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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- Module level electronics add unnecessary noise in the system requiring the inverter arc fault detection to have to be less nuanced. It is my opinion that this actually makes the likelihood of an arc fault to go undetected to be higher than a system that does not have the additional noise from MLPE.
- The MLPE requirement has created a duopoly within the inverter industry that has hampered the growth of the solar industry. It requires additional cost to the customer through the addition of equipment and installation time and complexity.