To prevent the unintended consequences of the current code requirements and to allow for systems that are simple, safe, and more reliable, we request that code makers make the following changes to the National Electric Code:
Request 1: Revert NEC 2020 690.12 (Module Level Shutdown) to NEC 2014 690.12 (Array Level Shutdown) requirements until proper solutions are available on the market, such as module-integrated, chip-based devices with an open industry standard
Request 2: Revert to NEC 2014 690.12 but keep the 1' array boundary
Request 3: Implementing a maximum electrical noise level requirement for rapid shutdown devices in 690.12
Request 4: Require 690.11 (Arc Fault Circuit Protection) to apply to all solar PV DC circuits, not just those above 80V, to detect any potential fire safety issues
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Elise Couillard
Couillard Solar Foundation and Legacy Solar Co-op
Also, Most AHJ’s (based on their interruptation of NEC intent) forcing ’blanket’s code requirements, to shut down an array on 1/2 of a residential hip roof, is unwarranted (not a safety issue) & just extra cost to homeowner!
That way no shock can occur when touching the positive line and the roof structure. Then have a separate conduit for both positive and negative separated by 3 ft. In this way the fireman cannot cut through both of the lines with his chainsaw at the same time so he cannot cause a short. To shut the array down, a simple cut off at the inverter is all that is needed to stop the current flow.
It doesn’t need to be any more complicated than that.
If technology advances to accommodate module level, let’s do it. It is way too early yo try this.
Thanks!
Dr. Daniel Dean
Design Engineer
Earth Wise Solar Technologies