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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