[RE-wrenches] Rapid Shutdown Again?

[Ray]

Greetings fellow wrenches;

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 /PV System DC Circuit/ stops at 
the /PV Disconnect/.  Note 2 says specifically the '/PV Disconnect 
separates the PV system from all other systems/'.  But then in the 
definitions in 690.2 on the next page, the new definition of a /P//V 
System DC Circuit/ 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?)

Then 690.12 which only applies to '/PV System circuits in or on 
buildings/', says we have to control conductors more than 3 ft after 
penetrating the building.

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 /PV system/ 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.

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 '/buildings with the sole purpose of housing PV system equipment/'?

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___/Charge Control/_,**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.

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.

-- 
Ray Walters
Remote Solar
303 505-8760

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