We support the 690.12(B)(2)(2) requirement of the NEC 2017 (known as Module Level Shutdown) to add an additional layer of safety for fire fighters. However, this additional safety should not come with new risks, reduced reliability, limited customer choice, and added cost. Today's solutions for 690.12(B)(2)(2) unfortunately do not fulfill the original intention of the NEC and while they reduce the voltage inside the array boundary, they add additional safety risks to the PV system. Therefore, we request for this requirement to be fixed.

If a module integrated solution based on an open industry standard is available, installation and maintenance experience for installers, system reliability, and performance would be just like it was before the shutdown requirement, while providing an additional layer of safety for fire fighters.