Answer

We don’t consider UL 3741 as a good solution because as is, it does not completely resolve all the underlying safety issues for shutdown, such as connection points, additional components on the roof, or noise interference with arc fault detection – so the root causes of these safety issues are not necessarily resolved. Furthermore, the standard does not present a real use case and is rather vague in its description. The certification process for a “safe array” involves many different parties (such as standard PV module, shutdown device, and inverter), who usually do not have R&D collaboration or joint certification processes and supply chains. Even when listed, installers might run into trouble in sourcing the exact components of a “safe array” and will have to do Module Level Shutdown as is.

There are also uncertainties on whether or not AHJs are approving solutions based on UL 3741: https://www.sepisolar.com/sepisolar-blogs/ul-3741-compliance/