[RE-wrenches] NEC 2014 690.12 Rapid Shutdown

Drake drake.chamberlin at redwoodalliance.org
Fri Jan 24 13:56:37 PST 2014 

Here is the email that I sent to Matt Paiss in response to his 
contact with me.

Matt,

Thanks for your email. I was in the midst of answering it yesterday 
when my reply disappeared into cyberspace.  Maybe it found its way to 
your mailbox.

We agree strongly that PV should be made as safe as possible, and 
that firefighters need to be educated about these systems.  The issue 
I raise is that the new rule came through with no lead time, no NRTL 
listed equipment available to satisfy the requirement, and no 
prescribed way to implement it.  Through the work of many, maybe 
including you, the ruling fortunately was not far more damaging.

There is no emergency requiring immediate implementation of a 
methodology that will create so many problems for the PV 
industry.  The dangers of rooftop PV do not show up on the radar 
compared to even the use of extension cords; much less traffic deaths 
and fatalities related to mis-prescribed medicines; and diseases 
suffered by the general public, caused by the extractive industries.

This new code requirement presents a major new issue for the industry 
to deal with. It is yet another block in the way of solar cost 
effectiveness, and with it the success ratio of the industry.  This 
requirement has come with no set solution, and will continue to cause 
considerable financial loss and stress until all the details are 
eventually worked out.

It is the fact that the PV industry has been wounded in this way that 
makes it seem like an ALEC-supported operation. This assault works 
well for the group's agenda. ALEC is not a matter of secret agendas; 
it is very visible, with an extremely well-orchestrated assault on 
the PV 
industry. 
<http://ecowatch.com/2014/01/22/largest-power-company-alec-solar/>http://ecowatch.com/2014/01/22/largest-power-company-alec-solar/ 

You may well be right that no committee members were lobbied. You 
were there and I was not. Nevertheless, I would really like to know 
who proposed the module level rapid disconnect requirement. Some may 
be alarmed about PV rooftop systems for good reason, and / or they 
may have been influenced to consider this relatively safe technology 
to be a threat.

Would it be possible for you to put me in contact with the people who 
presented this idea, and those who argued passionately for it? If 
they want to contact me, please forward my contact information to them.

Best regards,

Drake





At 02:11 PM 1/24/2014, you wrote:
>Wrenches,
>
>Matt Paiss is wanted to chime in here. He's a member of the 
>Code-Making Panel No. 4 Firefighter Safety Task Group, as well as 
>SEIA's PV Industry Forum.
>
>Since he can't post to the list, I am sharing his comments with the group:
>
>
>>Drake,
>>
>>After reading your initial comments, I think you have nailed both 
>>the intent of this code section as well as the benefits.  But in 
>>reading your second posting, I felt it important to write you.  As 
>>one of the representatives from the Fire Service that drafted 
>>690.12, I can tell you that while there is always room for 
>>improvement in language, the goal is to have PV that can not start 
>>a fire.  As I am not a "wrench" I can not post to the list (feel 
>>free to share any of my comments here if you wish), but I would 
>>like to chime in on this conversation.
>>
>>Your assertion that ALECs are targeting the PV industry is not 
>>taking place in this process.   There are many hard-working 
>>individuals from the PV industry, electrical inspectors, and the 
>>fire service working together to keep PV safe and secure for many 
>>years to come.  I for one have both PV and thermal on my home.
>>
>>While you are correct that no fire fighter fatalities have resulted 
>>from a PV system shock, the goal is to prevent the first. One 
>>problem is that the PV industry has not adequately addressed the 
>>arc and ground fault problems in the US.  Simply put, many rooftop 
>>systems are not NEC compliant; they can not detect and interrupt 
>>all faults.  This has unfortunately resulted in far too many 
>>fires.  The many additions & changes to sec 690 in the 2014 cycle 
>>will go far in achieving a much safer system.
>>
>>The fire service is becoming increasingly aware, educated, and 
>>involved in the code process for PV safety.  It should be clear 
>>that the goal for all parties is a safe electrical product.  There 
>>is no secret agenda to pull the rug out from under solar. To those 
>>that are concerned with the imbedded cost increases, please take a 
>>longer view than your current FY.  The systems that fire fighters 
>>respond to may be many years old, but in reality most of the fires 
>>have occurred on new systems.  We will respond to older systems 
>>over time, and some buildings will be lost due to concern over the 
>>inability to isolate power down to a safe level.  As I teach 
>>firefighters about electrical safety, many express both an interest 
>>in PV as well as concern that it should be possible to shut a 
>>system down in the event of an emergency either manually, or as a 
>>result of a fault.
>>
>>Thank you,
>>Matt
>>
>>CA Matthew Paiss, E19B
>>Bureau of Field Operations
>>San Jose Fire Department
>>1661 Senter Rd
>>San Jose, CA 95113
>>(831) 566-3057 c
>
>BTW: the stakeholders who developed the consensus language in 690.12 
>are listed in the NEC 2014 Report on Comments:
>
>This comment is the result of a consensus process established among 
>three groups of stakeholders: 1) CMP4 Firefighter SafetyTask Group; 
>2) SEIA Codes and Standards Working Group; and 3) PV Industry Forum. 
>Participants in these groups included the following individuals:
>
>CMP4 Firefighter Safety Task Group
>1. Ward Bower, CMP4 representing SEIA
>2. Bill Brooks, CMP4 representing SEIA and Chair of Task Group
>3. Bob Davidson, Davidson Code Concepts
>4. Mark Earley, Secretary, NFPA
>5. Bob James, UL
>6. Matt Paiss, City of San Jose Fire Department
>7. Jim Rogers, CMP4 representing IAEI
>8. Todd Stafford, CMP4 representing IBEW
>9. Ronnie Toomer, Chair of CMP4
>10. Peter Willse, Global Asset Protection Services
>
>SEIA Codes and Standards Working Group
>1. Mark Albers, SunPower
>2. Mark Baldassari, Enphase Energy
>3. Ward Bower, SEIA
>4. Bill Brooks, Brooks Engineering/SEIA
>5. Joe Cain, Chair of SEIA Codes and Standards Working Group
>6. Keith Davidson, SunTech
>7. Darrel Higgs, Dow Solar
>8. Lee Kraemer, First Solar
>9. Carl Lenox, SunPower
>10. Charles Luebke, Eaton
>11. Martin Mesmer, E.ON
>12. Steve Pisklak, Dow Solar13. Robert Rynar, First Solar
>14. Michael Schenck, First Solar
>15. John Smirnow, SEIA
>16. Kris VanDerzee, First Solar
>17. Leo Wu, SolarCity
>18. Tilak Gopalarathnam, REFUsol Incorporated
>
>PV Industry Forum
>1. Mark Albers, SunPower
>2. Greg Ball, DNV
>3. Bill Brooks, Brooks Engineering, lead for 690.12
>4. Mark Baldassari, Enphase Energy
>5. Ward Bower, SEIA
>6. Michael Coddington, NREL
>7. Marv Dargatz, SolarEdge
>8. Chris Flueckiger. UL
>9. Joerg Grosshennig, SMA
>10. Darrel Higgs, Dow Solar
>11. Dan Lepinski, Exeltech
>12. Carl Lenox, SunPower
>13. Charles Luebke, Eaton
>14. Matt Paiss, City of San Jose Fire Department
>15. Steve Pisklak, Dow Solar
>16. Jim Rogers, Town of Oak Bluffs
>17. Jon Sharp, Ampt
>18. Bhima Sheridan, SolarCity
>19. John Smirnow, SEIA
>20. Holly Thomas, U.S. Dept. of Energy
>21. Phil Undercuffler, Outback Power
>22. John Wiles, NMSU, Secretary of PV Industry Forum
>23. Leo Wu, SolarCity
>24. Tim Zgonena, UL
>
>
>On Jan 24, 2014, at 1:00 PM, 
><mailto:re-wrenches-request at lists.re-wrenches.org>re-wrenches-request at lists.re-wrenches.org 
>wrote:
>
>>From: Drake 
>><<mailto:drake.chamberlin at redwoodalliance.org>drake.chamberlin at redwoodalliance.org>
>>Subject: Re: [RE-wrenches] NEC 2014 690.12 Rapid Shutdown
>>Date: January 22, 2014 2:16:18 PM CST
>>To: RE-wrenches 
>><<mailto:re-wrenches at lists.re-wrenches.org>re-wrenches at lists.re-wrenches.org>
>>Reply-To: RE-wrenches 
>><<mailto:re-wrenches at lists.re-wrenches.org>re-wrenches at lists.re-wrenches.org>
>>
>>
>>
>>David,
>>
>>My sincere thanks to all of you who worked to keep the module level 
>>disconnect requirement out of the 2014 code cycle. That ruling 
>>would have amounted to a knockout punch for string and central 
>>inverters on buildings.
>>
>>What was the driving force behind this push for immediate module 
>>level disconnection? There has clearly not been a rash of 
>>firefighter deaths due to PV systems. Although PV needs to continue 
>>evolving safety standards that take into account the concerns of 
>>firefighters, there is no crisis that would justify thwarting one 
>>of the few growing sectors of our economy.
>>
>>The PV track record has been amazingly good. So far, I've found no 
>>accounts of solar related firefighter deaths or injuries. The NFPA 
>>statistics show that the highest cause of firefighter death is 
>>heart attack. 
>><http://www.nfpa.org/newsandpublications/nfpa-journal/2013/july-august-2013/features/firefighter-fatalities-in-the-united-states-2012>http://www.nfpa.org/newsandpublications/nfpa-journal/2013/july-august-2013/features/firefighter-fatalities-in-the-united-states-2012 
>>
>>
>>This push for crippling regulation bears the earmark of ALEC's 
>>extensive and effective war on solar. As you can read in the 
>>following links, the massively funded, Koch brothers-linked ALEC is 
>>lobbying heavily, on every level, to derail solar. All who are 
>>associated with the solar industry need to be aware of this 
>>powerful lobbying campaign.
>>
>><http://www.theguardian.com/world/2013/dec/04/alec-freerider-homeowners-assault-clean-energy>http://www.theguardian.com/world/2013/dec/04/alec-freerider-homeowners-assault-clean-energy 
>>
>>
>>http://www.salon.com/2013/12/05/alec_freeriders_with_solar_panels_must_pay_for_robbing_the_system/ 
>>
>>
>><http://beforeitsnews.com/environment/2014/01/alec-gain-an-inside-track-on-colorado-solar-2490132.html>http://beforeitsnews.com/environment/2014/01/alec-gain-an-inside-track-on-colorado-solar-2490132.html 
>>
>>
>>Is there any way that the solar community can be alerted when 
>>threats to our industry are being put before the NEC? Although few 
>>contractors have the time or money to walk away from their 
>>businesses and attend code writing committees, a substantial number 
>>might have the time to make phone calls and send letters or emails 
>>to code writers.
>>
>>The solar industry needs a strong lobby of its own.
>>
>>Drake
>>
>>
>
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