) as it is repetitive with the new 690.8(A)(5) and 690.9(A). Thereference to rounding up to standard device ratings is added for clarity. The informational note isedited for clarity and to comply with the style manual.

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Public Comment No. 434-NFPA 70-2018 [ Section No. 690.9(B) ]

(B) Device Ratings.

Overcurrent devices used in PV system dc circuits shall be listed for use in PV systems. Electronic devicesthat are listed to prevent backfeed current in PV system dc circuits shall be permitted to prevent overcurrentof conductors on the PV array side of the device. Overcurrent devices, where required, shall be rated inaccordance with one of the following:

(1) Not less than 125 percent of the maximum currents calculated in 690.8(A).

(2) An assembly, together with its overcurrent device(s), that is listed for continuous operation at100 percent of its rating shall be permitted to be used at 100 percent of its rating.

(3) Where a PV system dc circuit is connected to the input of an electronic power converter and theampacity of the conductor is less than the current calculated in 690.8(A)(1), the conductor shall beprotected with an overcurrent protective device rated or set not greater than the ampacity of theconductor. Conductor lengths of 3 m (10 ft) or less are permitted to be protected with a singleovercurrent device located on one end of the conductor.

Informational Note: Some electronic protective devices prevent backfeed current, which may be insome cases is the only source of overcurrent in some PV system dc circuits.

Statement of Problem and Substantiation for Public Comment

Apparently we MAY not use the word "may" in an inforMAYtional note. This removes the may.

Related Item

• CN 220

Submitter Information Verification

Submitter Full Name: William Brooks

Organization: Brooks Engineering

Street Address:

City:

State:

Zip:

Submittal Date: Mon Aug 06 18:27:58 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected but see related SR

Resolution: SR-7981-NFPA 70-2018 RESPONSE TO PC 427: This section is about device ratings under theovercurrent protection Section 690.9 so there is no need to repeat the term “overcurrentprotection” in the heading.

Statement: This revision removes 690.9(B)(3) as it is repetitive with the new 690.8(A)(5) and 690.9(A). Thereference to rounding up to standard device ratings is added for clarity. The informational note isedited for clarity and to comply with the style manual.

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Public Comment No. 481-NFPA 70-2018 [ Section No. 690.9(B) ]

(B) Device Ratings.

Overcurrent devices used in PV system dc circuits shall be listed for use in PV systems. Electronic devicesthat are listed to prevent backfeed current in PV system dc circuits shall be permitted to prevent overcurrentof conductors on the PV array side of the device. Overcurrent devices, where required, shall be rated inaccordance with one of the following:

(1) Not less than 125 percent of the maximum currents calculated in 690.8(A).

(2) An assembly, together with its overcurrent device(s), that is listed for continuous operation at100 percent of its rating shall be permitted to be used at 100 percent of its rating.

(3) Where a PV system dc circuit is connected to the input of an electronic power converter and theampacity of the conductor is less than the current calculated in 690.8(A)(1), the conductor shall beprotected with an overcurrent protective device rated or set not greater than the ampacity of theconductor. Conductor lengths of 3 m (10 ft) or less are permitted to be protected with a singleovercurrent device located on one end of the conductor.

Informational Note: Some electronic protective devices prevent backfeed current, which may be theonly source of overcurrent in some PV system dc circuits.

Statement of Problem and Substantiation for Public Comment

690.9(B)(3) is not needed since 690.9(B)(1) covers all the maximum current selections available in 690.8(A)(1) through (3) including PV DC circuits terminating in an electronic power converter. The allowance for load end only OCPD in conductors 10ft or less in length will result in having exposed unprotected conductors on roofs. This is not safe even in such a short length. Not even the tap rules in 240.21(B) allow this without putting the conductors in raceway.The specification requiring the OCPD be rated not greater than the ampacity of the conductor does not specify if that is the normal rating or the continuous current rating. This will cause confusion in application.

Related Item

• First Revision No. 8232-NFPA 70-2018

Submitter Information Verification

Submitter Full Name: MARVIN HAMON

Organization: HAMON ENGINEERING INC

Street Address:

City:

State:

Zip:

Submittal Date: Wed Aug 08 20:17:31 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected but see related SR

Resolution: SR-7981-NFPA 70-2018 RESPONSE TO PC 427: This section is about device ratings under theovercurrent protection Section 690.9 so there is no need to repeat the term “overcurrentprotection” in the heading.

Statement: This revision removes 690.9(B)(3) as it is repetitive with the new 690.8(A)(5) and 690.9(A). Thereference to rounding up to standard device ratings is added for clarity. The informational note isedited for clarity and to comply with the style manual.

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Public Comment No. 1190-NFPA 70-2018 [ Section No. 690.11 ]

690.11 Arc-Fault Circuit Protection (Direct Current).

Photovoltaic systems operating at 80 volts dc or greater between any two conductors shall be protected bya listed PV arc-fault circuit interrupter or other system components listed to provide equivalent protection.The system shall detect and interrupt arcing faults resulting from a failure in the intended continuity of aconductor, connection, module, or other system component in the PV system dc circuits.

Informational Note: Annex A includes the reference for the Photovoltaic DC Arc-Fault CircuitProtection product standard.

Exception: For PV systems not installed on or in buildings, PV output circuits and dc-to-dc converteroutput circuits that are installed in metallic raceways or metal-clad cables, or installed in enclosedmetallic cable trays, or are underground are permitted without arc-fault circuit protection. Detachedstructures whose sole purpose is to house PV system equipment shall not be considered buildingsaccording to this exception.

Additional Proposed Changes

File Name Description Approved

CN_221.pdf 70_CN221

Statement of Problem and Substantiation for Public Comment

NOTE: This Public Comment appeared as CC Note No. 221 in the First Draft Report on First Revision No. 8239.

The Correlating Committee directs that 690.11 Exception be rewritten to comply with the NEC Style Manual. Only mandatory language is permittedin the body of the code, which is characterized by the use of the word “shall.” Or “shall be permitted.” This action will be considered as a publiccomment.

Related Item

• First Revision No. 8239

Submitter Information Verification

Submitter Full Name: CC on NEC-AAC

Organization: NEC Correlating Committee

Street Address:

City:

State:

Zip:

Submittal Date: Fri Aug 24 10:26:13 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected but see related SR

Resolution: SR-7989-NFPA 70-2018

Statement: The words “with PV system dc circuits” is added to the first sentence to clarify that it is dc circuitsthat are operating at 80 volts dc or greater, not the PV system. The word “are” is replaced with“shall be” in the exception to comply with the NEC Style Manual.

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Correlating Committee Note No. 221-NFPA 70-2018 [ Section No. 690.11 ]

Submitter Information Verification

Submitter Full Name: Sarah CaldwellCommittee: Submittal Date: Fri May 11 15:19:48 EDT 2018

Committee Statement and Meeting Notes

Committee Statement:

The Correlating Committee directs that 690.11 Exception be rewritten to comply with the NEC Style Manual. Only mandatory language is permitted in the body of the code, which is characterized by the use of the word “shall.” Or “shall be permitted.” This action will be considered as a public comment.

First Revision No. 8239-NFPA 70-2018 [Section No. 690.11]

Ballot Results

This item has passed ballot

12 Eligible Voters0 Not Returned

12 Affirmative All0 Affirmative with Comments0 Negative with Comments0 Abstention

Affirmative AllBrunssen, James E.

Dressman, Kevin L.

Hickman, Palmer L.

Hittinger, David L.

Holub, Richard A.

Johnston, Michael J.

Kovacik, John R.

Manche, Alan

McDaniel, Roger D.

Pierce, James F.

Saporita, Vincent J.

Williams, David A.

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Public Comment No. 1576-NFPA 70-2018 [ Section No. 690.11 ]

690.11 Arc-Fault Circuit Protection (Direct Current).

Photovoltaic systems operating at 80 volts dc or greater between any two conductors shall be protected bya listed PV arc-fault circuit interrupter or other system components listed to provide equivalent protection.The system shall detect and interrupt arcing faults resulting from a failure in the intended continuity of aconductor, connection, module, or other system component in the PV system dc circuits.

Informational Note: Annex A includes the reference for the Photovoltaic DC Arc-Fault CircuitProtection product standard.

Exception: For PV systems not installed on or in buildings, PV output circuits and dc-to-dc converteroutput circuits that are installed in metallic raceways or metal-clad cables, or installed in enclosedmetallic cable trays, or are underground are permitted without arc-fault circuit protection. Detachedstructures whose sole purpose is to house PV system equipment shall not be considered buildingsaccording to this exception.

Statement of Problem and Substantiation for Public Comment

This exception circumvents the electrical safety requirements that are normally afforded to the electrical worker when working in and around these electrical systems which could potentially cause fires leading to unintentional catastrophic losses to the surrounding areas of the PV installations.

Related Item

• PI 1225; PI 2855

Submitter Information Verification

Submitter Full Name: Wendell Whistler

Organization: IBEW 280

Street Address:

City:

State:

Zip:

Submittal Date: Wed Aug 29 12:13:40 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected

Resolution: The purpose of the exception is to provide stipulations that provide for a similar level of protectionfrom arc faults without the need for arc-fault detection. This is explained in detail in the 2017 editionproceedings. This exception is not related to electrical worker hazards. It is related to fire safety ofPV systems as it relates to potential arcing fires.

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Public Comment No. 435-NFPA 70-2018 [ Section No. 690.11 ]

690.11 Arc-Fault Circuit Protection (Direct Current).

Photovoltaic systems operating at 80 volts dc or greater between any two conductors shall be protected bya listed PV arc-fault circuit interrupter or other system components listed to provide equivalent protection.The system shall detect and interrupt arcing faults resulting from a failure in the intended continuity of aconductor, connection, module, or other system component in the PV system dc circuits.

Informational Note: Annex A includes the reference for the Photovoltaic DC Arc-Fault CircuitProtection product standard.

Exception: For PV systems not installed on or in buildings, PV output circuits and dc-to-dc converteroutput circuits that are installed in metallic raceways or metal-clad cables, or installed in enclosed metalliccable trays, or are underground are shall be permitted without arc-fault circuit protection. Detachedstructures whose sole purpose is to house PV system equipment shall not be considered buildingsaccording to this exception.

Statement of Problem and Substantiation for Public Comment

Changed "are" to "shall be" to address CC's concern in CC 221.

Related Item

• CC 221

Submitter Information Verification

Submitter Full Name: William Brooks

Organization: Brooks Engineering

Street Address:

City:

State:

Zip:

Submittal Date: Mon Aug 06 18:32:32 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected but see related SR

Resolution: SR-7989-NFPA 70-2018

Statement: The words “with PV system dc circuits” is added to the first sentence to clarify that it is dc circuitsthat are operating at 80 volts dc or greater, not the PV system. The word “are” is replaced with“shall be” in the exception to comply with the NEC Style Manual.

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Public Comment No. 483-NFPA 70-2018 [ Section No. 690.11 ]

690.11 Arc-Fault Circuit Protection (Direct Current).

Photovoltaic systems operating at 80 volts dc or greater between any two conductors shall be protected bya listed PV arc-fault circuit interrupter or other system components listed to provide equivalent protection.The system shall detect and interrupt arcing faults resulting from a failure in the intended continuity of aconductor, connection, module, or other system component in the PV system dc circuits.

Informational Note: Annex A includes the reference for the Photovoltaic DC Arc-Fault CircuitProtection product standard.

Exception: For PV systems not installed on or in buildings, PV output circuits and dc-to-dc converteroutput circuits that are installed in metallic raceways or metal-clad cables, or installed in enclosed metalliccable trays, or are underground are shall be permitted without arc-fault circuit protection. Detachedstructures whose sole purpose is to house PV system equipment shall not be considered buildingsaccording to this exception.

Statement of Problem and Substantiation for Public Comment

I believe the NEC Style Manual would require the use of "shall be" rather than "are" in this case.

Related Item

• First Revision No. 8239-NFPA 70-2018

Submitter Information Verification

Submitter Full Name: MARVIN HAMON

Organization: HAMON ENGINEERING INC

Street Address:

City:

State:

Zip:

Submittal Date: Wed Aug 08 20:31:30 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected but see related SR

Resolution: SR-7989-NFPA 70-2018

Statement: The words “with PV system dc circuits” is added to the first sentence to clarify that it is dc circuitsthat are operating at 80 volts dc or greater, not the PV system. The word “are” is replaced with“shall be” in the exception to comply with the NEC Style Manual.

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Public Comment No. 2081-NFPA 70-2018 [ Section No. 690.12(A) ]

(A) Controlled Conductors.

Requirements for controlled conductors shall apply to the following:

(1) PV system dc circuits

(2) Inverter output circuits originating from inverters located within the array boundary

Informational Note: The rapid shutdown function reduces the risk of electrical shock that dc circuits in a PVsystem may pose for emergency responders. Unlike the dc conductors, the ac output conductors from PVsystems that include inverters will either be de-energized after shutdown initiation or will remain energizedby other sources such as a utility. To prevent PV arrays with attached inverters from having energized acconductors within the PV array(s), those circuits are also specifically controlled after shutdown initiation.

Statement of Problem and Substantiation for Public Comment

This informational language is suggested based on input we received from several members of the enforcement community at the IAEI Southwest Regional meeting in August 2018. This comment is provided solely by the submitter however, and not necessarily sanctioned or authorized by the IAEI. We offer it in an effort to improve the understanding of the changes made by in the First Draft to section 690.12(A) by users of the Code.

Related Item

• FR-8242

Submitter Information Verification

Submitter Full Name: Jason Fisher

Organization: Tesla Inc.

Street Address:

City:

State:

Zip:

Submittal Date: Thu Aug 30 16:31:14 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected but see related SR

Resolution: SR-7998-NFPA 70-2018

Statement: An informational note, based on FR-8242 and associated public inputs, has been added to helpusers of the Code better understand the reasoning for controlling inverter output circuits frominverters located within the array boundary. The term "emergency responders" has been changedto "fire fighters" to be consistent with SR-7994.

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Public Comment No. 1592-NFPA 70-2018 [ Section No. 690.12(B) ]

(B) Controlled Limits.

The use of the term array boundary in this section is defined as 305 mm (1 ft) from the array in alldirections. Controlled conductors outside the array boundary shall comply with 690.12(B)(1) and inside thearray boundary shall comply with 690.12(B)(2).

(1) Outside the Array Boundary.

Controlled conductors located outside the boundary or more than 1 m (3 ft) from the point of entry inside abuilding shall be limited to not more than 30 volts within 30 seconds of rapid shutdown initiation. Voltageshall be measured between any two conductors and between any conductor and ground.

(2) Inside the Array Boundary.

The PV system shall comply with one of the following:Provide shock hazard control for emergencyresponders through the use of be provided with a PV hazard control means listed for the purpose. ThePV hazard control components and equipment shall be installed and used in accordance with theinstructions included with the listing or field labeling. Where a hazard control system requires initiation toput it into a controlled state, the rapid shutdown initation device required in 690.12(C) shall perform thisinitiation.

Informational Note: A listed or field-labeled PV hazard control system may be comprised of eitheran individual piece of equipment that fulfills the necessary functions, or multiple pieces of equipmentcoordinated to perform the functions as described in the installation instructions to reduce the risk ofelectric shock hazard within a damaged PV array for fire fighters.

ControlledException: Where a listed PV hazard control means is not available, the following shall be permitted tomeet the 690.12(B)(2) requirements:

(1) PV arrays with all controlled conductors located inside the boundary shall be limited to not morethan 80 volts within 30 seconds of rapid shutdown initiation. Voltage shall be measured between anytwo circuit conductors and between any circuit conductor and ground.

(2) PV arrays with no exposed wiring methods, no exposed conductive parts, and installed more than2.5 m (8 ft) from exposed grounded conductive parts or ground shall not be required to comply with690 . 12(B)(2).

Statement of Problem and Substantiation for Public Comment

Since the first draft language was created there has been substantial progress made on the new UL3741 draft standard that is being written specifically for the purpose of setting clear performance requirements for any building-mounted PV array equipment that may contribute to potential electrical hazards faced by firefighters during firefighting operations. The current draft standard, as of this public comment submission date, addresses multiple variables not addressed by the existing language in 690.12(B)(2) or (3) and will provide a more reliable and understood level of safety. Since the previously stated need for the existing items 690.12(B)(2) and (3) was because no published standard was available, these items are being moved into an exception that will only apply where equipment listed for PV Hazard Control is not available. Our intent is that this new exception, whose language is largely drawn from 90.4 and the existing 690.12(B)(2)(2) and (3), would be used instead of any blanket 90.4 exemption. This would provide the practical backstop to give time for new products listed for PV Hazard Control to come to market yet ensure that equipment used to comply with the NEC 2017 version would still be used in the interim. A new sentence has been added to clarify that where initiation is required, the same initiation device in (C) will perform this function.

Related Item

• FR-8253 • PI-4143

Submitter Information Verification

Submitter Full Name: Jason Fisher

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Organization: Tesla Inc.

Affiliation: Solar Energy Industries Association (SEIA)

Street Address:

City:

State:

Zip:

Submittal Date: Wed Aug 29 12:41:00 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected but see related SR

Resolution: SR-8025-NFPA 70-2018

Statement: The first sentence of 690.12(B)(2)(1) has been rewritten to better comply with the NEC Style Manualand clarify the mandatory requirement to meet this subsection. The term “emergency responders” isremoved since the first sentence of 690.12 addresses the purpose of 690.12 as a whole. A newsentence has been added to clarify that where initiation is required, the same initiation device in (C)will perform this function, and not an additional device or action. A reference to UL 3741 has beenadded to the informational note to guide users of the Code to this new standard. The informationalnote has been changed to remove language that may be perceived as setting permissiverequirements.

This second revision makes minor edits to items 690.12(B)(2)(2) and 690.12(B)(2)(3) to supportexisting products and products currently in development. The last phrase of 690.12(B)(2)(3) isremoved to prevent misinterpretation of the option. The UL3741 standard is far along in thedevelopment process and is enhancing the understanding of fire fighter shock hazards in PVsystems. The future publication of the UL3741 standard will make it possible to reevaluate items690.12(B)(2)(2) and 690.12(B)(2)(3).

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Public Comment No. 1465-NFPA 70-2018 [ Section No. 690.12(B)(1) ]

(1) Outside the Array Boundary.

Controlled conductors Conductors located outside the boundary or more than 1 m (3 ft) from the point ofentry inside a building shall be limited to not more than 30 volts 250 volts within 30 seconds of rapidshutdown initiation. Voltage shall be measured between any two conductors and between any conductorand ground.

Statement of Problem and Substantiation for Public Comment

Per earlier comments. This allows pv source or output conductors to be in metallic raceway/conduit internal to a building at a voltage that eliminates RS requirements if charge controllers are used that one would normally find in multimode rooftop systems. Conductors outside the array boundary and exterior would be protected in conduit and visible.

There is no evidence that this section has or will afford any protection and provides a false sense of security.

Related Item

• PI

Submitter Information Verification

Submitter Full Name: Christopher Warfel

Organization: ENTECH Engineering, Inc.

Street Address:

City:

State:

Zip:

Submittal Date: Tue Aug 28 17:42:15 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected

Resolution: No technical substantiation was provided for removing the limitation of conductor length afterentering a building or for the voltage limit suggested. The 30 volt limit outside the array boundary isconsidered a touch safe voltage. Whereas, 250 volts is not a touch safe voltage.

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Public Comment No. 1192-NFPA 70-2018 [ Section No. 690.12(B)(2) ]

(2) Inside the Array Boundary.

The PV system shall comply with one of the following:

(1) Provide shock hazard control for emergency responders through the use of a PV hazard controlmeans listed for the purpose. The hazard control components shall be installed and used inaccordance with the instructions included with the listing or field labeling.

Informational Note: A listed or field-labeled hazard control system may be comprised of eitheran individual piece of equipment that fulfills the necessary functions, or multiple pieces ofequipment coordinated to perform the functions as described in the installation instructions toreduce the risk of electric shock hazard within a damaged PV array for fire fighters.

(2) Controlled conductors located inside the boundary shall be limited to not more than 80 volts within30 seconds of rapid shutdown initiation. Voltage shall be measured between any two conductors andbetween any conductor and ground.

(3) PV arrays with no exposed wiring methods, no exposed conductive parts, and installed more than2.5 m (8 ft) from exposed grounded conductive parts or ground shall not be required to comply with690.12(B)(2).

Additional Proposed Changes

File Name Description Approved

CN_222.pdf 70_CN222

Statement of Problem and Substantiation for Public Comment

NOTE: This Public Comment appeared as CC Note No. 222 in the First Draft Report on First Revision No. 8253.

The Correlating Committee directs that 690.12(B)(2)(1) be rewritten to comply with the NEC Style Manual. It is not written as a requirement and it isinconsistent with the format of the rest of the list. Only mandatory language is permitted in the body of the code, which is characterized by the use of theword “shall.” Or “shall be permitted.” The Correlating Committee directs the panel to reconsider the text of the informational note to remove permissivelanguage. The use of the word “may” makes this permissive. This action will be considered as a public comment.

Related Item

• First Revision No. 8253

Submitter Information Verification

Submitter Full Name: CC on NEC-AAC

Organization: NEC Correlating Committee

Street Address:

City:

State:

Zip:

Submittal Date: Fri Aug 24 10:34:19 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected but see related SR

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Resolution: SR-8025-NFPA 70-2018

Statement: The first sentence of 690.12(B)(2)(1) has been rewritten to better comply with the NEC Style Manualand clarify the mandatory requirement to meet this subsection. The term “emergency responders” isremoved since the first sentence of 690.12 addresses the purpose of 690.12 as a whole. A newsentence has been added to clarify that where initiation is required, the same initiation device in (C)will perform this function, and not an additional device or action. A reference to UL 3741 has beenadded to the informational note to guide users of the Code to this new standard. The informationalnote has been changed to remove language that may be perceived as setting permissiverequirements.

This second revision makes minor edits to items 690.12(B)(2)(2) and 690.12(B)(2)(3) to supportexisting products and products currently in development. The last phrase of 690.12(B)(2)(3) isremoved to prevent misinterpretation of the option. The UL3741 standard is far along in thedevelopment process and is enhancing the understanding of fire fighter shock hazards in PVsystems. The future publication of the UL3741 standard will make it possible to reevaluate items690.12(B)(2)(2) and 690.12(B)(2)(3).

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Correlating Committee Note No. 222-NFPA 70-2018 [ Section No. 690.12(B)(2) ]

Submitter Information Verification

Submitter Full Name: Sarah CaldwellCommittee: Submittal Date: Fri May 11 15:20:45 EDT 2018

Committee Statement and Meeting Notes

Committee Statement:

The Correlating Committee directs that 690.12(B)(2)(1) be rewritten to comply with the NEC Style Manual. It is not written as a requirement and it is inconsistent with the format of the rest of the list. Only mandatory language is permitted in the body of the code, which is characterized by the use of the word “shall.” Or “shall be permitted.” The Correlating Committee directs the panel to reconsider the text of the informational note to remove permissive language. The use of the word “may” makes this permissive. This action will be considered as a public comment.

First Revision No. 8253-NFPA 70-2018 [Section No. 690.12(B)(2)]

Ballot Results

This item has passed ballot

12 Eligible Voters0 Not Returned

12 Affirmative All0 Affirmative with Comments0 Negative with Comments0 Abstention

Affirmative AllBrunssen, James E.

Dressman, Kevin L.

Hickman, Palmer L.

Hittinger, David L.

Holub, Richard A.

Johnston, Michael J.

Kovacik, John R.

Manche, Alan

McDaniel, Roger D.

Pierce, James F.

Saporita, Vincent J.

Williams, David A.

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Public Comment No. 1395-NFPA 70-2018 [ Section No. 690.12(B)(2) ]

(2) Inside the Array Boundary.

The PV system shall comply with one of the following:

(1) Provide shock hazard control for emergency responders through the use of a PV hazard controlmeans listed for the purpose. The hazard control components shall be installed and used inaccordance with the instructions included with the listing or field labeling.

Informational Note: A listed or field-labeled hazard control system may be comprised of eitheran individual piece of equipment that fulfills the necessary functions, or multiple pieces ofequipment coordinated to perform the functions as described in the installation instructions toreduce the risk of electric shock hazard within a damaged PV array for fire fighters.

(2) Controlled conductors located inside the boundary shall be limited to not more than 80 volts within30 seconds of rapid shutdown initiation. Voltage shall be measured between any two conductors andbetween any conductor and ground.

(3) PV arrays with no exposed wiring methods, no exposed conductive parts, and installed more than2.5 m (8 ft) from exposed grounded conductive parts or ground shall not be required to comply with690.12(B)(2) .

Statement of Problem and Substantiation for Public Comment

The PV Hazard Control standard, UL3741, is showing that the conditions in "option 3" are insufficient to match the safety in the first two options. It makes sense to remove this item which also removes the logic problem with the last phrase in this item.

Related Item

• FR 8250

Submitter Information Verification

Submitter Full Name: William Brooks

Organization: Brooks Engineering

Street Address:

City:

State:

Zip:

Submittal Date: Tue Aug 28 01:41:00 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected

Resolution: The language in 690.12(B)(2)(2) and 690.12(B)(2)(3) remains unchanged to support existingproducts.

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Public Comment No. 1403-NFPA 70-2018 [ Section No. 690.12(B)(2) ]

(2) Inside the Array Boundary.

The PV system shall comply with one of the following:

(1) Provide shock hazard control for emergency responders through the use of a PV hazard controlmeans listed for the purpose. The hazard control components shall be installed and used inaccordance with the instructions included with the listing or field labeling.

Informational Note: A listed or field-labeled hazard control system may be comprised of eitheran individual piece of equipment that fulfills the necessary functions, or multiple pieces ofequipment coordinated to perform the functions as described in the installation instructions toreduce the risk of electric shock hazard within a damaged PV array for fire fighters.

(2) Controlled conductors located inside the boundary shall be limited to not more than 80 volts within30 seconds of rapid shutdown initiation. Voltage shall be measured between any two conductors andbetween any conductor and ground.

(3) PV arrays with no exposed wiring methods, no exposed conductive parts, and installed more than2.5 m (8 ft) from exposed grounded conductive parts or ground shall not be required to comply with690.12(B)(2).

The requirements of 690.12(B)(2)(2) and 690.12(B)(2)(3) shall become ineffective upon availability ofequipment complying with 690.12(B)(2)(1)

Statement of Problem and Substantiation for Public Comment

Public inputs such as No. 3929-NFPA 70-2017, 4143-NFPA 70-2017 and 3863-NFPA 70-2017 requested that 690.12(B)(2)(2) and 690.12(B)(2)(3) be deleted. This change was not made in the First Revision. A requirement is needed that 690.12(B)(2)(2) and 690.12(B)(2)(3) become ineffective once equipment complying with 690.12(B)(2)(1) is available. The new standard for PV Hazard Control, UL3741, and requirements in UL1741 for rapid shutdown equipment are intended to be applied to all equipment including those in options (2) and (3). Leaving options (2) and (3) as they are may create a situation where systems get installed that have not been evaluated to the correct standard for the application.

Related Item

• PI No. 3929-NFPA 70-2017 • PI No. 4143-NFPA 70-2017 • PI No. 3863-NFPA 70-2017

Submitter Information Verification

Submitter Full Name: Thomas A. Wegener

Organization: SMA Solar Technology AG

Street Address:

City:

State:

Zip:

Submittal Date: Tue Aug 28 07:10:45 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected but see related SR

Resolution: SR-8025-NFPA 70-2018

Statement: The first sentence of 690.12(B)(2)(1) has been rewritten to better comply with the NEC Style Manualand clarify the mandatory requirement to meet this subsection. The term “emergency responders” isremoved since the first sentence of 690.12 addresses the purpose of 690.12 as a whole. A newsentence has been added to clarify that where initiation is required, the same initiation device in (C)

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will perform this function, and not an additional device or action. A reference to UL 3741 has beenadded to the informational note to guide users of the Code to this new standard. The informationalnote has been changed to remove language that may be perceived as setting permissiverequirements.

This second revision makes minor edits to items 690.12(B)(2)(2) and 690.12(B)(2)(3) to supportexisting products and products currently in development. The last phrase of 690.12(B)(2)(3) isremoved to prevent misinterpretation of the option. The UL3741 standard is far along in thedevelopment process and is enhancing the understanding of fire fighter shock hazards in PVsystems. The future publication of the UL3741 standard will make it possible to reevaluate items690.12(B)(2)(2) and 690.12(B)(2)(3).

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Public Comment No. 1451-NFPA 70-2018 [ Section No. 690.12(B)(2) ]

(2) Inside the Array Boundary.

The PV system shall comply with one of the following:

(1) Provide shock hazard control for emergency responders through the use of a PV hazard controlmeans listed for the purpose. The hazard control components shall be installed and used inaccordance with the instructions included with the listing or field labeling.

Informational Note: A listed or field-labeled hazard control system may be comprised of eitheran individual piece of equipment that fulfills the necessary functions, or multiple pieces ofequipment coordinated to perform the functions as described in the installation instructions toreduce the risk of electric shock hazard within a damaged PV array for fire fighters.

(2) Controlled conductors located inside the boundary shall be limited to not more than 80 volts 250 voltswithin 30 seconds of rapid shutdown initiation. Voltage shall be measured between any two conductorsand between any conductor and ground.

(3) PV arrays with no exposed wiring methods, no exposed conductive parts, and installed more than2.5 m (8 ft) from exposed grounded conductive parts or ground shall not be required to comply with690.12(B)(2).

Statement of Problem and Substantiation for Public Comment

The current wording (no pun intended) encourages the installation of a more dangerous array within the array boundary, and external to the boundary when there is a failure of RS. It is less dangerous to allow series wiring of multimode systems that are commensurate with the charge controllers most likely to be used in rooftop systems. With this change, charge controllers that have proven themselves in the field can continue to be used without the addition of a remote operated disconnect that has not been shown to reduce significant shock exposure. The premise of the current requirement taken to the extreme would motivate high amperage installations.

Related Item

• PI

Submitter Information Verification

Submitter Full Name: Christopher Warfel

Organization: ENTECH Engineering, Inc.

Street Address:

City:

State:

Zip:

Submittal Date: Tue Aug 28 16:48:20 EDT 2018

Committee: NEC-P04

Committee Statement

Committee Action: Rejected

Resolution: There is no technical basis for the voltage limit suggested.

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Public Comment No. 1491-NFPA 70-2018 [ Section No. 690.12(B)(2) ]

(2) Inside the Array Boundary.

The PV system shall comply with one of the following:

(1) Provide shock hazard control for emergency responders through the use of a PV hazard controlmeans listed for the purpose. The hazard control components shall be installed and used inaccordance with the instructions included with the listing or field labeling evaluation .

Informational Note: A listed or field-labeled hazard control system may be comprised of eitheran individual piece of equipment that fulfills the necessary functions, or multiple pieces ofequipment coordinated to perform the functions as described in the installation instructions toreduce the risk of electric shock hazard within a damaged PV array for fire fighters.

(2) Controlled conductors located inside the boundary shall be limited to not more than 80 volts within30 seconds of rapid shutdown initiation. Voltage shall be measured between any two conductors andbetween any conductor and ground.

(3) PV arrays with no exposed wiring methods, no exposed conductive parts, and installed more than2.5 m (8 ft) from exposed grounded conductive parts or ground shall not be required to comply with690.12(B)(2).

Statement of Problem and Substantiation for Public Comment

The process of how “field labeling” is accomplished is not defined or set in the NEC. The definition of “field labeled” does not set any requirement or statement that a “serialized” label is provided as stated in the panel resolution statement. The process that leads to a field label is a function of the “field evaluation” process requirements found in NFPA 790 and NFPA 791. It has been stated that the term “field labeled” infers that a field evaluation would be completed. This may be the intent of the panel, but it is poor code writing to set a requirement that infers a process instead of stating the process, field evaluation, that is to be completed.

The NFPA style manual section 2.3.2.3 prohibits definitions from having requirements in the definition and therefore definitions cannot be used as establishing requirements.

It is noted that the field evaluation process is under the purview of the NFPA Electrical Equipment Evaluation (EEE) Technical Committee.A product or equipment can achieve a “field label” where a field evaluation is completed which has five distinct steps. A brief summary of these procedures includes selection of the correct nationally recognized standard, conducting a complete evaluation of construction, performing applicable non-destructive field testing, and documentation in formal engineering reports to both the client and the Authority having jurisdiction. When the process is completed with satisfactory results, then the serialized “field label” of the FEB is applied.

Please see the related comments for the definition of "field evaluation (field evaluated)" and the new section 110.3(D) that sets the process requirement and FEB qualification criteria.

To permit only the “field label” as suitable evidence for “approval” has allowed and will continue to allow unqualified entities to give a false sense of adequacy when they are in fact not performing the necessary rigorous evaluation that is provided in the requirement of the NFPA 790 and NFPA 791 documents.If the panel believes the term “field labeled” is still the correct term, it is requested this item be referred the Correlating Committee for correlation between the NEC and the documents under the purview of the NFPA EEE committee.

Related Public Comments for This Document

Related Comment Relationship

Public Comment No. 1353-NFPA 70-2018 [New Definition after Definition: FestoonLighting.]

Public Comment No. 1489-NFPA 70-2018 [New Section after 110.3(C)]

Public Comment No. 1353-NFPA 70-2018 [New Definition after Definition: FestoonLighting.]

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Public Comment No. 1489-NFPA 70-2018 [New Section after 110.3(C)]

Related Item

• PI 2602

Submitter Information Verification

Submitter Full Name: Charles Mello

Organization: Cdcmello Consulting Llc

Affiliation: Self

Street Address:

City:

State:

Zip:

Submittal Date: Tue Aug 28 23:44:37 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected

Resolution: Stating that equipment has a field evaluation does not guarantee that a field label is installed. NFPA791 includes a recommendation for a label to be installed but does not mandate it as quoted below.The process of applying a field label for field evaluated equipment is extremely important for AHJs.“8.1 Label application after all identified issues have been fully resolved, all electrical testing hasbeen satisfactorily completed, and the evaluation has determined that the equipment meets theapplicable requirements of the standard(s), a label should be affixed to the equipment.”

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Public Comment No. 1735-NFPA 70-2018 [ Section No. 690.12(B)(2) ]

(2) Inside the Array Boundary.

The PV system shall comply with one of the following: Provide shock hazard control for emergencyresponders through the use of a PV hazard control means listed for the purpose. The hazard controlcomponents shall be installed and used in accordance with the instructions included with the listing or fieldlabeling.

Informational Note: A listed or field-labeled hazard control system may be comprised of either anindividual piece of equipment that fulfills the necessary functions, or multiple pieces of equipmentcoordinated to perform the functions as described in the installation instructions to reduce the risk ofelectric shock hazard within a damaged PV array for fire fighters.

Controlled conductors located inside the boundary shall be limited to not more than 80 volts within30 seconds of rapid shutdown initiation. Voltage shall be measured between any two conductors andbetween any conductor and ground.

PV arrays with no exposed wiring methods, no exposed conductive parts, and installed more than 2.5 m(8 ft) from exposed grounded conductive parts or ground shall not be required to comply with690.12(B)(2) .

Statement of Problem and Substantiation for Public Comment

CMP4 made many good revisions to 690.12. This public comment is aligned with the standard for PV Hazard Control, UL 3741, which provides requirements for a listed PV hazard control system, thus negating the need for options (2) and (3). Option (2) specified an 80V limit was an estimate intended to be a compromise between traditional electric shock hazard limits and what was thought to be a feasible implementation. Option (2) was not based upon detailed shock hazard science, does not account for the many differences in PV equipment and system implementations, and relies exclusively upon a system implemented in the field rather than a designed and coordinated hazard control system.

The systems described in option (3) could yield a plausible implementation that may pass a UL3741 evaluation,however reliance on this design to perform the intended safety function should be demonstrated as part of a listing evaluation to the consensus standard specific to the purpose.

This public comment is intended to make use of the new UL 3741 Photovoltaic Hazard Control standard that evaluates PV equipment and systems to reduce hazards for fire fighters. UL 3741 was developed based on the US Department of Energy funded Technical Report Technical Report:“Hazard Analysis of Firefighter Interactions with Photovoltaic Arrays,” written by Sandia National Laboratories and UL LLC(February 27, 2018). Developed with that report as the basis, UL 3741 is written to evaluate the shock hazards and associated electric shock limits particular to fire fighters working in the vicinity of PV arrays. The research has been investigating common fire fighter PPE, work practices, working conditions and foreseeable abnormal conditions to identify defined, science-based criteria to reasonably limit hazards for fire fighters performing their duties on buildings with PV systems. The UL Standards Technical Panel (STP) responsible for this work (STP 3741) is comprised of members from the AHJs, Fire Fighting community, NEC experts, PVindustry, US National Labs, and others.

UL 3741 is presently out for comment . The STP is working to complete and publish UL 3741 by the end of 2018, or early 2019 (prior to the publication of the 2020 NEC®).The UL 3741 draft scope is provided below. 1 Scope UL3741 1.1 Introduction 1.1.1 Fire fighters performing operations involving buildings with attached Photovoltaic (PV) arrays may be exposed to electrical hazards from damaged PV equipment. These requirements for PV Hazard Control components, equipment and systems provide a reduced level of shock hazard from energized PV system equipment and circuits located within the PV array after the operation of any required hazard control initiation function.

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1.1.2 This standard is based on the presupposition that the PV array is installed by qualified persons in accordance with the installation instructions and all applicable installation codes and standards. Evaluation to this standard should not replace other requirements addressing the control of power source(s) for the purposes of worker safety during installation or maintenance. Energized circuits can remain in some PV array equipment after any required hazard control initiation function is operated which may include PV Rapid Shutdown Equipment (PVRSE).

NOTE: Requirements for PV arrays addressed in this standard are intended for compliance with the National Electrical Code (NEC), NFPA-70, requirements for controlling electrical shock hazards inside the array boundary as addressed in NEC section 690.12(B)(2), Rapid Shutdown of PV Systems on Buildings and with the Canadian Electrical Code (CEC) C22.1. 1.2 Equipment and conditions included in scope 1.2.1 These requirements relate to conditions where PV array equipment or systems are subjected to tests representing fire fighter operations during an emergency. These conditions may result in degradation or damage from stresses beyond those covered in existing product safety standards. 1.2.2 The acceptable shock hazard risk established by these requirements is based on defined assumptions related to specific personal protective equipment (PPE) in serviceable condition worn by fire fighters during fire fighting operations involving buildings. Consideration for damage to PPE that may result from the interaction with the PV array is included.

NOTE: See NFPA 1971 and NFPA 1851 for the selection, care, and maintenance of fire fighter PPE. 1.2.3 Types of fire fighter tools and extinguishing agents, including certain water plus foam solutions, during specific fire fighter tasks are considered in this standard.

NOTE: Specifications for these items are outlined in Fire Fighter PV Array Interactions, Section 12.3. 1.2.4 Body impedances of adult fire fighters are defined in this standard to set the criteria by which shock hazards are evaluated. 1.2.5 The materials and methods used to construct the PV array are included in the evaluation. The evaluation to this standard is intended to result in an identified list of PV Hazard Control Equipment (PVHCE) determined to be necessary for the PV hazard control means. The list of PVHCE, and any characteristics of other connected equipment or systems that are essential to maintain the operational integrity of the hazard control function are documented in the PVHCE and / or the PV Hazard Control System (PVHCS) installation instructions in accordance with this standard. 1.2.6 The evaluation is based on a risk assessment of the electrical shock hazards to fire fighters working in the vicinity of the PV array. 1.2.7 The evaluation addresses the electrical hazard potential of PV array equipment on or integrated into buildings. 1.3 Equipment and conditions excluded from scope 1.3.1 The evaluation does not include equipment where the hazard control systems or functions have been rendered ineffective due to physical damage not specifically addressed in this standard. Examples of physical damage not addressed are the direct exposure of components to fire, high-pressure hose spray, or major systemic physical damage such as building collapse. 1.3.2 The evaluation does not include consideration for any damage to PPE that occurred prior to fire fighter interaction with the PV array. 1.3.3 The use of extinguishing agents not specified in this standard, such as seawater or high foam concentrations, are not included in the evaluation. 1.3.4 These requirements are not intended to address hazards to electrical technicians or other persons interacting with PV array equipment. 1.3.5 Though all components, equipment, and systems that could be used to construct the PV array are considered

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in the evaluation, not all array components are required to be identified as hazard control components, or be specifically addressed in the installation instructions for the purposes of this standard. 1.3.6 These requirements do not address any electrical shock hazards not covered by this standard or other hazards that PV arrays may present such as slip, trip or fall hazards. 1.3.7 This standard does not address fire fighter interactions involving ground mounted PV array equipment.

NOTE: Additional installation requirements addressing rapid shutdown of PV system circuits can be found in the National Electrical Code (NEC), NFPA 70, Section 690.12, Rapid Shutdown of PV Systems on Buildings, and the Canadian Electrical Code (CEC) C22.1 64-218 requirements.

Related Item

• First Revision No. 8253-NFPA 70-2018

Submitter Information Verification

Submitter Full Name: Timothy Zgonena

Organization: UL LLC

Street Address:

City:

State:

Zip:

Submittal Date: Wed Aug 29 19:07:33 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected but see related SR

Resolution: SR-8025-NFPA 70-2018

Statement: The first sentence of 690.12(B)(2)(1) has been rewritten to better comply with the NEC Style Manualand clarify the mandatory requirement to meet this subsection. The term “emergency responders” isremoved since the first sentence of 690.12 addresses the purpose of 690.12 as a whole. A newsentence has been added to clarify that where initiation is required, the same initiation device in (C)will perform this function, and not an additional device or action. A reference to UL 3741 has beenadded to the informational note to guide users of the Code to this new standard. The informationalnote has been changed to remove language that may be perceived as setting permissiverequirements.

This second revision makes minor edits to items 690.12(B)(2)(2) and 690.12(B)(2)(3) to supportexisting products and products currently in development. The last phrase of 690.12(B)(2)(3) isremoved to prevent misinterpretation of the option. The UL3741 standard is far along in thedevelopment process and is enhancing the understanding of fire fighter shock hazards in PVsystems. The future publication of the UL3741 standard will make it possible to reevaluate items690.12(B)(2)(2) and 690.12(B)(2)(3).

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Public Comment No. 2152-NFPA 70-2018 [ Section No. 690.12(B)(2) ]

(2) Inside the Array Boundary.

The PV system shall comply with one of the following:

(1) Provide shock hazard control for emergency responders through the use of a PV hazard controlmeans listed for the purpose. The hazard control components shall be installed and used inaccordance with the instructions included with the listing or field labeling.

Informational Note: A listed or field-labeled hazard control system may be comprised of eitheran individual piece of equipment that fulfills the necessary functions, or multiple pieces ofequipment coordinated to perform the functions as described in the installation instructions toreduce the risk of electric shock hazard within a damaged PV array for fire fighters.UL3741,Standard for PV Hazard Control specifies details on the overall system as well as theequipment included in a listed PV hazard control system.

(2) Controlled conductors located inside the boundary shall be limited to not more than 80 volts within30 seconds of rapid shutdown initiation. Voltage shall be measured between any two conductors andbetween any conductor and ground.

(3) PV arrays with no exposed wiring methods, no exposed conductive parts, and installed more than2.5 m (8 ft) from exposed grounded conductive parts or ground shall not be required to comply with690.12(B)(2).

Statement of Problem and Substantiation for Public Comment

UL3741, now in review, provides a risk-assessment methodology to evaluating and mitigating the hazards posed to firefighters by PV systems.

Related Item

• PI 3929

Submitter Information Verification

Submitter Full Name: Robert Wills

Organization: Intergrid, LLC

Affiliation: AWEA

Street Address:

City:

State:

Zip:

Submittal Date: Thu Aug 30 20:56:30 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected but see related SR

Resolution: SR-8025-NFPA 70-2018

Statement: The first sentence of 690.12(B)(2)(1) has been rewritten to better comply with the NEC Style Manualand clarify the mandatory requirement to meet this subsection. The term “emergency responders” isremoved since the first sentence of 690.12 addresses the purpose of 690.12 as a whole. A newsentence has been added to clarify that where initiation is required, the same initiation device in (C)will perform this function, and not an additional device or action. A reference to UL 3741 has beenadded to the informational note to guide users of the Code to this new standard. The informationalnote has been changed to remove language that may be perceived as setting permissiverequirements.

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This second revision makes minor edits to items 690.12(B)(2)(2) and 690.12(B)(2)(3) to supportexisting products and products currently in development. The last phrase of 690.12(B)(2)(3) isremoved to prevent misinterpretation of the option. The UL3741 standard is far along in thedevelopment process and is enhancing the understanding of fire fighter shock hazards in PVsystems. The future publication of the UL3741 standard will make it possible to reevaluate items690.12(B)(2)(2) and 690.12(B)(2)(3).

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Public Comment No. 436-NFPA 70-2018 [ Section No. 690.12(B)(2) ]

(2) Inside the Array Boundary.

The PV system shall comply with one of the following:

(1) Provide shock hazard control for emergency responders through the use of a PV hazard controlmeans listed for the purpose. The hazard control components shall be installed and used inaccordance with the instructions included with the listing or field labeling.

Informational Note: A listed or field-labeled hazard control system may be is comprised ofeither an individual piece of equipment that fulfills the necessary functions, or multiple pieces ofequipment coordinated to perform the functions as described in the installation instructions toreduce the risk of electric shock hazard within a damaged PV array for fire fighters.

(2) Controlled conductors located inside the boundary shall be limited to not more than 80 volts within30 seconds of rapid shutdown initiation. Voltage shall be measured between any two conductors andbetween any conductor and ground.

(3) PV arrays with no exposed wiring methods, no exposed conductive parts, and installed more than2.5 m (8 ft) from exposed grounded conductive parts or ground shall not be required to comply with690.12(B)(2).

Statement of Problem and Substantiation for Public Comment

Apparently we MAY not use the word "may" in an inforMAYtional note. This removes the may.

Related Item

• CC 222

Submitter Information Verification

Submitter Full Name: William Brooks

Organization: Brooks Engineering

Street Address:

City:

State:

Zip:

Submittal Date: Mon Aug 06 18:35:42 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected but see related SR

Resolution: SR-8025-NFPA 70-2018

Statement: The first sentence of 690.12(B)(2)(1) has been rewritten to better comply with the NEC Style Manualand clarify the mandatory requirement to meet this subsection. The term “emergency responders” isremoved since the first sentence of 690.12 addresses the purpose of 690.12 as a whole. A newsentence has been added to clarify that where initiation is required, the same initiation device in (C)will perform this function, and not an additional device or action. A reference to UL 3741 has beenadded to the informational note to guide users of the Code to this new standard. The informationalnote has been changed to remove language that may be perceived as setting permissiverequirements.

This second revision makes minor edits to items 690.12(B)(2)(2) and 690.12(B)(2)(3) to supportexisting products and products currently in development. The last phrase of 690.12(B)(2)(3) isremoved to prevent misinterpretation of the option. The UL3741 standard is far along in the

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development process and is enhancing the understanding of fire fighter shock hazards in PVsystems. The future publication of the UL3741 standard will make it possible to reevaluate items690.12(B)(2)(2) and 690.12(B)(2)(3).

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Public Comment No. 1396-NFPA 70-2018 [ Section No. 690.12(C) ]

(C) Initiation Device.

The initiation device(s) shall initiate the rapid shutdown function of the PV system. The device’s “off”position shall indicate that the rapid shutdown function has been initiated for all PV systems connected tothat device. For one-family and two-family dwellings or their detached garages , and associated storagebuildings, an initiation device(s) shall be located at a readily accessible exterior location on the building towhich the PV array is attached .

The rapid shutdown initiation device(s) shall consist of at least one of the following:

(1) Service disconnecting means

(2) PV system disconnecting means

(3) Readily accessible switch that plainly indicates whether it is in the “off” or “on” position

Informational Note: One example of why an initiation device that complies with 690.12(C)(3)would be used is where a PV system is connected to an optional standby system that remainsenergized upon loss of utility voltage.

Where multiple PV systems are installed with rapid shutdown functions on a single service, the initiationdevice(s) shall consist of not more than six switches or six sets of circuit breakers, or a combination of notmore than six switches and sets of circuit breakers, mounted in a single enclosure, or in a group ofseparate enclosures. These initiation device(s) shall initiate the rapid shutdown of all PV systems with rapidshutdown functions on that service. Where auxiliary initiation devices are installed, these auxiliary devicesshall control all PV systems with rapid shutdown functions on that service.

Statement of Problem and Substantiation for Public Comment

The addition of the language in this section will likely cause several problems in designing PV systems where the PV array is on one building and the inverter is on an adjacent building. If the rapid shutdown initiation device is the main service disconnect, this additional language would require the inverter to be placed on the same building as the PV array, or would require a switch leg to be run back to the building with the PV.While the new language may appear logical, the unintended consequences are not well thought out. The same code requirements for shutting off utilities to an outbuilding should be applied to PV systems. The fire service will normally focus on the shutting off of electric utilities at the property service location. This will also kill power to outbuildings. The Rapid Shutdown initiation device should be located at the service entrance or provide information at the service disconnecting means as to where the rapid shutdown switch is located. Mandating a location in this case is a mistake and may add unnecessary cost and confusion in many installations.

Related Item

• PI 8249

Submitter Information Verification

Submitter Full Name: William Brooks

Organization: Brooks Engineering

Street Address:

City:

State:

Zip:

Submittal Date: Tue Aug 28 01:50:56 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected but see related SR

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Resolution: SR-8005-NFPA 70-2018

Statement: The new language added to this section during the first revision that addressed the location of rapidshutdown initiation devices on outbuildings has been deleted since there are multiple potential PVsystem configurations that would result in confusion by installers and enforcers in how to apply thisrequirement. The CMP-4 has reverted this sentence to the previous language for the 2017 Code.Since there is a requirement to group all rapid shutdown initiation devices on a service, a Codeconflict could exist where multiple PV arrays are attached to different buildings at a premises.Grouping all initiation devices for a service is the most practical method of setting clear requirementsand is consistent with the input this committee has received from fire service representatives whotrain fire fighters.

New language has been added to address the case where more than one initiation device is used ona single PV system. Where such a condition exists one of those devices shall be of the type locatedin list items 690.12(C)(1) through (3). Additionally, any other devices shall initiate rapid shutdown onthat system. This is to clarify that any rapid shutdown initiation cannot require the operation of morethan one initiation device, but more than one initiation device are permitted to be installed. Thereference to auxiliary device language has been struck as it could be perceived as conflicting withthe second revision changes and referred to undefined types of devices.

An editorial change has been made to the informational note to further clarify the types of systemsthat might often use the type of initiation device indicated in list item (3).

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Public Comment No. 1488-NFPA 70-2018 [ Section No. 690.12(C) ]

(C) Initiation Device.

The initiation device(s) shall device shall initiate the rapid shutdown function of the PV system. Thedevice’s “off” device “off” position shall indicate that the rapid shutdown function has been initiated for allPV systems connected to that device. For one-family and two-family dwellings or their detached garages,and associated storage buildings, an initiation device(s) shall the initiation device shall be located at areadily accessible exterior location on the building to which the PV array is attached.

The rapid shutdown initiation device (s) shall consist of at least one of the following:

(1) Service disconnecting means

(2) PV system disconnecting means

(3) Readily accessible switch that plainly indicates whether it is in the “off” or “on” position

Informational Note: One example of why an initiation device that complies with 690.12(C)(3)would be used is where a PV system is connected to an optional standby system that remainsenergized upon loss of utility voltage.

Where multiple PV systems are installed with rapid shutdown functions on a single service, the initiationdevice(s) shall consist of not more than six switches or six sets of circuit breakers, or a combination of notmore than six switches and sets of circuit breakers, mounted in a single enclosure, or in a group ofseparate enclosures. These initiation device(s) shall initiate the rapid shutdown of all PV systems with rapidshutdown functions on that service. Where auxiliary initiation devices are installed, these auxiliary devicesshall control all PV systems with rapid shutdown functions on that service.

Statement of Problem and Substantiation for Public Comment

With 690.12 the goal is to provide a method to reduce the current available in a PV system during an emergency. Per 690.1(b) in AC or DC coupled systems the inverter is not considered part of the PV system which creates a conflict in the application of 690.12. In these systems, this change clarifies that the initiation of rapid shutdown performs the intended function of shutting of an inverter regardless of its energy source.This will eliminate confusion by providing a single identified initiation device. Additionally the current language allowing for multiple initiation devices, confusion is created by increased labeling of each initiation device with no added benefit, or increase in safety.

Related Item

• FR 8249

Submitter Information Verification

Submitter Full Name: Anthony Granato

Organization: Manchester Fire Rescue EMS

Affiliation: International Association of Fire Fighters

Street Address:

City:

State:

Zip:

Submittal Date: Tue Aug 28 22:32:01 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected but see related SR

Resolution: SR-8005-NFPA 70-2018

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Statement: The new language added to this section during the first revision that addressed the location of rapidshutdown initiation devices on outbuildings has been deleted since there are multiple potential PVsystem configurations that would result in confusion by installers and enforcers in how to apply thisrequirement. The CMP-4 has reverted this sentence to the previous language for the 2017 Code.Since there is a requirement to group all rapid shutdown initiation devices on a service, a Codeconflict could exist where multiple PV arrays are attached to different buildings at a premises.Grouping all initiation devices for a service is the most practical method of setting clear requirementsand is consistent with the input this committee has received from fire service representatives whotrain fire fighters.

New language has been added to address the case where more than one initiation device is used ona single PV system. Where such a condition exists one of those devices shall be of the type locatedin list items 690.12(C)(1) through (3). Additionally, any other devices shall initiate rapid shutdown onthat system. This is to clarify that any rapid shutdown initiation cannot require the operation of morethan one initiation device, but more than one initiation device are permitted to be installed. Thereference to auxiliary device language has been struck as it could be perceived as conflicting withthe second revision changes and referred to undefined types of devices.

An editorial change has been made to the informational note to further clarify the types of systemsthat might often use the type of initiation device indicated in list item (3).

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Public Comment No. 1677-NFPA 70-2018 [ Section No. 690.12(C) ]

(C) Initiation Device.

The initiation device(s) shall initiate the rapid shutdown function of the PV system. The device’s “off”position shall indicate that the rapid shutdown function has been initiated for all PV systems connected tothat device. For one-family and two-family dwellings or their detached garages, and associated storagebuildings, an , an initiation device(s) shall be located at a readily accessible exterior location on thebuilding to which the PV array is attached .

The rapid shutdown initiation device(s) shall consist of at least one of the following:

(1) Service disconnecting means

(2) PV system disconnecting means

(3) Readily accessible switch that plainly indicates whether it is in the “off” or “on” position

Informational Note: One example of why an initiation device that complies with 690.12(C)(3)would be used is where a PV system is connected to an optional standby system that remainsenergized upon loss of utility voltage.

Where multiple PV systems are installed with rapid shutdown functions on a single service, the initiationdevice(s) shall consist of not more than six switches or six sets of circuit breakers, or a combination of notmore than six switches and sets of circuit breakers, mounted in a single enclosure, or in a group ofseparate enclosures. These initiation device(s) shall initiate the rapid shutdown of all PV systems with rapidshutdown functions on that service. Where auxiliary initiation devices are installed, these auxiliary devicesshall control all PV systems with rapid shutdown functions on that service.

Statement of Problem and Substantiation for Public Comment

The rapid shutdown initiation device should not be required to be located remotely from the service entrance, as would be the case with PV systems mounted on accessory buildings, unattached garages, etc according to the first draft language. There is no benefit to having the rapid shutdown switch for the PV system located remotely from the service entrance.

Related Item

• FR-8249

Submitter Information Verification

Submitter Full Name: Rebekah Hren

Organization: IPPNC LLC

Street Address:

City:

State:

Zip:

Submittal Date: Wed Aug 29 15:33:49 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected but see related SR

Resolution: SR-8005-NFPA 70-2018

Statement: The new language added to this section during the first revision that addressed the location of rapidshutdown initiation devices on outbuildings has been deleted since there are multiple potential PVsystem configurations that would result in confusion by installers and enforcers in how to apply thisrequirement. The CMP-4 has reverted this sentence to the previous language for the 2017 Code.

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Since there is a requirement to group all rapid shutdown initiation devices on a service, a Codeconflict could exist where multiple PV arrays are attached to different buildings at a premises.Grouping all initiation devices for a service is the most practical method of setting clear requirementsand is consistent with the input this committee has received from fire service representatives whotrain fire fighters.

New language has been added to address the case where more than one initiation device is used ona single PV system. Where such a condition exists one of those devices shall be of the type locatedin list items 690.12(C)(1) through (3). Additionally, any other devices shall initiate rapid shutdown onthat system. This is to clarify that any rapid shutdown initiation cannot require the operation of morethan one initiation device, but more than one initiation device are permitted to be installed. Thereference to auxiliary device language has been struck as it could be perceived as conflicting withthe second revision changes and referred to undefined types of devices.

An editorial change has been made to the informational note to further clarify the types of systemsthat might often use the type of initiation device indicated in list item (3).

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Public Comment No. 1732-NFPA 70-2018 [ Section No. 690.12(C) ]

(C) Initiation Device.

The initiation device(s) shall initiate the rapid shutdown function of the PV system. The device’s “off”position shall indicate that the rapid shutdown function has been initiated for all PV systems connected tothat device. For one-family and two-family dwellings or their detached garages, and associated storagebuildings, an initiation device(s) shall be located at a readily accessible exterior location on the building towhich the PV array is attached.

For a single PV system The rapid shutdown initiation shall occur by the operation of any single initiationdevice . device (s) shall consist of at least one of of one or more of the following:

(1) Service disconnecting means

(2) PV system disconnecting means

(3) Readily accessible switch that plainly indicates whether it is in the “off” or “on” position

Informational Note: One example of why an initiation device that complies with 690.12(C)(3)would be used is where a PV system is connected to an optional standby system that remainsenergized upon loss of utility voltage.

Where multiple PV systems are installed with rapid shutdown functions on a single service, the initiationdevice(s) shall consist of not more than six switches or six sets of circuit breakers, or a combination of notmore than six switches and sets of circuit breakers, mounted in a single enclosure, or in a group ofseparate enclosures. These initiation device(s) shall initiate the rapid shutdown of all PV systems with rapidshutdown functions on that service. Where auxiliary initiation devices are installed, these auxiliary devicesshall control all PV systems with rapid shutdown functions on that service.

Statement of Problem and Substantiation for Public Comment

The present text can be interpreted to have more than one meaning. One common misinterpretation is that a PV rapid shutdown system is permitted to have more than one initiator device where all of the initiators need to be operated for the rapid shutdown function to occur. The intent of this requirement is that the operation of any single initiator shall result in the tripping of the rapid shutdown system. This PVRSS requirement is clearly stated in the published UL 1741 requirements for rapid shutdown as shown and the NEC text should be revised to coordinate and clarify this point:

UL1741 - Section 90 Initiators

d) Where the PVRSS is capable of accepting initiation inputs from multiple manual or externalinitiation devices (e.g. fire alarm), the initiation system shall have those devices or inputsconnected in such a manner that activation of any one of the devices or inputs will result ininitiating the PVRSS.

Related Item

• First Revision No. 8249-NFPA 70-2018

Submitter Information Verification

Submitter Full Name: Timothy Zgonena

Organization: UL LLC

Street Address:

City:

State:

Zip:

Submittal Date: Wed Aug 29 19:00:13 EDT 2018

Committee: NEC-P04

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Committee Statement

CommitteeAction:

Rejected but see related SR

Resolution: SR-8005-NFPA 70-2018

Statement: The new language added to this section during the first revision that addressed the location of rapidshutdown initiation devices on outbuildings has been deleted since there are multiple potential PVsystem configurations that would result in confusion by installers and enforcers in how to apply thisrequirement. The CMP-4 has reverted this sentence to the previous language for the 2017 Code.Since there is a requirement to group all rapid shutdown initiation devices on a service, a Codeconflict could exist where multiple PV arrays are attached to different buildings at a premises.Grouping all initiation devices for a service is the most practical method of setting clear requirementsand is consistent with the input this committee has received from fire service representatives whotrain fire fighters.

New language has been added to address the case where more than one initiation device is used ona single PV system. Where such a condition exists one of those devices shall be of the type locatedin list items 690.12(C)(1) through (3). Additionally, any other devices shall initiate rapid shutdown onthat system. This is to clarify that any rapid shutdown initiation cannot require the operation of morethan one initiation device, but more than one initiation device are permitted to be installed. Thereference to auxiliary device language has been struck as it could be perceived as conflicting withthe second revision changes and referred to undefined types of devices.

An editorial change has been made to the informational note to further clarify the types of systemsthat might often use the type of initiation device indicated in list item (3).

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Public Comment No. 1971-NFPA 70-2018 [ Section No. 690.12(C) ]

(C) Initiation Device.

The initiation device(s) shall initiate the rapid shutdown function of the PV system. The device’s “off”position shall indicate that the rapid shutdown function has been initiated for all PV systems connected tothat device. For one-family and two-family dwellings or their detached garages , and associated storagebuildings, an initiation device(s) shall be located at a readily accessible exterior location on the building towhich the PV array is attached .

The rapid shutdown initiation device(s) shall consist of at least one of the following:

(1) Service disconnecting means

(2) PV system disconnecting means

(3) Readily accessible switch that plainly indicates whether it is in the “off” or “on” position

Informational Note: One example of why an initiation device that complies with 690.12(C)(3)would be used is where a PV system is connected to an optional standby system that remainsenergized upon loss of utility voltage.

Where multiple PV systems are installed with rapid shutdown functions on a single service, the initiationdevice(s) shall consist of not more than six switches or six sets of circuit breakers, or a combination of notmore than six switches and sets of circuit breakers, mounted in a single enclosure, or in a group ofseparate enclosures. These initiation device(s) shall initiate the rapid shutdown of all PV systems with rapidshutdown functions on that service. Where auxiliary initiation devices are installed, these auxiliary devicesshall control all PV systems with rapid shutdown functions on that service.

Statement of Problem and Substantiation for Public Comment

We need to keep the rapid shutdown requirements simple, understandable and enforceable. If there's PV on a building, it must have means of controlling the shock hazard, the initiation means must be readily accessible on the outside of that building, and the means of control needs to be clearly marked.

The previously added proposed added text damages that clarity. As written, it could require additional initiation devices on detached garages and associated storage buildings of one and two family dwellings, even if that building wasn't associated with the PV array. Similarly, auxiliary initiation device is not defined, but a requirement that such a device must control all other PV systems on the service when other initiation devices do not carry the same burden is an impractical requirement with no demonstrated benefit.

Related Item

• FR-8249

Submitter Information Verification

Submitter Full Name: Phil Undercuffler

Organization: Outback Power Technologies

Street Address:

City:

State:

Zip:

Submittal Date: Thu Aug 30 13:16:55 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected but see related SR

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Resolution: SR-8005-NFPA 70-2018

Statement: The new language added to this section during the first revision that addressed the location of rapidshutdown initiation devices on outbuildings has been deleted since there are multiple potential PVsystem configurations that would result in confusion by installers and enforcers in how to apply thisrequirement. The CMP-4 has reverted this sentence to the previous language for the 2017 Code.Since there is a requirement to group all rapid shutdown initiation devices on a service, a Codeconflict could exist where multiple PV arrays are attached to different buildings at a premises.Grouping all initiation devices for a service is the most practical method of setting clear requirementsand is consistent with the input this committee has received from fire service representatives whotrain fire fighters.

New language has been added to address the case where more than one initiation device is used ona single PV system. Where such a condition exists one of those devices shall be of the type locatedin list items 690.12(C)(1) through (3). Additionally, any other devices shall initiate rapid shutdown onthat system. This is to clarify that any rapid shutdown initiation cannot require the operation of morethan one initiation device, but more than one initiation device are permitted to be installed. Thereference to auxiliary device language has been struck as it could be perceived as conflicting withthe second revision changes and referred to undefined types of devices.

An editorial change has been made to the informational note to further clarify the types of systemsthat might often use the type of initiation device indicated in list item (3).

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Public Comment No. 485-NFPA 70-2018 [ Section No. 690.12(C) ]

(C) Initiation Device.

The initiation device(s) shall initiate the rapid shutdown function of the PV system. The device’s “off”position shall indicate that the rapid shutdown function has been initiated for all PV systems connected tothat device. For one-family and two-family dwellings or their detached garages, and associated storagebuildings, an initiation device(s) shall be located at a readily accessible exterior location on the building towhich the PV array is attached.

The rapid shutdown initiation device(s) shall consist of at least one of the following:

(1) Service disconnecting means

(2) PV system disconnecting means

(3) Readily accessible switch that plainly indicates whether it is in the “off” or “on” position

Informational Note: One example of why an initiation device that complies with 690.12(C)(3)would be used is where a PV system is connected to an optional standby system that remainsenergized upon loss of utility voltage.

Where multiple PV systems are installed with rapid shutdown functions on a single service, the initiationdevice(s) shall consist of not more than six switches or six sets of circuit breakers, or a combination of notmore than six switches and sets of circuit breakers, mounted in a single enclosure, or in a group ofseparate enclosures. These initiation device(s) shall initiate the rapid shutdown of all PV systems with rapidshutdown functions on that service. Where auxiliary initiation devices are installed, these auxiliary devicesshall control all PV systems with rapid shutdown functions on that service.

Statement of Problem and Substantiation for Public Comment

Requiring that the initiation device be on the exterior of the building will undermine the intention that disconnecting the utility service at the service disconnect would be the primary means of residential RSS initiation. In many areas of the US, including much of the North East, the utility disconnect is not on the exterior of the building. It is readily accessible in that local fire fighters know where service disconnects are in their area and they have a universal access device for opening doors and gaining access if needed to isolate both utility service and the PV system or service conductors on the exterior of the building can be cut to secure power to the building.

Related Item

• First Revision No. 8249-NFPA 70-2018

Submitter Information Verification

Submitter Full Name: MARVIN HAMON

Organization: HAMON ENGINEERING INC

Street Address:

City:

State:

Zip:

Submittal Date: Wed Aug 08 20:41:46 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected

Resolution: Consistent with revisions in Article 230, the requirement for an external utility disconnect alignswith the request from the fire service to provide external access for control of electrical service andrapid shutdown initiators.

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Public Comment No. 1436-NFPA 70-2018 [ Section No. 690.12 [Excluding any Sub-

Sections] ]

PV system circuits installed on or in buildings shall include a rapid shutdown function to reduce shockhazard 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 tohouse PV system equipment, shall not be required to comply with 690.12.

Statement of Problem and Substantiation for Public Comment

It would remove the current ambiguity regarding RS for ground mounted structures. RS was envisioned to protect Emergency Responders to roof mounted pv arrays.

Related Item

• PI

Submitter Information Verification

Submitter Full Name: Christopher Warfel

Organization: ENTECH Engineering, Inc.

Street Address:

City:

State:

Zip:

Submittal Date: Tue Aug 28 14:45:57 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected

Resolution: This exception is intended to clarify that these structures used solely for inverters and powerelectronics are commonly used for ground mount systems, and are not structures that wouldrequire roof access for firefighting operations. Additionally, PV circuits that are inside buildings arealso required to be covered under 690.12.

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Public Comment No. 484-NFPA 70-2018 [ Section No. 690.12 [Excluding any Sub-

Sections] ]

PV system circuits installed on or in buildings shall include a rapid shutdown function to reduce shockhazard for emergency responders fire fighters in accordance with 690.12(A) through (D).

Exception: Ground mounted PV system circuits that enter buildings, of which the sole purpose is to housePV system equipment, shall not be required to comply with 690.12.

Statement of Problem and Substantiation for Public Comment

Harmonize language with UL Standard 3741 indicating that the protected group is fire fighters.

Related Item

• First Revision No. 8253-NFPA 70-2018

Submitter Information Verification

Submitter Full Name: MARVIN HAMON

Organization: HAMON ENGINEERING INC

Street Address:

City:

State:

Zip:

Submittal Date: Wed Aug 08 20:36:48 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Accepted

Resolution: SR-7994-NFPA 70-2018

Statement: This term more accurately describes the personnel that this section is serving as there are otherfirst responders such as police, utility workers that are not the focus of 690.12.

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Public Comment No. 1404-NFPA 70-2018 [ Section No. 690.13(E) ]

(E) Type of Disconnect.

The PV system disconnecting means shall simultaneously disconnect the PV system conductors that arenot solidly grounded from all conductors of other wiring systems. The PV system disconnecting means shallbe one of the following:

(1) A manually operable switch or circuit breaker

(2) A connector meeting the requirements of 690.33(E D )(1) or (D)(3)

(3) A pull-out switch with the required interrupting rating

(4) A remote‐controlled switch or circuit breaker that is operable locally and opens automatically whencontrol power is interrupted

(5) A device listed or approved for the intended application

Informational Note: Circuit breakers marked “line” and “load” may not be suitable for backfeed orreverse current.

Statement of Problem and Substantiation for Public Comment

Article 690.33 was restructured such that 690.33(D) replaces 690.33(E). New option (D)(3) should be included in the allowance.

Related Item

• FR No. 8295-NFPA 70-2018 • FR No. 8395-NFPA 70-2018

Submitter Information Verification

Submitter Full Name: Thomas A. Wegener

Organization: SMA Solar Technology AG

Street Address:

City:

State:

Zip:

Submittal Date: Tue Aug 28 07:22:18 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected but see related SR

Resolution: SR-8033-NFPA 70-2018

Statement: Lockability requirements of 110.25 are included with language similar to 690.15. This languageprovides locking methods relevant to residential panelboards and adds the option of a connectorlisted with the equipment in 690.33(D)(3).

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Public Comment No. 1585-NFPA 70-2018 [ Section No. 690.13(E) ]

(E) Type of Disconnect.

The PV system disconnecting means shall simultaneously disconnect the PV system conductors that arenot solidly grounded from all conductors of other wiring systems. The PV system disconnecting means shallbe one of the following and shall with the requirements in Article 110.25 :

(1) A manually operable switch or circuit breaker

(2) A connector meeting the requirements of 690.33(E)(1)

(3) A pull-out switch with the required interrupting rating

(4) A remote‐controlled switch or circuit breaker that is operable locally and opens automatically whencontrol power is interrupted

(5) A device listed or approved for the intended application

Informational Note: Circuit breakers marked “line” and “load” may not be suitable for backfeed orreverse current.

Statement of Problem and Substantiation for Public Comment

This clarification insures that the disconnecting means will be lockable in the open position. Allowing for compliance with electrical safety lock out tag out procedures.

Related Item

• PI 1833; PI 3003; PI 1284

Submitter Information Verification

Submitter Full Name: Wendell Whistler

Organization: IBEW 280

Street Address:

City:

State:

Zip:

Submittal Date: Wed Aug 29 12:29:48 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected but see related SR

Resolution: SR-8033-NFPA 70-2018

Statement: Lockability requirements of 110.25 are included with language similar to 690.15. This languageprovides locking methods relevant to residential panelboards and adds the option of a connectorlisted with the equipment in 690.33(D)(3).

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Public Comment No. 1643-NFPA 70-2018 [ Section No. 690.15(A) ]

(A) Location.

Isolating devices or equipment disconnecting means shall be installed in circuits connected to equipment ata location within the equipment, or within sight and within 3 m (10 ft) of the equipment and meet therequirements of 110 .25. An equipment disconnecting means shall be permitted to be remote from theequipment where the equipment disconnecting means can be remotely operated from within 3 m (10 ft) ofthe equipment. Where disconnecting means of equipment operating above 30 volts are readily accessibleto unqualified persons, any enclosure door or hinged cover that exposes live parts when open shall belocked or require a tool to open.

Statement of Problem and Substantiation for Public Comment

By adding the requirements of 110.25 all circuits would be able to be locked out in accordance witht e lock out tag out safety procedures and provide the necessary level of safety for the electrical worker.

Related Item

• PI 3010; PI 3008

Submitter Information Verification

Submitter Full Name: Wendell Whistler

Organization: IBEW 280

Street Address:

City:

State:

Zip:

Submittal Date: Wed Aug 29 14:07:46 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected

Resolution: Elsewhere in this Code when 110.25 is referenced, it is most commonly referenced in the followingway: For example in 410.141(B) on luminaires (B) Within Sight or Locked Type. The switch or circuitbreaker shall be located within sight from the luminaires or lamps, or it shall be permitted to belocated elsewhere if it is lockable in accordance with 110.25. Where equipment is within sight, asrequired in 690.15, lockability is generally not required additionally in the NEC.

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Public Comment No. 1608-NFPA 70-2018 [ Section No. 690.15(B) ]

(B) Isolating Device.

An isolating device shall not be required to have an interrupting rating. Where an isolating device is notrated for interrupting the circuit current, it shall be marked “Do Not Disconnect Under Load” or “Not forCurrent Interrupting.” An isolating device shall not be required to simultaneously disconnect all current-carrying conductors of a circuit and comply with the requirements of Article 110 .25. The isolating deviceshall be one of the following:

(1) A connector meeting the requirements of 690.33 and listed and identified for use with specificequipment

(2) A finger-safe fuse holder

(3) An isolating device that requires a tool to place in the open (off) position

(4) An isolating device listed for the intended application

Statement of Problem and Substantiation for Public Comment

By using an isolating device to provide disconnection of an electrical circuit they are trying to circumvent the lockable requirements of a disconnecting means. This does not provide the necessary safety protections for an electrical worker when working in and around energized electrical equipment in PV installations.

Related Item

• PI 3010; PI 3008

Submitter Information Verification

Submitter Full Name: Wendell Whistler

Organization: IBEW 280

Street Address:

City:

State:

Zip:

Submittal Date: Wed Aug 29 13:10:49 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected

Resolution: Elsewhere in this Code when 110.25 is referenced, it is most commonly referenced in the followingway: For example in 410.141(B) on luminaires (B) Within Sight or Locked Type. The switch or circuitbreaker shall be located within sight from the luminaires or lamps, or it shall be permitted to belocated elsewhere if it is lockable in accordance with 110.25. Where equipment is within sight, asrequired in 690.15, lockability is generally not required additionally in the NEC.

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Public Comment No. 1617-NFPA 70-2018 [ Section No. 690.15(B) ]

(B) Isolating Device.

An isolating device shall not be required to have an interrupting rating. Where an isolating device is notrated for interrupting the circuit current, it shall be marked “Do Not Disconnect Under Load” or “Not forCurrent Interrupting.” An isolating device shall not be required to simultaneously disconnect all current-carrying conductors of a circuit. The isolating device shall be one of the following:

(1) A mating connector meeting the requirements of 690.33 and listed and identified for use with specificequipment

(2) A finger-safe fuse holder

(3) An isolating device that requires a tool to place in the open (off) position

(4) An isolating device listed for the intended application

Statement of Problem and Substantiation for Public Comment

This is an editorial comment to improve the applicability of this section. Connectors that meet the requirements of 690.33 are correctly called mating connectors. Other connectors can be used in PV systems including splicing connectors and terminal connectors. A complimenting public comment has been submitted for 690.33 as well. Additionally, this submitter has requested that UL add this clairfying term to UL 6703 and it's reference in UL 1703.

Related Item

• FR-8316

Submitter Information Verification

Submitter Full Name: Jason Fisher

Organization: Tesla Inc.

Affiliation: Solar Energy Industries Association (SEIA)

Street Address:

City:

State:

Zip:

Submittal Date: Wed Aug 29 13:23:27 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected but see related SR

Resolution: SR-8039-NFPA 70-2018

Statement: “Mating” was added in (B)(1) to differentiate the type of connector that applies to this section andto be consistent with changes in 690.33. The revision to Item (3) clarifies what is paced in theopen position.

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Public Comment No. 608-NFPA 70-2018 [ Section No. 690.15(B) ]

(B) Isolating Device.

An isolating device shall not be required to have an interrupting rating. Where an isolating device is notrated for interrupting the circuit current, it shall be marked “Do Not Disconnect Under Load” or “Not forCurrent Interrupting.” An isolating device shall not be required to simultaneously disconnect all current-carrying conductors of a circuit. The isolating device shall be one of the following:

(1) A connector meeting the requirements of 690.33 and listed and identified for use with specificequipment

(2) A finger-safe fuse holder

(3) An isolating device that requires a tool to place the electrical contacts in the open (off) position

(4) An isolating device listed for the intended application

Statement of Problem and Substantiation for Public Comment

Item 3 is incomplete statement.

Related Item

• FR-8316

Submitter Information Verification

Submitter Full Name: Jeffrey Hidaka

Organization: QF Energy

Affiliation: Employee

Street Address:

City:

State:

Zip:

Submittal Date: Mon Aug 13 18:42:22 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected but see related SR

Resolution: SR-8039-NFPA 70-2018

Statement: “Mating” was added in (B)(1) to differentiate the type of connector that applies to this section andto be consistent with changes in 690.33. The revision to Item (3) clarifies what is paced in theopen position.

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Public Comment No. 1607-NFPA 70-2018 [ Section No. 690.15(C) ]

(C) Circuits Connected to Electronic Power Converters.

Equipment disconnecting means in accordance with

Disconnect Type .

PV system dc circuits shall utilize a disconnecting means of the type identified in 690.15(D) shall berequired to isolate dc circuits over 30 amperes connected to the input of electronic power converters. Fordc circuits operating at 30 amperes or less connected to the input of electronic power converters, anisolating device C)(1) or 690.15(C)(2) as applicable.

(1) Circuits operating over 30 amperes. An equipment disconnecting means shall be installed inaccordance with 690.15(D)

(2) Circuits operating at or below 30 amperes. An isolating device installed in accordance with690.15(B) shall be permitted.

Informational Note: Examples of circuits connected to the input of electronic power convertersinclude, but are not limited to, the input circuits of dc-to-dc converters, electronic charge controllers,or inverters. If power electronics fail, these devices present a load to connected dc sources.

Where an isolating device is not utilized, an equipment disconnecting means shall be installed inaccordance with 690.15(D)

Statement of Problem and Substantiation for Public Comment

All text in this new section has been reorganized to improve the applicability of this section. Limiting these requirements only to circuits connected to electronic power converters leaves a gap in the Code for other circuits not connected to this equipment. This gap did not exist in the 2017 version of the NEC. The changes recommended in this comment to both the title and the reorganized text corrects this gap and returns the requirements to those in the 2017 edition.Additionally, the generic term ""dc circuits"" is replaced with the defined term ""PV system dc circuits"" to ensure that specific requirements in 690 intended only for PV system circuits do not inadvertently get applied to other dc circuits that might be associated with a PV system in some applications (such as control circuits).

Related Item

• FR-8321

Submitter Information Verification

Submitter Full Name: Jason Fisher

Organization: Tesla Inc.

Affiliation: Solar Energy Industries Association (SEIA)

Street Address:

City:

State:

Zip:

Submittal Date: Wed Aug 29 13:09:25 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected but see related SR

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Resolution: SR-8042-NFPA 70-2018

Statement: This clarifies the requirements related to disconnection of equipment. It changes the title and movesthe requirements to the end of 690.15. There are two different requirements for these devices.Circuits above 30 amps must have devices that meet 690.15(D) as the conversion device canpresent a load to the short-circuit limited circuit in the event of a failure and may not clear anovercurrent device or not even have an overcurrent device. Circuits under 30 amps where isolationis required for servicing equipment, isolating devices are acceptable.

Smaller electronic conversion devices are commonly used with isolating devices (microinverters) atcurrent of 30 amps or less and have been operated safely for well over a decade. This Code hasexpressly allowed those installations in the past several editions.

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Public Comment No. 1647-NFPA 70-2018 [ Section No. 690.15(C) ]

(C) Circuits Connected to Electronic Power Converters.

Equipment disconnecting means in accordance with 690.15(D) shall be required to isolate dc circuits over30 amperes circuits connected to the input of electronic power converters. For dc circuits operating at 30amperes or less connected to the input of electronic power converters, an isolating device in accordancewith 690.15(B) shall be permitted.

Informational Note: Examples of circuits connected to the input of electronic power convertersinclude, but are not limited to, the input circuits of dc-to-dc converters, electronic charge controllers,or inverters. If power electronics fail, these devices present a load to connected dc sources.

Statement of Problem and Substantiation for Public Comment

Disconnection of electrical circuits manually with an isolating device unnecessarily exposes the electrical worker to circuits even when the amperage is 30 amps or less.

Related Item

• PI 3010; PI 3008

Submitter Information Verification

Submitter Full Name: Wendell Whistler

Organization: IBEW 280

Street Address:

City:

State:

Zip:

Submittal Date: Wed Aug 29 14:17:09 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected

Resolution: There is no technical substantiation to eliminate the practice of using isolating devices to isolate PVequipment. The appropriate concerns are addressed by limiting the current on isolating devices toequipment to only those circuits that are below 30 amperes. Circuits over 30 amperes require loadbreak rated switches. All isolating devices must be checked for current prior to operation. Onlyqualified persons are permitted to work on PV systems so electrical workers installing andmaintaining these systems should be appropriately trained. These are not new requirements andfuses, microinverters, and other devices have been using these means safely for well over a decade.

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Public Comment No. 1397-NFPA 70-2018 [ Section No. 690.15(D) ]

(D) Equipment Disconnecting Means.

Equipment disconnecting means shall have ratings sufficient for the maximum circuit current, available faultcurrent, and voltage that is available at the terminals. Equipment disconnecting means shall simultaneouslydisconnect all current-carrying conductors that are not solidly grounded of the circuit to which it isconnected. Equipment disconnecting means shall be externally operable without exposing the operator tocontact with energized parts and shall indicate whether in the open (off) or closed (on) position. Where notwithin sight and not within 3 m (10 ft) of the equipment, the disconnecting means or its remote operatingdevice or enclosure providing access to the disconnecting means shall be capable of being locked inaccordance with 110.25. Equipment disconnecting means shall be of the same type as required in690.13(E).

Equipment disconnecting means, other than those complying with 690.33, shall be marked in accordancewith the warning in 690.13(B) if the line and load terminals can be energized in the open position.

Informational Note: A common installation practice is to terminate PV source-side dc conductors inthe same manner that utility source-side ac conductors are generally connected on the line side of adisconnecting means. This practice is more likely to de-energize load-side terminals, blades, andfuses when the disconnect is in the open position and no energized sources are connected to theload side of the disconnect.

Statement of Problem and Substantiation for Public Comment

The fourth sentence in the first paragraph could be misunderstood. The intention is clearly stated in panel statement that disconnects within sight AND within 10’ of the equipment would not be required to be lockable.

The word "not" is added to clarify that lockability is needed for for switches not near the equipment.

Related Item

Submitter Information Verification

Submitter Full Name: William Brooks

Organization: Brooks Engineering

Street Address:

City:

State:

Zip:

Submittal Date: Tue Aug 28 01:58:56 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected but see related SR

Resolution: SR-8045-NFPA 70-2018

Statement: This SR provides some editorial changes to clarify the last half of the first paragraph. The locationwhere lockability is required was potentially confusing and that sentence was improved for clarity.The last sentence of the first paragraph was edited for clarity to make it clear that the same typesused in 690.13 would be appropriate for equipment disconnecting means.

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Public Comment No. 1621-NFPA 70-2018 [ Section No. 690.15(D) ]

(D) Equipment Disconnecting Means.

Equipment disconnecting means shall have ratings sufficient for the maximum circuit current, available faultcurrent, and voltage that is available at the terminals. Equipment disconnecting means shall simultaneouslydisconnect all current-carrying conductors that are not solidly grounded of the circuit to which it isconnected. Equipment disconnecting means shall be externally operable without exposing the operator tocontact with energized parts and shall indicate whether in the open (off) or closed (on) position. Where notwithin sight and within 3 m (10 ft) of the equipment, the disconnecting means or its remote operating deviceor enclosure providing access to the disconnecting means shall be capable of being locked in accordancewith 110.25. Equipment An equipment disconnecting means, where used, shall be one of the same typeas required types identified in 690.13(E)(1) through (5) .

Equipment disconnecting means, other than those complying with 690.33, shall be marked in accordancewith the warning in 690.13(B) if the line and load terminals can be energized in the open position.

Informational Note: A common installation practice is to terminate PV source-side dc conductors inthe same manner that utility source-side ac conductors are generally connected on the line side of adisconnecting means. This practice is more likely to de-energize load-side terminals, blades, andfuses when the disconnect is in the open position and no energized sources are connected to theload side of the disconnect.

Statement of Problem and Substantiation for Public Comment

Editorial changes suggested to improve the applicability of this section.

Related Item

• FR-8327

Submitter Information Verification

Submitter Full Name: Jason Fisher

Organization: Tesla Inc.

Affiliation: Solar Energy Industries Association (SEIA)

Street Address:

City:

State:

Zip:

Submittal Date: Wed Aug 29 13:26:25 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected but see related SR

Resolution: SR-8045-NFPA 70-2018

Statement: This SR provides some editorial changes to clarify the last half of the first paragraph. The locationwhere lockability is required was potentially confusing and that sentence was improved for clarity.The last sentence of the first paragraph was edited for clarity to make it clear that the same typesused in 690.13 would be appropriate for equipment disconnecting means.

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Public Comment No. 1659-NFPA 70-2018 [ Section No. 690.15(D) ]

(D) Equipment Disconnecting Means.

Equipment disconnecting means shall have ratings sufficient for the maximum circuit current, available faultcurrent, and voltage that is available at the terminals. Equipment disconnecting means shall simultaneouslydisconnect all current-carrying conductors that are not solidly grounded of the circuit to which it isconnected. Equipment disconnecting means shall be externally operable without exposing the operator tocontact with energized parts and shall indicate whether in the open (off) or closed (on) position. Where notwithin sight and or within 3 m (10 ft) or less of the equipment, the disconnecting means or its remoteoperating device or enclosure providing access to the disconnecting means shall be capable of beinglocked in accordance with 110.25. Equipment disconnecting means shall be of the same type as required in690.13(E).

Equipment disconnecting means, other than those complying with 690.33, shall be marked in accordancewith the warning in 690.13(B) if the line and load terminals can be energized in the open position.

Informational Note: A common installation practice is to terminate PV source-side dc conductors inthe same manner that utility source-side ac conductors are generally connected on the line side of adisconnecting means. This practice is more likely to de-energize load-side terminals, blades, andfuses when the disconnect is in the open position and no energized sources are connected to theload side of the disconnect.

Statement of Problem and Substantiation for Public Comment

This is an editorial change as the language that was proposed allowed for disconnects that were located atdistances greater than 10 feet to not have to meet the requirements of 110.25.

Related Item

• PI 3011; PI 2250; PI 3012; PI 1584; PI2259

Submitter Information Verification

Submitter Full Name: Wendell Whistler

Organization: IBEW 280

Street Address:

City:

State:

Zip:

Submittal Date: Wed Aug 29 14:45:48 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected but see related SR

Resolution: SR-8045-NFPA 70-2018

Statement: This SR provides some editorial changes to clarify the last half of the first paragraph. The locationwhere lockability is required was potentially confusing and that sentence was improved for clarity.The last sentence of the first paragraph was edited for clarity to make it clear that the same typesused in 690.13 would be appropriate for equipment disconnecting means.

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Public Comment No. 2071-NFPA 70-2018 [ Section No. 690.15(D) ]

(D) Equipment Disconnecting Means.

Equipment disconnecting means shall have ratings sufficient for the maximum circuit current, available faultcurrent, and voltage that is available at the terminals. Equipment disconnecting means shall simultaneouslydisconnect all current-carrying conductors that are not solidly grounded of the circuit to which it isconnected. Equipment disconnecting means shall be externally operable without exposing the operator tocontact with energized parts and shall indicate whether in the open (off) or closed (on) position. Where notwithin sight and not within 3 m (10 ft) of the equipment, the disconnecting means or its remote operatingdevice or enclosure providing access to the disconnecting means shall be capable of being locked inaccordance with 110.25. Equipment disconnecting means shall be of the same type as required in690.13(E).

Equipment disconnecting means, other than those complying with 690.33, shall be marked in accordancewith the warning in 690.13(B) if the line and load terminals can be energized in the open position.

Informational Note: A common installation practice is to terminate PV source-side dc conductors inthe same manner that utility source-side ac conductors are generally connected on the line side of adisconnecting means. This practice is more likely to de-energize load-side terminals, blades, andfuses when the disconnect is in the open position and no energized sources are connected to theload side of the disconnect.

Statement of Problem and Substantiation for Public Comment

as many CMP members noted, this sentence reads better and adding "not" to "Where not within sight and "NOT" within 3 m (10 ft) of the equipment" clarifies the intention of the statement.

Related Item

• FR-8327

Submitter Information Verification

Submitter Full Name: Christopher Fox

Organization: SunPower

Street Address:

City:

State:

Zip:

Submittal Date: Thu Aug 30 16:08:32 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected but see related SR

Resolution: SR-8045-NFPA 70-2018

Statement: This SR provides some editorial changes to clarify the last half of the first paragraph. The locationwhere lockability is required was potentially confusing and that sentence was improved for clarity.The last sentence of the first paragraph was edited for clarity to make it clear that the same typesused in 690.13 would be appropriate for equipment disconnecting means.

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Public Comment No. 486-NFPA 70-2018 [ Section No. 690.15(D) ]

(D) Equipment Disconnecting Means.

Equipment disconnecting means shall have ratings sufficient for the maximum circuit current, available faultcurrent, and voltage that is available at the terminals. Equipment disconnecting means shall simultaneouslydisconnect all current-carrying conductors that are not solidly grounded of the circuit to which it isconnected. Equipment disconnecting means shall be externally operable without exposing the operator tocontact with energized parts and shall indicate whether in the open (off) or closed (on) position. Where notwithin sight and within 3 m (10 ft) of the equipment, the disconnecting means or its remote operating deviceor enclosure providing access to the disconnecting means shall be capable of being locked in accordancewith 110.25. Equipment disconnecting means shall be of the same type as required in 690.13(E).

Equipment disconnecting means, other than those complying with 690.33, shall be marked in accordancewith the warning in 690.13(B) if the line and load terminals can be energized in the open position.

Informational Note: A common installation practice is to terminate PV source-side dc conductors inthe same manner that utility source-side ac conductors are generally connected on the line side of adisconnecting means. This practice is more likely to de-energize load-side terminals, blades, andfuses when the disconnect is in the open position and no energized sources are connected to theload side of the disconnect.

Statement of Problem and Substantiation for Public Comment

This IN is teaching design practices and is not appropriate for inclusion in the NEC according to the Style Manual.

Related Item

• First Revision No. 8327-NFPA 70-2018

Submitter Information Verification

Submitter Full Name: MARVIN HAMON

Organization: HAMON ENGINEERING INC

Street Address:

City:

State:

Zip:

Submittal Date: Wed Aug 08 20:55:58 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected

Resolution: The informational note was added to address information that did not lend itself to a requirement.The informational note simply points out the common approach which may not be clear to aninstaller who is unfamiliar with these types of installations.

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Public Comment No. 1398-NFPA 70-2018 [ Section No. 690.15 [Excluding any Sub-

Sections] ]

Isolating devices shall be provided to disconnect PV modules, ac PV modules, fuses, dc-to-dc converters,inverters, and charge controllers from all conductors that are not solidly grounded. Equipment disconnectingmeans and PV system disconnecting means shall meet the requirements of isolating devices.

Informational Note: The purpose of these isolating devices is the safe and convenient replacement orservice of specific PV system equipment without exposure to energized conductors.

Statement of Problem and Substantiation for Public Comment

The last sentence in the paragraph unnecessarily has the word “shall”. The first sentence provided the shall. The second sentence is simply stating the fact that an equipment disconnect meets the requirements of isolating devices. Removing the “shall” makes this clear. Contorted logic could bring an inspector to somehow require that a switch meet the requirements of an isolating device RATHER than the equipment disconnect requirements, which is not the intent here.

Related Item

Submitter Information Verification

Submitter Full Name: William Brooks

Organization: Brooks Engineering

Street Address:

City:

State:

Zip:

Submittal Date: Tue Aug 28 02:16:29 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected but see related SR

Resolution: SR-8037-NFPA 70-2018

Statement: The SR points directly to 690.15(D) to clarify the types of disconnecting means allowed fordisconnection of equipment. This SR also removes the requirement that all PV modules haveisolating devices as some modules are connected using terminals. The last sentence is removed asthis information is included in 690.15(D)(2). The informational note was deleted as unnecessary forthe application of this section.

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Public Comment No. 1530-NFPA 70-2018 [ Section No. 690.15 [Excluding any Sub-

Sections] ]

Isolating devices shall be provided to disconnect PV modules PV module source circuits , ac PV modules,fuses, dc-to-dc converters, inverters, and charge controllers from all conductors that are not solidlygrounded. Equipment disconnecting means and PV system disconnecting means shall meet therequirements of isolating devices.

Informational Note: The purpose of these isolating devices is the safe and convenient replacement orservice of specific PV system equipment without exposure to energized conductors.

Statement of Problem and Substantiation for Public Comment

Isolating devices should not be required between each module in a series circuit, but should be required for the circuit. Many PV modules historically were manufactured with hard-wired junction boxes and small low voltage modules are still manufactured this way. In addition, there may be future equipment designs, in particular for BIPV systems, that should not require isolating devices between each module.

Related Item

• FR-8307

Submitter Information Verification

Submitter Full Name: Rebekah Hren

Organization: IPPNC LLC

Street Address:

City:

State:

Zip:

Submittal Date: Wed Aug 29 10:27:34 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected but see related SR

Resolution: SR-8037-NFPA 70-2018

Statement: The SR points directly to 690.15(D) to clarify the types of disconnecting means allowed fordisconnection of equipment. This SR also removes the requirement that all PV modules haveisolating devices as some modules are connected using terminals. The last sentence is removed asthis information is included in 690.15(D)(2). The informational note was deleted as unnecessary forthe application of this section.

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Public Comment No. 1610-NFPA 70-2018 [ Section No. 690.15 [Excluding any Sub-

Sections] ]

Isolating devices shall be provided to disconnect conductors from series-connected PV modules, ac PVmodules, fuses, dc-to-dc converters, inverters, and charge controllers from all conductors that are not solidlygrounded. Equipment disconnecting means and PV system disconnecting means shall meet therequirements of be permitted to be used as isolating devices.

Informational Note: The purpose of these isolating devices is the safe and convenient replacement orservice of specific PV system equipment without exposure to energized conductors.

Statement of Problem and Substantiation for Public Comment

The first draft text seems to suggest that any PV module, regardless of size, voltage, etc. would require a mating connector meeting 690.33, or a disconnect, in all conductors connected to it. This essentially makes listed PV modules with terminal block junctions boxes and conduits or cables no longer an option in the Code. There are still many PV applications where other connection methods besides “plug and play” connectors and exposed single conductor wiring methods should continue to be allowed to connect PV modules together in series. Improving guarding and physical protection are examples of how other wiring methods may be desirable.Other standards are not aligned with the first draft text since one can still list modules to 1703 with terminals or leads. This needs to be corrected in the NEC 2020 version. We should not require mating connectors when other suitable connection methods are available. This change would continue to ensure that means of disconnect/isolation is provided in both circuit conductors leaving a ""string"" (jargon) of series-connected modules but would not specifically require mating connectors or disconnects between all modules. This aligns with previous Code versions and matches practices that have been in place for many years. The use of mating connectors will remain a popular method of installation but other options should be kept in the Code for manufacturers and installers to select the most appropriate connection and wiring methods for the specific PV application.A change has also been made to the language ""shall meet the requirements of isolating devices"" to ""shall be permitted to be used as isolating devices"" in an effort to add clarity to this allowance.

Related Item

• FR-8305

Submitter Information Verification

Submitter Full Name: Jason Fisher

Organization: Tesla Inc.

Affiliation: Solar Energy Industries Association (SEIA)

Street Address:

City:

State:

Zip:

Submittal Date: Wed Aug 29 13:14:39 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected but see related SR

Resolution: SR-8037-NFPA 70-2018

Statement: The SR points directly to 690.15(D) to clarify the types of disconnecting means allowed fordisconnection of equipment. This SR also removes the requirement that all PV modules haveisolating devices as some modules are connected using terminals. The last sentence is removed asthis information is included in 690.15(D)(2). The informational note was deleted as unnecessary forthe application of this section.

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Public Comment No. 1681-NFPA 70-2018 [ Section No. 690.31(A) ]

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(A) Wiring Systems.

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All raceway and cable wiring methods included in this Code, other wiring systems and fittings specificallylisted for use in PV arrays, and wiring as part of a listed system shall be permitted. Where wiring deviceswith integral enclosures are used, sufficient length of cable shall be provided to facilitate replacement.

Where PV source and output circuits operating at voltages greater than 30 volts are installed in readilyaccessible locations, circuit conductors shall be guarded or installed in Type MC cable or in raceway. Forambient temperatures exceeding 30°C (86°F), conductor ampacities shall be corrected in accordance with The ampacity of 105°C (221°F) and 125°C (257°F) conductors shall be permitted to be determined byTable 690.31(A)( a). The ampacity of b) For ambient temperatures exceeding 30º C, 105°C (221°F) and125°C (257°F) conductors conductor ampacities shall be permitted to be determined by adjusted inaccordance with Table 690.31(A)(b a ).

Table 690.31(A)(a) Correction Factors

Temperature Rating of Conductor

Ambient Temperature (°C) 105°C (221°F) 125°C (257°F) Ambient Temperature (°F)

30 1 1 86

31–35 0.97 0.97 87–95

36–40 0.93 0.95 96–104

41–45 0.89 0.92 105–113

46–50 0.86 0.89 114–122

51–55 0.82 0.86 123–131

56–60 0.77 0.83 132–140

61–65 0.73 0.79 141–149

66–70 0.68 0.76 150–158

71–75 0.63 0.73 159–167

76–80 0.58 0.69 168–176

81–85 0.52 0.65 177–185

86–90 0.45 0.61 186–194

91–95 0.37 0.56 195–203

96–100 0.26 0.51 204–212

101–105 — 0.46 213–221

106–110 — 0.4 222–230

111–115 — 0.32 231–239

116–120 — 0.23 240–248

Table 690.31(A)(b) Ampacities of Insulated Conductors Rated Up To and Including 2000 Volts, 105°CThrough 125°C (221°F Through 257°F), Not More Than Three Current-Carrying Conductors in Raceway,Cable, or Earth (Directly Buried), Based on Ambient Temperature of 30°C (86°F)

AWGTypes

PVC, CSPE, XLPE 105°C XLPE, EPDM 125°C

18 15 16

16 19 20

14 29 31

12 36 39

10 46 50

8 64 69

6 81 87

4 109 118

3 129 139

2 143 154

1 168 181

1/0 193 208

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AWGTypes

PVC, CSPE, XLPE 105°C XLPE, EPDM 125°C

2/0 229 247

3/0 263 284

4/0 301 325

Informational Note: See 110.14(C) for conductor temperature limitations due to terminationprovisions.

Statement of Problem and Substantiation for Public Comment

Changing the sentence structure and deleting the reference to PV source and output circuits would allow the use of Table 310.15(B)(2)(a) for 90ºC rated PV source and output conductors. Table 310.15(B)(2)(a) has appropriate adjustment factors for 90ºC rated conductors. Since 90ºC rated conductors are no longer included in new Table 690.31 (A)(a) it presents a problem to require the use of this table for all PV source and output circuit adjustment factors.

Related Item

• FR-8645

Submitter Information Verification

Submitter Full Name: Rebekah Hren

Organization: IPPNC LLC

Street Address:

City:

State:

Zip:

Submittal Date: Wed Aug 29 15:42:23 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected but see related SR

Resolution: SR-8050-NFPA 70-2018

Statement: Editorial changes to the second paragraph better explain the use of the two new tables. The cabletype CSPE is changed to CPE in Table 690.31(A)(b) to match the product standard. While PVC,CPE, XLPE, and EPDM are not included in general wiring in Chapter 3, Chapter 6 modifies Chapter3 and there are reasons that PV systems may need higher rated conductors in certain hightemperature environments like rooftops.

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Public Comment No. 1730-NFPA 70-2018 [ Section No. 690.31(A) ]

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(A) Wiring Systems.

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All raceway and cable wiring methods included in this Code, other wiring systems and fittings specificallylisted for use in PV arrays, and wiring as part of a listed system shall be permitted. Where wiring deviceswith integral enclosures are used, sufficient length of cable shall be provided to facilitate replacement.

Where PV source and output circuits operating at voltages greater than 30 volts are installed in readilyaccessible locations, circuit conductors shall be guarded or installed in Type MC cable or in raceway. Forambient temperatures exceeding 30°C (86°F), conductor ampacities shall be corrected in accordance withTable 690.31(A)(a). The ampacity of 105°C (221°F) and 125°C (257°F) conductors shall be permitted to bedetermined by Table 690.31(A)(b).

Table 690.31(A)(a) Correction Factors

Temperature Rating of Conductor

Ambient Temperature (°C) 105°C (221°F) 125°C (257°F) Ambient Temperature (°F)

30 1 1 86

31–35 0.97 0.97 87–95

36–40 0.93 0.95 96–104

41–45 0.89 0.92 105–113

46–50 0.86 0.89 114–122

51–55 0.82 0.86 123–131

56–60 0.77 0.83 132–140

61–65 0.73 0.79 141–149

66–70 0.68 0.76 150–158

71–75 0.63 0.73 159–167

76–80 0.58 0.69 168–176

81–85 0.52 0.65 177–185

86–90 0.45 0.61 186–194

91–95 0.37 0.56 195–203

96–100 0.26 0.51 204–212

101–105 — 0.46 213–221

106–110 — 0.4 222–230

111–115 — 0.32 231–239

116–120 — 0.23 240–248

Table 690.31(A)(b) Ampacities of Insulated Conductors Rated Up To and Including 2000 Volts, 105°CThrough 125°C (221°F Through 257°F), Not More Than Three Current-Carrying Conductors in Raceway,Cable, or Earth (Directly Buried), Based on Ambient Temperature of 30°C (86°F)

AWGTypes

PVC,

CSPE

CPE , XLPE 105°C XLPE, EPDM 125°C

18 15 16

16 19 20

14 29 31

12 36 39

10 46 50

8 64 69

6 81 87

4 109 118

3 129 139

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CPE , XLPE 105°C XLPE, EPDM 125°C

2 143 154

1 168 181

1/0 193 208

2/0 229 247

3/0 263 284

4/0 301 325

Informational Note: See 110.14(C) for conductor temperature limitations due to terminationprovisions.

Statement of Problem and Substantiation for Public Comment

The column heading is incorrect. “CSPE” should be changed to “CPE” US safety standards address type CPE cable, which is the correct abbreviation for Chlorinated Polyethylene.

Related Item

• First Revision No. 8645-NFPA 70-2018

Submitter Information Verification

Submitter Full Name: Timothy Zgonena

Organization: UL LLC

Street Address:

City:

State:

Zip:

Submittal Date: Wed Aug 29 18:49:14 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected but see related SR

Resolution: SR-8050-NFPA 70-2018

Statement: Editorial changes to the second paragraph better explain the use of the two new tables. The cabletype CSPE is changed to CPE in Table 690.31(A)(b) to match the product standard. While PVC,CPE, XLPE, and EPDM are not included in general wiring in Chapter 3, Chapter 6 modifies Chapter3 and there are reasons that PV systems may need higher rated conductors in certain hightemperature environments like rooftops.

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Public Comment No. 1750-NFPA 70-2018 [ Section No. 690.31(A) ]

(A) Wiring Systems.

All raceway and cable wiring methods included in this Code, other wiring systems and fittings specificallylisted for use in PV arrays, and wiring as part of a listed system shall be permitted. Where wiring deviceswith integral enclosures are used, sufficient length of cable shall be provided to facilitate replacement.

Where PV source and output circuits operating at voltages greater than 30 volts are installed in readilyaccessible locations, circuit conductors shall be guarded or installed in Type MC cable or in raceway. Forambient temperatures exceeding 30°C (86°F), conductor ampacities shall be corrected in accordance withTable 690.31(A)(a) . The ampacity of 105°C (221°F) and 125°C (257°F) conductors shall be permitted to bedetermined by Table 690.31(A)(b).

Table 690.31(A)(a) Correction Factors

Temperature Rating of Conductor Ambient Temperature (°C) 105°C (221°F) 125°C (257°F) AmbientTemperature(°F) 30 1 1 86 31–35 0.97 0.97 87–95 36–40 0.93 0.95 96–104 41–45 0.89 0.92 105–113 46–50 0.86 0.89 114–12— 0.46 213–221 106–110 — 0.4 222–230 111–115 — 0.32 231–239 116–120 — 0.23 240–248

Table 690.31(A)(b) Ampacities of Insulated Conductors Rated Up To and Including 2000 Volts, 105°CThrough 125°C (221°F Through 257°F), Not More Than Three Current-Carrying Conductors in Raceway,Cable, or Earth (Directly Buried), Based on Ambient Temperature of 30°C (86°F)

AWG Types PVC, CSPE, XLPE 105°C XLPE, EPDM125°C 18 15 16 16 19 20 14 29 31 12 36 39 10 46 50 8 64 69 6 81 87 4 109 118 3 129 139 2 143 154 1 168 181 1/0/0 229 247 3/0 263 284 4/0 301 325

Informational Note: See 110.14(C) for conductor temperature limitations due to terminationprovisions.

Statement of Problem and Substantiation for Public Comment

The proposed ambient temperature correction tables have numerous issues. First, the references to XLPE, EPDM, etc. are not NEC types. Those are insulation compound types, and are inappropriate for use in the NEC. Second, the conductors rated at higher than 90C are dry location ratings. When installed in wet locations - which every raceway or cable tray installed outside would be - these ratings have no meaning, and the tables do not give any indication of that to the Code user. Additionally, there is no substantiation as to where those correction factors came from or how they were derived.

Related Item

• FR 8645

Submitter Information Verification

Submitter Full Name: Christel Hunter

Organization: Cerro Wire

Street Address:

City:

State:

Zip:

Submittal Date: Wed Aug 29 20:13:53 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected

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Resolution: The public comment raises important issues, some of which are being addressed in SR-8050.Because a conductor is subjected to conditions above 90C in an outdoor location does not prohibita rating. A 110C location can be damp, but not wet. The test standards are there and can be used.The temperature correction factors are based on the same equations that are used to derive theArticle 310 factors.

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Public Comment No. 612-NFPA 70-2018 [ Section No. 690.31(A) ]

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(A) Wiring Systems.

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All raceway and cable wiring methods included in this Code, other wiring systems and fittings specificallylisted for use in PV arrays, and wiring as part of a listed system shall be permitted. Where wiring deviceswith integral enclosures are used, sufficient length of cable shall be provided to facilitate replacement.

Where PV source and output circuits operating at voltages greater than 30 volts are installed in readilyaccessible locations, circuit conductors shall be guarded or installed in Type MC cable or in raceway. Forambient temperatures exceeding 30°C (86°F), conductor ampacities of 105°C (221°F) and 125°C (257°F)conductors shall be corrected in accordance with Table 690.31(A)(a). The ampacity of 105°C (221°F) and125°C (257°F) conductors shall be permitted to be determined by Table 690.31(A)(b).

Table 690.31(A)(a) Correction Factors

Temperature Rating of Conductor

Ambient Temperature (°C) 105°C (221°F) 125°C (257°F) Ambient Temperature (°F)

30 1 1 86

31–35 0.97 0.97 87–95

36–40 0.93 0.95 96–104

41–45 0.89 0.92 105–113

46–50 0.86 0.89 114–122

51–55 0.82 0.86 123–131

56–60 0.77 0.83 132–140

61–65 0.73 0.79 141–149

66–70 0.68 0.76 150–158

71–75 0.63 0.73 159–167

76–80 0.58 0.69 168–176

81–85 0.52 0.65 177–185

86–90 0.45 0.61 186–194

91–95 0.37 0.56 195–203

96–100 0.26 0.51 204–212

101–105 — 0.46 213–221

106–110 — 0.4 222–230

111–115 — 0.32 231–239

116–120 — 0.23 240–248

Table 690.31(A)(b) Ampacities of Insulated Conductors Rated Up To and Including 2000 Volts, 105°CThrough 125°C (221°F Through 257°F), Not More Than Three Current-Carrying Conductors in Raceway,Cable, or Earth (Directly Buried), Based on Ambient Temperature of 30°C (86°F)

AWGTypes

PVC, CSPE, XLPE 105°C XLPE, EPDM 125°C

18 15 16

16 19 20

14 29 31

12 36 39

10 46 50

8 64 69

6 81 87

4 109 118

3 129 139

2 143 154

1 168 181

1/0 193 208

2/0 229 247

3/0 263 284

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AWGTypes

PVC, CSPE, XLPE 105°C XLPE, EPDM 125°C

4/0 301 325

Informational Note: See 110.14(C) for conductor temperature limitations due to terminationprovisions.

Statement of Problem and Substantiation for Public Comment

Added text to specify that only 105°C (221°F) and 125°C (257°F) conductors are covered by the table.

Related Item

• First Revision No. 8645-NFPA 70-2018

Submitter Information Verification

Submitter Full Name: MARVIN HAMON

Organization: HAMON ENGINEERING INC

Street Address:

City:

State:

Zip:

Submittal Date: Mon Aug 13 23:34:30 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected but see related SR

Resolution: SR-8050-NFPA 70-2018

Statement: Editorial changes to the second paragraph better explain the use of the two new tables. The cabletype CSPE is changed to CPE in Table 690.31(A)(b) to match the product standard. While PVC,CPE, XLPE, and EPDM are not included in general wiring in Chapter 3, Chapter 6 modifies Chapter3 and there are reasons that PV systems may need higher rated conductors in certain hightemperature environments like rooftops.

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Public Comment No. 1785-NFPA 70-2018 [ Section No. 690.31(B)(1) ]

(1) Identification.

PV system dc circuit conductors shall be identified at all termination, connection, and splice points by colorcoding, marking tape, tagging, or other approved means. Circuits relying Conductors relying on other thancolor coding for polarity identification shall be identified by an approved permanent marking means such aslabeling, sleeving, or shrink-tubing that is suitable for the conductor size. The permanent marking means fornonsolidly grounded positive conductors shall include imprinted plus signs (+) or the word POSITIVE orPOS durably marked on insulation of a color other than green, white, or gray. The permanent markingmeans for nonsolidly grounded negative conductors shall include imprinted negative signs (−) or the wordNEGATIVE or NEG durably marked on insulation of a color other than green, white, gray, or red. Onlysolidly grounded PV system dc circuit conductors shall be marked in accordance with 200.6.

Exception: Where the identification of the conductors is evident by spacing or arrangement, furtheridentification shall not be required.

Statement of Problem and Substantiation for Public Comment

Conductors is a more accurate term to use (instead of circuits) at start of second sentence. Also adding "dc" in two places to align with the definition for the circuits this requirement covers.

Related Item

• FR-8648

Submitter Information Verification

Submitter Full Name: Jason Fisher

Organization: Tesla Inc.

Affiliation: Solar Energy Industries Association (SEIA)

Street Address:

City:

State:

Zip:

Submittal Date: Wed Aug 29 23:32:48 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected but see related SR

Resolution: SR-8055-NFPA 70-2018

Statement: Conductors is a more accurate term to use instead of circuits at the start of second sentence. Therevision also adds "dc" in two places to align with the definition for the circuits this requirementcovers.

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Public Comment No. 527-NFPA 70-2018 [ Section No. 690.31(B)(1) ]

(1) Identification.

PV system circuit conductors shall be identified at all termination, connection, and splice points by colorcoding, marking tape, tagging, or other approved means. Circuits relying on other than color coding forpolarity identification shall be identified by an approved permanent marking means such as labeling,sleeving, or shrink-tubing that is suitable for the conductor size. The permanent marking means fornonsolidly grounded positive conductors shall include imprinted plus signs (+) or the word POSITIVE orPOS durably marked on insulation of a color other than green, white, black or gray. The permanentmarking means for nonsolidly grounded negative conductors shall include imprinted negative signs (−) orthe word NEGATIVE or NEG durably marked on insulation of a color other than green, white, gray, or red.Only solidly grounded PV system circuit conductors shall be marked in accordance with 200.6.

Exception: Where the identification of the conductors is evident by spacing or arrangement, furtheridentification shall not be required.

Statement of Problem and Substantiation for Public Comment

Most installers carry black wire, but that color seems to be omitted. Unless we intend that they now carry all colors of wire? We should add the color black as that is commonly used.

Related Item

• First Draft Report

Submitter Information Verification

Submitter Full Name: Todd Fries

Organization: HellermannTyton

Street Address:

City:

State:

Zip:

Submittal Date: Fri Aug 10 11:49:03 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected

Resolution: The PC suggests adding “black” to the list of prohibited colors. The submitter's statementsuggests that they wanted black to be allowed which the current language permits.

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Public Comment No. 1764-NFPA 70-2018 [ Section No. 690.31(B) [Excluding any Sub-

Sections] ]

PV system dc circuits and Class 1 control circuits remote control, signaling, or power-limited circuits of aPV system shall be permitted to occupy the same equipment wiring enclosure, cable, or raceway. PVsystem dc circuits shall not occupy the same equipment wiring enclosure, cable, or raceway. as other non-PV systems, or inverter output circuits, unless the PV system dc circuits and Class 1 control circuits areseparated from other circuits by a cable jacket, barrier, or partition. PV system circuit conductors shall beidentified and grouped as required by 690.31(B)(1) through (B)(2).

Statement of Problem and Substantiation for Public Comment

The second use of ""and Class 1 control circuits"" in the first sentence should be removed. Sub-section 690.31(B) should only apply to PV system dc circuits and their relationship to other circuits, not to any co-location of Class 1 circuits with other circuits such as inverter output circuits. The installation requirements for these Class 1 circuits, where used, are best addressed through the application of other existing articles in the NEC such as 725. Class 1 circuits can already be combined with other circuits if existing NEC requirements applicable to the circuits are met. There should be no further restrictions added if used in these applications. With the expansion of rapid shutdown requirements to array equipment, reasonable options for the installation of control and signal wiring must be provided to users of the Code. Additional allowances, other than partitions, should be provided to continue to prevent the inadvertant connection of PV circuits to other circuits. It is common for flexible non-conductive barriers to be used when listing inverters for instance. By including language to allow for barriers specifically evaluated for this purpose the Committee will ensure that circuits remain separated and cleary identified as distinct from each other, while providing for continued inovation by manufacturers to meet this requirement.

Related Item

• FR-8647

Submitter Information Verification

Submitter Full Name: Jason Fisher

Organization: Tesla Inc.

Affiliation: Solar Energy Industries Association (SEIA)

Street Address:

City:

State:

Zip:

Submittal Date: Wed Aug 29 22:17:45 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected but see related SR

Resolution: SR-8053-NFPA 70-2018

Statement: The past several code cycles have prohibited PV system dc circuits from occupying the same wiringmethod as inverter output circuits without the use of partitions for separation. An option was addedfor barriers, in addition to partitions. An exception was added for other multiconductor cableassemblies, listed for the application, in the same wiring method. A barrier is a more generic termthan partition and would allow approved methods to keep these circuits from direct contact.

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Public Comment No. 2076-NFPA 70-2018 [ Section No. 690.31(B) [Excluding any Sub-

Sections] ]

PV system dc circuits and Class 1 control circuits of a PV system shall be permitted to occupy the sameequipment wiring enclosure, cable, or raceway. PV system dc circuits shall not occupy the same equipmentwiring enclosure, cable, or raceway. as other non-PV systems, or inverter output circuits, unless the PVsystem dc circuits and Class 1 control circuits are separated from other circuits by a partition. PV systemcircuit conductors shall be identified and grouped as required by 690.31(B)(1) through (B)(2).

Statement of Problem and Substantiation for Public Comment

This comment is submitted on behalf of Isaac Opalinsky, alternate member of CMP4:

The panel has not adequately addressed multiple PIs with this first revision. The statement that PV system DC and inverter output AC conductors should not be allowed to come into contact with one another needs further substantiation. As noted in the PIs, this prohibition disallows simple and safe wiring methods for a wide variety of small inverters.

Related Item

• FR-8647

Submitter Information Verification

Submitter Full Name: Christopher Fox

Organization: SunPower

Street Address:

City:

State:

Zip:

Submittal Date: Thu Aug 30 16:25:45 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected but see related SR

Resolution: SR-8053-NFPA 70-2018

Statement: The past several code cycles have prohibited PV system dc circuits from occupying the same wiringmethod as inverter output circuits without the use of partitions for separation. An option was addedfor barriers, in addition to partitions. An exception was added for other multiconductor cableassemblies, listed for the application, in the same wiring method. A barrier is a more generic termthan partition and would allow approved methods to keep these circuits from direct contact.

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Public Comment No. 1897-NFPA 70-2018 [ Section No. 690.31(C)(1) ]

(1) Single-Conductor Cable.

Single-conductor PV wire or cable, and single-conductor Type USE-2/RHH/RHW-2 identified as sunlightresistant shall be permitted in exposed outdoor locations in PV system dc circuits within the PV array.Exposed cables shall be supported and secured at intervals not to exceed 600 mm (24 in.) by cable ties,straps, hangers, or similar fittings listed and identified for securement and support in outdoor locations. PVwire or cable is permitted in all locations where RHW-2 is permitted.

Statement of Problem and Substantiation for Public Comment

Type USE-2/RHH/RHW-2 is a readily available commercial construction. Requiring this construction will ensure that AA-8000 series aluminum alloy conductors are used when the conductor type is aluminum. The revised language will also ensure that the insulation has been subjected to a 720-hour weather resistance test, which is equal to the sunlight resistance test exposure performed on PV wire. The committee statement that accompanied FR 8650 seems to support the need for the appropriate level of sunlight resistance. Conductors marked only with USE are only required to have a 300-hour weather resistance test, which is insufficient for PV applications.

Related Item

• PI 1122

Submitter Information Verification

Submitter Full Name: Christel Hunter

Organization: Cerro Wire

Street Address:

City:

State:

Zip:

Submittal Date: Thu Aug 30 11:29:59 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected but see related SR

Resolution: SR-8056-NFPA 70-2018

Statement: This SR changes the first "and" to an "or" to make it clear that either cable is acceptable. The SRalso requires Type USE-2 to have Type RHW-2 and sunlight resistant markings as well. Thisrequires that cables with these markings pass the 720-hour weather resistance test. No furtheridentification is necessary that could further complicate a field inspection. Type RHW-2 is necessarywhere conductors enter a building so requiring this rating simplifies the job of enforcement as they donot need to worry about whether the cable enters the building at any location. AHJs that do not seethe USE-2/RHH/RHW-2 marking may reject a perfectly good cable. Simply requiring these pertinentmarkings addresses the concern related to the need for a 720-hour weather resistance test andrequires that AA-8000 alloy be used for aluminum cables. The word “is” is changed to “shall be” inthe last sentence to comply with the style manual.

The new exception clarifies that the engineered design may supersede the requirements in Article690.

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Public Comment No. 1898-NFPA 70-2018 [ Section No. 690.31(C)(1) ]

(1) Single-Conductor Cable.

Single-conductor PV wire or cable, and single-conductor Type USE-2 identified marked as sunlightresistant shall be permitted in exposed outdoor locations in PV system dc circuits within the PV array.Exposed cables shall be supported and secured at intervals not to exceed 600 mm (24 in.) by cable ties,straps, hangers, or similar fittings listed and identified for securement and support in outdoor locations. PVwire or cable is permitted in all locations where RHW-2 is permitted.

Statement of Problem and Substantiation for Public Comment

Changing "identified" to "marked" will require the USE single conductors to comply with the same 720 hour weather resistance test that PV wire complies with. Currently, by only requiring USE to be "identified" as sunlight resistance, per the definition of identified in Article 100, the conductor does not have to be surface marked as sunlight resistant, and therefore does not have to comply with the requirement in UL 854 30.1 that requires the 720 hour test. Instead, USE that is not surface marked as sunlight resistant only undergoes a 300 hour weather resistant test, which is insufficient for PV applications.

Related Item

• PI 1122

Submitter Information Verification

Submitter Full Name: Christel Hunter

Organization: Cerro Wire

Street Address:

City:

State:

Zip:

Submittal Date: Thu Aug 30 11:37:10 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected but see related SR

Resolution: SR-8056-NFPA 70-2018

Statement: This SR changes the first "and" to an "or" to make it clear that either cable is acceptable. The SRalso requires Type USE-2 to have Type RHW-2 and sunlight resistant markings as well. Thisrequires that cables with these markings pass the 720-hour weather resistance test. No furtheridentification is necessary that could further complicate a field inspection. Type RHW-2 is necessarywhere conductors enter a building so requiring this rating simplifies the job of enforcement as they donot need to worry about whether the cable enters the building at any location. AHJs that do not seethe USE-2/RHH/RHW-2 marking may reject a perfectly good cable. Simply requiring these pertinentmarkings addresses the concern related to the need for a 720-hour weather resistance test andrequires that AA-8000 alloy be used for aluminum cables. The word “is” is changed to “shall be” inthe last sentence to comply with the style manual.

The new exception clarifies that the engineered design may supersede the requirements in Article690.

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Public Comment No. 1929-NFPA 70-2018 [ Section No. 690.31(C)(1) ]

(1) Single-Conductor Cable.

Single-conductor PV wire or cable, and single-conductor marked both Type USE-2 and Type RHW-2identified as sunlight resistant shall be permitted in exposed outdoor locations in PV system dc circuitswithin the PV array. Exposed cables shall be supported and secured at intervals not to exceed 600 mm (24in.) by cable ties, straps, hangers, or similar fittings listed and identified for securement and support inoutdoor locations. PV wire or cable is permitted in all locations where RHW-2 is permitted.

Statement of Problem and Substantiation for Public Comment

The UL standard needs to be fixed, but until it does get fixed, the proper rating for single conductor Type USE-2 is that it is also rated Type RHW-2 to get the 720 hour sunlight test. The term "sunlight resistant" should cover it, but apparently it does not. In my experience, all USE-2 is also rated RHW-2. Type RHW-2 is also beneficial as it allows the conductor to be run into a building, without transition as it is a building wire whereas USE-2 alone is not rated as building wire.

Christel Hunter of Cerro Wire is the one who pointed this out and she may not have time to enter her own PC on the same subject.

Related Item

Submitter Information Verification

Submitter Full Name: William Brooks

Organization: Brooks Engineering

Street Address:

City:

State:

Zip:

Submittal Date: Thu Aug 30 12:33:44 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected but see related SR

Resolution: SR-8056-NFPA 70-2018

Statement: This SR changes the first "and" to an "or" to make it clear that either cable is acceptable. The SRalso requires Type USE-2 to have Type RHW-2 and sunlight resistant markings as well. Thisrequires that cables with these markings pass the 720-hour weather resistance test. No furtheridentification is necessary that could further complicate a field inspection. Type RHW-2 is necessarywhere conductors enter a building so requiring this rating simplifies the job of enforcement as they donot need to worry about whether the cable enters the building at any location. AHJs that do not seethe USE-2/RHH/RHW-2 marking may reject a perfectly good cable. Simply requiring these pertinentmarkings addresses the concern related to the need for a 720-hour weather resistance test andrequires that AA-8000 alloy be used for aluminum cables. The word “is” is changed to “shall be” inthe last sentence to comply with the style manual.

The new exception clarifies that the engineered design may supersede the requirements in Article690.

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Public Comment No. 2035-NFPA 70-2018 [ Section No. 690.31(C)(2) ]

(2) Cable Tray.

PV system dc circuits using single-conductor PV wire or cable of all sizes and Inverter Output Circuitsusing Distributed Generation cable of all sizes , with or without a cable tray rating, shall be permitted incable trays installed in outdoor locations, provided that the cables are supported at intervals not to exceed300 mm (12 in.) and secured at intervals not to exceed 1.4 m (41⁄2 ft).

Informational Note: PV wire and cable and DG Cable have a nonstandard outer diameter. Table 1 ofChapter 9 contains the allowable percent of cross section of conduit and tubing for conductors andcables.

Statement of Problem and Substantiation for Public Comment

Distributed Generation cable is equivalent in environmental rating and use as PV Wire. The addition of this cable to this section recognizes that other system architectures such as microinverter systems and AC Module Systems will have DG cable in Inverter Output Circuits in the same location as PV Wire in PV System DC Circuits.

Related Item

• FR-8940

Submitter Information Verification

Submitter Full Name: Christopher Fox

Organization: SunPower

Street Address:

City:

State:

Zip:

Submittal Date: Thu Aug 30 15:21:25 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected but see related SR

Resolution: SR-8060-NFPA 70-2018

Statement: This SR adds DG cable as another cable allowed in cable tray without size restrictions. Theinformational note is also updated to include DG cable. The opening clause limiting to PV systemdc circuits is unnecessary as this section is addressing construction of the cable, not the circuit.Conductor separation is covered in 690.31(A).

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Public Comment No. 1995-NFPA 70-2018 [ New Section after 690.31(C)(3) ]

Flexible Harnesses and Cables.

Flexible wiring harnesses and cables in PV systems shall be installed in accordance with the instructionsincluded with the listed or labeled equipment. Where not included as part of a listed system, and where nototherwise covered in the Code specified in their instructions, they shall be installed in accordance with thefollowing:

(1) Shall closely follow the surface(s) to which they are adjacent

(2) Shall be protected from physical damage where necessary

(3) Shall be secured or supported at intervals not exceeding 1.8 m (6 ft) and within 300 mm (12 in.) ofevery connector. Sections of cords or cables protected from physical protection by raceways shall not berequired to be secured within the raceway

(4) Where readily accessible, cord or cables shall be guarded or protected by a raceway

Exception: Larger support spacings are permitted as defined elsewhere in this Code for the specific wiringmethod.

Statement of Problem and Substantiation for Public Comment

We support moving this section from 690.6 to 690.31. Text below is from substantiation written and submitted by SEIA in collaboration:

Changes to this section are recommended in concert with changes proposed to the First Draft language in 690.6 FR-8152. We propose to move the new language in 690.6(C) on flexible cords and cables for use in AC PV systems to 690.31(C)(3) Multiconductor Cable to Part IV – Wiring Methods. This is a better location for these requirements. There is nothing unique about the use of these wiring methods in AC PV systems that distinguishes it from a similar use in other circuits in a PV system. The need to provide specific requirements in the numbered list for these wiring methods is because some of the cable types and wiring methods used in these new systems may not be covered in Chapter 3 or 4 of this Code. Additionally, as members of CMP4 have pointed out in their ballot comments, the current language in 690.6(C)(1) is problematic because it could be interpreted to require common cable types (NM and UF) to be put in a raceway inside a structure. We have made an attempt to correct this in this new language.

Related Public Comments for This Document

Related Comment Relationship

Public Comment No. 1985-NFPA 70-2018 [Section No. 690.6] language originally in 690.6 moved here

Related Item

• FR-8939

Submitter Information Verification

Submitter Full Name: Christopher Fox

Organization: SunPower

Street Address:

City:

State:

Zip:

Submittal Date: Thu Aug 30 14:10:20 EDT 2018

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Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected but see related SR

Resolution: SR-8062-NFPA 70-2018

Statement: This SR completely revises and reorganize this section and incorporates the FR language onmulticonductor cables from 690.6 into this section. These cables should not be restricted only to acmodule systems but should be permitted to be used throughout PV systems based on their listings.This SR specifically permits cables marked sunlight resistant to be used outdoors and cablesmarked direct burial to be direct buried. The list of items is edited for readability and to match itemstructure. The secure requirement for cables entering mating connectors or enclosures has beenincreased from 12 inches to 24 inches to allow proper bending of cables.

The fact that DG cable has not yet been approved as an ANSI standard does not mean that it willnot be approved shortly or that DG cable should be held out of the 2020 NEC. There are eightmanufacturers of DG cable from a single NRTL. Multiconductor cables on or in buildings that are notlocated on rooftops must be in raceways.

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Public Comment No. 1786-NFPA 70-2018 [ Section No. 690.31(C)(3) ]

(3) Multiconductor Cable.

Distributed generation (DG) cable and other jacketed multiconductor cable assemblies used in accordancewith their listings shall be permitted for use in PV systems in outdoor locations . The cable shall besecured where listed or identified as sunlight resistant.

Flexible wiring harnesses and cables in PV systems shall be installed in accordance with the instructionsincluded with the listed or labeled equipment. Where not included as part of a listed system, and where nototherwise covered in the Code, they shall be installed in accordance with the following:

(1) Shall closely follow the surface(s) to which they are adjacent

(2) Shall be protected from physical damage where necessary

(3) Shall be secured or supported at intervals not exceeding 1.8 m (6 ft) and within 300 mm (12 in .) ofevery connector. Sections of cords or cables in raceways shall not be required to be secured within theraceway

(4) Where readily accessible, cord or cables shall be guarded or protected by a raceway.

Statement of Problem and Substantiation for Public Comment

Changes to this section are recommended in concert with changes proposed to the First Draft language in 690.6 FR-8152. We propose to move the new language in 690.6(C) on flexible cords and cables for use in AC PV systems to 690.31(C)(3) Multiconductor Cable to Part IV – Wiring Methods. This is a better location for these requirements. There is nothing unique about the use of these wiring methods in AC PV systems that distinguishes it from a similar use in other circuits in a PV system. The need to provide specific requirements in the numbered list for these wiring methods is because some of the cable types and wiring methods used in these new systems may not be covered in Chapter 3 or 4 of this Code. Additionally, as members of CMP4 have pointed out in their ballot comments, the current language in 690.6(C)(1) is problematic because it could be interpreted to require common cable types (NM and UF) to be put in a raceway inside a structure. We have made an attempt to correct this in this new language.

Related Public Comments for This Document

Related Comment Relationship

Public Comment No. 1568-NFPA 70-2018 [Section No.690.6(C)]

Source of new cable language(relocated)

Related Item

• FR-8940

Submitter Information Verification

Submitter Full Name: Jason Fisher

Organization: Tesla Inc.

Affiliation: Solar Energy Industries Association (SEIA)

Street Address:

City:

State:

Zip:

Submittal Date: Wed Aug 29 23:36:45 EDT 2018

Committee: NEC-P04

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Committee Statement

CommitteeAction:

Rejected but see related SR

Resolution: SR-8062-NFPA 70-2018

Statement: This SR completely revises and reorganize this section and incorporates the FR language onmulticonductor cables from 690.6 into this section. These cables should not be restricted only to acmodule systems but should be permitted to be used throughout PV systems based on their listings.This SR specifically permits cables marked sunlight resistant to be used outdoors and cablesmarked direct burial to be direct buried. The list of items is edited for readability and to match itemstructure. The secure requirement for cables entering mating connectors or enclosures has beenincreased from 12 inches to 24 inches to allow proper bending of cables.

The fact that DG cable has not yet been approved as an ANSI standard does not mean that it willnot be approved shortly or that DG cable should be held out of the 2020 NEC. There are eightmanufacturers of DG cable from a single NRTL. Multiconductor cables on or in buildings that are notlocated on rooftops must be in raceways.

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Public Comment No. 1904-NFPA 70-2018 [ Section No. 690.31(C)(3) ]

(3) Multiconductor Cable.

Distributed generation (DG) cable and other jacketed multiconductor cable assemblies used in accordancewith their listings

J acketed multiconductor cable assemblies listed and identified for wet locations and sunlight resistanceshall be permitted in outdoor locations. The cable shall be secured at intervals not exceeding 1.8 m (6 ft).

Statement of Problem and Substantiation for Public Comment

The proposed standard for DG (distributed generation) cable failed ballot. It will not be recognized as an ANSI standard, and DG cable should not be added to the NEC until - and if - the standard achieves consensus. In the interim, there are other Listed multiconductor cables that are suitable for the application that are evaluated to ANSI recognized product safety standards. Additionally, it is important that these cables are specifically suitable for use in wet locations and sunlight resistant.

Related Item

• PI 3804

Submitter Information Verification

Submitter Full Name: Christel Hunter

Organization: Cerro Wire

Street Address:

City:

State:

Zip:

Submittal Date: Thu Aug 30 11:46:20 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected but see related SR

Resolution: SR-8062-NFPA 70-2018

Statement: This SR completely revises and reorganize this section and incorporates the FR language onmulticonductor cables from 690.6 into this section. These cables should not be restricted only to acmodule systems but should be permitted to be used throughout PV systems based on their listings.This SR specifically permits cables marked sunlight resistant to be used outdoors and cablesmarked direct burial to be direct buried. The list of items is edited for readability and to match itemstructure. The secure requirement for cables entering mating connectors or enclosures has beenincreased from 12 inches to 24 inches to allow proper bending of cables.

The fact that DG cable has not yet been approved as an ANSI standard does not mean that it willnot be approved shortly or that DG cable should be held out of the 2020 NEC. There are eightmanufacturers of DG cable from a single NRTL. Multiconductor cables on or in buildings that are notlocated on rooftops must be in raceways.

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Public Comment No. 2105-NFPA 70-2018 [ Section No. 690.31(C)(5) ]

(5) Flexible, Fine-Stranded Cables.

Flexible, fine-stranded cables shall be terminated only with terminals, lugs, devices, or connectors inaccordance with 110.14.

Statement of Problem and Substantiation for Public Comment

The section on fine stranded wire was part of a PI to remove it on the grounds that it has been in the NEC for many code cycles, it is a well-known issue, and it is teaching the NEC. Some on the panel still believe there is value in teaching the Code here. There is also the insistence that language related to qualified persons be maintained in 690.4. Qualified people should know the requirements of 110.14 so this section needs to be deleted during the comment period. In fact, an AHJ could use this case to prove that an installer is unqualified if they do not understand this basic requirement.

Related Item

Submitter Information Verification

Submitter Full Name: William Brooks

Organization: Brooks Engineering

Street Address:

City:

State:

Zip:

Submittal Date: Thu Aug 30 18:04:21 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected

Resolution: Using improper terminations in PV systems is a common problem reported by AHJs and warrantsa reference to the code section that addresses termination of these cables.

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Public Comment No. 1193-NFPA 70-2018 [ Section No. 690.31(D) ]

(D) Direct-Current Circuits on or in a Building.

PV system dc circuits inside buildings greater than 30 volts and 70 watts shall be contained in metalraceways, in Type MC metal-clad cable that complies with 250.118(10), or in metal enclosures. Wiringmethods on or in a building shall comply with the additional installation requirements in 690.31(G)(1)through (4).

Exception: PV hazard control systems installed in accordance with 690.12(B)(2)(1) shall be providedwith or listed for use with nonmetallic enclosure(s), nonmetallic raceway(s), and cables of a permittedtype other than Type MC metal-clad cable(s), at the point of penetration of the surface of the building tothe PV hazard control actuator.

(1) Flexible Wiring Methods.

Where flexible metal conduit (FMC) smaller than metric designator 21 (trade size 3⁄4) or Type MC cablesmaller than 25 mm (1 in.) in diameter containing PV power circuit conductors is installed across ceilingsor floor joists, the raceway or cable shall be protected by substantial guard strips that are at least as highas the raceway or cable. Where run exposed, other than within 1.8 m (6 ft) of their connection toequipment, these wiring methods shall closely follow the building surface or be protected from physicaldamage by an approved means.

(2) Marking and Labeling Required.

Unless located and arranged so the purpose is evident, the following wiring methods and enclosures thatcontain PV system dc circuit conductors shall be marked with the wording PHOTOVOLTAIC POWERSOURCE or SOLAR PV DC CIRCUIT by means of permanently affixed labels or other approvedpermanent marking:

(1) Exposed raceways, cable trays, and other wiring methods

(2) Covers or enclosures of pull boxes and junction boxes

(3) Conduit bodies in which any of the available conduit openings are unused

The labels or markings shall be visible after installation. All letters shall be capitalized and shall be aminimum height of 9.5 mm (3⁄8 in.) in white on a red background. Labels shall appear on every section ofthe wiring system that is separated by enclosures, walls, partitions, ceilings, or floors. Spacing betweenlabels or markings, or between a label and a marking, shall not be more than 3 m (10 ft). Labels requiredby this section shall be suitable for the environment where they are installed.

Additional Proposed Changes

File Name Description Approved

CN_234.pdf 70_CN234

Statement of Problem and Substantiation for Public Comment

NOTE: This Public Comment appeared as CC Note No. 234 in the First Draft Report on First Revision No. 8692.

The Correlating Committee directs the panel to consider revising the structure of the first sentence for clarity. This action will be considered as apublic comment.

Related Item

• First Revision No. 8692

Submitter Information Verification

Submitter Full Name: CC on NEC-AAC

Organization: NEC Correlating Committee

Street Address:

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City:

State:

Zip:

Submittal Date: Fri Aug 24 10:38:41 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected but see related SR

Resolution: SR-8073-NFPA 70-2018

Statement: The words, “inside buildings” is relocated to lead the first sentence for clarity. The 70 watt thresholdis changed to 8 amps to better align with action taken in 690.42 and related standards for ground-fault detection. The exception is edited to clarify that the alternative wiring methods are permittedrather than required and moved above the requirements of (D)(1) through (4) so that it is clear thatPV hazard control systems are not exempt from (D)(1) through (4).

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Correlating Committee Note No. 234-NFPA 70-2018 [ Section No. 690.31(G) ]

Submitter Information Verification

Submitter Full Name: Sarah CaldwellCommittee: Submittal Date: Fri May 11 15:44:33 EDT 2018

Committee Statement and Meeting Notes

Committee Statement:

The Correlating Committee directs the panel to consider revising the structure of the first sentence for clarity. This action will be considered as a public comment.

First Revision No. 8692-NFPA 70-2018 [Section No. 690.31(G)]

Ballot Results

This item has passed ballot

12 Eligible Voters0 Not Returned

12 Affirmative All0 Affirmative with Comments0 Negative with Comments0 Abstention

Affirmative AllBrunssen, James E.

Dressman, Kevin L.

Hickman, Palmer L.

Hittinger, David L.

Holub, Richard A.

Johnston, Michael J.

Kovacik, John R.

Manche, Alan

McDaniel, Roger D.

Pierce, James F.

Saporita, Vincent J.

Williams, David A.

Page 1 of 1National Fire Protection Association Report

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Public Comment No. 1690-NFPA 70-2018 [ Section No. 690.31(D)(2) ]

(2) Marking and Labeling Required.

Unless located and arranged so the purpose is evident, the following wiring methods and enclosures thatcontain PV system dc circuit conductors shall be marked with the wording DANGER: PHOTOVOLTAICPOWER SOURCE or SOLAR PV DC CIRCUIT by means of permanently affixed labels or other approvedpermanent marking:

(1) Exposed raceways, cable trays, and other wiring methods

(2) Covers or enclosures of pull boxes and junction boxes

(3) Conduit bodies in which any of the available conduit openings are unused

The labels or markings shall be visible after installation. All letters shall be capitalized and shall be aminimum height of 9.5 mm (3⁄8 in.) in white on a red background. Labels shall appear on every section of thewiring system that is separated by enclosures, walls, partitions, ceilings, or floors. Spacing between labelsor markings, or between a label and a marking, shall not be more than 3 m (10 ft). Labels required by thissection shall be suitable for the environment where they are installed.

Statement of Problem and Substantiation for Public Comment

The word WARNING was not appropriate in the original 690.31 (G)(3) text. Instead the word WARNING should have been used. Eliminating the word WARNING in this revision may put first responders in imminent danger.

Related Item

• FR8692

Submitter Information Verification

Submitter Full Name: Leo Zieman

Organization: Florida Power & Light (Nextera

Affiliation: Edison Electric Institute

Street Address:

City:

State:

Zip:

Submittal Date: Wed Aug 29 16:09:49 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected

Resolution: The purpose of these labels is for identification. The words "warning" or "danger" are notrequired for PV circuits.

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Public Comment No. 1758-NFPA 70-2018 [ Section No. 690.31(D) [Excluding any Sub-

Sections] ]

PV system dc circuits inside buildings greater than 30 volts and 70 watts shall volts shall be contained inmetal raceways, in Type MC metal-clad cable that complies with 250.118(10), or in metal enclosures. Wiringmethods on or in a building shall comply with the additional installation requirements in 690.31(G)(1)through (4).

Exception: PV hazard control systems installed in accordance with 690.12(B)(2)(1) shall be provided withor listed for use with nonmetallic enclosure(s), nonmetallic raceway(s), and cables of a permitted typeother than Type MC metal-clad cable(s), at the point of penetration of the surface of the building to the PVhazard control actuator.

Statement of Problem and Substantiation for Public Comment

There is no rationale for having the 70 watt requirement here the 30 volt threshold is sufficient for this requirement and makes compliance and enforcement easier to understand

Related Item

• FR8692

Submitter Information Verification

Submitter Full Name: James Rogers

Organization: Towns Of Oak Bluffs, Tisbury,

Street Address:

City:

State:

Zip:

Submittal Date: Wed Aug 29 21:05:27 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected but see related SR

Resolution: SR-8073-NFPA 70-2018

Statement: The words, “inside buildings” is relocated to lead the first sentence for clarity. The 70 watt thresholdis changed to 8 amps to better align with action taken in 690.42 and related standards for ground-fault detection. The exception is edited to clarify that the alternative wiring methods are permittedrather than required and moved above the requirements of (D)(1) through (4) so that it is clear thatPV hazard control systems are not exempt from (D)(1) through (4).

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Public Comment No. 1769-NFPA 70-2018 [ Section No. 690.31(D) [Excluding any Sub-

Sections] ]

PV system dc circuits inside buildings greater than 30 volts and 70 watts shall be contained in metalraceways, in Type MC metal-clad cable that complies with 250.118(10), or in metal enclosures. Wiringmethods on or in a building shall comply with the additional installation requirements in 690.31(G)(1)through (4).

Exception: PV hazard control systems installed in accordance with 690.12(B)(2)(1) shall be permitted tobe provided with or listed for use with nonmetallic enclosure(s), nonmetallic raceway(s), and cables of apermitted type other than Type MC metal-clad cable(s), at the point of penetration of the surface of thebuilding to the PV hazard control actuator.

Statement of Problem and Substantiation for Public Comment

The requirement language is slightly revised to more correctly indicate that such methods are permitted, not required.

Related Item

• FR-8692

Submitter Information Verification

Submitter Full Name: Jason Fisher

Organization: Tesla Inc.

Affiliation: Solar Energy Industries Association (SEIA)

Street Address:

City:

State:

Zip:

Submittal Date: Wed Aug 29 22:26:13 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected but see related SR

Resolution: SR-8073-NFPA 70-2018

Statement: The words, “inside buildings” is relocated to lead the first sentence for clarity. The 70 watt thresholdis changed to 8 amps to better align with action taken in 690.42 and related standards for ground-fault detection. The exception is edited to clarify that the alternative wiring methods are permittedrather than required and moved above the requirements of (D)(1) through (4) so that it is clear thatPV hazard control systems are not exempt from (D)(1) through (4).

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Public Comment No. 437-NFPA 70-2018 [ Section No. 690.31(D) [Excluding any Sub-

Sections] ]

PV system dc circuits inside buildings greater than 30 volts and 70 watts inside buildings shall becontained in metal raceways, in Type MC metal-clad cable that complies with 250.118(10), or in metalenclosures. Wiring methods on or in a building shall comply with the additional installation requirements in690.31(G)(1) through (4).

Exception: PV hazard control systems installed in accordance with 690.12(B)(2)(1) shall be provided withor listed for use with nonmetallic enclosure(s), nonmetallic raceway(s), and cables of a permitted typeother than Type MC metal-clad cable(s), at the point of penetration of the surface of the building to the PVhazard control actuator.

Statement of Problem and Substantiation for Public Comment

Rearranging this first sentence improves clarity and addresses the CC's comment CN 234.

Related Item

• CN 234

Submitter Information Verification

Submitter Full Name: William Brooks

Organization: Brooks Engineering

Street Address:

City:

State:

Zip:

Submittal Date: Mon Aug 06 18:39:27 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected but see related SR

Resolution: SR-8073-NFPA 70-2018

Statement: The words, “inside buildings” is relocated to lead the first sentence for clarity. The 70 watt thresholdis changed to 8 amps to better align with action taken in 690.42 and related standards for ground-fault detection. The exception is edited to clarify that the alternative wiring methods are permittedrather than required and moved above the requirements of (D)(1) through (4) so that it is clear thatPV hazard control systems are not exempt from (D)(1) through (4).

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Public Comment No. 801-NFPA 70-2018 [ Section No. 690.31(D) [Excluding any Sub-

Sections] ]

PV system dc circuits inside buildings greater than 30 volts and 70 watts shall be contained in metalraceways, in Type MC metal-clad cable that complies with 250.118(10), or in metal enclosures. Wiringmethods on or in a building shall comply with the additional installation requirements in 690.31(G)(1)through (4).

Exception: PV hazard control systems installed in accordance with 690.12(B)(2)(1) shall be provided withor listed for use with nonmetallic enclosure(s), nonmetallic raceway(s), and cables of a permitted typeother than Type MC metal-clad cable(s), at the point of penetration of the surface of the building to the PVhazard control actuator.

Statement of Problem and Substantiation for Public Comment

It's fairly easy to calculate what type of PV design would max out at 30V, temperature corrected Voc* # of modules in series or output of DC-DC Converters. But without some background how is the 70W value calculated? Is that 70W using the Imp and Vmp STC module data sheet values? Is it the manufacturer module power rating? Without direction this 70W limit is meaningless. These power limits get added to 690 and then removed because no one knows how to calculate them or apply them in the field. Let's end the cycle by not adding this one in the first place.

Related Item

• First Revision No. 8692-NFPA 70-2018 • Public Input No. 3033-NFPA 70-2017

Submitter Information Verification

Submitter Full Name: MARVIN HAMON

Organization: HAMON ENGINEERING INC

Street Address:

City:

State:

Zip:

Submittal Date: Fri Aug 17 22:14:09 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected but see related SR

Resolution: SR-8073-NFPA 70-2018

Statement: The words, “inside buildings” is relocated to lead the first sentence for clarity. The 70 watt thresholdis changed to 8 amps to better align with action taken in 690.42 and related standards for ground-fault detection. The exception is edited to clarify that the alternative wiring methods are permittedrather than required and moved above the requirements of (D)(1) through (4) so that it is clear thatPV hazard control systems are not exempt from (D)(1) through (4).

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Public Comment No. 1766-NFPA 70-2018 [ Section No. 690.31(E) ]

(E) Bipolar Photovoltaic Systems.

Where the sum, without consideration of polarity, of the voltages of the two monopole subarray circuitsexceeds the rating of the conductors and connected equipment, monopole subarray circuits in a bipolar PVsystem shall be physically separated, and the electrical output circuits from each monopole subarray circuitshall be installed in separate raceways until connected to the inverter. The disconnecting means andovercurrent protective devices for each monopole subarray circuit output shall be in separate enclosures.All conductors from each separate monopole subarray circuit shall be routed in the same raceway. Solidlygrounded bipolar PV systems shall be clearly marked with a permanent, legible warning notice indicatingthat the disconnection of the grounded conductor(s) may result in overvoltage on the equipment.

Exception: Listed switchgear rated for the maximum voltage between circuits and containing a physicalbarrier separating the disconnecting means for each monopole subarray circuit shall be permitted to beused instead of disconnecting means in separate enclosures.

Statement of Problem and Substantiation for Public Comment

The term "subarray" is being removed in all case to align with proposed changes to this definition in 690.2. The term "circuit" is added in the exception to match the definition.

Related Public Comments for This Document

Related Comment Relationship

Public Comment No. 1555-NFPA 70-2018 [Definition: Monopole Subarray Circuit.]

Related Item

• FR-8694

Submitter Information Verification

Submitter Full Name: Jason Fisher

Organization: Tesla Inc.

Affiliation: Solar Energy Industries Association (SEIA)

Street Address:

City:

State:

Zip:

Submittal Date: Wed Aug 29 22:21:33 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Accepted

Resolution: SR-8078-NFPA 70-2018

Statement: The term "subarray" is removed in all cases to align with changes to this definition in 690.2. Theterm "circuit" is added in the exception to match the definition.

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Public Comment No. 2103-NFPA 70-2018 [ Section No. 690.31(F) ]

(F) Wiring Methods and Mounting Systems.

Roof-mounted PV array mounting systems shall be permitted to be held in place with an approved meansother than those required by 110.13 and shall utilize wiring methods that allow any expected movement ofthe array.

Informational Note: Structural design requirements for ballasted, unattached PV systems are found in thebuilding code and a structural standard referenced by the building code. Maximum expected seismicdisplacement of an unattached PV system can be obtained from the Structural Engineer of Record.

Statement of Problem and Substantiation for Public Comment

Structural design requirements for ballasted, unattached (non-penetrating) PV systems are found in Section 1613.3 of the 2018 International Building Code and Section 13.6.12 of ASCE 7-16, which is a referenced standard. These sections allow for some movement of an unattached PV array during a seismic event. The expected movement is calculated by the Structural Engineer of Record. Section 13.6.12.5 of ASCE 7-16 requires that “All electrical cables leading from a panel to another panel or to another roof object are designed to accommodate, without rupture or distress, differential movements between cable connections....” For wiring methods connected to a ballasted array, there needs to be flexibility built into the wiring method to prevent separation and damage for expected movement during a seismic event. Alternatively, the wiring method's termination points can be anchored to the structure so that regardless of movement within the PV array the wiring method remains in place. The designer of the PV system is encouraged to communicate with the Structural Engineer Of Record to obtain the maximum expected seismic displacement.

Related Item

• FR-8695

Submitter Information Verification

Submitter Full Name: Phil Undercuffler

Organization: Outback Power Technologies

Affiliation: Solar Energy Industries Association (SEIA)

Street Address:

City:

State:

Zip:

Submittal Date: Thu Aug 30 17:51:26 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected but see related SR

Resolution: SR-8080-NFPA 70-2018 The requirements of ASCE 7-16 should not become a requirement forthe electrical portion of every rooftop system that is not fully fastened.

Statement: The informational note is added to broadly inform that expected movement may be determinedwith structural calculations. There may be ways to prevent movement relative to the electricalwiring methods that do not require structural calculations.

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Public Comment No. 1787-NFPA 70-2018 [ Section No. 690.33 ]

690.33 33 Mating Connectors.

Connectors Mating connectors , other than those covered by 690.32, shall comply with 690.33(A) through(E D ).

(A) Configuration.

The connectors shall be polarized and shall have a configuration that is noninterchangeable withreceptacles in other electrical systems on the premises.

(B) Guarding.

The connectors shall be constructed and installed so as to guard against inadvertent contact with live partsby persons.

(C) Type.

The connectors shall be of the latching or locking type. Connectors that are readily accessible and that areused in circuits operating at over 30 volts dc or 15 volts ac shall require a tool for opening.

(D) Interruption of Circuit.

Connectors shall be one of the following:

(1) Rated for interrupting current without hazard to the operator.

(2) A type that requires the use of a tool to open and marked “Do Not Disconnect Under Load” or “Not forCurrent Interrupting.”

(3) Supplied as part of listed equipment and used in accordance with instructions provided with the listedconnected equipment.

Informational Note: Some listed equipment, such as micro inverters, are evaluated to make useof connectors as disconnect devices even though the connectors are marked as “Do NotDisconnect Under Load” or “Not for Current Interrupting.”

Statement of Problem and Substantiation for Public Comment

Sub-section references corrected to match new item numbering. Additionally, there are many connectors used in PV systems. Examples are splicing and terminal connectors. These changes would improve the applicability of the Code by removing potential confusion over how to apply the requirements in 690.33 to connectors used in PV systems. This term aligns with common UL standards.

Related Item

• FR-8395

Submitter Information Verification

Submitter Full Name: Jason Fisher

Organization: Tesla Inc.

Affiliation: Solar Energy Industries Association (SEIA)

Street Address:

City:

State:

Zip:

Submittal Date: Wed Aug 29 23:41:07 EDT 2018

Committee: NEC-P04

Committee Statement

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CommitteeAction:

Rejected but see related SR

Resolution: SR-8085-NFPA 70-2018

Statement: The generic term “connector” is too broad for this section since connectors suitable for use in PVcircuits exist in multiple configurations, not just the mating (i.e. pin and socket) types covered in thissection. The term “mating” has been added to further clarify the type of connectors covered insection 690.33. This term aligns with changes underway in applicable UL product safety standards.

A reference to “intermatability” has been added in subsection (C) to ensure that two different brandor types of mating connectors can only be installed together where they have been listed andidentified for this use. The term “intermatability” is used in UL 6703, the product safety standardcovering PV connectors.

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Public Comment No. 1982-NFPA 70-2018 [ Section No. 690.33 ]

690.33 33 Mating Connectors.

Connectors Mating connectors , other than those covered by 690.32, shall comply with 690.33(A) through(E).

(A) Configuration.

The mating connectors shall be polarized and shall have a configuration that is noninterchangeable withreceptacles in other electrical systems on the premises.

(B) Guarding.

The mating connectors shall be constructed and installed so as to guard against inadvertent contact withlive parts by persons.

(C) Type.

The mating connectors shall be of the latching or locking type. Connectors Mating connectors that arereadily accessible and that are used in circuits operating at over 30 volts dc or 15 volts ac shall require atool for opening.

(D) Intermatability.

Mating connectors shall be listed for intermateability with all connectors to which the connector is intendedto be mated or shall be mated only with connectors of identical type and brand.

(E) Interruption of Circuit.

Connectors Mating connectors shall be one of the following:

(1) Rated for interrupting current without hazard to the operator.

(2) A type that requires the use of a tool to open and marked “Do Not Disconnect Under Load” or “Not forCurrent Interrupting.”

(3) Supplied as part of listed equipment and used in accordance with instructions provided with the listedconnected equipment.

Informational Note: Some listed equipment, such as micro inverters, are evaluated to make useof connectors as disconnect devices even though the connectors are marked as “Do NotDisconnect Under Load” or “Not for Current Interrupting.”

Statement of Problem and Substantiation for Public Comment

The term "connector" is a very broad term that is mostly used for pressure terminals in the NEC. We in the PV world have used the term, even in UL6703, to be synonymous with mating connectors. We are actually referring to mating connectors in this section so we need to be very specific as it impacts other sections such as 690.15 for isolating devices.

Also, there is an important concern about the intermatability of connectors, a term used in UL6703. With the pending adoption of 690.12 the number of connections made between equipment from different manufacturers will increase dramatically. Connectors are frequently installed in not readily accessible locations, e.g. under a roof mounted array, and different brands may be very similar in appearance. Different brands of connectors commonly used in PV systems may be mechanically compatible but may not have been evaluated for electrical safety. Failures of connections made between connectors from different brands are well documented and represent an source of electrical and fire hazard. Equipment Standards for end use equipment, i.e. PV modules and Module Level Power Electronics, do not contain any mandatory requirements to indicate limitations on Intermatability of connectorsEquipment Standards for connectors do not contain clear testing protocols for intermatabilty or uniform ways to indicate when connectors have been evaluated for intermatabilty with connectors from other brands.

Intermatabilty between products from different manufacturers is an installation related safety issue that should be addressed in the Code. Adding specific language on intermatabilty in the Code will provide clear guidance the AHJ’s on this issue. Adding a Code requirement should also spur development of intermatabilty requirements in

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the applicable Equipment Standards.

From UL 6703:

1.5 This standard covers PV connectors whose dimensions are not defined in any national or international technical standard. Connectors are identified and tested with compatible mating part (or parts if multiple exist) and are to be of the same brand, unless multiple product manufacturers are submitting under the same evaluation for the purpose of proving intermatability.

Related Item

Submitter Information Verification

Submitter Full Name: William Brooks

Organization: Brooks Engineering

Affiliation: PVICC

Street Address:

City:

State:

Zip:

Submittal Date: Thu Aug 30 13:33:18 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected but see related SR

Resolution: SR-8085-NFPA 70-2018

Statement: The generic term “connector” is too broad for this section since connectors suitable for use in PVcircuits exist in multiple configurations, not just the mating (i.e. pin and socket) types covered in thissection. The term “mating” has been added to further clarify the type of connectors covered insection 690.33. This term aligns with changes underway in applicable UL product safety standards.

A reference to “intermatability” has been added in subsection (C) to ensure that two different brandor types of mating connectors can only be installed together where they have been listed andidentified for this use. The term “intermatability” is used in UL 6703, the product safety standardcovering PV connectors.

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Public Comment No. 1405-NFPA 70-2018 [ Section No. 690.33(C) ]

(C) Type.

The connectors shall be of the latching or locking type and be listed for compatibility as described in themanufacturer's instructions . Connectors that are readily accessible and that are used in circuits operatingat over 30 volts dc or 15 volts ac shall require a tool for opening.

Statement of Problem and Substantiation for Public Comment

First Revision No. 8395-NFPA 70-2018 restructures 690.33 and deletes information that should be covered by UL 6703 and UL 486. These standards only evaluate mated connectors of the same type and manufacturer. Therefore it should be made clear in this Code and in the manufacturer's instructions that due to the risk of fire, only mating connectors of the same brand and type are allowed unless alternate mating connectors are listed for the application. An IEC Technical Report on the risk of interconnection of "MC4 compatible" PV connectors from different manufacturers is under development. Other international installation standards, e.g. IEC 60364-7-712 and IEC 62548, have already addressed this concern.Further Reference: https://www.ise.fraunhofer.de/content/dam/ise/de/documents/publications/conference-paper/28-eupvsec-2013/Laukamp_5BV771.pdf

Related Item

• FR No. 8395-NFPA 70-2018

Submitter Information Verification

Submitter Full Name: Thomas A. Wegener

Organization: SMA Solar Technology AG

Street Address:

City:

State:

Zip:

Submittal Date: Tue Aug 28 07:40:52 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected but see related SR

Resolution: SR-8085-NFPA 70-2018

Statement: The generic term “connector” is too broad for this section since connectors suitable for use in PVcircuits exist in multiple configurations, not just the mating (i.e. pin and socket) types covered in thissection. The term “mating” has been added to further clarify the type of connectors covered insection 690.33. This term aligns with changes underway in applicable UL product safety standards.

A reference to “intermatability” has been added in subsection (C) to ensure that two different brandor types of mating connectors can only be installed together where they have been listed andidentified for this use. The term “intermatability” is used in UL 6703, the product safety standardcovering PV connectors.

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Public Comment No. 1456-NFPA 70-2018 [ Section No. 690.41(A) ]

(A) PV System Grounding Configurations.

One or more of the following system grounding configurations shall be employed:

(1) 2-wire PV arrays with one functionally grounded conductor

(2) Bipolar PV arrays according to 690.7(C) with a functional ground reference (center tap)

(3) PV arrays not isolated from the grounded inverter output circuit

(4) Ungrounded PV arrays

(5) Solidly grounded PV arrays as permitted in 690.41(B) Exception

(6) PV systems that use other methods that accomplish equivalent system protection in accordance with250.4(A) with equipment listed and identified for the use

Statement of Problem and Substantiation for Public Comment

In answer to PI 3525-NFPA 70-2017 and 3533-NFPA 70-2017, the committee resolution was, "The allowable configurations stated in 690.41(A)(1) and (3) describe methods use in existing listed equipment and are appropriate to provide a system ground reference required for the PV system dc ground-fault protection equipment to function properly."The problem with the resolution is that it refers to "system ground reference" and 690.41(A) refers to "system grounding" without the use of the term "reference." System grounding and reference grounding are completely separate concepts. A reference grounded conductor does not even require a connection to ground, it simply requires an electronic circuit measuring voltage between the conductor and ground to detect when the conductor faults to ground. We need to be much more careful in how we write about reference grounding in 690, we are still treating it like it is solid grounding and that is incorrect. An alternative change to this section would be to change "system ground" to "system or reference ground" to indicate they are different.

Related Item

• Public Input No. 3525-NFPA 70-2017 • Public Input No. 3533-NFPA 70-2017

Submitter Information Verification

Submitter Full Name: MARVIN HAMON

Organization: HAMON ENGINEERING INC

Street Address:

City:

State:

Zip:

Submittal Date: Tue Aug 28 17:03:58 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected but see related SR

Resolution: SR-8087-NFPA 70-2018 The allowable configurations stated in 690.41(A)(1) through (3) describemethods used in existing listed equipment and are appropriate to provide a ground referencerequired for the PV system dc ground-fault protection equipment to function properly. The use of theterm “grounding” in the subsection has been slightly modified based on the submitter’s comment.The use of the term “system grounding” in the title of this subdivision does not convey anymandatory requirement and is intentionally titled to aid a user of the Code to easily locate theserequirements.

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Statement: The term “grounding” is deleted since only one of the permitted system types in the list includessolidly grounded circuit conductors.

The word "exception" was deleted in Item (5) since the exception was changed to positive languagein the first draft.

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Public Comment No. 1194-NFPA 70-2018 [ Section No. 690.41(B)(2) ]

(2) Faulted Circuits.

The faulted circuits shall be controlled by one of the following methods:

(1) The current-carrying conductors of the faulted circuit shall be automatically disconnected.

(2) The device providing ground-fault protection fed by the faulted circuit shall automatically cease tosupply power to output circuits and interrupt the faulted PV system dc circuits from the groundreference in a functionally grounded system.

Additional Proposed Changes

File Name Description Approved

CN_225.pdf 70_CN225

Statement of Problem and Substantiation for Public Comment

NOTE: This Public Comment appeared as CC Note No. 225 in the First Draft Report on First Revision No. 8402.

The Correlating Committee directs the panel to reconsider the text of the informational note to remove permissive language. The use of the word“may” makes this permissive. The Correlating Committee directs the panel to correct the grammar/syntax of 690.41(B)(2)(3). This action will beconsidered as a public comment.

Related Item

• First Revision No. 8402

Submitter Information Verification

Submitter Full Name: CC on NEC-AAC

Organization: NEC Correlating Committee

Street Address:

City:

State:

Zip:

Submittal Date: Fri Aug 24 10:40:42 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected but see related SR

Resolution: SR-8099-NFPA 70-2018

Statement: Language in this section has been changed to better clarify the requirements.

The use of terms that may be perceived as permissive language have been removed from theinformational note.

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Correlating Committee Note No. 225-NFPA 70-2018 [ Section No. 690.41(B)(2) ]

Submitter Information Verification

Submitter Full Name: Sarah CaldwellCommittee: Submittal Date: Fri May 11 15:28:02 EDT 2018

Committee Statement and Meeting Notes

Committee Statement:

The Correlating Committee directs the panel to reconsider the text of the informational note to remove permissive language. The use of the word “may” makes this permissive. The Correlating Committee directs the panel to correct the grammar/syntax of 690.41(B)(2)(3). This action will be considered as a public comment.

First Revision No. 8402-NFPA 70-2018 [Section No. 690.41(B)(2)]

Ballot Results

This item has passed ballot

12 Eligible Voters0 Not Returned

12 Affirmative All0 Affirmative with Comments0 Negative with Comments0 Abstention

Affirmative AllBrunssen, James E.

Dressman, Kevin L.

Hickman, Palmer L.

Hittinger, David L.

Holub, Richard A.

Johnston, Michael J.

Kovacik, John R.

Manche, Alan

McDaniel, Roger D.

Pierce, James F.

Saporita, Vincent J.

Williams, David A.

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Public Comment No. 1963-NFPA 70-2018 [ Section No. 690.41(B)(3) ]

(3) Indication of Faults.

Equipment performing ground-fault protection mounted in not readily accessible locations shall havemeans to provide remote indication of ground faults.

Informational Note: Examples of remote indication may be provided by means such as, but notlimited to, the following: remote indicator light, display, monitor, signal to a monitored alarm system,or receipt of notification by web-based services.

Statement of Problem and Substantiation for Public Comment

The proposed addition provides no additional safety, and any potential benefit is not demonstrated. PV arrays, as installed per this Code with Listed equipment are safe, before and after any potential ground fault. Enforcement is subject to interpretation and confusion. The requirements for remote indication, if needed, should be determined by the safety standards.

Related Item

• FR-8402

Submitter Information Verification

Submitter Full Name: Phil Undercuffler

Organization: Outback Power Technologies

Affiliation: Solar Energy Industries Association (SEIA)

Street Address:

City:

State:

Zip:

Submittal Date: Thu Aug 30 13:10:24 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected

Resolution: The primary purpose of ground-fault protection in PV systems is for fire prevention. Though ground-fault protection has been proven to be very effective in PV systems, the presence of uncorrectedground-faults will lower the effectiveness of these systems over time. This requirement ensures thatin all applications, an indication of a ground-fault will be communicated without the necessity toremove of any equipment.

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Public Comment No. 439-NFPA 70-2018 [ Section No. 690.41(B)(3) ]

(3) Indication of Faults.

Equipment performing ground- Ground fault protection equipment mounted in not readily accessiblelocations shall have means to provide remote indication of ground faults.

Informational Note: Examples Some examples of remote indication may be provided by meanssuch as, but not limited to, the following: are remote indicator light, display, monitor, signal to amonitored alarm system, or receipt of notification by web-based services.

Statement of Problem and Substantiation for Public Comment

The first sentence is revised for clarity and to address the CC's comment CN 225. The may is removed from the informational note.

Related Item

• CN 225

Submitter Information Verification

Submitter Full Name: William Brooks

Organization: Brooks Engineering

Street Address:

City:

State:

Zip:

Submittal Date: Mon Aug 06 18:47:09 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected but see related SR

Resolution: SR-8099-NFPA 70-2018

Statement: Language in this section has been changed to better clarify the requirements.

The use of terms that may be perceived as permissive language have been removed from theinformational note.

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Public Comment No. 1195-NFPA 70-2018 [ Section No. 690.41(B) [Excluding any Sub-

Sections] ]

PV system dc circuits greater than 30 volts and 70 watts shall be provided with dc ground-fault protectionmeeting the requirements of 690.41(B)(1) and (B)(2) to reduce fire hazards.

Solidly grounded PV arrays with not more than two PV source circuits and with all PV system dc circuitsnot on or in buildings shall be permitted without ground-fault protection.

Informational Note: Not all inverters, charge controllers, or dc-to-dc converters include ground-faultprotection. Equipment that does not have ground-fault protection may have the following statementin the manual: “Warning: This unit is not provided with a GFDI device.”

Additional Proposed Changes

File Name Description Approved

CN_224.pdf 70_CN224

Statement of Problem and Substantiation for Public Comment

NOTE: This Public Comment appeared as CC Note No. 224 in the First Draft Report on First Revision No. 8398.

The Correlating Committee directs the panel to reconsider the text of the informational note to remove permissive language. The use of the word“may” makes this permissive. The Correlating Committee directs the panel to correct the grammar/syntax of 690.41(B)(3). This action will beconsidered as a public comment.

Related Item

• First Revision No. 8398

Submitter Information Verification

Submitter Full Name: CC on NEC-AAC

Organization: NEC Correlating Committee

Street Address:

City:

State:

Zip:

Submittal Date: Fri Aug 24 10:42:13 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected but see related SR

Resolution: SR-8092-NFPA 70-2018

Statement: The limits on voltage and current that are allowed for PV system dc system circuits without ground-fault protection have been updated to align with updates to UL-61730 covering class III PV modules.PV modules smaller than these values are generally recognized in multiple standards as providingan insufficient level of energy to ignite common materials found adjacent to PV system dc circuitconductors. Adding these limits provide an allowance for small PV modules to be used for traditionaldedicated applications where smaller low-voltage modules are all that is required. Changes werealso made to clarify that only solidly-grounded PV source circuits that do not exceed two modules inparallel can be installed without ground fault protection only where those circuits are not on or inbuildings.

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The use of terms that could be perceived as permissive language have also been removed from theinformational note.

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Correlating Committee Note No. 224-NFPA 70-2018 [ Section No. 690.41(B) [Excluding any Sub-Sections] ]

Submitter Information Verification

Submitter Full Name: Sarah CaldwellCommittee: Submittal Date: Fri May 11 15:25:53 EDT 2018

Committee Statement and Meeting Notes

Committee Statement:

The Correlating Committee directs the panel to reconsider the text of the informational note to remove permissive language. The use of the word “may” makes this permissive. The Correlating Committee directs the panel to correct the grammar/syntax of 690.41(B)(3). This action will be considered as a public comment.

First Revision No. 8398-NFPA 70-2018 [Section No. 690.41(B) [Excluding any Sub-Sections]]

Ballot Results

This item has passed ballot

12 Eligible Voters0 Not Returned

12 Affirmative All0 Affirmative with Comments0 Negative with Comments0 Abstention

Affirmative AllBrunssen, James E.

Dressman, Kevin L.

Hickman, Palmer L.

Hittinger, David L.

Holub, Richard A.

Johnston, Michael J.

Kovacik, John R.

Manche, Alan

McDaniel, Roger D.

Pierce, James F.

Saporita, Vincent J.

Williams, David A.

Page 1 of 1National Fire Protection Association Report

8/23/2018https://submittals.nfpa.org/TerraViewWeb/FormLaunch?id=/TerraView/Content/70-2017....

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Public Comment No. 1759-NFPA 70-2018 [ Section No. 690.41(B) [Excluding any Sub-

Sections] ]

PV system dc circuits greater than 30 volts and 70 watts shall volts shall be provided with dc ground-faultprotection meeting the requirements of 690.41(B)(1) and (B)(2) to reduce fire hazards.

Solidly grounded PV arrays with not more than two PV source circuits and with all PV system dc circuits noton or in buildings shall be permitted without ground-fault protection.

Informational Note: Not all inverters, charge controllers, or dc-to-dc converters include ground-faultprotection. Equipment that does not have ground-fault protection may have the following statement inthe manual: “Warning: This unit is not provided with a GFDI device.”

Statement of Problem and Substantiation for Public Comment

The 70 watts is not necessary for this requirement the 30 volt threshold is sufficient

Related Item

• FR8398

Submitter Information Verification

Submitter Full Name: James Rogers

Organization: Towns Of Oak Bluffs, Tisbury,

Street Address:

City:

State:

Zip:

Submittal Date: Wed Aug 29 21:11:25 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected but see related SR

Resolution: SR-8092-NFPA 70-2018

Statement: The limits on voltage and current that are allowed for PV system dc system circuits without ground-fault protection have been updated to align with updates to UL-61730 covering class III PV modules.PV modules smaller than these values are generally recognized in multiple standards as providingan insufficient level of energy to ignite common materials found adjacent to PV system dc circuitconductors. Adding these limits provide an allowance for small PV modules to be used for traditionaldedicated applications where smaller low-voltage modules are all that is required. Changes werealso made to clarify that only solidly-grounded PV source circuits that do not exceed two modules inparallel can be installed without ground fault protection only where those circuits are not on or inbuildings.

The use of terms that could be perceived as permissive language have also been removed from theinformational note.

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Public Comment No. 438-NFPA 70-2018 [ Section No. 690.41(B) [Excluding any Sub-

Sections] ]

PV system dc circuits greater than 30 volts and 70 watts shall be provided with dc ground-fault protectionmeeting the requirements of 690.41(B)(1) and (B)(2) to reduce fire hazards.

Solidly grounded PV arrays with not more than two PV source circuits and with all PV system dc circuits noton or in buildings shall be permitted without ground-fault protection.

Informational Note: Not all inverters, charge controllers, or dc-to-dc converters include ground-faultprotection. Equipment that does not have ground-fault protection may have often includes thefollowing statement in the manual: “Warning: This unit is not provided with a GFDI device.”

Statement of Problem and Substantiation for Public Comment

Apparently we MAY not use the word "may" in an inforMAYtional note. This removes the may.

Related Item

• CN 224

Submitter Information Verification

Submitter Full Name: William Brooks

Organization: Brooks Engineering

Street Address:

City:

State:

Zip:

Submittal Date: Mon Aug 06 18:44:57 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected but see related SR

Resolution: SR-8092-NFPA 70-2018

Statement: The limits on voltage and current that are allowed for PV system dc system circuits without ground-fault protection have been updated to align with updates to UL-61730 covering class III PV modules.PV modules smaller than these values are generally recognized in multiple standards as providingan insufficient level of energy to ignite common materials found adjacent to PV system dc circuitconductors. Adding these limits provide an allowance for small PV modules to be used for traditionaldedicated applications where smaller low-voltage modules are all that is required. Changes werealso made to clarify that only solidly-grounded PV source circuits that do not exceed two modules inparallel can be installed without ground fault protection only where those circuits are not on or inbuildings.

The use of terms that could be perceived as permissive language have also been removed from theinformational note.

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Public Comment No. 803-NFPA 70-2018 [ Section No. 690.41(B) [Excluding any Sub-

Sections] ]

PV system dc circuits greater than 30 volts and 70 watts shall be provided with dc ground-fault protectionmeeting the requirements of 690.41(B)(1) and (B)(2) to reduce fire hazards.

Solidly grounded PV arrays with not more than two PV source circuits and with all PV system dc circuits noton or in buildings shall be permitted without ground-fault protection.

Informational Note: Not all inverters, charge controllers, or dc-to-dc converters include ground-faultprotection. Equipment that does not have ground-fault protection may have the following statement inthe manual: “Warning: This unit is not provided with a GFDI device.”

Statement of Problem and Substantiation for Public Comment

It's fairly easy to calculate what type of PV design would max out at 30V, temperature corrected Voc* # of modules in series or output of DC-DC Converters. But without some background how is the 70W value calculated? Is that 70W using the Imp and Vmp STC module data sheet values? Is it the manufacturer module power rating? Without direction this 70W limit is meaningless. These power limits get added to 690 and then removed because no one knows how to calculate them or apply them in the field. Let's end the cycle by not adding this one in the first place.

Related Item

• First Revision No. 8398-NFPA 70-2018 • Public Input No. 3016-NFPA 70-2017

Submitter Information Verification

Submitter Full Name: MARVIN HAMON

Organization: HAMON ENGINEERING INC

Street Address:

City:

State:

Zip:

Submittal Date: Fri Aug 17 22:35:08 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected but see related SR

Resolution: SR-8092-NFPA 70-2018

Statement: The limits on voltage and current that are allowed for PV system dc system circuits without ground-fault protection have been updated to align with updates to UL-61730 covering class III PV modules.PV modules smaller than these values are generally recognized in multiple standards as providingan insufficient level of energy to ignite common materials found adjacent to PV system dc circuitconductors. Adding these limits provide an allowance for small PV modules to be used for traditionaldedicated applications where smaller low-voltage modules are all that is required. Changes werealso made to clarify that only solidly-grounded PV source circuits that do not exceed two modules inparallel can be installed without ground fault protection only where those circuits are not on or inbuildings.

The use of terms that could be perceived as permissive language have also been removed from theinformational note.

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Public Comment No. 2107-NFPA 70-2018 [ Section No. 690.43 ]

690.43 Equipment Grounding and Bonding.

Exposed non–current-carrying metal parts of PV module frames, electrical equipment, and conductorenclosures of PV systems shall be connected to an equipment grounding conductor in accordance with250.134 or 250.136(A), regardless of voltage. Equipment grounding conductors and devices shall complywith 690.43(A) through (E D ).

(A) Photovoltaic Module Mounting Systems and Devices.

Devices and systems used for mounting PV modules that are also used for bonding module frames shall belisted, labeled, and identified for bonding PV modules. Devices that mount adjacent PV modules shall bepermitted to bond adjacent PV modules.

(B) Equipment Secured to Grounded Metal Supports.

Devices listed, labeled, and identified for bonding and grounding the metal parts of PV systems shall bepermitted to bond the equipment to grounded metal supports. Metallic support structures shall haveidentified bonding jumpers connected between separate metallic sections or shall be identified forequipment bonding and shall be connected to the equipment grounding conductor.

(C) With Circuit Conductors.

Equipment grounding conductors for the PV array and support structure where installed, shall be containedwithin the same raceway or cable, or otherwise run with the PV system conductors where those circuitconductors leave the vicinity of the PV array.

(D) Bonding for Over 250 Volts.

The bonding requirements contained in 250.97 shall apply only to solidly grounded PV system circuitsoperating over 250 volts to ground.

(E) Conductor Installation.

Equipment grounding and bonding conductors shall comply with 250.120.

Statement of Problem and Substantiation for Public Comment

The language that was moved from 690.46 and 690.50 to 690.43(E) needs to be removed. The section on equipment grounding conductor size and installation was part of a PI to remove it on the grounds that it has been in the NEC for many code cycles, it is a well-known issue, and it is teaching the NEC. Some on the panel still believe there is value in teaching the Code here. There is also the insistence that language related to qualified persons be maintained in 690.4. Qualified people should know the requirements of 250.120 so this section needs to be deleted during the comment period. In fact, an AHJ could use this case to prove that an installer is unqualified if they do not understand this basic requirement.

Related Item

Submitter Information Verification

Submitter Full Name: William Brooks

Organization: Brooks Engineering

Street Address:

City:

State:

Zip:

Submittal Date: Thu Aug 30 18:08:27 EDT 2018

Committee: NEC-P04

Committee Statement

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CommitteeAction:

Rejected but see related SR

Resolution: SR-8101-NFPA 70-2018

Statement: The language in subsection (E) has been deleted since the single reference to 250.120 isinadequate to provide complete guidance as to the requirements covering the installation ofequipment grounding conductors in PV systems. Deleting this section will not cause gaps orconflicts in the Code since Chapter 2, and thus Parts 6 and 7 of Article 250 are not modified by anyother sections in Article 690 so will still apply.

The reference to the subsection letters in the main paragraph have been updated to reflect thisdeletion.

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Public Comment No. 804-NFPA 70-2018 [ Section No. 690.43(D) ]

(D) Bonding for Over 250 Volts.

The bonding requirements contained in 250.97 shall apply only to solidly grounded PV system circuitsoperating over 250 volts to ground.

Statement of Problem and Substantiation for Public Comment

The justifications for exempting functionally grounded PV systems over 250V from NEC 250.97 are based on incorrect information.

In Public Input No. 3020-NFPA 70-2017 it is asserted that, "All functionally grounded PV system dc circuits have ground fault protection that will limit the amount of fault current to any metallic raceways or cable sheaths." and "The additional bonding requirements in 250.97 should not be required for any functionally grounded PV system regardless of voltage." But functionally grounded PV systems do not require that ground fault current be limited or isolated at the source, the PV modules. It requires that on detection of a fault that the load be disconnected and a fault indication be given. The fault current can continue to circulate in the DC conductors as long as the PV modules are illuminated and the fault exists, possibility for years. So this statement is incorrect. Given this, the requirements of 250.97 are needed for the safety of all PV systems over 250V.

Related Item

• First Revision No. 8408-NFPA 70-2018 • Public Input No. 3020-NFPA 70-2017

Submitter Information Verification

Submitter Full Name: MARVIN HAMON

Organization: HAMON ENGINEERING INC

Street Address:

City:

State:

Zip:

Submittal Date: Fri Aug 17 22:44:25 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected

Resolution: The additional grounding requirements found in 250.97, that are outlined in 250.92(B) “Methods ofBonding at the Service”, are unnecessary for PV system dc circuits above 250V to ground, that arenot solidly grounded, based on the fact that these circuits have limited fault currents (especially whencompared to services), will contain overcurrent protection per 690.9, and must incorporate ground-fault protection per 690.41(B). The requirements for equipment grounding conductors in 690.43 and690.45 and as otherwise unmodified in Article 250, such as in 250.96(A), are adequate to ensurethat any ground fault current that may travel on metal raceways or cables with metal sheaths will notexceed the ability of the equipment grounding conductor to carry that current and open theovercurrent protection device and/or operate the ground fault protection device.

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Public Comment No. 805-NFPA 70-2018 [ Section No. 690.43(E) ]

(E) Conductor Installation.

Equipment grounding and bonding conductors shall comply with 250.120.

Statement of Problem and Substantiation for Public Comment

The nature of chapter 6 is that it overrides the other chapters 1-4 when needed for special equipment. If it does not specifically override the requirements then they automatically apply. So having a statement in 690 that says 250.120 applies to equipment bonding and grounding conductors becomes extraneous text. Since removing text is good and this text serves no purpose other than as a reminder that 250.120 exists let's remove it.

Related Item

• First Revision No. 8408-NFPA 70-2018

Submitter Information Verification

Submitter Full Name: MARVIN HAMON

Organization: HAMON ENGINEERING INC

Street Address:

City:

State:

Zip:

Submittal Date: Fri Aug 17 23:06:10 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected but see related SR

Resolution: SR-8101-NFPA 70-2018

Statement: The language in subsection (E) has been deleted since the single reference to 250.120 isinadequate to provide complete guidance as to the requirements covering the installation ofequipment grounding conductors in PV systems. Deleting this section will not cause gaps orconflicts in the Code since Chapter 2, and thus Parts 6 and 7 of Article 250 are not modified by anyother sections in Article 690 so will still apply.

The reference to the subsection letters in the main paragraph have been updated to reflect thisdeletion.

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Public Comment No. 1164-NFPA 70-2018 [ Section No. 690.45 ]

690.45 Size of Equipment Grounding Conductors.

(A) PV System AC and DC Circuits.

Equipment grounding conductors shall be sized in accordance with 250.122. Where no overcurrentprotective device is used in the circuit, an assumed overcurrent device rated in accordance with690.9(B)shall be used when applying Table 250.122.

(B) PV System DC Circuits.

Increases in equipment grounding conductor size to address voltage drop considerations shall not berequired.

Additional Proposed Changes

File Name Description Approved

CN_235.pdf 70_CN 235

Statement of Problem and Substantiation for Public Comment

NOTE: This Public Comment appeared as CC Note No. 235 in the First Draft Report on First Revision Nos. 8413 and 8114.

The Correlating Committee directs that this first revision be reconsidered and correlated with first revision 8114.

This action will be considered as a public comment.

Related Item

• FR 8413 • FR 8114

Submitter Information Verification

Submitter Full Name: CC on NEC-AAC

Organization: NEC Correlating Committee

Street Address:

City:

State:

Zip:

Submittal Date: Fri Aug 24 09:14:42 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected

Resolution: Revisions made to 250.122 in the second draft resolved the issues regarding these publiccomments.

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Public Comment No. 2108-NFPA 70-2018 [ Section No. 690.45 ]

690.45 Size of Equipment Grounding Conductors.

(A) PV System AC and DC Circuits.

Equipment grounding conductors for PV system circuits shall be sized in accordance with 250.122. Whereno overcurrent protective device is used in the circuit, an assumed overcurrent device rated in accordancewith 690.9(B)shall be used when applying Table 250.122.

(B) PV System DC Circuits.

Increases in equipment grounding conductor size to address voltage drop considerations shall not berequired.

Statement of Problem and Substantiation for Public Comment

In the first draft 250.122 was dramatically revised to the point that our 690.45 is no longer accurate. Also, the discussion surrounding sizing conductors based on voltage drop did not receive the attention that it deserved in the first draft. Due to the fact that it appears that CMP5 may be doing away with using the overcurrent device rating for sizing the conductor, it is time for CMP4 to rethink sizing of conductors on both dc and ac sides given the very conservative approach taken by CMP5 on the subject.

Related Item

Submitter Information Verification

Submitter Full Name: William Brooks

Organization: Brooks Engineering

Street Address:

City:

State:

Zip:

Submittal Date: Thu Aug 30 18:15:10 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected but see related SR

Resolution: SR-8107-NFPA 70-2018

Statement: This revision simplifies the sizing of grounding conductors and allows ac equipment groundingconductors to remain the same based on the overcurrent device rating regardless of sizeincreases for performance related reasons.

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Public Comment No. 889-NFPA 70-2018 [ Section No. 690.45 ]

690.45 Size of Equipment Grounding Conductors.

(A) PV System AC and DC Circuits.

Equipment grounding conductors shall be sized in accordance with 250.122. Where no overcurrentprotective device is used in the circuit, an assumed overcurrent device rated in accordance with690.9(B)shall be used when applying Table 250.122.

(B) PV System DC Circuits.

Increases in equipment grounding conductor size to address voltage drop considerations shall not berequired.

Additional Proposed Changes

File Name Description Approved

CN_242.pdf 70_CN 242

Statement of Problem and Substantiation for Public Comment

NOTE: This Public Comment appeared as CC Note No. 242 in the First Draft Report on First Revision No. 8114.

The Correlating Committee directs Code-Making Panel 5 to correlate FR 8114 with 250.102(D), 250.104(B), and 250.190(C)(3).

The Correlating Committee directs that FR 8114 be referred to Code-Making Panel 2 for correlation with Annex D Example D3(a).

The Correlating Committee directs that FR 8114 be referred to Code-Making Panel 4 for correlation with 690.45.

The Correlating Committee directs that FR 8114 be referred to Code-Making Panel 10 for correlation with 215.2(A)(2)(b)(2) and 215.2(B).

The Correlating Committee directs that FR 8114 be referred to Code-Making Panel 15 for correlation with 525.11.

The Correlating Committee directs that FR 8114 be referred to Code-Making Panel 18 for correlation with 600.7(A)(2).

These actions will be considered as public comments.

The Correlating Committee directs that FR 8114 be sent to all panels for information.

Related Item

• FR 8114

Submitter Information Verification

Submitter Full Name: CC on NEC-AAC

Organization: NEC Correlating Committee

Street Address:

City:

State:

Zip:

Submittal Date: Mon Aug 20 14:56:28 EDT 2018

Committee: NEC-P04

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Committee Statement

CommitteeAction:

Rejected

Resolution: Revisions made to 250.122 in the second draft resolved the issues regarding these publiccomments.

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Public Comment No. 360-NFPA 70-2018 [ Section No. 690.47(A) ]

(A) Buildings or Structures Supporting a PV System.

A building or structure(s) supporting a PV system shall

utilize

have a grounding electrode system

installed

in accordance with Part III of Article 250.

PV array equipment grounding conductors shall be connected to a grounding electrode system inaccordance with Part VII of Article 250. This connection shall be in addition to any other equipmentgrounding conductor requirements in 690.43(C) . The PV array equipment grounding conductors shall besized in accordance with 690.45 . For specific PV system grounding configurations

(1) For PV systems that are not solidly grounded, as permitted in 690.41(A),

one of

the

following conditions shall apply:For PV systems that are not solidly grounded, the

equipment grounding conductor for the output of the PV system, where connected to associateddistribution equipment that is connected to a grounding electrode system, shall be permitted to be theonly connection required to

ground for

the

system.For solidly grounded PV systems, as permitted in 690.41(A)(5) , the grounded conductor shall beconnected to a

grounding electrode system

by means of a grounding electrode conductor sized in accordance with 250

.

166.

Informational Note:

Most PV

PV systems are typically functionally grounded systems rather than solidly grounded systems as definedin

this

this Code . For functionally grounded PV systems with an interactive inverter output, the ac equipmentgrounding conductor is connected to associated grounded ac distribution equipment. This connection ismost often the connection to ground for ground-fault protection and equipment grounding of the PV array.

(2) For solidly grounded PV systems, as permitted in 690.41(A)(5), the grounded conductor shall beconnected to a grounding electrode system by means of a grounding electrode conductor sized inaccordance with 250.166.

Statement of Problem and Substantiation for Public Comment

I made a few edits to improve usability of this section as it related to Article 250... not technical changes.

Related Item

• FR-8417

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Submitter Information Verification

Submitter Full Name: Mike Holt

Organization: Mike Holt Enterprises Inc

Street Address:

City:

State:

Zip:

Submittal Date: Thu Aug 02 17:28:53 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected

Resolution: Though the proposed changes were not technical, the existing language from the first draft waspreferred by CMP-4.

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Public Comment No. 362-NFPA 70-2018 [ Section No. 690.47(B) ]

(B) Grounding Electrodes and Grounding Electrode Conductors.

Additional grounding electrodes shall be permitted to be

(4) Auxiliary Grounding Electrode. Auxiliary grounding electrode( s) installed in accordance with 250.

52 and 250.

54

. Grounding electrodes

shall be permitted

to be connected directly to the PV

, but not required for PV module frame(s) or support

structure. A grounding electrode conductor shall be sized according to 250.66 . A support structure for aground-mounted PV array shall be permitted to be considered a grounding electrode if it meets therequirements of 250.52 . PV arrays mounted to buildings shall be permitted to use the metal structuralframe of the building if the requirements of 250.68(C)(2) are met.

structures covered by this article .

Statement of Problem and Substantiation for Public Comment

I revised this text to have it follow the text used in 600.7 for Auxiliary Grounding Electrodes. Auxiliarly electrode(s), are electrodes that are not required by the NEC, but if they are installed, we need to have a rule to address it's installation requirement. A simple reference to 250.54 does all that needs to be done to cover this issue. Panel 4 does not need to reinvent the wheel with all kinds of complicated text. Panel 5 Grounding and Bonding, has already solved this task.

Related Item

• FR-8419

Submitter Information Verification

Submitter Full Name: Mike Holt

Organization: Mike Holt Enterprises Inc

Street Address:

City:

State:

Zip:

Submittal Date: Thu Aug 02 17:32:26 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected

Resolution: The first draft language in this section addresses several details in PV systems regardinggrounding electrodes and conductors. The references in this section, while not changing existingrequirements in Article 250, provide specific pointers to requirements that relate to equipmentunique to PV systems.

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Public Comment No. 1165-NFPA 70-2018 [ Section No. 690.56(C) ]

(C) Buildings with Rapid Shutdown.

Buildings with PV systems shall have a permanent label located at each service equipment location towhich the PV systems are connected or at an approved readily visible location and shall indicate thelocation of all identified rapid shutdown initiation devices, if not at the same location. The label shallinclude a simple diagram of a building with a roof and shall include the following words:

SOLAR PV SYSTEM IS EQUIPPED WITH RAPID SHUTDOWN. TURN RAPID SHUTDOWN SWITCHTO THE “OFF” POSITION TO SHUT DOWN PV SYSTEM AND REDUCE SHOCK HAZARD IN ARRAY.

The title “SOLAR PV SYSTEM IS EQUIPPED WITH RAPID SHUTDOWN” shall utilize capitalizedcharacters with a minimum height of 9.5 mm (3⁄8 in.) in black on yellow background, and the remainingcharacters shall be capitalized with a minimum height of 4.8 mm (3⁄16 in.) in black on white background.

Informational Note: See Informational Note Figure 690.56(C).

Figure 690.56(C) Label for Roof-Mounted PV Systems.

(1) Buildings with More Than One Rapid Shutdown Type.

For buildings that have PV systems with more than one rapid shutdown type or a PV system with no rapidshutdown, a detailed plan view diagram of the roof shall be provided showing each different PV systemand a dotted line around areas that remain energized after the rapid shutdown switch is operated.

(2) Rapid Shutdown Switch.

A rapid shutdown switch shall have a label that includes the following wording located on or no more than1 m (3 ft) from the switch:

RAPID SHUTDOWN SWITCH FOR SOLAR PV SYSTEM

The label shall be reflective, with all letters capitalized and having a minimum height of 9.5 mm (3⁄8 in.) inwhite on red background.

Additional Proposed Changes

File Name Description Approved

CN_226.pdf 70_CN 226

Statement of Problem and Substantiation for Public Comment

NOTE: This Public Comment appeared as CC Note No. 226 in the First Draft Report on First Revision No. 8715.

The Correlating Committee directs that “Informational Note” be added to Figure 690.56(C).

This action will be considered as a public comment.

Related Item

• FR 8715

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Submitter Information Verification

Submitter Full Name: CC on NEC-AAC

Organization: NEC Correlating Committee

Street Address:

City:

State:

Zip:

Submittal Date: Fri Aug 24 09:16:55 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected but see related SR

Resolution: SR-8102-NFPA 70-2018

Statement: The phrases “all identified” and “if not at the same location” have been removed from the mainparagraph since marking and location requirements for rapid shutdown initiation devices are in690.56(C)(2) and 690.12(C) respectfully.

The figure title has been changed to include the identification that it is an informational note.

Editorial changes were made to (C)(1) to further clarify the requirements.

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+,--./01234�+,55211..�6,1.�6,7�889:6;<=�>?:8?@A�B�C.D12,3�6,7�9E?7F9G+H�ICJK5211.-�L3M,-5012,3�N.-2M2D012,3CJK5211.-�;J//�605.OP�����Q� &"� +,55211..OCJK52110/�R01.O ���S�T�����U��V��W�XY �����+,55211..�C101.5.31�03Z�[..1234�6,1.\+,55211..C101.5.31O � ���Q���� ����Q������&��������]��������� ����_�����&&�&��������WV��UWQa��� ��������" ��������&���&��������� ���������������b���������(�U)�����(�)�����cP���������WV��UWQade0//,1�f.\J/1\�gh2\�21.5�h0\�i0\\.Z�K0//,1���X �� ��!���������������&���������b��� ��������b��"��Q������������b��"��Q���������������=MM2-5012j.�=//k�������l�m�����X�Y�������l�n�b��o�p�q���l��� ����o�p����l�Y�b&�o�p� ��l������&���m������l�S���� �m�n�b��ql�m������S�����l�� ��S�Y��� l�������Y������l�m�������P�����l�!�����m�# ���l�Y�b&���

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Public Comment No. 1763-NFPA 70-2018 [ Section No. 690.56(C)(1) ]

(1) Buildings with More Than One Rapid Shutdown Type.

For buildings that have PV systems with more than one rapid shutdown type(s) or a PV system(s) with norapid shutdown, a detailed plan view diagram of the roof shall be provided showing each differentPV system and with a dotted line around areas that remain energized after the rapid shutdown switch (s)is operated initiated .

Statement of Problem and Substantiation for Public Comment

With the multiple changes in rapid shutdown requirements over the last three code cycles and with more changes in the 2020 NEC and beyond, it is likely some roofs will have not just two types of Rapid Shutdown types. The changes will allow for these situations and still includes the possibility of rapid shutdown with legacy PV installations.

Related Item

• FR-8715

Submitter Information Verification

Submitter Full Name: Jason Fisher

Organization: Tesla Inc.

Affiliation: Solar Energy Industries Association (SEIA)

Street Address:

City:

State:

Zip:

Submittal Date: Wed Aug 29 22:06:17 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected but see related SR

Resolution: SR-8102-NFPA 70-2018

Statement: The phrases “all identified” and “if not at the same location” have been removed from the mainparagraph since marking and location requirements for rapid shutdown initiation devices are in690.56(C)(2) and 690.12(C) respectfully.

The figure title has been changed to include the identification that it is an informational note.

Editorial changes were made to (C)(1) to further clarify the requirements.

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Public Comment No. 1540-NFPA 70-2018 [ Section No. 690.56(C)(2) ]

(2) Rapid Shutdown Switch.

A rapid shutdown switch shall have a label that includes the following wording located on or no more than1 m (3 ft) from the switch:

RAPID SHUTDOWN SWITCH FOR SOLAR PV SYSTEM

The label shall be reflective, with all letters capitalized and having a minimum height of 9.5 mm ( 3 ⁄ 8 in.) incapitalized in white on red background.

Statement of Problem and Substantiation for Public Comment

It has come to my attention that the minimum size requirement for this label makes it impractical or impossible to install on some devices and adjacent to devices like breakers. If a breaker in a panel is the rapid shutdown switch, best practice would dictate that this label is installed on the exterior of the panel and on the interior of the panel adjacent to the correct switch. However, the label doesn't fit inside most residential service panels. An alternate approach would be to add an informational notes that ONE label must meet the required minimum size, but additional labels could be smaller.

Related Item

• FR-8715

Submitter Information Verification

Submitter Full Name: Rebekah Hren

Organization: IPPNC LLC

Street Address:

City:

State:

Zip:

Submittal Date: Wed Aug 29 11:00:10 EDT 2018

Committee: NEC-P04

Committee Statement

Committee Action: Rejected

Resolution: For this label to be effective, a minimum text size is required.

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Public Comment No. 1487-NFPA 70-2018 [ Section No. 690.56(C) [Excluding any Sub-

Sections] ]

Buildings with PV systems shall have a permanent label located at each service equipment location towhich the PV systems are connected or at an approved readily visible location and shall indicate thelocation of all identified rapid shutdown initiation devices, if not at the same location. The The rapidshutdown label shall include a simple diagram of a building with a roof and shall include the followingwords:

SOLAR PV SYSTEM IS EQUIPPED WITH RAPID SHUTDOWN. TURN RAPID SHUTDOWN SWITCHTO THE “OFF” POSITION TO SHUT DOWN PV SYSTEM AND REDUCE SHOCK HAZARD IN ARRAY.

The title “SOLAR PV SYSTEM IS EQUIPPED WITH RAPID SHUTDOWN” shall utilize capitalizedcharacters with a minimum height of 9.5 mm (3⁄8 in.) in black on yellow background, and the remainingcharacters shall be capitalized with a minimum height of 4.8 mm (3⁄16 in.) in black on white background.

Informational Note: See Informational Note Figure 690.56(C).

Figure 690.56(C) Label for Roof-Mounted PV Systems.

Statement of Problem and Substantiation for Public Comment

This comment supports another comment on 690.12(c) requiring a single initiation device to address the gap in hybrid inverter installations with ESS where the rapid shutdown initiator would fail to shut off the inverter.

Related Item

• FR 8715

Submitter Information Verification

Submitter Full Name: Anthony Granato

Organization: Manchester Fire Rescue EMS

Affiliation: International Association of Fire Fighters

Street Address:

City:

State:

Zip:

Submittal Date: Tue Aug 28 22:20:34 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected but see related SR

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Resolution: SR-8102-NFPA 70-2018

Statement: The phrases “all identified” and “if not at the same location” have been removed from the mainparagraph since marking and location requirements for rapid shutdown initiation devices are in690.56(C)(2) and 690.12(C) respectfully.

The figure title has been changed to include the identification that it is an informational note.

Editorial changes were made to (C)(1) to further clarify the requirements.

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Public Comment No. 1762-NFPA 70-2018 [ Section No. 690.56(C) [Excluding any Sub-

Sections] ]

Buildings with PV systems shall have a permanent label located at each service equipment location towhich the PV systems are connected or at an approved readily visible location and shall indicate thelocation of all identified rapid shutdown initiation devices, if not at the same location. The label shall includea simple diagram of a building with a roof and shall include the following words:

SOLAR PV SYSTEM IS EQUIPPED WITH RAPID SHUTDOWN. TURN RAPID SHUTDOWN SWITCHTO THE “OFF” POSITION TO SHUT DOWN PV SYSTEM AND REDUCE SHOCK HAZARD IN ARRAY.

The title “SOLAR PV SYSTEM IS EQUIPPED WITH RAPID SHUTDOWN” shall utilize capitalizedcharacters with a minimum height of 9.5 mm (3⁄8 in.) in black on yellow background, and the remainingcharacters shall be capitalized with a minimum height of 4.8 mm (3⁄16 in.) in black on white background.

Informational Note: See Informational Note Figure 690.56(C).

Informational Note Figure 690.56(C) Label for Roof-Mounted PV Systems with RapidShutdown .

Statement of Problem and Substantiation for Public Comment

The figure title should include the identification that it is an informational note.

Related Item

• FR-8715

Submitter Information Verification

Submitter Full Name: Jason Fisher

Organization: Tesla Inc.

Affiliation: Solar Energy Industries Association (SEIA)

Street Address:

City:

State:

Zip:

Submittal Date: Wed Aug 29 22:02:16 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected but see related SR

Resolution: SR-8102-NFPA 70-2018

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Statement: The phrases “all identified” and “if not at the same location” have been removed from the mainparagraph since marking and location requirements for rapid shutdown initiation devices are in690.56(C)(2) and 690.12(C) respectfully.

The figure title has been changed to include the identification that it is an informational note.

Editorial changes were made to (C)(1) to further clarify the requirements.

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Public Comment No. 1399-NFPA 70-2018 [ Section No. 691.1 ]

691.1 Scope.

This article covers the installation of large-scale PV electric supply stations with an inverter generatingcapacity of no less than 5000 kW, and not under exclusive utility control, and meeting the criteria of 691 .4.

Informational Note No. 1: Facilities covered by this article have specific design and safety featuresunique to large-scale PV facilities and are operated for the sole purpose of providing electric supplyto a system operated by a regulated utility for the transfer of electric energy.

Informational Note No. 2: Section 90.2(B)(5) includes information about utility-owned properties notcovered under this Code. For additional information on electric supply stations, see ANSI/IEEEC2-2017, National Electrical Safety Code.

Informational Note No. 3: See Informational Note Figure 691.1.

Figure Informational Note Figure 691.1 Identification of Large Scale PV Electric Supply StationComponents.

Statement of Problem and Substantiation for Public Comment

The 5MW limit is arbitrarily chosen and is not specifically related to any safety measures. All necessary criteria for "Large Scale PV Electric Supply Stations" are already listed in 691.4.

Related Item

• FR No. 8585-NFPA 70-2018

Submitter Information Verification

Submitter Full Name: Thomas A. Wegener

Organization: SMA Solar Technology AG

Street Address:

City:

State:

Zip:

Submittal Date: Tue Aug 28 04:39:49 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected

Resolution: The 5MW limit is needed to define the minimum threshold for the size of large scale PVsystems.

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Public Comment No. 1928-NFPA 70-2018 [ Section No. 691.1 ]

691.1 Scope.

This article covers the installation of large-scale PV electric supply stations with an inverter generatingcapacity of no less than 5000 kW, and not under exclusive utility control.

Informational Note No. 1: Facilities covered by this article have specific design and safety featuresunique to large-scale PV facilities and are operated for the sole purpose of providing electric supplyto a system operated by a regulated utility for the transfer of electric energy.

Informational Note No. 2: Section 90.2(B)(5) includes information about utility-owned properties notcovered under this Code. For additional information on electric supply stations, see ANSI/IEEEC2-2017, National Electrical Safety Code.

Informational Note No. 3: See Informational Note Figure 691.1.

Figure Informational Informational Note Figure 691.1 Identification of Large Scale PV ElectricSupply Station Components.

Statement of Problem and Substantiation for Public Comment

The word "Figure" at the start of the informational note is redundant.

Related Item

• FR 8585

Submitter Information Verification

Submitter Full Name: Lee Kraemer

Organization: First Solar

Affiliation: Large Scale Solar Association

Street Address:

City:

State:

Zip:

Submittal Date: Thu Aug 30 12:33:12 EDT 2018

Committee: NEC-P04

Committee Statement

Committee Action: Rejected

Resolution: The word "figure" cannot be deleted since it is part of the NEC template.

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Public Comment No. 806-NFPA 70-2018 [ Section No. 691.4 ]

691.4 Special Requirements for Large-Scale PV Electric Supply Stations.

Large-scale PV electric supply stations shall be accessible only to authorized personnel and comply withthe following:

(1) Electrical circuits and equipment shall be maintained and operated only by qualified personnel.

Informational Note: Refer to NFPA 70E -2018, Standard for Electrical Safety in the Workplace , forelectrical safety requirements.

(2) Access to PV electric supply stations shall be restricted by fencing or other adequate means inaccordance with 110.31. Field-applied hazard markings shall be applied in accordance with 110.21(B).

(3) The connection between the PV electric supply station and the system operated by a utility for thetransfer of electrical energy shall be through medium- or high-voltage switch gear, substation, switchyard, or similar methods whose sole purpose shall be to safely and effectively interconnect the twosystems.

(4) The electrical loads within the PV electric supply station shall only be used to power auxiliaryequipment for the generation of the PV power.

(5) Large-scale PV electric supply stations shall not be installed on buildings.

Statement of Problem and Substantiation for Public Comment

It's understood by the electrical industry that NFPA 70E is applicable here as it is elsewhere in the NEC for workplace safety. This note is not really needed. Since older versions of the NEC continue to be used long after new revisions of the NEC have been issued there is a danger that users will be directed to an out of date version of 70E. Better to just delete it.

Related Item

• First Revision No. 8948-NFPA 70-2018

Submitter Information Verification

Submitter Full Name: MARVIN HAMON

Organization: HAMON ENGINEERING INC

Street Address:

City:

State:

Zip:

Submittal Date: Fri Aug 17 23:35:37 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected

Resolution: NFPA 70E is frequently referenced in the Code to call attention to work-related safetyrequirements.

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Public Comment No. 1492-NFPA 70-2018 [ Section No. 691.5 ]

691.5 Equipment.

All electrical equipment shall be approved for installation by one of the following:

(1) Listing and labeling

(2) Field labeling Evaluation

(3) Where products complying with 691.5(1) or (2) are not available, by engineering review validating thatthe electrical equipment is evaluated and tested to relevant standards or industry practice

Statement of Problem and Substantiation for Public Comment

The process of how “field labeling” is accomplished is not defined or set in the NEC. The definition of “field labeled” does not set any requirement or statement that a “serialized” label is provided as stated in the panel resolution statement. The process that leads to a field label is a function of the “field evaluation” process requirements found in NFPA 790 and NFPA 791. It has been stated that the term “field labeled” infers that a field evaluation would be completed. This may be the intent of the panel, but it is poor code writing to set a requirement that infers a process instead of stating the process, field evaluation, that is to be completed.

The NFPA style manual section 2.3.2.3 prohibits definitions from having requirements in the definition and therefore definitions cannot be used as establishing requirements.

It is noted that the field evaluation process is under the purview of the NFPA Electrical Equipment Evaluation (EEE) Technical Committee.A product or equipment can achieve a “field label” where a field evaluation is completed which has five distinct steps. A brief summary of these procedures includes selection of the correct nationally recognized standard, conducting a complete evaluation of construction, performing applicable non-destructive field testing, and documentation in formal engineering reports to both the client and the Authority having jurisdiction. When the process is completed with satisfactory results, then the serialized “field label” of the FEB is applied.

Please see the related comments for the definition of "field evaluation (field evaluated)" and the new section 110.3(D) that sets the process requirement and FEB qualification criteria.

To permit only the “field label” as suitable evidence for “approval” has allowed and will continue to allow unqualified entities to give a false sense of adequacy when they are in fact not performing the necessary rigorous evaluation that is provided in the requirement of the NFPA 790 and NFPA 791 documents.If the panel believes the term “field labeled” is still the correct term, it is requested this item be referred the Correlating Committee for correlation between the NEC and the documents under the purview of the NFPA EEE committee.

Related Public Comments for This Document

Related Comment Relationship

Public Comment No. 1353-NFPA 70-2018 [New Definition after Definition: FestoonLighting.]

Public Comment No. 1489-NFPA 70-2018 [New Section after 110.3(C)]

Public Comment No. 1353-NFPA 70-2018 [New Definition after Definition: FestoonLighting.]

Public Comment No. 1489-NFPA 70-2018 [New Section after 110.3(C)]

Related Item

• PI 2612

Submitter Information Verification

Submitter Full Name: Charles Mello

Organization: Cdcmello Consulting Llc

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Affiliation: Self

Street Address:

City:

State:

Zip:

Submittal Date: Tue Aug 28 23:48:00 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected but see related SR

Resolution: SR-8221-NFPA 70-2018

Statement: Stating that equipment has a field evaluation does not guarantee that a field label is installed. NFPA791 includes a recommendation for a label to be installed but does not mandate it as quoted below.The process of applying a field label for field evaluated equipment is extremely important for AHJs.

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Public Comment No. 1461-NFPA 70-2018 [ Section No. 691.6 ]

691.6 Engineered Design.

Documentation of the electrical portion of the engineered design of the electric supply station shall bestamped and provided upon request of the AHJ. Additional stamped independent engineering reportsdetailing compliance of the design with applicable electrical standards and industry practice shall beprovided upon request of the AHJ. The independent engineer shall be a licensed professional electricalengineer retained by the system owner or installer. This . This documentation shall include details ofconformance of the design with Article 690, and any alternative methods to Article 690, or other articles ofthis Code.

Statement of Problem and Substantiation for Public Comment

In answering Public Input No. 3808-NFPA 70-2017 the committee resolution in part was, "The purpose of stating who is responsible for retaining the engineer is to clarify that the AHJ is not responsible for the costs and fees associated with retaining the independent engineer." It is not the purpose of the NEC, or the NFPA, to determine financial responsibility for the various aspects of projects or who pays for meeting requirements called out in the codes. It's common practice for AHJs to require engineered designs, calculations, and reports and I have let to hear of someone trying to make an AHJ pay for them. If the purpose of this wording ,as stated by the committee, is to control who pays for a requirement then it is inappropriate and should be removed.

Related Item

• Public Input No. 3808-NFPA 70-2017

Submitter Information Verification

Submitter Full Name: MARVIN HAMON

Organization: HAMON ENGINEERING INC

Street Address:

City:

State:

Zip:

Submittal Date: Tue Aug 28 17:19:26 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected

Resolution: The existing language defines who is responsible for producing 3rd party engineering reportswhen requested by an AHJ.

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Public Comment No. 1463-NFPA 70-2018 [ Section No. 691.7 ]

691.7 Conformance of Construction to Engineered Design.

Documentation that the construction of the electric supply station conforms to the electrical engineereddesign shall be provided upon request of the AHJ. Additional stamped independent engineering reportsdetailing the construction conforms with this Code, applicable standards and industry practice shall beprovided upon request of the AHJ. The independent engineer shall be a licensed professional electricalengineer retained by the system owner or installer . This documentation, where requested, shall beavailable prior to commercial operation of the station.

Statement of Problem and Substantiation for Public Comment

In answering Public Input No. 3810-NFPA 70-2017 the committee resolution in part was, "The intention of stating who is responsible for retaining the engineer is to clarify that the AHJ is not responsible for the costs and fees associated with retaining the independent engineer." It is not the purpose of the NEC, or the NFPA, to determine financial responsibility for the various aspects of projects or who pays for meeting requirements called out in the codes. It's common practice for AHJs to require engineered designs, calculations, and reports and I have let to hear of someone trying to make an AHJ pay for them. If the purpose of this wording ,as stated by the committee, is to control who pays for a requirement then it is inappropriate and should be removed.

Related Item

• Public Input No. 3810-NFPA 70-2017

Submitter Information Verification

Submitter Full Name: MARVIN HAMON

Organization: HAMON ENGINEERING INC

Street Address:

City:

State:

Zip:

Submittal Date: Tue Aug 28 17:29:16 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected

Resolution: The existing language defines who is responsible for producing 3rd party engineering reportswhen requested by an AHJ.

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Public Comment No. 1166-NFPA 70-2018 [ Section No. 691.9 ]

691.9 Disconnecting Means for Isolating Photovoltaic Equipment.

Isolating devices shall not be required within sight of equipment and may be located remotely fromequipment. The engineered design per 691.6 shall document disconnection procedures and means ofisolating equipment.

Informational Note: For information on electrical system maintenance, see NFPA 70B-2019,Recommended Practice for Electrical Equipment Maintenance. For information on writtenprocedures and conditions of maintenance, including lockout/tagout procedures, see NFPA70E-2018.

Buildings whose sole purpose is to house and protect supply station equipment shall not be required tocomply with 690.12. Written standard operating procedures shall be available at the site detailingnecessary shutdown procedures in the event of an emergency.

Additional Proposed Changes

File Name Description Approved

CN_228.pdf 70_CN 228

Statement of Problem and Substantiation for Public Comment

NOTE: This Public Comment appeared as CC Note No. 228 in the First Draft Report on First Revision No. 8440.

The Correlating Committee directs that consideration be given to the replacement of the word "per" with the phrase "in accordance with" to comply with the NEC Style Manual.

The Correlating Committee directs that the panel reconsider the text (use of the word “may”) to rewrite it in mandatory language.

This action will be considered as a public comment.

The Correlating Committee directs that FR 8440 be referred to Code-Making Panel 1 for information.

Related Item

• FR 8440

Submitter Information Verification

Submitter Full Name: CC on NEC-AAC

Organization: NEC Correlating Committee

Street Address:

City:

State:

Zip:

Submittal Date: Fri Aug 24 09:20:09 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected but see related SR

Resolution: SR-8112-NFPA 70-2018

Statement: Replaced the word “per” with the term “required by” rather than the phrase “in accordance with”for improved clarity. Additionally replaced “may” with the term “shall be permitted to”.

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Public Comment No. 1168-NFPA 70-2018 [ Section No. 691.11 ]

691.11 Fence Bonding and Grounding.

Fence grounding requirements and details shall be included in the documentation required in 691.6.

Informational Note: See 250.194 for fence bonding and grounding requirements enclosingsubstation portions of an electric supply station. Other portions of electric supply station fencingmay be assessed based on the presence of overhead conductors, proximity to generation anddistribution equipment, and associated step and touch potential.

Additional Proposed Changes

File Name Description Approved

CN_229.pdf 70_CN 229

Statement of Problem and Substantiation for Public Comment

NOTE: This Public Comment appeared as CC Note No. 229 in the First Draft Report on First Revision No. 8444.

The Correlating Committee directs the panel to reconsider the text of the informational note to remove permissive language. The use of the word “may” makes this permissive.

This action will be considered as a public comment.

Related Item

• FR 8444

Submitter Information Verification

Submitter Full Name: CC on NEC-AAC

Organization: NEC Correlating Committee

Street Address:

City:

State:

Zip:

Submittal Date: Fri Aug 24 09:23:57 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected but see related SR

Resolution: SR-8115-NFPA 70-2018

Statement: Added the term “Grounding requirements for” to add clarity and replaced the permissive term“may be” with “are” to eliminate the term “may”.

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Public Comment No. 1996-NFPA 70-2018 [ Section No. 691.11 ]

691.11 Fence Bonding and Grounding.

Fence grounding requirements and details shall be included in the documentation required in 691.6.

Informational Note: See 250.194 for fence bonding and grounding requirements enclosing substationportions of an electric supply station. Other Grounding requirements for other portions of electricsupply station fencing may be assessed based on the presence of overhead conductors, proximity togeneration and distribution equipment, and associated step and touch potential.

Statement of Problem and Substantiation for Public Comment

Added the words "Grounding requirements for" to the second sentence of the informational note to add clarity to the sentence.

Related Item

• FR-8444

Submitter Information Verification

Submitter Full Name: Lee Kraemer

Organization: First Solar

Affiliation: Large Scale Solar Association

Street Address:

City:

State:

Zip:

Submittal Date: Thu Aug 30 14:11:09 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected but see related SR

Resolution: SR-8115-NFPA 70-2018

Statement: Added the term “Grounding requirements for” to add clarity and replaced the permissive term“may be” with “are” to eliminate the term “may”.

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Public Comment No. 1861-NFPA 70-2018 [ Section No. 692.4(B) ]

(B) Identification of Power Sources.

Fuel cell systems shall be identified according to 692.4(B)(1) through (B)(3).

(1) Interconnected AC Systems.

Plaques or directories shall be installed in accordance with 705.10.

(2) Interconnected DC Microgrid Systems.

Plaques or directories shall be installed in accordance with 712.10(A) .

(3) Stand-Alone Systems.

Plaques or directories shall be installed in accordance with 710.10.

Statement of Problem and Substantiation for Public Comment

Changes made to this section are part of a larger group of changes to other articles that are being recommended in an effort to harmonize all directory requirements for onsite sources. During the public input phase we submitted several inputs that were also being coordinated with changes being proposed to other fire and building codes. Our intention is to standardize and harmonize these requirements to address the situation where different onsite sources may be installed by different groups at different times. During the First Draft state we received significant input and support by both CMP-13 and CMP-4 to improve our inputs. This comment is related to several other comments that realign all the changes made in the First Draft to ensure all requirements remain harmonized across the different articles.

Related Item

• FR-8485

Submitter Information Verification

Submitter Full Name: Jason Fisher

Organization: Tesla Inc.

Street Address:

City:

State:

Zip:

Submittal Date: Thu Aug 30 10:38:32 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected but see related SR

Resolution: SR-8117-NFPA 70-2018

Statement: The title has been changed to reflect Article 712, Direct Current Microgrids. All sections of712.10 may apply in different applications.

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Public Comment No. 1513-NFPA 70-2018 [ Section No. 692.6 ]

692.6 Listing Requirement.

The fuel cell system shall be listed or field labeled evaluated for its intended application.

Statement of Problem and Substantiation for Public Comment

The process of how “field labeled” is accomplished is not defined or set in the NEC. The definition of “field labeled” does not set any requirement or statement that a “serialized” label is provided as stated in the panel resolution statement. The process that leads to a field label is a function of the “field evaluation” process requirements found in NFPA 790 and NFPA 791. It has been stated that the term “field labeled” infers that a field evaluation would be completed. This may be the intent of the panel, but it is poor code writing to set a requirement that infers a process instead of stating the process, field evaluation, that is to be completed.

The NFPA style manual section 2.3.2.3 prohibits definitions from having requirements in the definition and therefore definitions cannot be used as establishing requirements.

It is noted that the field evaluation process is under the purview of the NFPA Electrical Equipment Evaluation (EEE) Technical Committee.A product or equipment can achieve a “field label” where a field evaluation is completed which has five distinct steps. A brief summary of these procedures includes selection of the correct nationally recognized standard, conducting a complete evaluation of construction, performing applicable non-destructive field testing, and documentation in formal engineering reports to both the client and the Authority having jurisdiction. When the process is completed with satisfactory results, then the serialized “field label” of the FEB is applied.

Please see the related comments for the definition of "field evaluation (field evaluated)" and the new section 110.3(D) that sets the process requirement and FEB qualification criteria.

To permit only the “field label” as suitable evidence for “approval” has allowed and will continue to allow unqualified entities to give a false sense of adequacy when they are in fact not performing the necessary rigorous evaluation that is provided in the requirement of the NFPA 790 and NFPA 791 documents.If the panel believes the term “field labeled” is still the correct term, it is requested this item be referred the Correlating Committee for correlation between the NEC and the documents under the purview of the NFPA EEE committee.

Related Public Comments for This Document

Related Comment Relationship

Public Comment No. 1353-NFPA 70-2018 [New Definition after Definition: FestoonLighting.]

Public Comment No. 1489-NFPA 70-2018 [New Section after 110.3(C)]

Public Comment No. 1353-NFPA 70-2018 [New Definition after Definition: FestoonLighting.]

Public Comment No. 1489-NFPA 70-2018 [New Section after 110.3(C)]

Related Item

• PI 2604

Submitter Information Verification

Submitter Full Name: Charles Mello

Organization: Cdcmello Consulting Llc

Affiliation: Self

Street Address:

City:

State:

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Zip:

Submittal Date: Wed Aug 29 09:55:25 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected but see related SR

Resolution: SR-8224-NFPA 70-2018

Statement: Stating that equipment has a field evaluation does not guarantee that a field label is installed. NFPA791 includes a recommendation for a label to be installed but does not mandate it as quoted below.The process of applying a field label for field evaluated equipment is extremely important for AHJs.

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Public Comment No. 1169-NFPA 70-2018 [ Section No. 694.2 ]

694.2 Definitions.

Diversion Charge Controller.

Equipment that regulates the charging process of a battery or other energy storage device by divertingpower from energy storage to dc or ac loads, or to an interconnected utility service.

Diversion Load.

A load connected to a diversion charge controller or diversion load controller, also known as a dump load.

Diversion Load Controller.

Equipment that regulates the output of a wind generator by diverting power from the generator to dc or acloads or to an interconnected utility service.

Maximum Output Power.

The maximum 1 minute average power output a wind turbine produces in normal steady-state operation(instantaneous power output can be higher).

Maximum Voltage.

The maximum voltage the wind turbine produces in operation including open circuit conditions.

Nacelle.

An enclosure housing the alternator and other parts of a wind turbine.

Rated Power.

The output power of a wind turbine at its rated wind speed.

Informational Note: The method for measuring wind turbine power output is specified in IEC61400-12-1, Power Performance Measurements of Electricity Producing Wind Turbines.

Tower (as applied to wind electric systems).

A pole or other structure that supports a wind turbine.

Wind Turbine.

A mechanical device that converts wind energy to electrical energy.

Wind Turbine Output Circuit.

The circuit conductors between the internal components of a wind turbine (which might include analternator, integrated rectifier, controller, and/or inverter) and other equipment.

Informational Note: See also definitions for interconnected systems in Article 705.

Additional Proposed Changes

File Name Description Approved

CN_161.pdf 70_CN 161

Statement of Problem and Substantiation for Public Comment

NOTE: This Public Comment appeared as CC Note No. 161 in the First Draft Report on First Revision No. 8492.

The Correlating Committee directs the panel to take action on section 694.2 to correlate with other actions taken throughout the code with respect to the application of definitions in the XXX.2 sections.

This action will be considered as a public comment.

Related Item

• FR 8492

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Submitter Information Verification

Submitter Full Name: CC on NEC-AAC

Organization: NEC Correlating Committee

Street Address:

City:

State:

Zip:

Submittal Date: Fri Aug 24 09:25:28 EDT 2018

Committee: NEC-P04

Committee Statement

Committee Action: Rejected but see related SR

Resolution: SR-8118-NFPA 70-2018

Statement: The added sentence defines the application of 694.2, Definitions.

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Public Comment No. 2123-NFPA 70-2018 [ Section No. 694.2 ]

694.2 Definitions. The definitions in this section shall apply only within this article.

Diversion Charge Controller.

Equipment that regulates the charging process of a battery or other energy storage device by divertingpower from energy storage to dc or ac loads, or to an interconnected utility service.

Diversion Load.

A load connected to a diversion charge controller or diversion load controller, also known as a dump load.

Diversion Load Controller.

Equipment that regulates the output of a wind generator by diverting power from the generator to dc or acloads or to an interconnected utility service.

Maximum Output Power.

The maximum 1 minute average power output a wind turbine produces in normal steady-state operation(instantaneous power output can be higher).

Maximum Voltage.

The maximum voltage the wind turbine produces in operation including open circuit conditions.

Nacelle.

An enclosure housing the alternator and other parts of a wind turbine.

Rated Power.

The output power of a wind turbine at its rated wind speed.

Informational Note: The method for measuring wind turbine power output is specified in IEC61400-12-1, Power Performance Measurements of Electricity Producing Wind Turbines.

Tower (as applied to wind electric systems).

A pole or other structure that supports a wind turbine.

Wind Turbine.

A mechanical device that converts wind energy to electrical energy.

Wind Turbine Output Circuit.

The circuit conductors between the internal components of a wind turbine (which might include analternator, integrated rectifier, controller, and/or inverter) and other equipment.

Informational Note: See also definitions for interconnected systems in Article 705.

Statement of Problem and Substantiation for Public Comment

The proposed language is part of a global effort to provide guidance to the user of the code regarding applicability of definitions located in the .2 sections within individual articles. The language makes it clear that the definitions apply only within Article 694.

Related Item

• CN 161

Submitter Information Verification

Submitter Full Name: Christel Hunter

Organization: Cerro Wire

Street Address:

City:

State:

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Zip:

Submittal Date: Thu Aug 30 19:28:21 EDT 2018

Committee: NEC-P04

Committee Statement

Committee Action: Rejected but see related SR

Resolution: SR-8118-NFPA 70-2018

Statement: The added sentence defines the application of 694.2, Definitions.

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Public Comment No. 1170-NFPA 70-2018 [ Section No. 694.7 ]

694.7 Installation.

Systems covered by this article shall be installed only by qualified persons.

Informational Note: See Article 100 for the definition of Qualified Person.

(A) Wind Electric Systems.

A wind electric system(s) shall be permitted to supply a building or other structure in addition to othersources of supply.

(B) Equipment.

Wind electric systems shall be listed and labeled or field labeled for the application. Wind electric systemsundergoing evaluation for type certification and listing shall be permitted to be operated in a controlledlocation with access limited to qualified personnel.

Informational Note: Testing for certification and listing is typically performed under the supervision ofa qualified electrical testing organization. Qualified testing organizations may also be used forelectrical system assessments to assist local authorities having jurisdiction.

(C) Diversion Load Controllers.

A wind electric system employing a diversion load controller as the primary means of regulating the speedof a wind turbine rotor shall be equipped with an additional, independent, reliable means to prevent over-speed operation. An interconnected utility service shall not be considered to be a reliable diversion load.

(D) Surge Protective Devices (SPD).

A surge protective device shall be installed between a wind electric system and any loads served by thepremises electrical system. The surge protective device shall be permitted to be a Type 3 SPD on thecircuit serving a wind electric system or a Type 2 SPD located anywhere on the load side of the servicedisconnect. Surge protective devices shall be installed in accordance with Part II of Article 285.

(E) Receptacles.

A receptacle shall be permitted to be supplied by a wind electric system branch or feeder circuit formaintenance or data acquisition use. Receptacles shall be protected with an overcurrent device with arating not to exceed the current rating of the receptacle. All 125-volt, single-phase, 15- and 20-amperereceptacles installed for maintenance of the wind turbine shall have ground-fault circuit-interrupterprotection for personnel.

(F) Poles or Towers Supporting Wind Turbines Used as a Raceway.

A pole or tower shall be permitted to be used as a raceway if evaluated as part of the listing for the windturbine or otherwise shall be listed or field labeled for the purpose.

(G) Working Clearances.

Working space shall be provided for electrical cabinets and other electrical equipment in accordance with110.26(A).

For large wind turbines where service personnel enter the equipment, where conditions of maintenanceand supervision ensure that only qualified persons perform the work, working clearances shall bepermitted to comply with Table 694.7 for systems up to 1000 V nominal.

Table 694.7 Working Spaces

Nominal Voltage to Ground Condition 1 Condition 2 Condition 3

0–150 900 mm (3 ft) 900 mm (3 ft) 900 mm (3 ft)

151–1000 900 mm (3 ft) 1.0 m (3 ft 6 in.) 1.2 m (4 ft)

Additional Proposed Changes

File Name Description Approved

CN_230.pdf 70_CN 230

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Statement of Problem and Substantiation for Public Comment

NOTE: This Public Comment appeared as CC Note No. 230 in the First Draft Report on First Revision No. 8501.

The Correlating Committee directs the panel to reconsider the text of the informational note to remove permissive language. The use of the word “may” makes this permissive.

This action will be considered as a public comment.

Related Item

• FR 8501

Submitter Information Verification

Submitter Full Name: CC on NEC-AAC

Organization: NEC Correlating Committee

Street Address:

City:

State:

Zip:

Submittal Date: Fri Aug 24 09:28:05 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected but see related SR

Resolution: SR-8119-NFPA 70-2018

Statement: Stating that equipment has a field evaluation does not guarantee that a field label is installed. NFPA791 includes a recommendation for a label to be installed but does not mandate it as quoted below.The process of applying a field label for field evaluated equipment is extremely important for AHJs.

The second sentence in the informational note does not add to understanding of the section and isnot directly relevant to the sentence it supports. Deleting the sentence addresses the word “may”.

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+,--./01234�+,55211..�6,1.�6,7�89:;6<=>�?:;8:@A�B�C.D12,3�6,7�EFG7?HIJ�KCLM5211.-�N3O,-5012,3�P.-2O2D012,3CLM5211.-�<L//�605.QR�����S� &"� +,55211..QCLM52110/�T01.Q ���U�V�����W�X(����YZ �����+,55211..�C101.5.31�03[�\..1234�6,1.]+,55211..C101.5.31Q� ���S���� ����S������&������������ ���������&����������������������� ����������_��������_�� ��������� �������������"��&���Va���b������������_��� �������" ��������&���&��������� ���������������_���������W��)�����(�)�����cR���������de��(fghiI0//,1�j.]L/1]�kl2]�21.5�l0]�m0]].[�M0//,1���Y �� ��!���������������&���������_��� ��������_��"��S������������_��"��S���������������>OO2-5012n.�>//g�������o�p�����Y�Z�������o�q�_��r�s�b���o��� ����r�s����o�Z�_&�r�s� ��o������&���p������o�U���� �p�q�_��bo�p������U�����o�� ��U�Z��� o�������Z������o�p�������R�����o�!�����p�# ���o�Z�_&���

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Public Comment No. 1518-NFPA 70-2018 [ Section No. 694.7(B) ]

(B) Equipment.

Wind electric systems shall be listed and labeled or field labeled evaluated for the application. Windelectric systems undergoing evaluation for type certification and listing shall be permitted to be operated ina controlled location with access limited to qualified personnel.

Informational Note: Testing for certification and listing is typically performed under the supervision ofa qualified electrical testing organization. Qualified testing organizations may also be used forelectrical system assessments to assist local authorities having jurisdiction.

Statement of Problem and Substantiation for Public Comment

The process of how “field labeled” is accomplished is not defined or set in the NEC. The definition of “field labeled” does not set any requirement or statement that a “serialized” label is provided as stated in the panel resolution statement. The process that leads to a field label is a function of the “field evaluation” process requirements found in NFPA 790 and NFPA 791. It has been stated that the term “field labeled” infers that a field evaluation would be completed. This may be the intent of the panel, but it is poor code writing to set a requirement that infers a process instead of stating the process, field evaluation, that is to be completed.

The NFPA style manual section 2.3.2.3 prohibits definitions from having requirements in the definition and therefore definitions cannot be used as establishing requirements.

It is noted that the field evaluation process is under the purview of the NFPA Electrical Equipment Evaluation (EEE) Technical Committee.A product or equipment can achieve a “field label” where a field evaluation is completed which has five distinct steps. A brief summary of these procedures includes selection of the correct nationally recognized standard, conducting a complete evaluation of construction, performing applicable non-destructive field testing, and documentation in formal engineering reports to both the client and the Authority having jurisdiction. When the process is completed with satisfactory results, then the serialized “field label” of the FEB is applied.

Please see the related comments for the definition of "field evaluation (field evaluated)" and the new section 110.3(D) that sets the process requirement and FEB qualification criteria.

To permit only the “field label” as suitable evidence for “approval” has allowed and will continue to allow unqualified entities to give a false sense of adequacy when they are in fact not performing the necessary rigorous evaluation that is provided in the requirement of the NFPA 790 and NFPA 791 documents.If the panel believes the term “field labeled” is still the correct term, it is requested this item be referred the Correlating Committee for correlation between the NEC and the documents under the purview of the NFPA EEE committee.

Related Public Comments for This Document

Related Comment Relationship

Public Comment No. 1353-NFPA 70-2018 [New Definition after Definition: FestoonLighting.]

Public Comment No. 1489-NFPA 70-2018 [New Section after 110.3(C)]

Public Comment No. 1353-NFPA 70-2018 [New Definition after Definition: FestoonLighting.]

Public Comment No. 1489-NFPA 70-2018 [New Section after 110.3(C)]

Related Item

• PI 2605

Submitter Information Verification

Submitter Full Name: Charles Mello

Organization: Cdcmello Consulting Llc

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Affiliation: Self

Street Address:

City:

State:

Zip:

Submittal Date: Wed Aug 29 09:59:46 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected but see related SR

Resolution: SR-8119-NFPA 70-2018

Statement: Stating that equipment has a field evaluation does not guarantee that a field label is installed. NFPA791 includes a recommendation for a label to be installed but does not mandate it as quoted below.The process of applying a field label for field evaluated equipment is extremely important for AHJs.

The second sentence in the informational note does not add to understanding of the section and isnot directly relevant to the sentence it supports. Deleting the sentence addresses the word “may”.

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Public Comment No. 1771-NFPA 70-2018 [ Section No. 694.7(B) ]

(B) Equipment.

Wind electric systems shall be listed and labeled or field labeled for the application. Wind electric systemsundergoing evaluation for type certification and listing shall be permitted to be operated in a controlledlocation with access limited to qualified personnel.

Informational Note: Testing for certification and listing is typically performed under the supervision ofa qualified electrical testing organization. Qualified testing organizations may also be aresometimes used for electrical system assessments to assist local authorities having jurisdiction.

Statement of Problem and Substantiation for Public Comment

The word "also" does not add value. The intended use of the term "may" was replaced with "are sometimes" to be informative only.

Related Item

• FR-8501

Submitter Information Verification

Submitter Full Name: Jason Fisher

Organization: Tesla Inc.

Affiliation: Solar Energy Industries Association (SEIA)

Street Address:

City:

State:

Zip:

Submittal Date: Wed Aug 29 22:30:34 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected but see related SR

Resolution: SR-8119-NFPA 70-2018

Statement: Stating that equipment has a field evaluation does not guarantee that a field label is installed. NFPA791 includes a recommendation for a label to be installed but does not mandate it as quoted below.The process of applying a field label for field evaluated equipment is extremely important for AHJs.

The second sentence in the informational note does not add to understanding of the section and isnot directly relevant to the sentence it supports. Deleting the sentence addresses the word “may”.

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Public Comment No. 1649-NFPA 70-2018 [ Section No. 694.7(E) ]

(E) Receptacles.

A receptacle shall be permitted to be supplied by a wind electric system branch or feeder circuit formaintenance or data acquisition use. Receptacles shall be protected with an overcurrent device with arating not to exceed the current rating of the receptacle. All In addition to the requirements in 210.8, all125-volt, single-phase, 15- and 20-ampere receptacles installed for maintenance of the wind turbine shallhave ground-fault circuit-interrupter protection for personnel.

Statement of Problem and Substantiation for Public Comment

This Public Comment is the work of an NEC Correlating Committee task group directed to develop standardized text to improve correlation, clarity and usability of the NEC. This effort identified GFCI requirements that supplement or modify the general requirements of 210.8. The present GFCI requirements throughout the NEC were developed by various Technical Committees when the general GFCI requirements in 210.8 were limited to dwelling units. The consequences of time and various committees working to enhance safety have created significant correlation issues with the general requirements in 210.8. The arrangement of the NEC, as detailed in 90.3 clarifies that the general requirements of Chapters 1 through 4 apply “generally to all electrical installations.” The work of this Task Group resulted in 41 public comments to provide necessary correlation, clarity and usability. The task group’s work was identified in and based upon Correlating Committee Note 152 to the 2020 First Revisions. The Task Group members consisted of Jim Dollard, Chair, Steve Campolo, Donny Cook, Tom Domitrovich, Mark Hilbert, Keith Lofland, Alan Manche and Steve Rood.

Related Item

• CCN 152

Submitter Information Verification

Submitter Full Name: James Dollard

Organization: IBEW Local Union 98

Street Address:

City:

State:

Zip:

Submittal Date: Wed Aug 29 14:18:50 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Accepted

Resolution: SR-8121-NFPA 70-2018

Statement: The additional text clarifies that the general requirements for GFCIs from 210.8 are alsoapplicable.

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Public Comment No. 1519-NFPA 70-2018 [ Section No. 694.7(F) ]

(F) Poles or Towers Supporting Wind Turbines Used as a Raceway.

A pole or tower shall be permitted to be used as a raceway if evaluated as part of the listing for the windturbine or otherwise shall be listed or field labeled evaluated for the purpose.

Statement of Problem and Substantiation for Public Comment

The process of how “field labeled” is accomplished is not defined or set in the NEC. The definition of “field labeled” does not set any requirement or statement that a “serialized” label is provided as stated in the panel resolution statement. The process that leads to a field label is a function of the “field evaluation” process requirements found in NFPA 790 and NFPA 791. It has been stated that the term “field labeled” infers that a field evaluation would be completed. This may be the intent of the panel, but it is poor code writing to set a requirement that infers a process instead of stating the process, field evaluation, that is to be completed.

The NFPA style manual section 2.3.2.3 prohibits definitions from having requirements in the definition and therefore definitions cannot be used as establishing requirements.

It is noted that the field evaluation process is under the purview of the NFPA Electrical Equipment Evaluation (EEE) Technical Committee.A product or equipment can achieve a “field label” where a field evaluation is completed which has five distinct steps. A brief summary of these procedures includes selection of the correct nationally recognized standard, conducting a complete evaluation of construction, performing applicable non-destructive field testing, and documentation in formal engineering reports to both the client and the Authority having jurisdiction. When the process is completed with satisfactory results, then the serialized “field label” of the FEB is applied.

Please see the related comments for the definition of "field evaluation (field evaluated)" and the new section 110.3(D) that sets the process requirement and FEB qualification criteria.

To permit only the “field label” as suitable evidence for “approval” has allowed and will continue to allow unqualified entities to give a false sense of adequacy when they are in fact not performing the necessary rigorous evaluation that is provided in the requirement of the NFPA 790 and NFPA 791 documents.If the panel believes the term “field labeled” is still the correct term, it is requested this item be referred the Correlating Committee for correlation between the NEC and the documents under the purview of the NFPA EEE committee.

Related Public Comments for This Document

Related Comment Relationship

Public Comment No. 1353-NFPA 70-2018 [New Definition after Definition: FestoonLighting.]

Public Comment No. 1489-NFPA 70-2018 [New Section after 110.3(C)]

Public Comment No. 1353-NFPA 70-2018 [New Definition after Definition: FestoonLighting.]

Public Comment No. 1489-NFPA 70-2018 [New Section after 110.3(C)]

Related Item

• PI 2607

Submitter Information Verification

Submitter Full Name: Charles Mello

Organization: Cdcmello Consulting Llc

Affiliation: Self

Street Address:

City:

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State:

Zip:

Submittal Date: Wed Aug 29 10:01:53 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected but see related SR

Resolution: SR-8226-NFPA 70-2018

Statement: Stating that equipment has a field evaluation does not guarantee that a field label is installed. NFPA791 includes a recommendation for a label to be installed but does not mandate it as quoted below.The process of applying a field label for field evaluated equipment is extremely important for AHJs.

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Public Comment No. 1864-NFPA 70-2018 [ Section No. 694.54 ]

694.54 Identification of Power Sources.

Wind turbine systems shall be identified according to 694.54(A) through (B).

(A) Interconnected AC Systems.

Plaques or directories shall be installed in accordance with 705.10.

(B) Interconnected DC Microgrid Systems.

Plaques or directories shall be installed in accordance with 712.10(A) .

(C) Stand-Alone Systems.

Plaques or directories shall be installed in accordance with 710.10.

Statement of Problem and Substantiation for Public Comment

Changes made to this section are part of a larger group of changes to other articles that are being recommended in an effort to harmonize all directory requirements for onsite sources. During the public input phase we submitted several inputs that were also being coordinated with changes being proposed to other fire and building codes. Our intention is to standardize and harmonize these requirements to address the situation where different onsite sources may be installed by different groups at different times. During the First Draft state we received significant input and support by both CMP-13 and CMP-4 to improve our inputs. This comment is related to several other comments that realign all the changes made in the First Draft to ensure all requirements remain harmonized across the different articles.

Related Item

• FR-8513

Submitter Information Verification

Submitter Full Name: Jason Fisher

Organization: Tesla Inc.

Street Address:

City:

State:

Zip:

Submittal Date: Thu Aug 30 10:41:24 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected but see related SR

Resolution: SR-8122-NFPA 70-2018

Statement: The title has been changed to reflect Article 712, Direct Current Microgrids. All sections of712.10 may apply in different applications.

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Public Comment No. 1504-NFPA 70-2018 [ New Section after 705.2 ]

705.3 Other Articles. Interconnected electric power production sources shall comply with this article and alsowith the applicable requirements of the articles in Table 705.3. Table 705.3 Other Articles Equipment/System ArticleGenerators 445Solar photovoltaic systems 690Fuel cell systems 692Wind electric systems 694Emergency systems 700Legally required standby systems 701Optional standby systems 702Energy storage systems 706Stand-alone systems 710DC microgrids 712

Statement of Problem and Substantiation for Public Comment

Undelete

This language was removed simply to take wording out of the code book. Even though the experienced user of the NEC doesn’t necessarily need these references someone new to multi source installations may find this information valuable. It is not the job of any CMP to remove code language for the sake of making the code smaller.

Related Item

• FR 8599

Submitter Information Verification

Submitter Full Name: David Clements

Organization: Intl Assoc Elec Insp

Street Address:

City:

State:

Zip:

Submittal Date: Wed Aug 29 08:47:16 EDT 2018

Committee: NEC-P04

Committee Statement

Committee Action: Rejected

Resolution: The NEC Style Manual does not permit broad references to other articles.

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Public Comment No. 1760-NFPA 70-2018 [ New Section after 705.2 ]

Restore 705.3

Statement of Problem and Substantiation for Public Comment

There was no technical rationale for deleting 705.3 this Section may not be important to regular users of Article 705 but may be of assistance to those that do not use the Article. Many Articles throughout the NEC use the .3 Section to reference other Articles that may need to be reviewed for their associated compliance. There is no sound reason for not doing that here as well

Related Item

• FR8599

Submitter Information Verification

Submitter Full Name: James Rogers

Organization: Towns Of Oak Bluffs, Tisbury,

Street Address:

City:

State:

Zip:

Submittal Date: Wed Aug 29 21:30:23 EDT 2018

Committee: NEC-P04

Committee Statement

Committee Action: Rejected

Resolution: The NEC Style Manual does not permit broad references to other articles.

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Public Comment No. 1772-NFPA 70-2018 [ Definition: Microgrid Interconnect Device

(MID). ]

Microgrid Interconnect Device (MID).

A device that allows enables a microgrid system to separate from and reconnect to operate in parallel witha primary power source.

Informational Note. Microgrid controllers typically are used to measure and evaluate electrical parameters,provide the logic for and the signal to initiate and complete transition processes. IEEE Std 1547 and IEEEStd 2030.7 and IEEE Std 2030.8 provide information on interconnect requirements, dispatch and transitionprocesses.

Statement of Problem and Substantiation for Public Comment

This definition is important to distinguish these devices, which isolate or connect different sources in parallel, as being different from transfer switches, which always isolate different sources from one another. This text would be improved however, by adding the phrase "to operate" before the phrase "in parallel".

Related Item

• FR-8592

Submitter Information Verification

Submitter Full Name: Jason Fisher

Organization: Tesla Inc.

Affiliation: Solar Energy Industries Association (SEIA)

Street Address:

City:

State:

Zip:

Submittal Date: Wed Aug 29 22:32:33 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected but see related SR

Resolution: SR-8146-NFPA 70-2018

Statement: Grammatical changes are made to this definition with a new informational note added todistinguish these devices, which isolate or connect different sources in parallel, as being differentfrom transfer switches, which always isolate different sources from one another.

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Public Comment No. 1775-NFPA 70-2018 [ Definition: Power Source Output Circuit. ]

Power Source Output Circuit.

The conductors between power production equipment or a power source and the service or distributionequipment.

Statement of Problem and Substantiation for Public Comment

Including the phrase "or power source" will likely cause confusion as to how to apply this new term. The defined term "power production equipment" is general enough to cover any source as a system. Including "or power source" might cause someone to think that the conductors between a PV array (dc) and a PV inverter should be called Power Source Output Circuit conductors, when in fact these conductors are defined uniquely in Artile 690 as PV source or PV output conductors. By limiting this definition to the term power production equipment, the Committee will make clear we are not talking about any conductors other than the conductor that leave the source's system disconnect to the point where they connect to another distribution or service conductor or equipment.

Related Item

• FR-8596

Submitter Information Verification

Submitter Full Name: Jason Fisher

Organization: Tesla Inc.

Affiliation: Solar Energy Industries Association (SEIA)

Street Address:

City:

State:

Zip:

Submittal Date: Wed Aug 29 22:38:50 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Accepted

Resolution: SR-8147-NFPA 70-2018

Statement: The phrase "or power source" is deleted from this term since it is unnecessary. The defined term"power production equipment" is general enough to cover any source as a system.

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Public Comment No. 2089-NFPA 70-2018 [ New Definition after Definition: Power

Source Output Circui... ]

705.3 Other Articles

Interconnected electric power production sources shall comply with this article and also with the applicablerequirements of the articles in Table 705.3.

Table 705.3 Other Articles

Equipment/System Article

Generators 445

Solar photovoltaic systems 690

Fuel cell systems 692

Wind electric systems 694

Emergency systems 700

Legally required standby systems 701

Optional standby systems 702

Energy storage systems 706

Stand-alone systems 710

DC microgrids 712

Statement of Problem and Substantiation for Public Comment

This input reinstates the "Other Articles" table that was deleted in the first draft. While not all users of the Code will need this table, its presence at the beginning of Article 705 can be helpful to some users particularly since this article will apply to applications where many of the systems mentioned in the table could be interconnected to other systems. We recommend the Committee add this table 705.3 back in to this article.

Related Item

• FR-8599

Submitter Information Verification

Submitter Full Name: Jason Fisher

Organization: Tesla Inc.

Street Address:

City:

State:

Zip:

Submittal Date: Thu Aug 30 16:50:31 EDT 2018

Committee: NEC-P04

Committee Statement

Committee Action: Rejected

Resolution: The NEC Style Manual does not permit broad references to other articles.

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Public Comment No. 1428-NFPA 70-2018 [ Section No. 705.6 ]

705.6 Equipment Approval.

All equipment shall be approved for the intended use. Interactive equipment intended to operate in parallelwith electric power production sources including, but not limited to, interactive inverters, engine generators,energy storage equipment, and wind turbines shall be listed or field labeled , or both, for the intended useof interconnection service.

Statement of Problem and Substantiation for Public Comment

The current text refers to energy storage and other equipment and that such interactive power supplying equipment (e.g. ESS) must be listed or field labeled or both. The subject language has multiple requirements in that it says listed OR field labeled and then says or both. For a minimum standard it is not appropriate to have multiple requirements (e.g. and/or). Such equipment should be listed OR field labeled not both. In practice those seeking a permit would likely opt for the 'or' as would many AHJs. That said the existence of and/or opens the door for someone to require both and in a neighboring jurisdiction accept either.

Related Item

• 8602-NFPA 70-2018

Submitter Information Verification

Submitter Full Name: David Conover

Organization: Pacific Northwest National Lab

Street Address:

City:

State:

Zip:

Submittal Date: Tue Aug 28 13:33:47 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected

Resolution: The existing language allows for equipment or systems that may include both listed equipment, andequipment whose existing listing, or lack of listing, would require field labeling for the specificapplication. Furthermore, it is possible that listed equipment could be modified in the field in such away that could require field labeling.

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Public Comment No. 1521-NFPA 70-2018 [ Section No. 705.6 ]

705.6 Equipment Approval.

All equipment shall be approved for the intended use. Interactive equipment intended to operate in parallelwith electric power production sources including, but not limited to, interactive inverters, engine generators,energy storage equipment, and wind turbines shall be listed or field labeled evaluated , or both, for theintended use of interconnection service.

Statement of Problem and Substantiation for Public Comment

The process of how “field labeled” is accomplished is not defined or set in the NEC. The definition of “field labeled” does not set any requirement or statement that a “serialized” label is provided as stated in the panel resolution statement. The process that leads to a field label is a function of the “field evaluation” process requirements found in NFPA 790 and NFPA 791. It has been stated that the term “field labeled” infers that a field evaluation would be completed. This may be the intent of the panel, but it is poor code writing to set a requirement that infers a process instead of stating the process, field evaluation, that is to be completed.

The NFPA style manual section 2.3.2.3 prohibits definitions from having requirements in the definition and therefore definitions cannot be used as establishing requirements.

It is noted that the field evaluation process is under the purview of the NFPA Electrical Equipment Evaluation (EEE) Technical Committee.A product or equipment can achieve a “field label” where a field evaluation is completed which has five distinct steps. A brief summary of these procedures includes selection of the correct nationally recognized standard, conducting a complete evaluation of construction, performing applicable non-destructive field testing, and documentation in formal engineering reports to both the client and the Authority having jurisdiction. When the process is completed with satisfactory results, then the serialized “field label” of the FEB is applied.

Please see the related comments for the definition of "field evaluation (field evaluated)" and the new section 110.3(D) that sets the process requirement and FEB qualification criteria.

To permit only the “field label” as suitable evidence for “approval” has allowed and will continue to allow unqualified entities to give a false sense of adequacy when they are in fact not performing the necessary rigorous evaluation that is provided in the requirement of the NFPA 790 and NFPA 791 documents.If the panel believes the term “field labeled” is still the correct term, it is requested this item be referred the Correlating Committee for correlation between the NEC and the documents under the purview of the NFPA EEE committee.

Related Public Comments for This Document

Related Comment Relationship

Public Comment No. 1353-NFPA 70-2018 [New Definition after Definition: FestoonLighting.]

Public Comment No. 1489-NFPA 70-2018 [New Section after 110.3(C)]

Public Comment No. 1353-NFPA 70-2018 [New Definition after Definition: FestoonLighting.]

Public Comment No. 1489-NFPA 70-2018 [New Section after 110.3(C)]

Related Item

• PI 2608

Submitter Information Verification

Submitter Full Name: Charles Mello

Organization: Cdcmello Consulting Llc

Affiliation: Self

Street Address:

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City:

State:

Zip:

Submittal Date: Wed Aug 29 10:04:25 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected but see related SR

Resolution: SR-8228-NFPA 70-2018

Statement: Stating that equipment has a field evaluation does not guarantee that a field label is installed. NFPA791 includes a recommendation for a label to be installed but does not mandate it as quoted below.The process of applying a field label for field evaluated equipment is extremely important for AHJs.

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Public Comment No. 1171-NFPA 70-2018 [ Section No. 705.10 ]

705.10 Identification of Power Sources.

A permanent plaque or directory shall be installed at each service equipment location, or at an approvedreadily visible location. The plaque or directory shall denote the location of each power sourcedisconnecting means for the premises or be grouped with other plaques or directories for other on-sitesources. The plaque or directory shall be marked with the wording “CAUTION: MULTIPLE SOURCES OFPOWER”. Any diagrams shall be correctly oriented with respect to the diagram's location. The markingshall comply with 110.21(B).

Exception: Installations with multiple co-located power production sources shall be permitted to beidentified as a group(s). The plaque or directory shall not be required to identify each power sourceindividually.

Additional Proposed Changes

File Name Description Approved

CN_233.pdf 70_CN 233

Statement of Problem and Substantiation for Public Comment

NOTE: This Public Comment appeared as CC Note No. 233 in the First Draft Report on First Revision No. 8608.

The Correlating Committee directs the pound (#) symbol be removed from 705.11(B).

This action will be considered as a public comment.

The Correlating Committee directs that FR 8608 be referred to Code-Making Panels 5 and 10 for information.

Related Item

• FR 8608

Submitter Information Verification

Submitter Full Name: CC on NEC-AAC

Organization: NEC Correlating Committee

Street Address:

City:

State:

Zip:

Submittal Date: Fri Aug 24 09:33:07 EDT 2018

Committee: NEC-P04

Committee Statement

Committee Action: Rejected but see related SR

Resolution: SR-8155-NFPA 70-2018

Statement: The "#" symbol was removed to comply with the NEC Style Manual.

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Public Comment No. 1466-NFPA 70-2018 [ Section No. 705.10 ]

705.10 Identification of Power Sources.

A permanent plaque or directory shall be installed at each service equipment location, or at an approvedreadily visible location. The plaque or directory shall denote:

1) The system type (string with dc/dc optimizers, string without dc/dc optimizers, microinverter, ac module,multimode (grid interconnected with battery)), the location of each power source disconnecting means forthe premises or be grouped with other plaques or directories for other on-site sources. The plaque ordirectory shall be marked with the wording “CAUTION: MULTIPLE SOURCES OF POWER”. Any diagramsshall be correctly oriented with respect to the diagram's location. The marking shall comply with 110.21(B).

Exception: Installations with multiple co-located power production sources shall be permitted to beidentified as a group(s). The plaque or directory shall not be required to identify each power sourceindividually.

Statement of Problem and Substantiation for Public Comment

Requiring system type on the Directory would provide more immediate information to Emergency Personnel. De-energizing dc per earlier comments and ac would afford more certain de-energizing to Emergency Personnel.

Under current wording, Emergency Personnel have scant information available to divine system type, especially in an emergency.

Related Item

• PI

Submitter Information Verification

Submitter Full Name: Christopher Warfel

Organization: ENTECH Engineering, Inc.

Street Address:

City:

State:

Zip:

Submittal Date: Tue Aug 28 17:51:43 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected

Resolution: Details regarding types of PV systems should not be outlined in Article 705 which addresses theinterconnection of any type of power production equipment. CMP-4 does not support the inclusionof undefined terms on this placard.

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Public Comment No. 1848-NFPA 70-2018 [ Section No. 705.10 ]

705.10 Identification of Power Sources.

A permanent plaque or directory shall be installed at each service equipment location, or at an approvedreadily visible location. The plaque or directory shall denote the location of each power sourcedisconnecting means for the premises building or be grouped with other plaques or directories for otheron-site sources. The plaque or directory shall be marked with the wording “CAUTION: MULTIPLESOURCES OF POWER”. Any diagrams shall be correctly oriented with respect to the diagram's location.The marking shall comply with 110.21(B).

Exception: Installations with multiple co-located power production sources shall be permitted to beidentified as a group(s). The plaque or directory shall not be required to identify each power sourceindividually.

Statement of Problem and Substantiation for Public Comment

Changes made to this section are part of a larger group of changes to other articles that are being recommended in an effort to harmonize all directory requirements for onsite sources. During the public input phase we submiitted several inputs that were also being coordinated with changes being proposed to other fire and building codes. Our intention is to standardize and harmonize these requirements to address the situation where different onsite sources may be installed by different groups at different times. During the First Draft state we received significant input and support by both CMP-13 and CMP-4 to improve our inputs. This comment is related to several other comments that realign all the changes made in the First Draft to ensure all requirements remain harmonized accross the different articles.With respect to the recommended removal of the language addressing orientation, this change was not made to parallel requirements in other articles and is impractical to apply since the final location of any directory may not be know until installation since AHJs (including fire marshall's etc.) can make the final location selection. The phrase "or other approved readily visible location" was intentional language requested by fire service persons and allows this directory to comply with other building/fire codes that have this requirement.

Related Public Comments for This Document

Related Comment Relationship

Public Comment No. 1854-NFPA 70-2018 [Section No. 710.10]

Related Item

• FR-8603

Submitter Information Verification

Submitter Full Name: Jason Fisher

Organization: Tesla Inc.

Street Address:

City:

State:

Zip:

Submittal Date: Thu Aug 30 10:13:46 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected but see related SR

Resolution: SR-8154-NFPA 70-2018

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Statement: Changes are made to this section to align with related changes to identification of power sourcesin other articles in a continued effort to harmonize all directory requirements for onsite sourcesunder a variety of applications.

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Public Comment No. 42-NFPA 70-2018 [ Section No. 705.10 ]

705.10 Identification of Power Sources.

A permanent plaque or directory shall be installed at each service equipment location, or at an approvedreadily visible location for commercial and industrial installations . For one- and two- family dwelling units,a permmaent plaque or directory shall be installed at the first responder disconnect required in 230.85. Theplaque or directory shall denote the location of each power source disconnecting means for the premises orbe grouped with other plaques or directories for other on-site sources. The plaque or directory shall bemarked with the wording “CAUTION: MULTIPLE SOURCES OF POWER”. Any diagrams shall be correctlyoriented with respect to the diagram's location. The marking shall comply with 110.21(B).

Exception: Installations with multiple co-located power production sources shall be permitted to beidentified as a group(s). The plaque or directory shall not be required to identify each power sourceindividually.

Statement of Problem and Substantiation for Public Comment

FR 8462 added new shutdown requirements that allow first responders to safety remove the normal source of power from one and two family dwelling units. Where conditions 230.85(2) or (3) are installed, the service disconnect will be located elsewhere on or within the one- or two- family dwelling unit. For this reason, the plaque or directory required in 705.10 should be located at the first responder disconnect required in 230.85 on any one- or two-family dwelling unit to alert the first responders that there are interconnect power production sources that also have to be safety shutdown so that all sources of power are removed. For industrial and commercial installations, the plaque or directory should be at the service entrance equipment location.

Related Public Comments for This Document

Related Comment Relationship

Public Comment No. 41-NFPA 70-2018 [Section No.702.7]

Labeling the first responder disconnect required in230.85

Public Comment No. 1112-NFPA 70-2018 [Section No.480.7(A)]

Related Item

• FR 8462 NFPA 70-2018

Submitter Information Verification

Submitter Full Name: Brian Baughman

Organization: Generac Power Systems Inc

Street Address:

City:

State:

Zip:

Submittal Date: Wed Jun 27 11:15:42 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected

Resolution: Section 705.10 already requires this marking to be located at the service equipment, unless there isanother approved location provided by an AHJ. Where a service disconnect is located outdoors,regardless of the building type, the existing language would already accomplish what the submittersuggests while continuing to allow for new power production equipment installations on existingbuildings that may not have the disconnect referenced in 230.85.

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Public Comment No. 1776-NFPA 70-2018 [ Section No. 705.11 ]

705.11 Supply-Side Source Connections.

An electric power production source, where connected on the supply side of the service disconnectingmeans as permitted in 230.82(6), shall comply with 705.11(A) through (F).

(A) Output Rating.

The sum of the power source continuous current output ratings on a service, other than those controlled inaccordance with 705.13, shall not exceed the ampacity of the service conductors.

Informational Note: See Article 100 definition for Service Conductors.

(B) Conductors.

The power source output circuit conductors from the service conductors point of connection to the firstovercurrent protection device shall be sized in accordance with 705.28 and in no case sized smaller than#6 AWG copper or #4 AWG aluminum. These conductors shall be installed in accordance with 230.30 or230.43.

(C) Overcurrent Protection.

The power source output circuit conductors shall be protected from overcurrent in accordance with 705.28and 705.30. If fuses are not integral with the disconnecting means the disconnecting means shall belocated on the service side of the fuses. Where the power source output circuit conductors make theirconnection to the service outside of a building, they shall be protected by overcurrent devices in a readilyaccessible location outside the building or at the first readily accessible location where the power sourceconductors enter the building. Where the power source output circuit conductors make their connection tothe service inside a building, they shall be protected with one of the following methods:

(1) Within 5 m (16.5 ft). With an overcurrent device within 5 m (16.5 ft) of conductor length from the pointof connection to the service

(2) Within 20 m (71 ft). With cable limiters at the limiters installed in all ungrounded conductors within 5m (16.5 ft) of conductor length from the point of connection to the service and an overcurrent devicelocated within 20 m (71 ft) of conductor length from the point of connection to the service

(D) Bonding and Grounding.

All metal enclosures, metallic wiring methods, and metal parts associated with the power source outputconductors in 705.11(B) shall be bonded in accordance with 250.92(B). This metallic equipment shall beconnected to the grounding electrode system for the service at the power source disconnecting means withonly one of the methods in 705.11(D)(1) or (D)(2). Where the power sources use a grounded conductor,705.11(D)(1) shall apply.

(1) Grounded Conductor Brought to Power Source Disconnecting Means.

Where a grounded service conductor is brought to the power source disconnecting means, the groundedconductor shall be connected to the disconnecting means grounded conductor terminal or bus. A bondingconductor shall connect the grounded service conductor to the metallic equipment enclosing the powersource output circuit conductors. This bonding conductor shall be sized in accordance with 250.102 basedon the size of the power source output circuit conductors.

(2) Grounded Conductor Not Brought to Power Source Disconnecting Means.

Where a grounded service conductor is not brought to the power source disconnecting means, the metallicequipment enclosing the power source output circuit conductors shall be bonded to the grounding electrodesystem using a separate bonding conductor sized in accordance with 250.102 based on the size of thepower source output circuit conductors.

(E) Connections.

The A connection of power source output circuit conductors to the service conductors shall be made usinglisted connectors as described in 110.14 and comply with all enclosure fill requirements Any modificationsto existing equipment shall be made in accordance with the manufacturer’s instructions or the modificationmust be field labeled.

Informational Note: Electric utilities enforce their requirements for connections to equipment undertheir control. See 90.2.

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(F) Disconnecting Means.

The power source disconnecting means shall meet the requirements of 705.20. The power sourcedisconnecting means shall not be considered as one of the service disconnecting means as required by230.70. The requirements of 230.71 or 230.72 shall not apply to the power source disconnecting means.The conductors Conductors between the point of connection and the disconnect shall be connected to theline side of the disconnect.

(G) Ground-Fault Protection.

For connections rated 1000 amperes or more to solidly grounded wye services exceeding 150 volts toground but not exceeding 1000 volts, phase-to-phase, ground-fault protection meeting the requirements of230.95 shall be provided.

Statement of Problem and Substantiation for Public Comment

Current limiters need to be installed in all ungrounded conductors, including parallel conductors. Some allowance to have some conductor length from the point of connection to an in-line current limiter should be provided in order to allow the installer to locate the current limiter in a location that is easily serviceable. This distance matches the allowance given to the location of OCPDs found in 705.11(C)(1).Editorial changes to 705.11(E) and 705.11(F) are suggested to recognize that some disconnecting means may connect directly to busbars without the use of conductors.

Related Item

• FR-8608

Submitter Information Verification

Submitter Full Name: Jason Fisher

Organization: Tesla Inc.

Street Address:

City:

State:

Zip:

Submittal Date: Wed Aug 29 22:42:03 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected but see related SR

Resolution: SR-8156-NFPA 70-2018

Statement: Conductor lengths in this section were chosen to address installations where equipment distanceswould be impractical or impossible to apply consistently. These lengths represent practical valuesthat will allow suitable listed equipment to be installed in a manner that does not violate it’s listing.

Where cable limiters are used they must be installed in all ungrounded conductors, includingparallel conductors. A practical conductor length has been added from the point of connection to anin-line cable limiter to allow the location of the cable limiter to be placed where easily serviceable.

These distances change based upon occupancy type because cable limiters are not commonlyused in dwelling units.

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Public Comment No. 440-NFPA 70-2018 [ Section No. 705.11(B) ]

(B) Conductors.

The power source output circuit conductors from the service conductors point of connection to the firstovercurrent protection device shall be sized in accordance with 705.28 and in no case sized smaller than#6 6 AWG copper or #4 4 AWG aluminum. These conductors shall be installed in accordance with 230.30or 230.43.

Statement of Problem and Substantiation for Public Comment

This PC simply removes the "#" symbol to address one of the concerns in the CC's CN 233.

Related Item

• CN 233

Submitter Information Verification

Submitter Full Name: William Brooks

Organization: Brooks Engineering

Street Address:

City:

State:

Zip:

Submittal Date: Mon Aug 06 19:00:56 EDT 2018

Committee: NEC-P04

Committee Statement

Committee Action: Rejected but see related SR

Resolution: SR-8155-NFPA 70-2018

Statement: The "#" symbol was removed to comply with the NEC Style Manual.

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Public Comment No. 309-NFPA 70-2018 [ New Section after 705.11(C) ]

TITLE OF NEW CONTENT Overcurrent Protection

Type your content here ...

(C) Overcurrent Protection. The power source output circuit conductors shall be protected from overcurrent inaccordance with 705.28 and 705.30. If fuses are not integral with the disconnecting means the disconnecting meansshall be located on the service side of the fuses. Where the power source output circuit conductors make theirconnection to the service outside of a building, they shall be protected by overcurrent devices in a readily accessiblelocation outside the building or at the first readily accessible location where the power source conductors enter thebuilding. The overcurrent protection shall be located within 3 m (10 ft) of the point where the power source outputcircuit conductors are connected to the service.

Exception: Where the overcurrent protection for the power source is located more than 3m (10 ft) from the point ofconnection for the power source output circuit conductors to the service conductors, cable limiters or current-limitingcircuit breakers for each ungrounded conductor shall be installed at the point where the power source output circuitconductors are connected to the service conductors.

Statement of Problem and Substantiation for Public Comment

Delete the text of 705.11 (C) as it appears in the First Draft FR-6808 and replace it with the proposed text of this comment.

No technical substantiation was given by the technical committee or by any public input to change the distances for 705.31 when this information was incorporated in 705.11 (C). This comment restores the text of 705.31 into the new 705.11 (C).

Related Item

• FR 6808

Submitter Information Verification

Submitter Full Name: Timothy Croushore

Organization: FirstEnergy

Affiliation: Edison Electric Institute - Electric Light and Power Task Force

Street Address:

City:

State:

Zip:

Submittal Date: Fri Jul 27 12:43:36 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected but see related SR

Resolution: SR-8156-NFPA 70-2018

Statement: Conductor lengths in this section were chosen to address installations where equipment distanceswould be impractical or impossible to apply consistently. These lengths represent practical valuesthat will allow suitable listed equipment to be installed in a manner that does not violate it’s listing.

Where cable limiters are used they must be installed in all ungrounded conductors, includingparallel conductors. A practical conductor length has been added from the point of connection to anin-line cable limiter to allow the location of the cable limiter to be placed where easily serviceable.

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These distances change based upon occupancy type because cable limiters are not commonlyused in dwelling units.

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Public Comment No. 1657-NFPA 70-2018 [ Section No. 705.11(C) ]

(C) Overcurrent Protection.

The power source output circuit conductors shall be protected from overcurrent in accordance with 705.28and 705.30. If fuses are not integral with the disconnecting means the disconnecting means shall belocated on the service side of the fuses. Where the power source output circuit conductors make theirconnection to the service outside of a building, they shall be protected by overcurrent devices in a readilyaccessible location outside the building or at the first readily accessible location where the power sourceconductors enter the building. Where the The overcurrent protection shall be located within 3 m (10 ft) ofthe point where the power source output circuit conductors make their connection are connected to theservice inside a building, they shall be protected with one of the following methods:Within 5 m (16.5 ft).With an overcurrent device within 5 m (16.5 ft) of conductor length .

Exception – to be as worded in 705.31

Exception: Where the overcurrent protection for the power source is located more than 3m (10 ft) from the point of

connection for the power source output circuit conductors to the service Within 20 m (71 ft). With cable limitersat the connection to the service and an overcurrent device located within 20 m (71 ft) of conductor lengthfrom the point of connection to the service conductors, cable limiters or current-limiting circuit breakers for

each ungrounded conductor shall be installed at the point where the power source output circuit conductors are

connected to the service conductors

Statement of Problem and Substantiation for Public Comment

No technical substantiation was given by the technical committee or by any public input to change the distances for 705.31 when this information was incorporated in 705.11 (C).

Related Item

• FR6808

Submitter Information Verification

Submitter Full Name: Leo Zieman

Organization: Florida Power &amp; Light (Nextera

Affiliation: Edison Electric Institute

Street Address:

City:

State:

Zip:

Submittal Date: Wed Aug 29 14:45:40 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected but see related SR

Resolution: SR-8156-NFPA 70-2018

Statement: Conductor lengths in this section were chosen to address installations where equipment distanceswould be impractical or impossible to apply consistently. These lengths represent practical valuesthat will allow suitable listed equipment to be installed in a manner that does not violate it’s listing.

Where cable limiters are used they must be installed in all ungrounded conductors, includingparallel conductors. A practical conductor length has been added from the point of connection to anin-line cable limiter to allow the location of the cable limiter to be placed where easily serviceable.

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These distances change based upon occupancy type because cable limiters are not commonlyused in dwelling units.

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Public Comment No. 1990-NFPA 70-2018 [ Section No. 705.11(D) ]

(D) Bonding and Grounding.

All metal enclosures, metallic wiring methods, and metal parts associated with the power source outputconductors in 705.11(B) shall be bonded in accordance with 250.92(B). This metallic equipment shall beconnected to the grounding electrode system for the service at the power source disconnecting means withonly one of the methods in 705.11(D)(1) or (D)(2). Where If the power sources use source disconnectingmeans is connected to a grounded conductor ac system , 705.11(D)(1) shall apply. If the power sourcedisconnecting means is connected to an ungrounded ac system, 705.11(D)(2) shall apply.

(1) Grounded Conductor Brought to Power Source Disconnecting Means.

Where a A grounded service conductor is brought shall be brought to the power source disconnectingmeans , the and the grounded conductor shall be connected to the disconnecting means groundedconductor terminal or bus. A bonding conductor shall connect the grounded service conductor to themetallic equipment enclosing the power source output circuit conductors. This bonding conductor andgrounded service conductor shall be sized in accordance with 250.102 based on the size of the powersource output circuit conductors.

(2) Grounded Conductor Not Brought to Power Source Disconnecting Means.

Where a grounded service conductor is not brought to the power source disconnecting means, the metallicequipment enclosing the power source output circuit conductors shall be bonded to the grounding electrodesystem using a separate bonding conductor sized in accordance with 250.102 based on the size of thepower source output circuit conductors.

Statement of Problem and Substantiation for Public Comment

The first revision to add grounding and bonding requirements for the power source disconnect is a needed requirement for these disconnects Allowing the installer to choose to install the grounded service disconnect to the power source disconnecting means on the basis that the power production source does or does not need the grounded conductor is a mistake. The grounded conductor needs to be installed as it is the fault path back to the source, no different than a service supplied ac disconnect from a grounded ac system. These disconnects could be installed per the allowance of 230.82(6), and would be connected for example directly to a grounded ac system supplied by the utility, and are therefore no different than a service and should be grounded and bonded just like a service. A grounded condcutor needs to be brought whether or not used by the power production system as its more important role is as a fault path. Connecting the equipment only to the grounding electrode system with a grounded ac supply system would be dangerous and not consistent with what is required for similar service equipment.

Related Item

• FR-8608

Submitter Information Verification

Submitter Full Name: Derrick Atkins

Organization:

Street Address:

City:

State:

Zip:

Submittal Date: Thu Aug 30 13:48:25 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected but see related SR

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Resolution: SR-8159-NFPA 70-2018

Statement: The revised text better explains the bonding and grounding methods for this type of equipment. Thefirst draft text permitted the possibility of parallel paths and was unclear on the use of groundedconductors. These requirements provide adequately sized conductors for an effective fault currentpath back to the utility source.

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Public Comment No. 363-NFPA 70-2018 [ Section No. 705.11(D) ]

(2) Grounded Conductor Not Brought to Power Source Disconnecting Means.

Where a grounded service conductor is not brought to the power source disconnecting means, the metallicequipment enclosing the power source output circuit conductors shall be bonded to the grounding electrodesystem using a separate bonding conductor sized in accordance with 250.102 based on the size of thepower source output circuit conductors

(D)

Bonding Bonding and Grounding.

All metal enclosures, metallic wiring methods, and metal parts associated with the power source outputconductors in 705.11(B) shall be bonded in accordance with 250.92(B). This metallic equipment shall beconnected to the grounding electrode system for the service at the power source disconnecting meanswith only one of the methods in 705.11(D)(1) or (D)(2). Where the power sources use a groundedconductor, 705.11(D)(1) shall apply.

(1) Grounded Conductor Brought to Power Source Disconnecting Means.

Where a grounded service conductor is brought to the power source disconnecting means, the groundedconductor shall be connected to the disconnecting means grounded conductor terminal or bus. A bondingconductor shall connect the grounded service conductor to the metallic equipment enclosing the powersource output circuit conductors. This bonding conductor shall be sized in accordance with 250.102 basedon the size of the power source output circuit conductors.

The supply side disconnect shall be grounded and bonded in accordance with 250.25 .

Statement of Problem and Substantiation for Public Comment

Revised text to reference the new 250.25 for the 2020 Code that code panel 5 added to address grounding and bonding for supply side disconnects.

Related Item

• FR-8608 and FR8198

Submitter Information Verification

Submitter Full Name: Mike Holt

Organization: Mike Holt Enterprises Inc

Street Address:

City:

State:

Zip:

Submittal Date: Thu Aug 02 17:51:49 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected but see related SR

Resolution: SR-8159-NFPA 70-2018

Statement: The revised text better explains the bonding and grounding methods for this type of equipment. Thefirst draft text permitted the possibility of parallel paths and was unclear on the use of groundedconductors. These requirements provide adequately sized conductors for an effective fault currentpath back to the utility source.

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Public Comment No. 1999-NFPA 70-2018 [ Section No. 705.11(D) [Excluding any Sub-

Sections] ]

All metal enclosures, metallic wiring methods, and metal parts associated with the power source outputconductors in 705.11(B) shall be bonded in accordance with 250.92(B). This metallic equipment shall beconnected to the grounding electrode system for the service at the power source disconnecting means withonly one of the methods in 705.11(D)(1) or (D)(2). Where the power sources use a grounded conductor aregrounded alternating current systems , 705.11(D)(1) shall apply.

Statement of Problem and Substantiation for Public Comment

The wording "Where the power sources use a grounded conductor" should be clarified. Whether or not the grounded conductor is being used shouldn't have any bearing on it being installed. If a grounded alternating current system is being used the grounded conductor is the fault path and should be installed. The current wording could be misinterpreted to give code users the understanding that they wouldn't need to install the grounded conductor which could lead to a very dangerous situation.

Related Item

• FR8608

Submitter Information Verification

Submitter Full Name: Trevor Turek

Organization: [ Not Specified ]

Street Address:

City:

State:

Zip:

Submittal Date: Thu Aug 30 14:17:08 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected but see related SR

Resolution: SR-8159-NFPA 70-2018

Statement: The revised text better explains the bonding and grounding methods for this type of equipment. Thefirst draft text permitted the possibility of parallel paths and was unclear on the use of groundedconductors. These requirements provide adequately sized conductors for an effective fault currentpath back to the utility source.

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Public Comment No. 1531-NFPA 70-2018 [ Section No. 705.11(E) ]

(E) Connections.

The connection of power source output circuit conductors to the service conductors shall be made usinglisted connectors as described in 110.14 and comply with all enclosure fill requirements Any modificationsto existing equipment shall be made in accordance with the manufacturer’s instructions or the modificationmust be field labeled evaluated .

Informational Note: Electric utilities enforce their requirements for connections to equipment undertheir control. See 90.2.

Statement of Problem and Substantiation for Public Comment

The process of how “field labeled” is accomplished is not defined or set in the NEC. The definition of “field labeled” does not set any requirement or statement that a “serialized” label is provided as stated in the panel resolution statement. The process that leads to a field label is a function of the “field evaluation” process requirements found in NFPA 790 and NFPA 791. It has been stated that the term “field labeled” infers that a field evaluation would be completed. This may be the intent of the panel, but it is poor code writing to set a requirement that infers a process instead of stating the process, field evaluation, that is to be completed.

The NFPA style manual section 2.3.2.3 prohibits definitions from having requirements in the definition and therefore definitions cannot be used as establishing requirements.

It is noted that the field evaluation process is under the purview of the NFPA Electrical Equipment Evaluation (EEE) Technical Committee.A product or equipment can achieve a “field label” where a field evaluation is completed which has five distinct steps. A brief summary of these procedures includes selection of the correct nationally recognized standard, conducting a complete evaluation of construction, performing applicable non-destructive field testing, and documentation in formal engineering reports to both the client and the Authority having jurisdiction. When the process is completed with satisfactory results, then the serialized “field label” of the FEB is applied.

Please see the related comments for the definition of "field evaluation (field evaluated)" and the new section 110.3(D) that sets the process requirement and FEB qualification criteria.

To permit only the “field label” as suitable evidence for “approval” has allowed and will continue to allow unqualified entities to give a false sense of adequacy when they are in fact not performing the necessary rigorous evaluation that is provided in the requirement of the NFPA 790 and NFPA 791 documents.If the panel believes the term “field labeled” is still the correct term, it is requested this item be referred the Correlating Committee for correlation between the NEC and the documents under the purview of the NFPA EEE committee.

Related Public Comments for This Document

Related Comment Relationship

Public Comment No. 1353-NFPA 70-2018 [New Definition after Definition: FestoonLighting.]

Public Comment No. 1489-NFPA 70-2018 [New Section after 110.3(C)]

Related Item

• FR 8608

Submitter Information Verification

Submitter Full Name: Charles Mello

Organization: Cdcmello Consulting Llc

Affiliation: Self

Street Address:

City:

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State:

Zip:

Submittal Date: Wed Aug 29 10:29:05 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected but see related SR

Resolution: SR-8176-NFPA 70-2018

Statement: Stating that equipment has a field evaluation does not guarantee that a field label is installed. NFPA791 includes a recommendation for a label to be installed but does not mandate it as quoted below.The process of applying a field label for field evaluated equipment is extremely important for AHJs.

This change incorporates the informational note into positive Code text to clarify that connections inequipment under the exclusive control of a utility shall only be made where approved by the utility,in accordance with 90.2(B).

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Public Comment No. 1671-NFPA 70-2018 [ Section No. 705.11(E) ]

(E) Connections.

The connection of power source output circuit conductors to the service conductors shall be made usinglisted connectors as described in 110.14 and comply with all enclosure fill requirements Any modificationsto existing equipment shall be made in accordance with the manufacturer’s instructions or the modificationmust be field labeled.

Informational Note: Electric utilities enforce their requirements for connections to equipment under theircontrol. See 90.2.

Connections shall not be made in meter socket enclosures or other apparatus under the exclusive controlof the electric utility.

Statement of Problem and Substantiation for Public Comment

Incorporate the new Informational Note into positive Code text. Many installers have taken it upon themselves to break into utility meter cans to install unapproved connections under the guise that the code did not specifically state such installation was not allowed. This has caused numerous hardships, not only to the utility and installers, but also to the customers/property owners as well. Adding this text will flag installers to review with the utility before making such connection(s).

Related Item

• FR6808

Submitter Information Verification

Submitter Full Name: Leo Zieman

Organization: Florida Power &amp; Light (Nextera

Affiliation: Edison Electric Institute

Street Address:

City:

State:

Zip:

Submittal Date: Wed Aug 29 15:19:57 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected but see related SR

Resolution: SR-8176-NFPA 70-2018

Statement: Stating that equipment has a field evaluation does not guarantee that a field label is installed. NFPA791 includes a recommendation for a label to be installed but does not mandate it as quoted below.The process of applying a field label for field evaluated equipment is extremely important for AHJs.

This change incorporates the informational note into positive Code text to clarify that connections inequipment under the exclusive control of a utility shall only be made where approved by the utility,in accordance with 90.2(B).

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Public Comment No. 310-NFPA 70-2018 [ Section No. 705.11(E) ]

(E) Connections.

The connection of power source output circuit conductors to the service conductors shall be made usinglisted connectors as described in 110.14 and comply with all enclosure fill requirements Any modificationsto existing equipment shall be made in accordance with the manufacturer’s instructions or the modificationmust be field labeled. Connections shall not be made in meter socket enclosures under the exclusivecontrol of the electric utility.

Informational Note: Electric utilities enforce their requirements for connections to equipment undertheir control. See 90.2.

Statement of Problem and Substantiation for Public Comment

Incorporates the requirement referenced in the informational note into positive Code text.

Related Item

• FR 8608

Submitter Information Verification

Submitter Full Name: Timothy Croushore

Organization: FirstEnergy

Affiliation: Edison Electric Institute - Electric Light and Power Task Force

Street Address:

City:

State:

Zip:

Submittal Date: Fri Jul 27 12:49:52 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected but see related SR

Resolution: SR-8176-NFPA 70-2018

Statement: Stating that equipment has a field evaluation does not guarantee that a field label is installed. NFPA791 includes a recommendation for a label to be installed but does not mandate it as quoted below.The process of applying a field label for field evaluated equipment is extremely important for AHJs.

This change incorporates the informational note into positive Code text to clarify that connections inequipment under the exclusive control of a utility shall only be made where approved by the utility,in accordance with 90.2(B).

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Public Comment No. 1209-NFPA 70-2018 [ Section No. 705.11(F) ]

(F) Disconnecting Means.

The power source disconnecting means shall meet the requirements of 705.20. The power sourcedisconnecting means shall not be considered as one of the service disconnecting means as required by230.70. The requirements of 230.71 or 230.72 shall not apply to the power source disconnecting means.The conductors between the point of connection and the disconnect shall be connected to the line side ofthe disconnect. Equipment containing a power source disconnecting means rated 1000V or less shall bemarked to identify it as being suitable for use as service equipment.

Statement of Problem and Substantiation for Public Comment

The same hazards that exist for service entrance equipment exist for line side connections. While most of the safeguards implied by equipment marked as being suitable for use as service equipment are included in this section, some are not. In particular, barriering around line-side components that are not de-energized when the disconnect is opened in certain types of equipment, such as UL 891 switchboards, would be covered by requiring marking as suitable for use as service equipment.

Related Item

• FR 8608 • FR 8266

Submitter Information Verification

Submitter Full Name: Bill Brown

Organization: Schneider Electric

Street Address:

City:

State:

Zip:

Submittal Date: Fri Aug 24 12:48:59 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected but see related SR

Resolution: SR-8178-NFPA 70-2018

Statement: The revised text mandates SUSE rating of this disconnecting means and recognizes the applicationof the service disconnect rules that are defined in Article 230, as applying to this section.

The same hazards that exist for service entrance equipment exist for line side connections. Whilemost of the safeguards implied by equipment marked as being suitable for use as service equipmentare included in this section, some are not. In particular, barriers around line-side components thatare not de-energized when the disconnect is opened in certain types of equipment, such as UL 891switchboards, are covered by requiring marking as suitable for use as service equipment.

Additional references to 230.2(A)(5) and 230.40 Exception No. 5 identify requirements already inexistence to clarify that premises are permitted to have an additional service for parallel powerproduction and service entrance conductors connected to the supply side of normal servicedisconnecting means are permitted to supply several systems.

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Public Comment No. 1678-NFPA 70-2018 [ Section No. 705.11(F) ]

(F) Disconnecting Means.

The power source disconnecting means shall meet the requirements of 705.20. The power sourcedisconnecting means shall not be considered as one of the service disconnecting means as required by230.70. The requirements of 230.71 or 230.72 shall not apply to the power source disconnecting means.The conductors between the point of connection and the disconnect power source disconnecting meansshall be connected to the line side of the disconnect and meet the requirements of 230 .6.

Statement of Problem and Substantiation for Public Comment

The current text of the revision would eliminate the longstanding maximum requirement for a maximum of 6 disconnects as the service disconnecting means. Increasing the number of disconnects causes the emergency personnel to operate multiple disconnects to remove the connection from the serving utility.

Related Item

• FR6808

Submitter Information Verification

Submitter Full Name: Leo Zieman

Organization: Florida Power &amp; Light (Nextera

Affiliation: Edison Electric Institute

Street Address:

City:

State:

Zip:

Submittal Date: Wed Aug 29 15:36:13 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected but see related SR

Resolution: SR-8178-NFPA 70-2018

Statement: The revised text mandates SUSE rating of this disconnecting means and recognizes the applicationof the service disconnect rules that are defined in Article 230, as applying to this section.

The same hazards that exist for service entrance equipment exist for line side connections. Whilemost of the safeguards implied by equipment marked as being suitable for use as service equipmentare included in this section, some are not. In particular, barriers around line-side components thatare not de-energized when the disconnect is opened in certain types of equipment, such as UL 891switchboards, are covered by requiring marking as suitable for use as service equipment.

Additional references to 230.2(A)(5) and 230.40 Exception No. 5 identify requirements already inexistence to clarify that premises are permitted to have an additional service for parallel powerproduction and service entrance conductors connected to the supply side of normal servicedisconnecting means are permitted to supply several systems.

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Public Comment No. 315-NFPA 70-2018 [ Section No. 705.11(F) ]

(F) Disconnecting Means.

The power source disconnecting means shall meet the requirements of 705.20 . The power sourcedisconnecting means shall not be considered as one of the service disconnecting means as required by230.70. The requirements of 230.71 or 230.72 shall not apply to the power source disconnecting means.The conductors between the point of connection and the disconnect shall be connected to the line side ofthe disconnect. See attached uploaded file.

Additional Proposed Changes

File Name Description Approved

Section_705.11_F_Recommended_text.docx Revised 705.11 (F)

Statement of Problem and Substantiation for Public Comment

The disconnecting means for Interconnected Electric Power Production Sources are service disconnecting means by new CMP-10 definition of "service". CMP-4 and CMP-10 need to get together to understand and correlate the changes in the material covered by these two technical committees. In addition, this disconnecting means should be outside the premises as in 230.6. Replace the existing text of the First Revision with the text of the included file.

Related Public Comments for This Document

Related Comment Relationship

Public Comment No. 311-NFPA 70-2018 [Definition: Service.] New Definition of Service

Public Comment No. 312-NFPA 70-2018 [Section No. 230.82] Requirement for Interconnected Sources

Related Item

• FR-6808

Submitter Information Verification

Submitter Full Name: Timothy Croushore

Organization: FirstEnergy

Affiliation: Edison Electric Institute - Electric Light and Power Task Force

Street Address:

City:

State:

Zip:

Submittal Date: Fri Jul 27 13:24:05 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected but see related SR

Resolution: SR-8178-NFPA 70-2018

Statement: The revised text mandates SUSE rating of this disconnecting means and recognizes the applicationof the service disconnect rules that are defined in Article 230, as applying to this section.

The same hazards that exist for service entrance equipment exist for line side connections. Whilemost of the safeguards implied by equipment marked as being suitable for use as service equipmentare included in this section, some are not. In particular, barriers around line-side components thatare not de-energized when the disconnect is opened in certain types of equipment, such as UL 891

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switchboards, are covered by requiring marking as suitable for use as service equipment.

Additional references to 230.2(A)(5) and 230.40 Exception No. 5 identify requirements already inexistence to clarify that premises are permitted to have an additional service for parallel powerproduction and service entrance conductors connected to the supply side of normal servicedisconnecting means are permitted to supply several systems.

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Recommended text: (F) Disconnecting Means. The power source disconnecting means shall meet the requirements of 705.20. The power source disconnecting means shall be considered as one of the service disconnecting means as required by 230.70. The requirements of 230.71 and 230.72 shall apply to the power source disconnecting means. The conductors between the point of connection and the power source disconnecting means shall be connected to the line side of the disconnect and meet the requirements of 230.6.

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Public Comment No. 1911-NFPA 70-2018 [ Section No. 705.12 ]

705.12 Load-Side Source Connections.

The output of an interconnected electric power source shall be permitted to be connected to the load sideof the service disconnecting means of the other source(s) at any distribution equipment on the premises.Where distribution equipment, including switchgear, switchboards, or panelboards, is fed simultaneously bya primary source(s) of electricity and one or more other power source(s), and where this distributionequipment is capable of supplying multiple branch circuits or feeders, or both, the interconnectingprovisions for other power sources shall comply with 705.12(A) through (E G ).

(A) Dedicated Overcurrent and Disconnect.

Each source interconnection of one or more power sources installed in one system shall be made at adedicated circuit breaker or fusible disconnecting means.

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(B) Bus or Conductor Ampere Rating.

One hundred twenty-five percent of the power source output circuit current shall be used in ampacitycalculations for the following:

(1) Where the power source output connection is made to a feeder, the feeder shall have an ampacitygreater than or equal to 125 percent of the power-source output circuit current. Where the power-source output connection is made to a feeder at a location other than the opposite end of the feederfrom the primary source overcurrent device, that portion of the feeder on the load side of the powersource output connection shall be protected by one of the following:

(2) The feeder ampacity shall be not less than the sum of the primary source overcurrent device and125 percent of the power-source output circuit current.

(3) An overcurrent device at the load side of the power source connection point shall be rated notgreater than the ampacity of the feeder.

(4) Where power source output connections are made at feeders, all taps shall be sized based on thesum of 125 percent of all power source(s) output circuit current(s) and the rating of the overcurrentdevice protecting the feeder conductors for sizing tap conductors using the calculations in 240.21(B).

(5) One of the following methods shall be used to determine the ratings of busbars:

(a) The sum of 125 percent of the power source(s) output circuit current and the rating of theovercurrent device protecting the busbar shall not exceed the ampacity of the busbar.

(b) Where two sources, one a primary power source and the other another power source, arelocated at opposite ends of a busbar that contains loads, the sum of 125 percent of the power-source(s)output circuit current and the rating of the overcurrent device protecting the busbar shall not exceed120 percent of the ampacity of the busbar. The busbar shall be sized for the loads connected inaccordance with Article 220. A permanent warning label shall be applied to the distribution equipmentadjacent to the back-fed breaker from the power source that displays the following or equivalentwording:

WARNING: POWER SOURCE OUTPUT CONNECTION —DO NOT RELOCATE THISOVERCURRENT DEVICE.

The warning sign(s) or label(s) shall comply with 110.21(B).

(c) The sum of the ampere ratings of all overcurrent devices on panelboards, both load andsupply devices, excluding the rating of the overcurrent device protecting the busbar, shall not exceedthe ampacity of the busbar. The rating of the overcurrent device protecting the busbar shall not exceedthe rating of the busbar. Permanent warning labels shall be applied to distribution equipment displayingthe following or equivalent wording:

WARNING: THIS EQUIPMENT FED BY MULTIPLE SOURCES. TOTAL RATING OF ALLOVERCURRENT DEVICESEXCLUDING MAIN SUPPLY OVERCURRENT DEVICESHALL NOTEXCEED AMPACITY OF BUSBAR.

The warning sign(s) or label(s) shall comply with 110.21(B).

(d) A connection at either end of a center-fed panelboard in dwellings shall be permitted wherethe sum of 125 percent of the power-source(s) output circuit current and the rating of the overcurrentdevice protecting the busbar does not exceed 120 percent of the current rating of the busbar.

(e) Connections shall be permitted on switchgear, switchboards, and panelboards inconfigurations other than those permitted in 705.12(B)(3)(a) through (d) where designed underengineering supervision that includes available fault-current and busbar load calculations.

(f) Connections shall be permitted on busbars that supply feed-through lugs and conductorsconnected to the lugs opposite the main source of supply. The ampacity of the busbar and connectedfeeders shall not be less than the sum of the primary source overcurrent device and 125 percent of thepower-source output circuit current.

Informational Note to a: This general rule assumes no limitation in the number of the loads orsources applied to busbars or their locations.

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(C) Marking.

Equipment containing overcurrent devices in circuits supplying power to a busbar or conductor suppliedfrom multiple sources shall be marked to indicate the presence of all sources.

(D) Suitable for Backfeed.

Fused disconnects, unless otherwise marked, shall be suitable for backfeed. Circuit breakers, if backfed,shall be suitable for such operation.

Informational Note: Circuit breakers marked “line” and “load” may not be suitable for backfeed orreverse current.

(E) Fastening.

Listed plug-in-type circuit breakers backfed from electric power sources that are listed and identified asinteractive shall be permitted to omit the additional fastener normally required by 408.36(D) for suchapplications.

(G) With Power Control Systems.

Where two sources, one a primary power source and the other another power source(s), are located at opposite705.13, monitoring the primary power source and controlling the other power source(s), the sum of all power soampacity of the busbar.

Statement of Problem and Substantiation for Public Comment

A new section 705.13 was added with a reference back to 705.11 and 705.12 stating that the Power Control System maximum continuous output setting shall be used as the power source output current rating for the calculations. Section 705.12 (B)(3)(a) to (f) does not include an option for using a listed Power Control System (PCS). A PCS monitoring the primary power source and adjusting the other source(s) output(s) accordingly is listed to ensure the sum of the currents from the primary source and other sources does not exceed 120% of the busbar ampacity. Section 705.11 does make reference to a PCS, section 705.13

Related Item

• FR-8745

Submitter Information Verification

Submitter Full Name: Jason Fisher

Organization: Tesla Inc.

Affiliation: Solar Energy Industries Association (SEIA)

Street Address:

City:

State:

Zip:

Submittal Date: Thu Aug 30 12:06:45 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected but see related SR

Resolution: SR-8184-NFPA 70-2018

Statement: A reference to 705.13 has been added to clarify the current values to be used in the calculationswithin 705.12 where connecting feeders connected to PCS to other distribution equipment.Removal of specific equipment terms has been removed to ensure that the rules in subsections of705.12(B) are properly applied without conflicts.

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Public Comment No. 115-NFPA 70-2018 [ Section No. 705.12(B) ]

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(B) Bus or Conductor Ampere Rating.

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One hundred twenty-five percent of the power source output circuit current shall be used in ampacitycalculations for the following:

(1) Where the power source output connection is made to a feeder, the feeder shall have an ampacitygreater than or equal to 125 percent of the power-source output circuit current. Where the power-source output connection is made to a feeder at a location other than the opposite end of the feederfrom the primary source overcurrent device, that portion of the feeder on the load side of the powersource output connection shall be protected by one of the following:

(2) The feeder ampacity shall be not less than the sum of the primary source overcurrent device and125 percent of the power-source output circuit current.

(3) An overcurrent device at the load side of the power source connection point shall be rated notgreater than the ampacity of the feeder.

(4) Where power source output connections are made at feeders, all taps shall be sized based on thesum of 125 percent of all power source(s) output circuit current(s) and the rating of the overcurrentdevice protecting the feeder conductors for sizing tap conductors using the calculations in 240.21(B).

(5) One of the following methods shall be used to determine the ratings of busbars:

(a) The sum of 125 percent of the power source(s) output circuit current and the rating of theovercurrent device protecting the busbar shall not exceed the ampacity of the busbar.

(b) Where two sources, one a primary power source and the other another power source, arelocated at opposite ends of a busbar that contains loads, the sum of 125 percent of the power-source(s)output circuit current and the rating of the overcurrent device protecting the busbar shall not exceed120 percent of the ampacity of the busbar. The busbar shall be sized for the loads connected inaccordance with Article 220. A permanent warning label shall be applied to the distribution equipmentadjacent to the back-fed breaker from the power source that displays the following or equivalentwording:

WARNING: POWER SOURCE OUTPUT CONNECTION —DO NOT RELOCATE THISOVERCURRENT DEVICE.

The warning sign(s) or label(s) shall comply with 110.21(B).

(c) The sum of the ampere ratings of all overcurrent devices on panelboards, both load andsupply devices, excluding the rating of the overcurrent device protecting the busbar, and excluding thesmallest overcurrent device, shall not exceed the ampacity of the busbar. The rating of the overcurrentdevice protecting the busbar shall not exceed the rating of the busbar. Permanent warning labels shallbe applied to distribution equipment displaying the following or equivalent wording:

WARNING: THIS EQUIPMENT FED BY MULTIPLE SOURCES. TOTAL RATING OF ALLOVERCURRENT

DEVICESEXCLUDING

DEVICES EXCLUDING MAIN SUPPLY OVERCURRENT

DEVICESHALL

DEVICE AND EXCLUDING SMALLEST OVERCURRENT DEVICE SHALL NOT EXCEEDAMPACITY OF BUSBAR.

The warning sign(s) or label(s) shall comply with 110.21(B).

(d) A connection at either end of a center-fed panelboard in dwellings shall be permitted wherethe sum of 125 percent of the power-source(s) output circuit current and the rating of the overcurrentdevice protecting the busbar does not exceed 120 percent of the current rating of the busbar.

(e) Connections shall be permitted on switchgear, switchboards, and panelboards inconfigurations other than those permitted in 705.12(B)(3)(a) through (d) where designed underengineering supervision that includes available fault-current and busbar load calculations.

Connections shall be permitted on busbars that supply feed-through lugs and conductors connectedto the lugs opposite the main source of supply. The ampacity of the busbar and connected feedersshall not be less than the sum of the primary source overcurrent device and 125 percent of thepower-source output circuit current.

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(f) Where conductors are connected directly to a busbar without overcurrent conduction, theyshall be considered an extension of the busbar. The resulting extended busbar shall be rated at thelesser of the busbar rating and the conductor ampacity. The extended busbar shall comply with one ofthe foregoing sections when considering all overcurrent devices directly connected to this extendedbusbar.

(g) Informational Note to a:

This

(1)

(a) This general rule assumes no limitation in the number of the loads or sources applied to busbarsor their locations.

Statement of Problem and Substantiation for Public Comment

I make two separate proposed changes to 705.12(B)(2)(3); Terraview appears to require me to submit them as one comment. First:

Subsection (c) This proposal increases installation flexibility without any reduction in safety or increased risk of overloading the bus.

As a simple example, consider a solar combiner panel with a 60A bus, a 60A feeder from the utility, and (3) 20A inverter output circuits (for 16A inverter output current). This arrangement complies with subsection (c). Now consider adding a fourth 20A breaker to this panel to feed some monitoring equipment; this panel would no longer qualify under subsection (c) or any of the other subsections. However, this arrangement is still incapable of overloading the panel bus:

My understanding of the protection philosophy of subsection (c) is that in order to keep enforcement and analysis simple and robust, each breaker is considered to be both a potential source or potential sink of current, ignoring what is actually connected to the breaker. Then the rules should ensure that the bus is not overloaded under any possible combination of sources and sinks.

So if the 60A breaker is a source (respectively sink), and all (4) 20A breakers are sinks (respectively sources), the bus will be protected by the 60A breaker. And if only the 60A breaker and 1 of the 20A breakers are sources (respectively sinks), the bus will be protected by the (3) 20A breakers, the sum of whose ratings is less than the bus rating. Likewise for the 60A breaker and 2 or 3 of the 20A breakers being sources (respectively sinks).

This argument generalizes to any number of breakers of any size: with one breaker protecting the bus from the primary source, if the sum of the other breakers, excluding the smallest, does not exceed the rating of the bus, it is mathematically impossible to overload the bus unless one of the individual breakers is overloaded. This follows directly from the fact that the total current flowing into the bus and the total current flowing out of the bus must be equal, along with a discrete counting argument as above.

Also, please note that for the case of just 3 breakers in a panel (including the breaker protecting the bus), the bus's electrical configuration is identical to that of a feeder with a single splice in it under 705.12(B)(2)(1). In that case, the proposed change to 705.12(B)(2)(3)(c) brings the section into accordance with the allowances of 705.12(B)(2)(1)(b).

Second, subsection (f). The proposed language in the first draft is unnecessarily restrictive, effectively requiring the the extended busbar to comply with 705.12(B)(2)(3)(a) and excluding the other options in 705.12(B)(2)(3). The revised language I propose restores the level of safety and flexibility permitted in the 2017 NEC.

Related Item

• FR-8902-NFPA 70-2018

Submitter Information Verification

Submitter Full Name: Wayne Whitney

Organization: None

Affiliation: None

Street Address:

City:

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State:

Zip:

Submittal Date: Sat Jun 30 11:29:16 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected but see related SR

Resolution: SR-8148-NFPA 70-2018

Statement: Editorial changes have been made to the main paragraph of this section, along with thereinstatement of the subsection titles, to better align with the NEC Style Manual.

The informational note has been moved to be located directly after subsection (B)(3) list item (1)to comply with the Style Manual [2015 3.1.3].

705.12(B)(3)(6) is further edited to clarify how panelboards with feed-through conductors shall besized and how the feed-through conductors are sized.

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Public Comment No. 1464-NFPA 70-2018 [ Section No. 705.12(B) ]

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(B) Bus or Conductor Ampere Rating.

One hundred twenty-five percent of the power source output circuit current shall be used in ampacitycalculations for the following:

(1) Where the power source output connection is made to a feeder, the feeder shall have an ampacitygreater than or equal to 125 percent of the power-source output circuit current. Where the power-source output connection is made to a feeder at a location other than the opposite end of the feederfrom the primary source overcurrent device, that portion of the feeder on the load side of the powersource output connection shall be protected by one of the following:

(2) The feeder ampacity shall be not less than the sum of the primary source overcurrent device and125 percent of the power-source output circuit current.

(3) An overcurrent device at the load side of the power source connection point shall be rated notgreater than the ampacity of the feeder.

(4) Where power source output connections are made at feeders, all taps shall be sized based on thesum of 125 percent of all power source(s) output circuit current(s) and the rating of the overcurrentdevice protecting the feeder conductors for sizing tap conductors using the calculations in 240.21(B).

(5) One of the following methods shall be used to determine the ratings of busbars:

(a) The sum of 125 percent of the power source(s) output circuit current and the rating of theovercurrent device protecting the busbar shall not exceed the ampacity of the busbar.

(b) Where two sources, one a primary power source and the other another power source, arelocated at opposite ends of a busbar that contains loads, the sum of 125 percent of the power-source(s)output circuit current and the rating of the overcurrent device protecting the busbar shall not exceed120 percent of the ampacity of the busbar. The busbar shall be sized for the loads connected inaccordance with Article 220. A permanent warning label shall be applied to the distribution equipmentadjacent to the back-fed breaker from the power source that displays the following or equivalentwording:

WARNING: POWER SOURCE OUTPUT CONNECTION —DO NOT RELOCATE THISOVERCURRENT DEVICE.

The warning sign(s) or label(s) shall comply with 110.21(B).

(c) The sum of the ampere ratings of all overcurrent devices on panelboards, both load andsupply devices, excluding the rating of the overcurrent device protecting the busbar, shall not exceedthe ampacity of the busbar. The rating of the overcurrent device protecting the busbar shall not exceedthe rating of the busbar. Permanent warning labels shall be applied to distribution equipment displayingthe following or equivalent wording:

WARNING: THIS EQUIPMENT FED BY MULTIPLE SOURCES. TOTAL RATING OF ALLOVERCURRENT DEVICESEXCLUDING MAIN SUPPLY OVERCURRENT DEVICESHALL NOTEXCEED AMPACITY OF BUSBAR.

The warning sign(s) or label(s) shall comply with 110.21(B).

(d) A connection at either end of a center-fed panelboard in dwellings shall be permitted wherethe sum of 125 percent of the power-source(s) output circuit current and the rating of the overcurrentdevice protecting the busbar does not exceed 120 percent of the current rating of the busbar.

(e) Connections shall be permitted on switchgear, switchboards, and panelboards inconfigurations other than those permitted in 705.12(B)(3)(a) through (d) where designed underengineering supervision that includes available fault-current and busbar load calculations.

(f) Connections shall be permitted on busbars that supply feed-through lugs and conductorsconnected to the lugs opposite the main source of supply. The ampacity of the busbar and connectedfeeders shall not be less than the sum of the primary source overcurrent device and 125 percent of thepower-source output circuit current.

Informational Note to a: This general rule assumes no limitation in the number of the loads orsources applied to busbars or their locations.

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Statement of Problem and Substantiation for Public Comment

In Public Input No. 403-NFPA 70-2017 I changed "dwellings" to "one and two family dwellings" so that the provision for center-fed interconnections would not be extending to larger services supplying multi-family apartment and condo buildings. The committee response was, "There is no substantiation to limit this to only one and two-family dwellings and the existing text is sufficient to address the situation." If that is true then there is also no substantiation to limit this to dwellings. There is no functional difference between a center-fed panelboard for a dwelling and that for a commercial office so all center-fed panelboards should receive the benefit.

Related Item

• Public Input No. 403-NFPA 70-2017

Submitter Information Verification

Submitter Full Name: MARVIN HAMON

Organization: HAMON ENGINEERING INC

Street Address:

City:

State:

Zip:

Submittal Date: Tue Aug 28 17:39:36 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected

Resolution: A restriction to "dwellings" limits this allowance to practical applications where loads are morelikely to be intermittent.

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Public Comment No. 1777-NFPA 70-2018 [ Section No. 705.12(B) ]

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(B) Bus or Conductor Ampere Rating.

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One hundred twenty-five percent of the power source output circuit current shall be used in ampacitycalculations for the following:

(1) Where the power source output connection is made to a feeder, the feeder shall have an ampacitygreater than or equal to 125 percent of the power-source output circuit current. Where the power-source output connection is made to a feeder at a location other than the opposite end of the feederfrom the primary source overcurrent device, that portion of the feeder on the load side of the powersource output connection shall be protected by one of the following:

(2) The feeder ampacity shall be not less than the sum of the primary source overcurrent device and125 percent of the power-source output circuit current.

(3) An overcurrent device at the load side of the power source connection point shall be rated notgreater than the ampacity of the feeder.

(4) Where power source output connections are made at feeders , all taps shall be sized based on theusing taps all equipment sizing calculations in 240.21(B) shall use the sum of 125 percent of all powersource(s) output circuit current(s) and the rating of the overcurrent device protecting the feederconductors for sizing tap conductors using the calculations in 240.21(B) . the combined calculatedloads.

(5) One of the following methods shall be used to determine the ratings of busbars:

(a) The sum of 125 percent of the power source(s) output circuit current and the rating of theovercurrent device protecting the busbar shall not exceed the ampacity of the busbar.

(b) Where two sources, one a primary power source and the other another power source, arelocated at opposite ends of a busbar that contains loads, the sum of 125 percent of the power-source(s)output circuit current and the rating of the overcurrent device protecting the busbar shall not exceed120 percent of the ampacity of the busbar. The busbar shall be sized for the loads connected inaccordance with Article 220. A permanent warning label shall be applied to the distribution equipmentadjacent to the back-fed breaker from the power source that displays the following or equivalentwording:

WARNING: POWER SOURCE OUTPUT CONNECTION —DO NOT RELOCATE THISOVERCURRENT DEVICE.

The warning sign(s) or label(s) shall comply with 110.21(B).

(c) The sum of the ampere ratings of all overcurrent devices on panelboards, both load andsupply devices, excluding the rating of the overcurrent device protecting the busbar, shall not exceedthe ampacity of the busbar. The rating of the overcurrent device protecting the busbar shall not exceedthe rating of the busbar. Permanent warning labels shall be applied to distribution equipment displayingthe following or equivalent wording:

WARNING: THIS EQUIPMENT FED BY MULTIPLE SOURCES. TOTAL RATING OF ALLOVERCURRENT DEVICESEXCLUDING MAIN SUPPLY OVERCURRENT DEVICESHALL NOTEXCEED AMPACITY OF BUSBAR.

The warning sign(s) or label(s) shall comply with 110.21(B).

(d) A connection at either end of a center-fed panelboard in dwellings shall be permitted wherethe sum of 125 percent of the power-source(s) output circuit current and the rating of the overcurrentdevice protecting the busbar does not exceed 120 percent of the current rating of the busbar.

(e) Connections shall be permitted on switchgear, switchboards, and panelboards inconfigurations other than those permitted in 705.12(B)(3)(a) through (d) where designed underengineering supervision that includes available fault-current and busbar load calculations.

(f) Connections shall be permitted on busbars of panelboards that supply feed-through lugs andconductors connected to the lugs opposite the main source of supply. The ampacity of the busbar andconnected feeders shall not be less than the sum of the primary source overcurrent device and 125percent of the power-source output circuit current.

Informational Note to a: This general rule assumes no limitation in the number of the loads orsources applied to busbars or their locations.

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Statement of Problem and Substantiation for Public Comment

Note that not all text underlined by Terraview has been changed.Editorial changes to 705.12(B)(2) suggested to improve the applicability of this section.Added the phrase ""of panelboards"" to 705.12(B)(3)(f) to clarify where this requirement applies and to correctly differentiate this allowance from, and not conflict with, subsection 705.12(B)(3)(e).

Related Item

• FR-8902

Submitter Information Verification

Submitter Full Name: Jason Fisher

Organization: Tesla Inc.

Affiliation: Solar Energy Industries Association (SEIA)

Street Address:

City:

State:

Zip:

Submittal Date: Wed Aug 29 22:48:43 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected but see related SR

Resolution: SR-8148-NFPA 70-2018

Statement: Editorial changes have been made to the main paragraph of this section, along with thereinstatement of the subsection titles, to better align with the NEC Style Manual.

The informational note has been moved to be located directly after subsection (B)(3) list item (1)to comply with the Style Manual [2015 3.1.3].

705.12(B)(3)(6) is further edited to clarify how panelboards with feed-through conductors shall besized and how the feed-through conductors are sized.

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Public Comment No. 210-NFPA 70-2018 [ Section No. 705.12(B) ]

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(B) Bus or Conductor Ampere Rating.

One hundred twenty-five percent of the power source output circuit current shall be used in ampacitycalculations for the following:

(1) Where the power source output connection is made to a feeder, the feeder shall have an ampacitygreater than or equal to 125 percent of the power-source output circuit current. Where the power-source output connection is made to a feeder at a location other than the opposite end of the feederfrom the primary source overcurrent device, that portion of the feeder on the load side of the powersource output connection shall be protected by one of the following:

(2) The feeder ampacity shall be not less than the sum of the primary source overcurrent device and125 percent of the power-source output circuit current.

(3) An overcurrent device at the load side of the power source connection point shall be rated notgreater than the ampacity of the feeder.

(4) Where power source output connections are made at feeders, all taps shall be sized based on thesum of 125 percent of all power source(s) output circuit current(s) and the rating of the overcurrentdevice protecting the feeder conductors for sizing tap conductors using the calculations in 240.21(B).

(5) One of the following methods shall be used to determine the ratings of busbars:

(a) The sum of 125 percent of the power source(s) output circuit current and the rating of theovercurrent device protecting the busbar shall not exceed the ampacity of the busbar.

(b) Where two sources, one a primary power source and the other another power source, arelocated at opposite ends of a busbar that contains loads, the sum of 125 percent of the power-source(s)output circuit current and the rating of the overcurrent device protecting the busbar shall not exceed120 percent of the ampacity of the busbar. The busbar shall be sized for the loads connected inaccordance with Article 220. A permanent warning label shall be applied to the distribution equipmentadjacent to the back-fed breaker from the power source that displays the following or equivalentwording:

WARNING: POWER SOURCE OUTPUT CONNECTION —DO NOT RELOCATE THISOVERCURRENT DEVICE.

The warning sign(s) or label(s) shall comply with 110.21(B).

(c) The sum of the ampere ratings of all overcurrent devices on panelboards, both load andsupply devices, excluding the rating of the overcurrent device protecting the busbar, shall not exceedthe ampacity of the busbar. The rating of the overcurrent device protecting the busbar shall not exceedthe rating of the busbar. Permanent warning labels shall be applied to distribution equipment displayingthe following or equivalent wording:

WARNING: THIS EQUIPMENT FED BY MULTIPLE SOURCES. TOTAL RATING OF ALLOVERCURRENT DEVICESEXCLUDING MAIN SUPPLY OVERCURRENT DEVICESHALL NOTEXCEED AMPACITY OF BUSBAR.

The warning sign(s) or label(s) shall comply with 110.21(B).

(d) A connection at either end of a center-fed panelboard in dwellings shall be permitted wherethe sum of 125 percent of the power-source(s) output circuit current and the rating of the overcurrentdevice protecting the busbar does not exceed 120 percent of the current rating of the busbar.

(e) Connections shall be permitted on switchgear, switchboards, and panelboards inconfigurations other than those permitted in 705.12(B)(3)(a) through (d) where designed underengineering supervision that includes available fault-current and busbar load calculations.

(f) Connections shall be permitted on busbars that elsewhere supply feeders connected to feed-through lugs and conductors connected to the lugs opposite the main source of supply . The ampacityof the busbar and connected feeders shall not be less than the sum of the primary source overcurrentdevice and 125 percent of the power-source output circuit current.

Informational Note to a: This general rule assumes no limitation in the number of the loads orsources applied to busbars or their locations.

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Statement of Problem and Substantiation for Public Comment

Unless the code-making panel is aware of detailed empirical evidence suggesting otherwise, I do not believe that the 'opposite end' requirement is necessary to include in this new rule. If a busbar and feeder are rated for the combined circuit current of multiple sources, they should withstand operating at that current, regardless of the feed-through lugs' location. In fact, this is the same principle as 705.12(B)(3)(a) at the top of this same section. Moreover, it would be unfortunate if an AHJ used the 'opposite end' language to disallow a connection where feed-through lugs happened not to be at the opposite end, even if all components were rated well above the combined circuit currents.

I suggest adding the word 'elsewhere' because the first two times I read this new section, I misunderstood it as also applying to power sources connected via the feeder on the feed-through lugs. Adding 'elsewhere' clarifies the situations that the new rule is addressing. A power source connection made via the feed through lugs would be subject to one of the other rules in 705.(12)(B)(3).

A side benefit to these revisions is that the subsection would end up more concise.

Related Item

• First Revision No. 8902-NFPA 70-2018 [ Section No. 705.12 ]

Submitter Information Verification

Submitter Full Name: Joel Frangquist

Organization: Skytech Solar

Street Address:

City:

State:

Zip:

Submittal Date: Sun Jul 15 13:55:59 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected but see related SR

Resolution: SR-8148-NFPA 70-2018

Statement: Editorial changes have been made to the main paragraph of this section, along with thereinstatement of the subsection titles, to better align with the NEC Style Manual.

The informational note has been moved to be located directly after subsection (B)(3) list item (1)to comply with the Style Manual [2015 3.1.3].

705.12(B)(3)(6) is further edited to clarify how panelboards with feed-through conductors shall besized and how the feed-through conductors are sized.

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Public Comment No. 2195-NFPA 70-2018 [ Section No. 705.12(B) ]

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(B) Bus or Conductor Ampere Rating.

One hundred twenty-five percent of the power source output circuit current shall be used in ampacitycalculations for the following:

(1) Feeders. Where the power source output connection is made to a feeder, the feeder shall have anampacity greater than or equal to 125 percent of the power-source output circuit current. Where thepower-source output connection is made to a feeder at a location other than the opposite end of thefeeder from the primary source overcurrent device, that portion of the feeder on the load side of thepower source output connection shall be protected by one of the following:

(2) The feeder ampacity shall be not less than the sum of the primary source overcurrent device and125 percent of the power-source output circuit current.

(3) An overcurrent device at the load side of the power source connection point shall be rated notgreater than the ampacity of the feeder.

(4) Taps. Where power source output connections are made at feeders, all taps shall be sized based onthe sum of 125 percent of all power source(s) output circuit current(s) and the rating of the overcurrentdevice protecting the feeder conductors for sizing tap conductors using the calculations in 240.21(B).

(5) Busbars. One of the following methods shall be used to determine the ratings of busbars:

(a) The sum of 125 percent of the power source(s) output circuit current and the rating of theovercurrent device protecting the busbar shall not exceed the ampacity of the busbar.

(b) Where two sources, one a primary power source and the other another power source, arelocated at opposite ends of a busbar that contains loads, the sum of 125 percent of the power-source(s)output circuit current and the rating of the overcurrent device protecting the busbar shall not exceed120 percent of the ampacity of the busbar. The busbar shall be sized for the loads connected inaccordance with Article 220. A permanent warning label shall be applied to the distribution equipmentadjacent to the back-fed breaker from the power source that displays the following or equivalentwording:

WARNING: POWER SOURCE OUTPUT CONNECTION —DO NOT RELOCATE THISOVERCURRENT DEVICE.

The warning sign(s) or label(s) shall comply with 110.21(B).

(c) The sum of the ampere ratings of all overcurrent devices on panelboards, both load andsupply devices, excluding the rating of the overcurrent device protecting the busbar, shall not exceedthe ampacity of the busbar. The rating of the overcurrent device protecting the busbar shall not exceedthe rating of the busbar. Permanent warning labels shall be applied to distribution equipment displayingthe following or equivalent wording:

WARNING: THIS EQUIPMENT FED BY MULTIPLE SOURCES. TOTAL RATING OF ALLOVERCURRENT DEVICESEXCLUDING MAIN SUPPLY OVERCURRENT DEVICESHALL NOTEXCEED AMPACITY OF BUSBAR.

The warning sign(s) or label(s) shall comply with 110.21(B).

(d) A connection at either end of a center-fed panelboard in dwellings shall be permitted wherethe sum of 125 percent of the power-source(s) output circuit current and the rating of the overcurrentdevice protecting the busbar does not exceed 120 percent of the current rating of the busbar.

(e) Connections shall be permitted on switchgear, switchboards, and panelboards inconfigurations other than those permitted in 705.12(B)(3)(a) through (d) where designed underengineering supervision that includes available fault-current and busbar load calculations.

(f) Connections shall be permitted on busbars that supply feed-through lugs and conductorsconnected to the lugs opposite the main source of supply. The ampacity of the busbar and connectedfeeders shall not be less than the sum of the primary source overcurrent device and 125 percent of thepower-source output circuit current.

Informational Note to a: This general rule assumes no limitation in the number of the loads orsources applied to busbars or their locations.

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Statement of Problem and Substantiation for Public Comment

This public comment only adds heading to the list. All other underlining is the mistake of TerraView.

It appears that the reorganization of 705.12(A) and (B) to 705.11 and 705.12 got “Terrafied” as the titles of the list in the now 705.12(B) for “Feeders”, “Taps”, and “Busbars” got eliminated. I do not remember that change being part of the reorganization or edits and creates a violation of style manual as titles are required for a list. No mention of eliminating these titles is mentioned in the Panel statement, so it appears to be an error of TerraView that should be rectified prior to the Correlating Committee reviewing the work of CMP4.

Rant on. The consensus process in developing Code should not be held hostage by programming errors when it can be shown that a programming error created an error in the Code text. ANSI would expect that NEC follow the mistakes of TerraView over the wishes of the Panel. When we find a clear mistake, we should be able to fix it without excessive measures like TIAs. Rant off.

Related Item

Submitter Information Verification

Submitter Full Name: William Brooks

Organization: Brooks Engineering

Street Address:

City:

State:

Zip:

Submittal Date: Thu Aug 30 23:04:58 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected but see related SR

Resolution: SR-8148-NFPA 70-2018

Statement: Editorial changes have been made to the main paragraph of this section, along with thereinstatement of the subsection titles, to better align with the NEC Style Manual.

The informational note has been moved to be located directly after subsection (B)(3) list item (1)to comply with the Style Manual [2015 3.1.3].

705.12(B)(3)(6) is further edited to clarify how panelboards with feed-through conductors shall besized and how the feed-through conductors are sized.

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Public Comment No. 1778-NFPA 70-2018 [ Section No. 705.12(D) ]

(D) Suitable for Backfeed.

Fused disconnects, unless otherwise marked, shall be considered suitable for backfeed. Circuit breakers, ifbackfed, shall be suitable for such operation.

Informational Note: Circuit breakers marked “line” and “load” may not be suitable for backfeed orreverse current.

Statement of Problem and Substantiation for Public Comment

Editorial.

Related Item

• FR-8902

Submitter Information Verification

Submitter Full Name: Jason Fisher

Organization: Tesla Inc.

Affiliation: Solar Energy Industries Association (SEIA)

Street Address:

City:

State:

Zip:

Submittal Date: Wed Aug 29 22:54:09 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected but see related SR

Resolution: SR-8150-NFPA 70-2018

Statement: This SR provides editorial changes to further clarify the requirement and moves the informationalnote into the regulatory text to remove the “may” in the note.

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Public Comment No. 2169-NFPA 70-2018 [ Section No. 705.13 ]

705.13 Power Control Systems.

A power control system (PCS) is a listed system that controls is evaluated to control the output of one ormore power production sources, energy storage systems (ESS), and other equipment. The PCS limitscurrent and loading on the busbars and conductors supplied by the PCS. The sum of the individualproduction power source output ratings of all sources controlled by a PCS shall be permitted to exceed therating of the busbars or the ampacity of the conductors supplied by the PCS-controlled power productionsources. A PCS shall be listed for the purpose and installed

For the circuits connected to a PCS, the PCS shall limit the current to the ampacity of the conductors or theratings of the busbars to which it is connected in accordance with the following:

(1) Monitoring. The PCS power controller shall monitor or control all currents supplying a within thePCS. Any busbar or conductor . The PCS listing shall include functionality as an overcurrentprotective device. on the load side of the service disconnecting means, that is not monitored by thePCS, shall comply with 705.12. Where the PCS is connected in accordance with 705.11, the serviceconductors shall be monitored and operated within their rating.

(2) Settings. The sum of all PCS controlled power source currents plus all monitored currents fromother sources of supply shall not exceed the ratings of any busbar conductor ampacity supplied by thepower production source currents. Where the PCS is connected to an overcurrent device protectingany busbar or conductor not monitored by the PCS, the maximum setting of the of the PCS shall beset within the ratings of that overcurrent device.

(3) Overcurrent Protection. The PCS shall provide overcurrent protection either by overcurrent devicesor by including the function of overcurrent devices in the product listing.

(4) Single Power Source Rating. The rating of the overcurrent device for any single power sourceoutput overcurrent protective device controlled by the PCS shall not exceed the rating of the busbar orthe ampacity of the conductors to which it is connected.

(5) The controlled maximum continuous output setting of the PCS controller shall be used as the powersource output current rating used for the calculation of currents in connections complying with 705.11or 705.12 .

(6) Access to Settings. The access to power control settings of the PCS shall be restricted to qualifiedpersonnel only in accordance with the requirements of 240.6(C)(1), (C)(2), or (C)(3) .

Statement of Problem and Substantiation for Public Comment

This public comment is a continued refinement of the language developed during the first draft process. Most of the comments are reorganizing the information for clarity. Much of this reorganization is based on experience working with AHJs where this new section has been presented and discussed. Constructive feedback showed that it was important to differentiate monitoring from control functions. A PCS will often be evaluated as an overcurrent device or be connected to an overcurrent device to protect the output in the event of a control failure. The language related to 705.11 and 705.12 was confusing and is related much more to how things are monitored. This is an improvement in the language and we look forward to continued forward progress through the second revision.

Related Item

Submitter Information Verification

Submitter Full Name: William Brooks

Organization: Brooks Engineering

Affiliation: PVICC

Street Address:

City:

State:

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Zip:

Submittal Date: Thu Aug 30 21:41:13 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected but see related SR

Resolution: SR-8151-NFPA 70-2018

Statement: The first paragraph was converted to requirements to comply with the Style Manual.

This second revision is a continued refinement of the language developed during the first draftprocess. Most of the changes are reorganizing the information for clarity. The language related to705.11 and 705.12 needed to be clarified as it is related much more to how things are monitored.PCS connected using 705.11 requires that the PCS monitor the service conductors and preventtheir overload.

The language was revised to differentiate monitoring from control functions. A PCS will often beevaluated as an overcurrent device or be connected to an overcurrent device to protect the outputin the event of a control failure.

Access to settings are revised to simply refer to 240.6 as all subsections may apply.

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Public Comment No. 1842-NFPA 70-2018 [ New Section after 705.20 ]

705.21 Disconnect Type

The type of disconnecting means in 705(20) shall be one of the following:

(a) A manually operable switch or circuit breaker

(b) A load-break-rated pull-out switch

(c) A remote-controlled switch or circuit breaker that is operable locally and opens automatically whencontrol power is interrupted

(d) A device listed or approved for the intended application.

Statement of Problem and Substantiation for Public Comment

In the first draft the types of disconnecting means were included in the long list of requirements contained within 705.20. This change simply moves the types from previous list item (9) in 705.20 to a new section 705.21. This change is recommended to improve the usability of this article.

Related Public Comments for This Document

Related Comment Relationship

Public Comment No. 1829-NFPA 70-2018 [Section No. 705.20] Source of this language

Related Item

• FR-8747

Submitter Information Verification

Submitter Full Name: Jason Fisher

Organization: Tesla Inc.

Street Address:

City:

State:

Zip:

Submittal Date: Thu Aug 30 09:52:58 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected but see related SR

Resolution: SR-8153-NFPA 70-2018

Statement: Changes made to this section relocate the mandatory disconnect types to the top of the list andconsolidate duplicative language to improve the usability of the Code. The use of undefined termshave been removed and several editorial changes have been made to improve grammar.

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Public Comment No. 1829-NFPA 70-2018 [ Section No. 705.20 ]

705.20 Disconnecting Means, Source.

Means shall be provided to disconnect all ungrounded conductors that are not solidly grounded of anelectric power production source(s) from all other conductors.

The disconnecting means shall consist of a manual or power operated switch(es) or circuit breaker(s) thatcomplies comply with the following:

(1) Located where readily accessible

(2) Externally operable without exposing the operator to contact with live parts and, if power operated, of atype that is manually opened by hand in the event of a power-supply failure

(3) Where disconnecting means are readily accessible to unqualified persons, any enclosure door orhinged cover that exposes when opened exposes live parts when open shall be locked or require atool to open.

(4) Plainly indicate whether in the open (off) or closed (on) position

(5) Have ratings sufficient for the maximum circuit current, available fault current, and voltage that isavailable at the terminals

(6) Where the line and load terminals are capable of being energized in the open position, marked inaccordance with the warning in 690.13(B)

Informational Note : In parallel generation systems, some equipment, including knife bladeswitches and fuses, is likely to be energized from both directions. See 240.40.

(7) Simultaneously disconnect all ungrounded conductors of the circuit

(8) Be lockable in the open (off) position in accordance with 110.25

(9) Disconnecting means shall be one of the following:

(10) A manually operable switch or circuit breaker

(11) A load-break-rated pull-out switch

(12) A remote-controlled switch or circuit breaker that is operable locally and opens automaticallywhen control power is interrupted

(13) A device listed or approved for the intended application

Statement of Problem and Substantiation for Public Comment

Some editorial changes are suggested to improve the application of this section. The change back to "ungrounded" is recommended since this is in the general Article 705 that covers all types of power production equipment, not just PV systems. Specific articles should address any unique requirements for that equipment and would then modify this section where necessary. The permitted types of disconnects are recommended to be moved to a new section 705.21 (see other PC).

Related Public Comments for This Document

Related Comment Relationship

Public Comment No. 1842-NFPA 70-2018 [New Section after 705.20]

Related Item

• FR-8747

Submitter Information Verification

Submitter Full Name: Jason Fisher

Organization: Tesla Inc.

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Affiliation: Solar Energy Industries Association (SEIA)

Street Address:

City:

State:

Zip:

Submittal Date: Thu Aug 30 09:26:34 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected but see related SR

Resolution: SR-8153-NFPA 70-2018

Statement: Changes made to this section relocate the mandatory disconnect types to the top of the list andconsolidate duplicative language to improve the usability of the Code. The use of undefined termshave been removed and several editorial changes have been made to improve grammar.

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Public Comment No. 1779-NFPA 70-2018 [ Section No. 705.28(B) ]

(B) Conductor Ampacity.

The loads on Unless the power source is otherwise identified, the currents on power source output circuitconductors are shall be considered as continuous currents. The circuit conductors shall be sized to carrynot less than 125 percent of the maximum currents as calculated in 705.28(B). Power source output circuitconductors that are connected to a feeder, if smaller than the feeder conductors, shall be sized to carry notless than the larger of the current as calculated in 705.28(B) or as calculated in accordance with 240.21(B)based on the over-current device protecting the feeder.

Statement of Problem and Substantiation for Public Comment

It is possible that some power sources, like some ESS, could provide intermittent or other non-continuous duty functions. If not otherwise identified, it is sensible to default these calculations to assume they are capable of continuous duty however an allowance for other systems should be provided if identified as such.

Related Item

• FR-8663

Submitter Information Verification

Submitter Full Name: Jason Fisher

Organization: Tesla Inc.

Affiliation: Solar Energy Industries Association (SEIA)

Street Address:

City:

State:

Zip:

Submittal Date: Wed Aug 29 23:00:29 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected but see related SR

Resolution: SR-8190-NFPA 70-2018

Statement: This revision aligns the current and ampacity requirements with similar work done by this panel inArticle 690 and provides an opening sentence in 705.28 for clarity. Changes made to this subsectionallow for current and ampacity calculations for specific power sources if defined elsewhere in theCode. Where guidance is not otherwise provided, clarified requirements are provided here forconductors that need correction or adjustment in 705.28(B). A list is created to clarify that theampacity is the largest of three possible calculations. The language in 705.28(C) is revised to alignwith language in 690 and to clarify how line-to-neutral connected equipment and neutrals not usedfor power output are sized.

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Public Comment No. 320-NFPA 70-2018 [ New Section after 705.40 ]

TITLE OF NEW CONTENT

Type your content here ... See Uploaded File for restoring 705.42

Additional Proposed Changes

File Name Description Approved

Section_705.42_Restore_text.docx Text of 705.42 from 2017 NEC

Statement of Problem and Substantiation for Public Comment

FR 8750 Removed 705.42 which needs to be restored in the NEC.

Related Item

• FR-8750

Submitter Information Verification

Submitter Full Name: Timothy Croushore

Organization: FirstEnergy

Affiliation: FirstEnergy

Street Address:

City:

State:

Zip:

Submittal Date: Fri Jul 27 14:04:36 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected but see related SR

Resolution: SR-8195-NFPA 70-2018

Statement: Minor edits are made to the text and exception for clarification. All the instances of “source” arechanged to be more specific and accurate of what is being referred to. The words “or more” areadded when discussing loss of phase, since it is possible to lose 2 out of 3 phases in a 3-phasesystem. The exception adds that an inverter shall either trip or cease exporting power.

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Public Comment No. 1773-NFPA 70-2018 [ Section No. 705.40 ]

705.40 Loss of Primary Source.

An electric power production source shall be automatically disconnected from all ungrounded conductors ofthe interconnected systems when one of the phases opens to which it is connected. The electric powerproduction source shall not be reconnected until all the phases of the source to which it connected arerestored. This requirement shall not be applicable to an electric power production source providing powerfor an emergency or , legally required standby , or an optional standby system with automatic transferequipment complying with 702 . 5 or automatic disconnection complying 702.5 Exception 2.

Exception: A listed interactive inverter shall be permitted to automatically cease exporting power whenone of the phases of the source opens and shall not be required to automatically disconnect allungrounded conductors from the primary source. A listed interactive inverter shall be permitted toautomatically or manually resume exporting power to the utility once all phases of the source to which it isconnected are restored.

Informational Note No. 1: Risks to personnel and equipment associated with the primary sourcecould occur if an interactive electric power production source can operate as an intentional island.Special detection methods are required to determine that a primary source supply system outagehas occurred and whether there should be automatic disconnection. When the primary sourcesupply system is restored, special detection methods can be required to limit exposure of powerproduction sources to out-of-phase reconnection.

Informational Note No. 2: Induction-generating equipment on systems with significant capacitancecan become self-excited upon loss of the primary source and experience severe overvoltage as aresult.

An interactive power production source shall be permitted to operate in a stand-alone or islanded mode tosupply loads that have been disconnected from the electric power production and distribution network.

Statement of Problem and Substantiation for Public Comment

The committee action in the First Revision 8750 to this section addressed a portion of the industry concern related to standby system operation. Optional standby systems also provide power to designated loads upon the loss of the primary source and this comment seeks to include these systems and align with corresponding comments to Sections 702.4(B) and 702.5 Exception.

Related Item

• FR 8750 • PC 1770 • PC 1768

Submitter Information Verification

Submitter Full Name: Keith Waters

Organization: Schneider Electric

Affiliation: Schneider Electric

Street Address:

City:

State:

Zip:

Submittal Date: Wed Aug 29 22:33:01 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected

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Resolution: Optional standby systems with automatic transfer equipment are not interactive and do notoperate in parallel with other sources, so this section would not apply to those systems.

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Public Comment No. 1815-NFPA 70-2018 [ Section No. 705.40 ]

705.40 Loss of Primary Source.

An The output of electric power production source equipment shall be automatically disconnected from allungrounded conductors of the interconnected systems when one of the phases opens to which it isconnected opens . The electric power production source equipment shall not be reconnected until all thephases of the source interconnected system to which it connected are restored. This requirement shall notbe applicable to an electric to electric power production source providing equipment providing power forto an emergency or legally required standby system.

Exception: A listed interactive inverter shall be permitted to automatically cease exporting power whenone of the phases of the source interconnected system opens and shall not be required to automaticallydisconnect all ungrounded conductors from the primary source. A listed interactive inverter shall bepermitted to automatically or manually resume exporting power to the utility interconnected system onceall phases of the source to which it is connected are restored.

Informational Note No. 1: Risks to personnel and equipment associated with the primary sourcecould occur if an interactive electric power production source can operate as an intentional island.Special detection methods are required to determine that a primary source supply system outagehas occurred and whether there should be automatic disconnection. When the primary sourcesupply system is restored, special detection methods can be are typically required to limit exposureof power production sources to out-of-phase reconnection.

Informational Note No. 2: Induction-generating equipment on connected to systems with significantcapacitance can become self-excited upon loss of the primary source and experience severeovervoltage as a result.

An interactive Interactive power production source equipment shall be permitted to operate in a stand-alone or islanded mode to supply loads that have been disconnected from the electric power productionand distribution network.

Statement of Problem and Substantiation for Public Comment

Sentence structures and use of correct terminology was substituted to provide clarifications. Note that the defined term in Article 100 is Power Production Equipment.

Related Item

• FR-8750

Submitter Information Verification

Submitter Full Name: Jason Fisher

Organization: Tesla Inc.

Affiliation: Solar Energy Industries Association (SEIA)

Street Address:

City:

State:

Zip:

Submittal Date: Thu Aug 30 09:07:02 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected but see related SR

Resolution: SR-8195-NFPA 70-2018

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Statement: Minor edits are made to the text and exception for clarification. All the instances of “source” arechanged to be more specific and accurate of what is being referred to. The words “or more” areadded when discussing loss of phase, since it is possible to lose 2 out of 3 phases in a 3-phasesystem. The exception adds that an inverter shall either trip or cease exporting power.

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Public Comment No. 1780-NFPA 70-2018 [ Section No. 705.150 ]

705.150 System Operation.

Microgrid systems shall be permitted to disconnect from the primary source of power or otherinterconnected electric power production sources and operate in stand-alone or as a separate microgridsystem or in an islanded mode.

Statement of Problem and Substantiation for Public Comment

This change removes the uncertainty of mixing stand-alone language and grid tied language and is consitent with IEEE language for the new IEEE 1547 and the IEEE 2030.7 and 2030.8. There is now a need to provide a definition for islanded mode ion addition to the 710 definition for stand-alone.

Related Item

• FR-8683

Submitter Information Verification

Submitter Full Name: Jason Fisher

Organization: Tesla Inc.

Affiliation: Solar Energy Industries Association (SEIA)

Street Address:

City:

State:

Zip:

Submittal Date: Wed Aug 29 23:06:49 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected but see related SR

Resolution: SR-8199-NFPA 70-2018

Statement: The revision edits the section for clarity to refer to isolated microgrids and island mode forconsistency with other sections. Changes in terminology in this section better align with that usedin other standards.

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Public Comment No. 2188-NFPA 70-2018 [ Section No. 705.150 ]

705.150 50 System Operation.

Microgrid systems shall be permitted to disconnect from the primary source of power or otherinterconnected electric power production sources and operate in stand-alone or islanded mode.

Statement of Problem and Substantiation for Public Comment

The numbering from the reorganization was intended to reduce all the sections 705.150 through 705.170 to 100 less or 705.50 through 705.70. Any references that may exist in the NEC to any sections of article 705 need to be reviewed for accuracy since the construction of the whole article has changed so much.

Related Item

Submitter Information Verification

Submitter Full Name: William Brooks

Organization: Brooks Engineering

Street Address:

City:

State:

Zip:

Submittal Date: Thu Aug 30 22:28:49 EDT 2018

Committee: NEC-P04

Committee Statement

Committee Action: Rejected but see related SR

Resolution: SR-8198-NFPA 70-2018

Statement: The Part and Section numbering is updated as a result of the reorganization at first draft.

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Public Comment No. 318-NFPA 70-2018 [ Section No. 705.150 ]

705.150 System Operation.

Microgrid systems shall be permitted to disconnect from the primary source of power or otherinterconnected electric power production sources and operate in stand-alone or islanded island mode.

Statement of Problem and Substantiation for Public Comment

Stand-Alone systems do not have a connection to the electric utility per definition. The change is consistent with IEEE 1547-2018.

Related Public Comments for This Document

Related Comment Relationship

Public Comment No. 308-NFPA 70-2018 [Definition: Stand-Alone (Islanded) Mode. ] Same issue

Public Comment No. 306-NFPA 70-2018 [Definition: Stand-Alone System.] Same issue

Related Item

• FR-8683

Submitter Information Verification

Submitter Full Name: Timothy Croushore

Organization: FirstEnergy

Affiliation: Edison Electric Institute - Electric Light and Power Task Force

Street Address:

City:

State:

Zip:

Submittal Date: Fri Jul 27 13:52:51 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected but see related SR

Resolution: SR-8199-NFPA 70-2018

Statement: The revision edits the section for clarity to refer to isolated microgrids and island mode forconsistency with other sections. Changes in terminology in this section better align with that usedin other standards.

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Public Comment No. 1781-NFPA 70-2018 [ Section No. 705.160 ]

705.160 Primary Power Source Connection.

Connections to primary power sources that are external to the microgrid system shall comply with therequirements of 705.11 and or 705.12 or 705 . 13 . Power source conductors connecting to a microgridsystem, including conductors supplying distribution equipment, shall be considered as power source outputconductors.

Statement of Problem and Substantiation for Public Comment

Editorial changes to improve applicability of this section by referencing all three connection options.

Related Item

• FR-8687

Submitter Information Verification

Submitter Full Name: Jason Fisher

Organization: Tesla Inc.

Affiliation: Solar Energy Industries Association (SEIA)

Street Address:

City:

State:

Zip:

Submittal Date: Wed Aug 29 23:10:07 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected but see related SR

Resolution: SR-8200-NFPA 70-2018

Statement: This revision adds a reference to 705.13 to allow for the connection of PCS equipment and addsan “or” to clarify that only one of these sections is required for compliance.

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Public Comment No. 2185-NFPA 70-2018 [ Section No. 705.160 ]

705.160 Primary Power Source Connection.

Connections to primary power sources that are external to the microgrid system shall comply with therelevant requirements of 705.11 and , 705.12, or 705 .13. Power source conductors connecting to amicrogrid system, including conductors supplying distribution equipment, shall be considered as powersource output conductors.

Statement of Problem and Substantiation for Public Comment

The current language may cause an AHJ to try to use a mixture of requirements from 705.11 and 705.12. Ultimately, depending on how the microgrid is connected, it could be 705.11, 705.12, or 705.13 that applies.

Related Item

Submitter Information Verification

Submitter Full Name: William Brooks

Organization: Brooks Engineering

Street Address:

City:

State:

Zip:

Submittal Date: Thu Aug 30 22:22:03 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected but see related SR

Resolution: SR-8200-NFPA 70-2018

Statement: This revision adds a reference to 705.13 to allow for the connection of PCS equipment and addsan “or” to clarify that only one of these sections is required for compliance.

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Public Comment No. 1523-NFPA 70-2018 [ Section No. 705.170 ]

705.170 Microgrid Interconnect Devices (MID).

Microgrid interconnect devices shall comply with the following:

(1) Be required for any connection between a microgrid system and a primary power source

(2) Be listed or field labeled evaluated for the application

(3) Have sufficient number of overcurrent devices located to provide overcurrent protection from allsources

Informational Note: MID functionality is often incorporated in an interactive or multimode inverter,energy storage system, or similar device identified for interactive operation.

Statement of Problem and Substantiation for Public Comment

The process of how “field labeled” is accomplished is not defined or set in the NEC. The definition of “field labeled” does not set any requirement or statement that a “serialized” label is provided as stated in the panel resolution statement. The process that leads to a field label is a function of the “field evaluation” process requirements found in NFPA 790 and NFPA 791. It has been stated that the term “field labeled” infers that a field evaluation would be completed. This may be the intent of the panel, but it is poor code writing to set a requirement that infers a process instead of stating the process, field evaluation, that is to be completed.

The NFPA style manual section 2.3.2.3 prohibits definitions from having requirements in the definition and therefore definitions cannot be used as establishing requirements.

It is noted that the field evaluation process is under the purview of the NFPA Electrical Equipment Evaluation (EEE) Technical Committee.A product or equipment can achieve a “field label” where a field evaluation is completed which has five distinct steps. A brief summary of these procedures includes selection of the correct nationally recognized standard, conducting a complete evaluation of construction, performing applicable non-destructive field testing, and documentation in formal engineering reports to both the client and the Authority having jurisdiction. When the process is completed with satisfactory results, then the serialized “field label” of the FEB is applied.

Please see the related comments for the definition of "field evaluation (field evaluated)" and the new section 110.3(D) that sets the process requirement and FEB qualification criteria.

To permit only the “field label” as suitable evidence for “approval” has allowed and will continue to allow unqualified entities to give a false sense of adequacy when they are in fact not performing the necessary rigorous evaluation that is provided in the requirement of the NFPA 790 and NFPA 791 documents.If the panel believes the term “field labeled” is still the correct term, it is requested this item be referred the Correlating Committee for correlation between the NEC and the documents under the purview of the NFPA EEE committee.

Related Public Comments for This Document

Related Comment Relationship

Public Comment No. 1353-NFPA 70-2018 [New Definition after Definition: FestoonLighting.]

Public Comment No. 1489-NFPA 70-2018 [New Section after 110.3(C)]

Public Comment No. 1353-NFPA 70-2018 [New Definition after Definition: FestoonLighting.]

Public Comment No. 1489-NFPA 70-2018 [New Section after 110.3(C)]

Related Item

• PI 2610

Submitter Information Verification

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Submitter Full Name: Charles Mello

Organization: Cdcmello Consulting Llc

Affiliation: Self

Street Address:

City:

State:

Zip:

Submittal Date: Wed Aug 29 10:06:31 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected but see related SR

Resolution: SR-8229-NFPA 70-2018

Statement: Stating that equipment has a field evaluation does not guarantee that a field label is installed. NFPA791 includes a recommendation for a label to be installed but does not mandate it as quoted below.The process of applying a field label for field evaluated equipment is extremely important for AHJs.

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Public Comment No. 1177-NFPA 70-2018 [ Section No. 710.1 ]

710.1 Scope.

This article covers electric power production sources operating in stand-alone or islanded mode. It alsocovers installations that are not connected to an electric power production and distribution network.

Informational Note: These sources are capable of operating in stand-alone or islanded mode,independent from the electric power production and distribution network, and may be eitherinteractive or isolated microgrid systems. Stand-alone systems may include sources such as enginegenerators, solar PV, wind, ESS, or batteries.

Additional Proposed Changes

File Name Description Approved

CN_231.pdf 70_CN 231

Statement of Problem and Substantiation for Public Comment

NOTE: This Public Comment appeared as CC Note No. 231 in the First Draft Report on First Revision No. 8718.

The Correlating Committee directs the panel to reconsider the text of the informational note to remove permissive language. The use of the word “may” makes this permissive.

This action will be considered as a public comment.

The Correlating Committee advises that article scope statements are the responsibility of the Correlating Committee and the Correlating Committee accepts the panel action.

Related Item

• FR 8718

Submitter Information Verification

Submitter Full Name: CC on NEC-AAC

Organization: NEC Correlating Committee

Street Address:

City:

State:

Zip:

Submittal Date: Fri Aug 24 10:07:33 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected but see related SR

Resolution: SR-8202-NFPA 70-2018

Statement: CMP-4 requests that the Correlating Committee review these changes to the scope of Article 710,which better align the scope with the revised content of the Article. The informational note wasrevised to remove language that could be perceived as being permissive and to recognize thatstand-alone systems could include single or multiple sources, where they are compatible with eachother.

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Public Comment No. 1783-NFPA 70-2018 [ Section No. 710.1 ]

710.1 Scope.

This article covers electric power production sources systems capable of operating in stand-alone orislanded mode . It also covers installations and installations that are not connected to an electric powerproduction and distribution network.

Informational Note: These sources systems are capable of operating in stand-alone or islandedmode, independent from the electric power production and distribution network, and may but maybe either interactive or isolated microgrid systems or interactive with other power sources . Stand-alone systems may include single or a compatible interconnection of sources such as enginegenerators, solar PV, wind, ESS, or batteries.

Statement of Problem and Substantiation for Public Comment

This change is necessary to expand code requirements for stand-alone or islanded systems that include not just the source. The new definition is applicable but not contradictory to other articles such as 705. The change paves the way for larger stand-alone or islanded systems that can be expanded into three-phase applications.

Related Item

• FR-8718

Submitter Information Verification

Submitter Full Name: Jason Fisher

Organization: Tesla Inc.

Affiliation: Solar Energy Industries Association (SEIA)

Street Address:

City:

State:

Zip:

Submittal Date: Wed Aug 29 23:16:39 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected but see related SR

Resolution: SR-8202-NFPA 70-2018

Statement: CMP-4 requests that the Correlating Committee review these changes to the scope of Article 710,which better align the scope with the revised content of the Article. The informational note wasrevised to remove language that could be perceived as being permissive and to recognize thatstand-alone systems could include single or multiple sources, where they are compatible with eachother.

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Public Comment No. 1179-NFPA 70-2018 [ Section No. 710.2 ]

710.2 Definitions.

Stand-Alone (Islanded) Mode.

The mode when a multimode inverter or microgrid is disconnected from the electric power production anddistribution network primary power source.

Informational Note: For isolated stand-alone systems and isolated microgrids, stand-alone orislanded mode is the primary mode of operation. Isolated microgrids are distinguished frominterconnected microgrids, which are defined in 705.2.

Additional Proposed Changes

File Name Description Approved

CN_163.pdf 70_CN 163

Statement of Problem and Substantiation for Public Comment

NOTE: This Public Comment appeared as CC Note No. 163 in the First Draft Report on First Revision No. 8720.

The Correlating Committee directs the panel to take action on section 710.2 to correlate with other actions taken throughout the code with respect to the application of definitions in the XXX.2 sections.

This action will be considered as a public comment.

Related Item

• FR 8720

Submitter Information Verification

Submitter Full Name: CC on NEC-AAC

Organization: NEC Correlating Committee

Street Address:

City:

State:

Zip:

Submittal Date: Fri Aug 24 10:10:16 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected but see related SR

Resolution: SR-8206-NFPA 70-2018

Statement: A new sentence has been added to clarify that definitions within 710.2 apply only within Article710.

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Public Comment No. 2125-NFPA 70-2018 [ Section No. 710.2 ]

710.2 Definitions.

Stand-Alone (Islanded) Mode. The definition in this section shall apply within this article andthroughout the code.

The mode when a multimode inverter or microgrid is disconnected from the electric power production anddistribution network primary power source.

Informational Note: For isolated stand-alone systems and isolated microgrids, stand-alone orislanded mode is the primary mode of operation. Isolated microgrids are distinguished frominterconnected microgrids, which are defined in 705.2.

Statement of Problem and Substantiation for Public Comment

The proposed language is part of a global effort to provide guidance to the user of the code regarding applicability of definitions located in the .2 sections within individual articles. The language makes it clear that the definition is not limited to Article 710.

Related Item

• CN 163

Submitter Information Verification

Submitter Full Name: Christel Hunter

Organization: Cerro Wire

Street Address:

City:

State:

Zip:

Submittal Date: Thu Aug 30 19:30:26 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected but see related SR

Resolution: SR-8206-NFPA 70-2018

Statement: A new sentence has been added to clarify that definitions within 710.2 apply only within Article710.

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Public Comment No. 1782-NFPA 70-2018 [ Definition: Stand-Alone (Islanded) Mode. ]

Stand-Alone (Islanded) Mode.

The mode when a multimode inverter or a microgrid is disconnected from the electric power production anddistribution network or other primary power source.

Informational Note: For isolated stand-alone systems and isolated microgrids, stand-alone orislanded mode is the primary mode of operation. Isolated microgrids are distinguished frominterconnected microgrids, which are defined in 705.2.

Statement of Problem and Substantiation for Public Comment

Changed to include sources in addition to the electric power production and distribution network

Related Item

• FR-8720

Submitter Information Verification

Submitter Full Name: Jason Fisher

Organization: Tesla Inc.

Affiliation: Solar Energy Industries Association (SEIA)

Street Address:

City:

State:

Zip:

Submittal Date: Wed Aug 29 23:13:33 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected but see related SR

Resolution: SR-8208-NFPA 70-2018

Statement: Changes are made to this definition to better clarify the use of the term and how it applies tovarious applications that operate in island mode.

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Public Comment No. 308-NFPA 70-2018 [ Definition: Stand-Alone (Islanded) Mode. ]

Stand-Alone (Islanded) Mode Island Mode .

The mode when a multimode inverter or microgrid is disconnected from the electric power production anddistribution network primary power source.

Informational Note: For isolated stand-alone systems and isolated microgrids, stand-alone orislanded and interconnected microgrids, island mode is the primary mode ofoperation operationwen ot connected to a primary source or electric utility . Isolated microgrids aredistinguished from interconnected microgrids, which are defined in 705.2.

Statement of Problem and Substantiation for Public Comment

CMP-4 has added the definition of Stand-Alone (Islanded Mode) in Article 710. In addition, the changes made to the definition of Stand-Alone System in Article 100 causes confusion with the definition of Microgrid System in Article 705.

To remedy the confusion, the term in 710.2 for Stand-alone (Islanded) Mode should be changed to Island Mode.

In addition, the Informational Note after the definition of Stand-Alone System in Article 100 should be deleted. A premises wiring system with a connection to a primary source (electric utility) is a Microgrid system as defined in Article 705.

These changes are consistent with IEEE 1547-2018 - IEEE Standard for Interconnection and Interoperability of Distributed Energy Resources with Associated Electric Power Systems Interfaces.

Related Public Comments for This Document

Related Comment Relationship

Public Comment No. 306-NFPA 70-2018 [Definition: Stand-Alone System.] Same Issue

Public Comment No. 306-NFPA 70-2018 [Definition: Stand-Alone System.]

Public Comment No. 318-NFPA 70-2018 [Section No. 705.150]

Related Item

• FR8720

Submitter Information Verification

Submitter Full Name: Timothy Croushore

Organization: FirstEnergy

Affiliation: Edison Electric Institute - Electric Light and Power Task Force

Street Address:

City:

State:

Zip:

Submittal Date: Fri Jul 27 12:29:54 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected but see related SR

Resolution: SR-8208-NFPA 70-2018

Statement: Changes are made to this definition to better clarify the use of the term and how it applies tovarious applications that operate in island mode.

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Public Comment No. 1525-NFPA 70-2018 [ Section No. 710.6 ]

710.6 Equipment Approval.

All equipment shall be listed or field labeled evaluated for the intended use.

Statement of Problem and Substantiation for Public Comment

The process of how “field labeled” is accomplished is not defined or set in the NEC. The definition of “field labeled” does not set any requirement or statement that a “serialized” label is provided as stated in the panel resolution statement. The process that leads to a field label is a function of the “field evaluation” process requirements found in NFPA 790 and NFPA 791. It has been stated that the term “field labeled” infers that a field evaluation would be completed. This may be the intent of the panel, but it is poor code writing to set a requirement that infers a process instead of stating the process, field evaluation, that is to be completed.

The NFPA style manual section 2.3.2.3 prohibits definitions from having requirements in the definition and therefore definitions cannot be used as establishing requirements.

It is noted that the field evaluation process is under the purview of the NFPA Electrical Equipment Evaluation (EEE) Technical Committee.A product or equipment can achieve a “field label” where a field evaluation is completed which has five distinct steps. A brief summary of these procedures includes selection of the correct nationally recognized standard, conducting a complete evaluation of construction, performing applicable non-destructive field testing, and documentation in formal engineering reports to both the client and the Authority having jurisdiction. When the process is completed with satisfactory results, then the serialized “field label” of the FEB is applied.

Please see the related comments for the definition of "field evaluation (field evaluated)" and the new section 110.3(D) that sets the process requirement and FEB qualification criteria.

To permit only the “field label” as suitable evidence for “approval” has allowed and will continue to allow unqualified entities to give a false sense of adequacy when they are in fact not performing the necessary rigorous evaluation that is provided in the requirement of the NFPA 790 and NFPA 791 documents.If the panel believes the term “field labeled” is still the correct term, it is requested this item be referred the Correlating Committee for correlation between the NEC and the documents under the purview of the NFPA EEE committee.

Related Public Comments for This Document

Related Comment Relationship

Public Comment No. 1353-NFPA 70-2018 [New Definition after Definition: FestoonLighting.]

Public Comment No. 1489-NFPA 70-2018 [New Section after 110.3(C)]

Public Comment No. 1353-NFPA 70-2018 [New Definition after Definition: FestoonLighting.]

Public Comment No. 1489-NFPA 70-2018 [New Section after 110.3(C)]

Related Item

• PI 2611

Submitter Information Verification

Submitter Full Name: Charles Mello

Organization: Cdcmello Consulting Llc

Affiliation: Self

Street Address:

City:

State:

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Zip:

Submittal Date: Wed Aug 29 10:08:48 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected but see related SR

Resolution: SR-8209-NFPA 70-2018

Statement: Stating that equipment has a field evaluation does not guarantee that a field label is installed. NFPA791 includes a recommendation for a label to be installed but does not mandate it as quoted below.The process of applying a field label for field evaluated equipment is extremely important for AHJs.

A new informational note has been added to clarify how different terms in product standards areused in Article 710.

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Public Comment No. 1854-NFPA 70-2018 [ Section No. 710.10 ]

710.10 Identification of Power Sources.

A permanent plaque or directory shall be installed at a building supplied by a stand-alone system at eachservice equipment location, or at an approved readily visible location. The plaque or directory shall denotethe location of each power source disconnecting means for the premises building or be grouped with otherplaques or directories for other on-site sources. The Where multiple sources supply the building the plaqueor directory shall be marked with the wording “CAUTION: MULTIPLE SOURCES OF POWER”. Themarking shall comply with 110.21(B).

Exception: Installations with multiple co-located power production sources shall be permitted to beidentified as a group(s). The plaque or directory shall not be required to identify each power sourceindividually.

Statement of Problem and Substantiation for Public Comment

Changes made to this section are part of a larger group of changes to other articles that are being recommended in an effort to harmonize all directory requirements for onsite sources. During the public input phase we submiitted several inputs that were also being coordinated with changes being proposed to other fire and building codes. Our intention is to standardize and harmonize these requirements to address the situation where different onsite sources may be installed by different groups at different times. During the First Draft state we received significant input and support by both CMP-13 and CMP-4 to improve our inputs. This comment is related to several other comments that realign all the changes made in the First Draft to ensure all requirements remain harmonized accross the different articles.

Related Public Comments for This Document

Related Comment Relationship

Public Comment No. 1848-NFPA 70-2018 [Section No. 705.10]

Related Item

• FR-8721

Submitter Information Verification

Submitter Full Name: Jason Fisher

Organization: Tesla Inc.

Street Address:

City:

State:

Zip:

Submittal Date: Thu Aug 30 10:27:29 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Accepted

Resolution: SR-8210-NFPA 70-2018

Statement: Changes made to this section harmonize the directory requirements for onsite sources acrossvarious articles.

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Public Comment No. 1784-NFPA 70-2018 [ Section No. 710.15 ]

710.15 General.

Premises wiring systems shall be adequate to meet the requirements of this Code for similar installationssupplied by a feeder or service. The wiring on the supply side of the building or structure disconnectingmeans shall comply with the requirements of this Code, except as modified by 710.15(A) through (F).

(A) Supply Output.

Power supply to premises wiring systems fed by stand-alone or isolated microgrid power sources shall bepermitted to have less capacity than the calculated load. The capacity of the sum of all sources of theof the stand-alone supply shall be equal to or greater than the load posed by the largest single utilizationequipment connected to the system. Calculated general lighting loads shall not be considered as a singleload.

Informational Note: For general-use loads the system capacity can be calculated using the sum ofthe capacity of the firm sources, such as generators and ESS inverters. For specialty loads intendedto be powered directly from a variable source, the capacity can be calculated using the sum of thevariable sources, such as PV or wind inverters, or the combined capacity of both firm and variablesources.

(B) Sizing and Protection.

The circuit conductors between a stand-alone or microgrid source and a building or structure disconnectingmeans shall be sized based on the sum of the output ratings of the stand-alone or microgrid source(s). Forthree phase interconnections, the phase loads shall be controlled or balanced to be compatible withspecifications of the sum ot the power supply capacities.

(C) Single 120-Volt Supply.

Stand-alone and isolated microgrid systems shall be permitted to supply 120 volts to single-phase, 3-wire,120/240-volt service equipment or distribution panels where there are no 240-volt outlets and where thereare no multiwire branch circuits. In all installations, the sum of the ratings of the power sources shall be lessthan the rating of the neutral bus in the service equipment. This equipment shall be marked with thefollowing words or equivalent:

WARNING:SINGLE 120-VOLT SUPPLY. DO NOT CONNECT MULTIWIRE BRANCH CIRCUITS!Thewarning sign(s) or label(s) shall comply with 110.21(B).

(D) Three-phase Supply. Stand-alone and microgrid systems shall be permitted to supply three-phase,3-wire or 4-wire systems, up to a maximum of 480-volt to service equipment or distribution panels wherewhere the summation of loads are controlled and balanced to be compatible with the limits of the sum ofthe firm sources. The sum of the ratings of the power sources shall be less than the bus ratings in theservice equipment in all installations.

(E) Energy Storage or Backup Power System Requirements .

Energy storage or backup power supplies shall not be required.

(E F ) Backfed Back-fed Circuit Breakers.

Plug-in-type backfed back-fed circuit breakers connected to an interconnected supply shall be secured inaccordance with 408.36(D). Circuit breakers marked “line” and “load” shall not be backfed back-fed .

(F G ) Voltage and Frequency Control.

The stand-alone or isolated microgrid supply shall be controlled so that voltage and frequency remain withinsuitable limits for the connected loads.

Statement of Problem and Substantiation for Public Comment

The changes provide for larger systems.The term backfed has been changed to add a hyphen to align with the majority of uses of this term in the Code.

Related Item

• FR-8722 • FR-8725

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Submitter Information Verification

Submitter Full Name: Jason Fisher

Organization: Tesla Inc.

Affiliation: Solar Energy Industries Association (SEIA)

Street Address:

City:

State:

Zip:

Submittal Date: Wed Aug 29 23:22:28 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected but see related SR

Resolution: SR-8213-NFPA 70-2018

Statement: New language has been added to (B) and a new (D) to recognize that stand-alone systemsoften include three-phase applications.

The term back-fed has been changed to add a hyphen to align with the majority of usage of thisterm in the Code.

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Public Comment No. 526-NFPA 70-2018 [ New Part after I. ]

PV WIRE

Photovoltaic wire , also known as PV wire , is a single-conductor wire used to connect the panels of

a photovoltaic electric energy system. PV systems, or solar panels, are electric-power production

systems that capture sunlight in order to produce electricity through an energy conversion process

Statement of Problem and Substantiation for Public Comment

There is no definition for PV wire. What is PV wire? Is it RHW-2 or something else or a general term. As an example, in 690.31(C)(1), it references the following: "PV Wire or Cable is permitted in all locations where RHW-2 is permitted."

Related Item

• First Draft Report

Submitter Information Verification

Submitter Full Name: Todd Fries

Organization: HellermannTyton

Street Address:

City:

State:

Zip:

Submittal Date: Fri Aug 10 11:44:43 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected but see related SR

Resolution: SR-8149-NFPA 70-2018

Statement: This revision provides a specific requirement that both PV wire or cable, and DG cable must belisted. The informational note points the user to the relevant product standards.

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Public Comment No. 319-NFPA 70-2018 [ Part IV. ]

Part IV. Microgrid Systems

Statement of Problem and Substantiation for Public Comment

Add back Part II and Part III of Article 705 from the 2017 NEC. FR 8674 deleted too much necessary technical material.

Related Item

• FR-8674

Submitter Information Verification

Submitter Full Name: Timothy Croushore

Organization: FirstEnergy

Affiliation: FirstEnergy

Street Address:

City:

State:

Zip:

Submittal Date: Fri Jul 27 14:00:47 EDT 2018

Committee: NEC-P04

Committee Statement

CommitteeAction:

Rejected but see related SR

Resolution: SR-8152-NFPA 70-2018 See also Second Revisions No. 8193 and 8196.

Statement: In the first draft, the section that was moved from 705.143 to the second sentence of 705.14 wasnot correctly recorded. This SR also deletes the extraneous wording in the first sentence.

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