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<p>HI Chris;</p>
<p>As with all things bureaucratic, good intentions can go awry
when actually implemented. Years ago, I was one of the wrenches
pushing for some form of disconnect closer to the power source, or
the PV array. I had no idea it would come back to bite us small
off grid folks so hard, though. I'm not quite for scrapping all
of 690.12, but I do think it needs some serious work. <i>In or
on the building</i> needs to be defined more clearly as 'on the
roof'. Ground mounts need a clearer exemption. The PV disconnect
needs to be clearly defined and also clearly stated that the Rapid
disconnect system stops there. The time limit needs to be bumped
up to 90 seconds: no one is going to throw the switch and be
hacking on the roof that fast. The array voltage should be 150
vdc, so that lower voltage off grid systems could be exempt, and I
really think 690.12 should only apply to larger arrays (over 10kW)
that have long exposed runs of conduit (over 10 yards) or that
cover more than a certain percentage of the total roof area. If
an array covers one face of the garage it should be exempt, and if
it covers half the total roof, then it should have Rapid
disconnect, for instance. We need to be sensible, do the fire
fighters have a good spot to cut and vent the roof without
electrical hazards or not? <br>
</p>
<p>Its interesting how article 690 has morphed from being almost
entirely oriented towards off grid in 99 and 02, to now off grid
is barely even considered. Just look at the lack of thought when
they wrote the definitions for <i>DC to DC Converters</i>. The
solar industry has been ready and willing to be thrown under the
bus at every turn. I think its about time we started advocating
for our own self interests like all the other parties involved.
This also means that us off grid folks need to be properly
represented, and off grid considered with all code changes. I
think DC coupled PV should have its own section and be separated
from AC coupled PV. The systems are so different that it doesn't
make sense to throw them into the same section. The emergence of
article 706 is a step in the right direction.<br>
</p>
<pre class="moz-signature" cols="72">Ray Walters
Remote Solar
303 505-8760</pre>
<div class="moz-cite-prefix">On 8/23/18 5:31 PM,
<a class="moz-txt-link-abbreviated" href="mailto:cwarfel@entech-engineering.com">cwarfel@entech-engineering.com</a> wrote:<br>
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<p>I think Rapid Shutdown should be scrapped professionally and
personally. It was ill conceived and ill written. Anyone
willing to join me in a petition to CMP 44 and the like, contact
me off list. </p>
<p>To your question directly, you have a ground mounted system and
you are not subject to 690.12 unless your conductors are "in or
on building" which i cannot seem to find what that actually
means. Exempted are buildings that are isolated only for the PV
system This is a big win for installers as almost everyone
installs systems like this....... Right. They used to have
a dimension to this, but I guess that gave installers too much
information. This is a stupid Code addition for roof mounted pv
systems, disguised as protecting Firefighters, but not doing so
in reality. The NEC looks politically compromised by consultants
and manufacturers who too advantage of this fear mongering. No
other country with a pv industry has historically done this. Why
are installers not up in arms about this?</p>
<p>This is the NEC reference.</p>
<p>690.12 Rapid Shutdown of PV Systems on Buildings. PV system
circuits installed on or in buildings shall include a rapid
shutdown function to reduce shock hazard for emergency
responders in accordance with 690.12(A) through (D).</p>
<p>If your system is ground mounted, you are outside the
"altruistic" intent of 690.12 of protecting Firefighters. Put a
initiation device disconnect switch at the array. Any
supporters of RS should chime in with the support of 690.12 and
add clarity and guidance to those of us who actually install
systems and have to deal with this baloney. 690.12 has caused
more problems for multimode systems than any tariffs, which are
bad enough. I don' think the industry needs any more "safe
design and installation" assistance from the CMPs involved with
this issue.</p>
<p>Chris Warfel</p>
<p><br>
</p>
<p><br>
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<p>On 2018-08-23 00:31, Ray wrote:</p>
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<p>Greetings fellow wrenches;</p>
<p>I know we have beat this many times but I once again have not
been able to resolve the contradictory information in 690 in
regards to implementing 690.12. As Rebekah Hren pointed out
before, the diagrams shown in Figure 690.1(b) show that the <em>PV
System DC Circuit</em> stops at the <em>PV Disconnect</em>.
Note 2 says specifically the '<em>PV Disconnect separates the
PV system from all other systems</em>'. But then in the
definitions in 690.2 on the next page, the new definition of a
<em>P</em><em>V System DC Circuit</em> says that it includes
DC to DC converter output circuits. (which are Solar Edge
module level controls, but could be interpreted as a MPPT
battery charge Controller?) </p>
<p>Then 690.12 which only applies to '<em>PV System circuits in
or on buildings</em>', says we have to control conductors
more than 3 ft after penetrating the building. </p>
<p>So in my case, I'm looking at a ground mount, and installing
an external lockable disconnect on the wall before it goes
into the building. This will officially be the PV
Disconnect. In my interpretation, I should not need to do any
Rapid Shutdown, because I've essentially prevented the <em>PV
system</em> from ever entering the building at all ( based
on the 5th diagram and Note 2) However, I could see an AHJ
claiming I had to do RS all the way to the output side of the
charge controller.</p>
<p>If this were true, could I simply apply RS equipment from the
PV disconnect to the output of the charge controller, or am I
back to module level shutdown for my ground mounted array, or
could I build a tiny building that just housed the PV
Disconnect and take the exemption for '<em>buildings with the
sole purpose of housing PV system equipment</em>'? </p>
<p>Essentially the definitions in 690.2 are too broad, and are
at odds with the Figure and Notes of 690.1. They really
didn't fix this in the 2017 code for us lowly off gridders.
Charge controllers are covered by article 706.23<u> </u><u><em>Charge
Control</em></u>, and NOT by 690.12 at all. IMHO, the
charge controller needs to be clearly defined and
differentiated from DC to DC converters like Solar Edge's
module level DC equipment. </p>
<p>I just want to go back to doing solar designs and
installations, and quit acting like an attorney parsing every
word of this confusing code language.</p>
<pre class="moz-signature">--
Ray Walters
Remote Solar
303 505-8760</pre>
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