National Fire Protection Association
1 Batterymarch Park, Quincy, MA 02169-7471
Phone: 617-770-3000 • Fax: 617-770-0700 • www.nfpa.org
MEMORANDUM
TO:
NEC® Code-Making Panel 4
FROM:
Kimberly Shea, Administrator, Technical Projects
DATE:
April 3, 2015
SUBJECT:
NFPA 70 First Draft TC Ballot Circulation (A2016)
The April 1, 2015 date for receipt of the NEC First Draft Ballots has passed.
The preliminary First Draft ballot results are shown on the attached report.
13 Members Eligible to Vote on Articles 225, 230
14 Members Eligible to Vote on Articles 694
15 Eligible to Vote on Articles 690, 692 and 705
0 Ballots Not Returned
In accordance with the NFPA Regulations Governing the Development of NFPA Standards,
attached are reasons for negative votes for review so you may change your ballot if you wish.
Abstentions and affirmative comments are also included. Ballots received from alternate members
are not included unless the ballot from the principal member was not received.
If you wish to change your vote, the change must be received at NFPA on or before Friday,
April 10, 2015. Members who have not returned a ballot may do so now. Changes must be
submitted through the NFPA Vote.net Ballot site.
The return of ballots is required by the Regulations Governing the Development of NFPA
Standards.
Panel 4 First Draft Ballot Circulation
NEC-P04 First Draft Ballot Circulation (A2016)
FR-901, Definition: Photovoltaic (PV) System., See FR-901
Eligible to Vote: 15
Not Returned : 0
Affirmative
15
Affirmative with Comment
0
Negative
0
Abstain
0
FR-955, Definition: Utility-Interactive Inverter., See FR-955
Eligible to Vote: 15
Not Returned : 0
Vote Selection
Votes Comments
Affirmative
14
Affirmative with Comment
1
Ward I. Bower
This panel member believes this definition is short sighted. The language "An inverter intended for use in parallel with an electric utility
to supply common loads that may deliver power to the utility." when combined with the new Figure 1(b) indicates the inverter (named a
multimode inverter with an interactive inverter disconnect) is confusing. Perhaps the disconnect should be named multimode inverter
disconnect, but that would likely require another definition). This comment indicates additional work during the comment period.
Negative
0
Abstain
0
FR-1041, New Definition after Definition: Festoon Lighting., See FR-1041
Vote Selection
Votes Comments
Affirmative
13
Affirmative with Comment
1
Thomas E. Buchal
These definitions do not appear to cover festoon lighting
Negative
1
Malcolm Allison
Introducing and defining the terms field labeled and field evaluation body is unnecessary and will create confusion beyond just PV
applications. This also impacts FR's 935, 7511, 1012, 912, 1039, and 1045.
Abstain
0
FR-904, Section No. 225.4, See FR-904
Eligible to Vote: 12
Not Returned : 0
Affirmative
11
Affirmative with Comment
1
Thomas E. Buchal
It is unclear why there is an additional requirement for festoon lighting in this Article, however there is merit to the requirement.
Negative
Abstain
FR-902, Section No. 225.7(D), See FR-902
0
0
1 of 40
Panel 4 First Draft Ballot Circulation
Eligible to Vote: 12
Not Returned : 0
Affirmative
Affirmative with Comment
Negative
Abstain
FR-1023, Section No. 225.10, See FR-1023
Eligible to Vote: 12
Not Returned : 0
12
0
0
0
Vote Selection
Votes
Affirmative
12
Affirmative with Comment
0
Negative
0
Abstain
0
FR-905, Section No. 225.12, See FR-905
Vote Selection
Votes
Affirmative
12
Affirmative with Comment
0
Negative
0
Abstain
0
FR-906, Section No. 225.17, See FR-906
Vote Selection
Votes
Affirmative
12
Affirmative with Comment
0
Negative
0
Abstain
0
FR-907, Section No. 225.18, See FR-907
Vote Selection
Votes
Affirmative
12
Affirmative with Comment
0
Negative
0
Abstain
0
FR-908, Section No. 225.19(A), See FR-908
Vote Selection
Votes
Affirmative
12
Affirmative with Comment
0
Negative
0
Abstain
0
FR-909, Section No. 225.19(D)(2), See FR-909
Vote Selection
Votes
Affirmative
12
Comments
Comments
Comments
Comments
Comments
Comments
2 of 40
Panel 4 First Draft Ballot Circulation
Affirmative with Comment
0
Negative
0
Abstain
0
FR-910, Section No. 225.19(D)(3), See FR-910
Vote Selection
Votes
Affirmative
12
Affirmative with Comment
0
Negative
0
Abstain
0
FR-911, Section No. 225.20, See FR-911
Vote Selection
Votes
Affirmative
12
Affirmative with Comment
0
Negative
0
Abstain
0
FR-919, Section No. 225.22, See FR-919
Vote Selection
Votes
Affirmative
12
Affirmative with Comment
0
Negative
0
Abstain
0
FR-920, Section No. 225.27, See FR-920
Vote Selection
Votes
Affirmative
12
Affirmative with Comment
0
Negative
0
Abstain
0
FR-921, Section No. 225.30, See FR-921
Eligible to Vote: 12
Not Returned : 0
Vote Selection
Votes
Affirmative
10
Affirmative with Comment
1
Thomas E. Buchal
Negative
h
1
Abstain
0
Comments
Comments
Comments
Comments
Comments
The term labeled should be removed from 225.30 (A)(7). The requirement for labeling is a certification requirement as determined by
the NRTL and does not belong in an installation code.
NEMA opposes section A.7. "Electric Vehicles" are too specific and would exclude other electrical equipment. We suggest using "free
standing electrical structures" NEMA does not support the new section (F) which permits an unlimited number of feeders to a dwelling
unit. It would permit multiple feeder entries into a home similar to having multiple services with multiple sources of power entering the
building. Location and number of disconnects are addressed in NEC 225.32 and 225.33.
3 of 40
Panel 4 First Draft Ballot Circulation
FR-922, Section No. 225.32, See FR-922
Eligible to Vote: 12
Not Returned : 0
Vote Selection
Votes
Affirmative
12
Affirmative with Comment
0
Negative
0
Abstain
0
FR-923, Section No. 225.36, See FR-923
Eligible to Vote: 12
Not Returned : 0
Vote Selection
Votes
Affirmative
11
Affirmative with Comment
1
Wendell R. Whistler
Negative
0
Abstain
0
FR-924, Section No. 225.38(C), See FR-924
Eligible to Vote: 12
Not Returned : 0
Vote Selection
Votes
Affirmative
12
Affirmative with Comment
0
Negative
0
Abstain
0
FR-925, Section No. 225.52(C), See FR-925
Eligible to Vote: 12
Not Returned : 0
Vote Selection
Votes
Affirmative
12
Affirmative with Comment
0
Negative
0
Abstain
0
FR-1000, New Section after 225.61, See FR-1000
Eligible to Vote: 12
Not Returned : 0
Vote Selection
Votes
Affirmative
11
Affirmative with Comment
1
Comments
Comments
This disconnecting means shall meet the requirements of 110.25
Comments
Comments
Comments
4 of 40
Panel 4 First Draft Ballot Circulation
Wendell R. Whistler
Negative
0
Abstain
0
FR-926, Section No. 230.7, See FR-926
Eligible to Vote: 12
Not Returned : 0
Vote Selection
Votes
Affirmative
12
Affirmative with Comment
0
Negative
0
Abstain
0
FR-927, Section No. 230.9(B), See FR-927
Eligible to Vote: 12
Not Returned : 0
Vote Selection
Votes
Affirmative
12
Affirmative with Comment
0
Negative
0
Abstain
0
FR-928, Section No. 230.10, See FR-928
Eligible to Vote: 12
Not Returned : 0
Vote Selection
Votes
Affirmative
12
Affirmative with Comment
0
Negative
0
Abstain
0
FR-929, Section No. 230.24(B), See FR-929
Eligible to Vote: 12
Not Returned : 0
Vote Selection
Votes
Affirmative
12
Affirmative with Comment
0
Negative
0
Abstain
0
FR-936, Section No. 230.29, See FR-936
Eligible to Vote: 12
Not Returned : 0
225.71 Support. Outdoor overhead conductors operating over 1000 volts shall meet any specified clearance requirements as applicable
in 225.60 and 225.61. The engineering design required by this section shall be performed by licensed professional engineers engaged
primarily in the design of such ELECTRICAL systems including the conductor spacings and clearances, and the installation of support
structures. THIS DESIGN SHALL HAVE A WET STAMP BY THE LICENSED PROFFESIONAL ELECTRICAL ENGINEER.
Comments
Comments
Comments
Comments
5 of 40
Panel 4 First Draft Ballot Circulation
Vote Selection
Affirmative
Affirmative with Comment
Wendell R. Whistler
Negative
Abstain
Thomas E. Buchal
Votes Comments
10
1
For a grounded system, where the substantial structure is metal, it shall be bonded by means of a bonding jumper and listed connector
to the grounded overhead service conductor. The bonding jumper shall be of the same conductor size and material as the grounded
overhead service conductor. FOR UNGROUNDED SYSTEMS WHERE THE SUBSTANTIAL STRUCTURE METAL IT SHALL BE BONDED TO THE
GROUNDING ELECTRODE SYSTEM.
0
1
It is unclear how this could be accomplished if the metal building in not associated with the overhead wiring. Would a mast have to be
installed on that building to accomodate the bonding jumper? I do not disagree with the concept.
FR-930, Section No. 230.30(A), See FR-930
Eligible to Vote: 12
Not Returned : 0
Vote Selection
Votes Comments
Affirmative
12
Affirmative with Comment
0
Negative
0
Abstain
0
FR-931, Section No. 230.40, See FR-931
Eligible to Vote: 12
Not Returned : 0
Vote Selection
Votes Comments
Affirmative
12
Affirmative with Comment
0
Negative
0
Abstain
0
FR-932, Section No. 230.41, See FR-932
Eligible to Vote: 12
Not Returned : 0
Vote Selection
Votes Comments
Affirmative
12
Affirmative with Comment
0
Negative
0
Abstain
0
Total Voted : 12
FR-947, Section No. 230.42(A), See FR-947
Eligible to Vote: 12
Not Returned : 0
6 of 40
Panel 4 First Draft Ballot Circulation
Vote Selection
Affirmative
Affirmative with Comment
Thomas E. Buchal
Negative
Abstain
Total Voted : 12
FR-933, Section No. 230.44, See FR-933
Eligible to Vote: 12
Not Returned : 0
Vote Selection
Affirmative
Affirmative with Comment
Negative
Malcolm Allison
Votes Comments
11
1
It was my understanding that when the term labeled was going to be used with the term listed, that it would be clear that this was a field
label.
0
0
Votes Comments
11
0
1
List item 5 should be revised to read: (5)Single-conductors 1/0 and larger that are listed for used in cable tray. The additional language
"or Cable Assemblies with Type TC rating" is confusing since "cable assemblies" is not defined and "Type TC" is a cable wiring method
that has not been evaluated for use as service conductors in cable tray.
Abstain
0
FR-903, Section No. 230.53, See FR-903
Eligible to Vote: 12
Not Returned : 0
Vote Selection
Votes Comments
Affirmative
12
Affirmative with Comment
0
Negative
0
Abstain
0
FR-934, Section No. 230.54(C), See FR-934
Eligible to Vote: 12
Not Returned : 0
Vote Selection
Votes Comments
Affirmative
11
Affirmative with Comment
1
James J. Rogers
This needs to be fixed in the comment period as the language as written would only address weatherheads when they are installed on
raceways and that was not intended.
Negative
0
Abstain
0
FR-935, Section No. 230.66, See FR-935
Eligible to Vote: 12
7 of 40
Not Returned : 0
Panel 4 First Draft Ballot Circulation
Vote Selection
Affirmative
Affirmative with Comment
Negative
Thomas E. Buchal
Votes Comments
11
0
1
The term labeled in conjunction with listed should be dropped from the text as this implies that an installation code is specifying terms of
certification. The concept of field labeling service equipment is dubious at best but I would not object to retaining that part.
Abstain
0
FR-937, Section No. 230.71(A), See FR-937
Eligible to Vote: 12
Not Returned : 0
Vote Selection
Votes
Affirmative
12
Affirmative with Comment
0
Negative
0
Abstain
0
FR-938, Section No. 230.75, See FR-938
Eligible to Vote: 12
Not Returned : 0
Vote Selection
Votes
Affirmative
12
Affirmative with Comment
0
Negative
0
Abstain
0
FR-939, Section No. 230.82, See FR-939
Eligible to Vote: 12
Not Returned : 0
Vote Selection
Votes
Affirmative
12
Affirmative with Comment
0
Negative
0
Abstain
0
FR-948, Section No. 230.91, See FR-948
Eligible to Vote: 12
Not Returned : 0
Vote Selection
Votes
Affirmative
11
Affirmative with Comment
1
Wendell R. Whistler
Negative
Abstain
0
0
Comments
Comments
Comments
Comments
Where fuses are used as the service overcurrent device, the disconnecting means shall be located ahead of the supply side of the fuses.
THE DISCONNECTING MEANS SHALL MEET THE REQUIREMENTS OF 110.25
8 of 40
Panel 4 First Draft Ballot Circulation
FR-941, Section No. 230.95(C), See FR-941
Eligible to Vote: 12
Not Returned : 0
Vote Selection
Votes
Affirmative
12
Affirmative with Comment
0
Negative
0
Abstain
0
FR-942, Section No. 230.209, See FR-942
Eligible to Vote: 12
Not Returned : 0
Vote Selection
Votes
Affirmative
12
Affirmative with Comment
0
Negative
0
Abstain
0
Total Voted : 12
FR-949, Section No. 690.1, See FR-949
Eligible to Vote: 15
Not Returned : 0
Vote Selection
Votes
Affirmative
13
Affirmative with Comment
2
Wendell R. Whistler
Ward I. Bower
Comments
Comments
Comments
Would like to see more delineation between PV and rest of the electrical systems in these drawings such as adding dotted lines for
delineation and clarity
The Figure 690.1(a) shows a location for dc-dc converters in the circuit that may not always be the case. I recommend that note 4 should
read "..., some components are optional or in located within the PV power source. The current language could easily lead AHJs to insist
the location be per the drawing.
Negative
0
Abstain
0
FR-950, Definition: Array., See FR-950
Eligible to Vote: 15
Not Returned : 0
Vote Selection
Votes Comments
Affirmative
15
Affirmative with Comment
0
Negative
0
Abstain
0
FR-958, Definition: Bipolar Photovoltaic Array., See FR-958
Eligible to Vote: 15
Not Returned : 0
9 of 40
Panel 4 First Draft Ballot Circulation
Vote Selection
Votes Comments
Affirmative
15
Affirmative with Comment
0
Negative
0
Abstain
0
FR-959, Definition: Interactive System., See FR-959
Eligible to Vote: 15
Not Returned : 0
Vote Selection
Votes Comments
Affirmative
14
Affirmative with Comment
1
Thomas E. Buchal
This term is not exclusive to PV. Does PV need to be there?
Negative
0
Abstain
0
Total Voted : 12
FR-961, Definition: Multimode Inverter., See FR-961
Eligible to Vote: 15
Not Returned : 0
Vote Selection
Votes Comments
Affirmative
15
Affirmative with Comment
0
Negative
0
Abstain
0
Total Voted : 12
FR-951, Definitions (690.2): Blocking Di... to Building In..., See FR-951
Eligible to Vote: 15
Not Returned : 0
Vote Selection
Votes Comments
Affirmative
15
Affirmative with Comment
0
Negative
0
Abstain
0
FR-960, Definitions (690.2): Inverter In... to Inverter Ou..., See FR-960
Eligible to Vote: 15
Not Returned : 0
Vote Selection
Votes Comments
Affirmative
14
Affirmative with Comment
1
Ward I. Bower
The language is technically correct but some inverters may have more than one dc input and some of the inputs are not intended for PV
connections. There is likely a clarification needed for the public comment period.
10 of 40
Negative
0
Panel 4 First Draft Ballot Circulation
Abstain
0
FR-952, New Definition after Definition: DC-to-DC Converter., See FR-952
Eligible to Vote: 15
Not Returned : 0
Vote Selection
Votes Comments
Affirmative
15
Affirmative with Comment
0
Negative
0
Abstain
0
FR-1002, New Definition after Definition: Electrical Production and ..., See FR-1002
Eligible to Vote: 15
Not Returned : 0
Vote Selection
Votes Comments
Affirmative
13
Affirmative with Comment
2
Wendell R. Whistler
Ward I. Bower
Engineering Supervision. Designed,approved AND STAMPED by a licensed professional engineer ENGAGED IN the DESIGN OR
MAINTENANCE OF THE PHOTOVOLTAIC INSTALLATION AND competent BY LICENSURE in the specific area under THEIR DESIGN
supervision.
This panel member suggests the language needs clarification to read "The sum of parallel-connected inverter maximum continuous
output power at 40°C in kilowatts”
Negative
0
Abstain
0
Total Voted : 12
FR-953, New Definition after Definition: Interactive System., See FR-953
Eligible to Vote: 15
Not Returned : 0
Vote Selection
Votes Comments
Affirmative
15
Affirmative with Comment
0
Negative
0
Abstain
0
FR-954, New Definition after Definition: Photovoltaic System Voltag..., See FR-954
Eligible to Vote: 15
Not Returned : 0
Vote Selection
Votes Comments
Affirmative
15
Affirmative with Comment
0
Negative
0
Abstain
0
FR-7501, Detail, See FR-7501
Eligible to Vote: 15
11 of 40
Panel 4 First Draft Ballot Circulation
Not Returned : 0
Vote Selection
Affirmative
Affirmative with Comment
Ward I. Bower
Votes Comments
14
1
It appears the system did not display the correct diagrams in the FR. The diagrams need to be reviewed during the comment period with
industry consensus goals. The term Interactive Inverter Output Disconnect creates confusion since some circuits contain both interactive
inverters and multimode inverters. In at least one example the interactive inverter output disconnect is connected to the output of a
multimode inverter.
Negative
0
Abstain
0
FR-956, Section No. 690.3, See FR-956
Eligible to Vote: 15
Not Returned : 0
Vote Selection
Votes Comments
Affirmative
15
Affirmative with Comment
0
Negative
0
Abstain
0
FR-957, Section No. 690.4(B), See FR-957
Eligible to Vote: 15
Not Returned : 0
Vote Selection
Votes Comments
Affirmative
13
Affirmative with Comment
2
James J. Rogers
It is important to note here that even though the general requirement is for listed or field evaluated equipment this Section does not
prohibit the AHJ from granting approval of new and innovative equipment that might evolve and exhibit similar safety criteria and that is
not yet listed due to non-existent product standards or other reasons
Thomas E. Buchal
The term labeled in conjunction with listed should be dropped from the text as this implies that an installation code is specifying terms of
certification. I would vote negative on this except that the overall prescriptive requirement has more merit than the errant use of the
term labeled.
Negative
0
Abstain
0
FR-962, New Section after 690.4(D), See FR-962
Eligible to Vote: 15
Not Returned : 0
Vote Selection
Votes Comments
Affirmative
15
Affirmative with Comment
0
Negative
0
12 of 40
Panel 4 First Draft Ballot Circulation
Abstain
0
FR-963, Section No. 690.4(D), See FR-963
Eligible to Vote: 15
Not Returned : 0
Vote Selection
Votes Comments
Affirmative
13
Affirmative with Comment
1
Ward I. Bower
The term "dc" should be deleted where it appears before "PV system disconnecting means"
Negative
1
James J. Rogers
This language needs to be changed there may be times when there are multiple inverters on a single system. In such an installation it
should be permissible to have the inverters installed at different locations and if so placarding is necessary
Abstain
0
FR-964, Sections 690.6(C), 690.6(D), See FR-964
Eligible to Vote: 15
Not Returned : 0
Vote Selection
Votes
Affirmative
14
Affirmative with Comment
1
Ward I. Bower
Negative
0
Abstain
0
FR-1020, Section No. 690.7, See FR-1020
Eligible to Vote: 15
Not Returned : 0
Vote Selection
Votes
Affirmative
13
Affirmative with Comment
2
James J. Rogers
Ward I. Bower
Comments
There is an error in the reference to the section being deleted. The second (C) should be (D)
Comments
The concept being addressed in this change has merit, the definition and requirement for engineering supervision may need to be better
defined during the comment period
690.7. The term "two family" should be hyphenated. 690.7(A)Remove the term "PV SYstem" Some sections as shown below are almost
exact duplicates of 690.7(A) through (C). The following almost duplication should be deleted. "(1) The open-circuit voltage temperature
coefficients module voltage in accordance with the instructions included in the listing of the module. (2) For crystalline and
multicrystalline silicon modules, the correction factors provided in Table 690.7(A) shall be permitted to be used. (3) For PV systems with
a generating capacity of 100 kilowatts or greater,alternate methods shall be permitted to be used under engineering supervision." The
pdf version of the first revision contains the words "690.8 Circuit Sizing and Current. 690.8 Circuit Sizing and Current “(A) Calculation of
Maximum Circuit Current." that should be used in 690.8. The deleted section “690.7(C) Circuits over 120 Volts to Ground” should be
labeled “(D) Circuits over 120 Volts to Ground”.
13 of 40
Negative
0
Panel 4 First Draft Ballot Circulation
Abstain
0
FR-969, Section No. 690.8(A) [Excluding any Sub-Sections], See FR-969
Eligible to Vote: 15
Not Returned : 0
Vote Selection
Votes Comments
Affirmative
15
Affirmative with Comment
0
Negative
0
Abstain
0
FR-966, Section No. 690.8(A)(1), See FR-966
Eligible to Vote: 15
Not Returned : 0
Vote Selection
Votes Comments
Affirmative
14
Affirmative with Comment
1
Timothy P. Zgonena
The calculations could result in use of a smaller wire size than is appropriate for the equipment. Suggest appending the following text to
the end of item (2): "The wire size shall not be smaller than the minimum wire size for the wiring terminal of the equipment, and the
minimum wire size based on the product ratings and installation instructions."
Negative
0
Abstain
0
FR-968, Section No. 690.8(A)(5), See FR-968
Eligible to Vote: 15
Not Returned : 0
Vote Selection
Votes Comments
Affirmative
15
Affirmative with Comment
0
Negative
0
Abstain
0
FR-972, Section No. 690.9, See FR-972
Eligible to Vote: 15
Not Returned : 0
Vote Selection
Votes Comments
Affirmative
13
Affirmative with Comment
2
James J. Rogers
This language does not read clearly and needs to be changed in the comment period
Ward I. Bower
690.9(A) the terms "interactive inverter’s" should be added before inverter’s output circuits for clarification. 690.9(A)(2)the terms "odule
or dc-to-dc converter" should be added at the end of the sentence. This appeared to be omitted during the transfer from PI to FR. The
informational note should read ..overcurrent "protection" when connected in parallel. The term protection was lost in translation
14 of 40
Panel 4 First Draft Ballot Circulation
Negative
Abstain
FR-970, Section No. 690.10, See FR-970
Eligible to Vote: 15
Not Returned : 0
Vote Selection
Affirmative
Affirmative with Comment
Thomas E. Buchal
Negative
Abstain
FR-971, Section No. 690.11, See FR-971
Eligible to Vote: 15
Not Returned : 0
Vote Selection
Affirmative
Affirmative with Comment
Ward I. Bower
0
0
Votes Comments
14
1
690.10(C) appears a bit confusing. It would seem as though some additional rules would apply if a 120 volt supply is being connected to
120/240 volt service.
0
0
Votes Comments
11
2
Change the following “….shall be protected by a listed (dc) and labeled PV arc-fault circuit interrupter, PV type, or other system
components listed to provide equivalent protection” to “….shall be protected by a listed (dc) and labeled PV arc-fault circuit interrupter,
PV type, or other system components listed and labeled to provide equivalent protection” Removing the requirement that disabled or
disconnected equipment be manually restarted is proper and places the operational specifications within the standard used for listing
the hardware. This is also true of the need for an annunciator and the need to reset the indications. There is a concern to this panel
member that a standard is not yet written and approved, and there is no standard to assure the reliability of the arc-fault detection
equipment over the lifetime of the PV system. AC arc fault protection and ground fault detection carries a label that it should be tested
on monthly intervals. The environment for dc arc-fault protection is more severe. The standard should also require regular testing that
may be automated or done manually. Without regular testing the functionality of the devices may quickly become unknown.
Michael K. Weitzel
"Or other system components listed to provide equivalent protection" has not been defined. The language could be consider ambiguous.
CMP 4 should consider providing clarification, or removal of this text.
Negative
James J. Rogers
Thomas E. Buchal
2
Abstain
FR-1008, Section No. 690.12, See FR-1008
Eligible to Vote: 15
Not Returned : 0
0
The existing language does not get involved in product standard issues relative to requiring manual reset
The specification of 80 volts does not appear to address bipolar sources. A reference for the voltage rating is needed. Also, labeled does
not belong in the text in conjunction with the term listed as this is a certification issue and not an installation issue.
15 of 40
Panel 4 First Draft Ballot Circulation
Vote Selection
Affirmative
Affirmative with Comment
Wendell R. Whistler
Votes Comments
11
2
The ultimate goal of Rapid Shutdown is to achieve an electrically safe work condition both inside the array and outside of the array. This
should include electrically safe work conditions of 30 volts or less at the module level as well as out side of the array.
Timothy P. Zgonena
Negative
We recognize the need for more discussion on the topic of rapid shutdown of PV systems. With this in mind, we look forward to Public
Comments to this First Revision, and other collaborative efforts in the product standard community, to develop the optimal
requirements. Additional work to establish agreement on the precise objectives of the rapid shutdown systems, consider the practicality
of accomplishing the defined objectives with respect to different PV systems, consider the benefits and transition plan for any new
requirements, and promote first responder safety are all important considerations as we move forward. We look forward to working
with interested parties to accomplish this work.
2
16 of 40
Panel 4 First Draft Ballot Circulation
Ward I. Bower
The addition of requiring 80V or less within the PV array by using electronics is premature in time. There is no proof whatsoever that the
electronics that will provide this function will ever be reliable enough (within economic constraints) to provide the safety needed for first
responders. The products that can provide the shutdown are limited in numbers and types and all involve electronics, the circuit boards,
interconnections and sometimes communications. Some of today’s and certainly later versions of rapid shutdown devices require
communications as PV is increasingly required to provide Smart Grid functionalities. The addition of the required communications in the
rooftop environment will add even more reliability problems to the estimated hundreds of millions of devices installed annually. The
environment for electronics in the proximity of PV arrays is brutal with large daily temperature swings that will cause numerous failures
in commercial grade electronics packages over the 25-30 year lifetime of PV modules. Today’s documented failure rate of electronics in
PV systems ranges from hundreds to thousands times the documented failure rates of PV modules. Installing millions of electronics
packages on or near a PV array will turn a very reliable industry one fraught with failures and production losses. I site the following topics
for delaying the use of electronics for safety applications such as rapid shutdown. The presence of the concept presents huge
opportunities for a false sense of security and safety. The short list of reasons this requirement is premature follows: 1. Unknown
reliabilities of electronics in the environment and a huge number of those unproven devices installed on rooftops 2. There appears to be
no burden to prove the reliability of devices that are going to be used as rapid shutdown devices 3. A false sense of security is instilled
with 80 V still a dangerous level where less trained firefighters or first responders will be lured into thinking the systems are touch safe
with rapid shutdown 4. There is a lack of standards for listing devices and determining the required long term reliability under brutal
rooftop conditions 5. Even today’s ac module electronics reliability with relentless reliability testing is less than that of PV modules 6.
There will be a flood of new electronic products that have not been developed with reliability and that will eventually result in loss of
confidence of all systems. (Note: The reliability of products will require relentless quality programs AND reliability and safety standards
for rapid shutdown are still to be written) 7. There is a lack of methods to determine if an installed product still works after even just a
few years in the field. (Note: Testing and reporting methods for the module level products in the field must be required to assure safety
if module level code requirements are adopted. 8. Will fire-fighters or first responders change anything while fighting fires or responding
to emergencies. There is a huge mix of legacy systems already installed with no rapid shutdown, many systems use the 2014 NEC
requirements that allow full array voltage, and now new rapid shutdown code requirements with a still dangerous 80 volts allowed
within the PV array. 9. There are no products that will provide just a rapid shutdown function at the PV module level.
17 of 40
Panel 4 First Draft Ballot Circulation
Robert H. Wills
The intent of 690.12 as written in the 2014 NEC is to ensure that a local source of electricity (i.e. the PV array) can be easily disconnected
from a building electrical system in the event of a fire. 690.12 in the 2014 NEC is clear, concise and easy to understand. Somehow this
very reasonable requirement (for disconnection promoting firefighter safety) has morphed into a very UN-reasonable requirement that
the PV array on the roof itself be “disabled” by pushing a button or turning off ac power. This change is being promoted by a small,
influential part of the solar industry (micro-inverters and dc-maximizer manufacturers) that stand to gain immensely from such a code
change. It is not supported by PV module manufacturers or the solar energy industry (i.e. SEIA) as a whole. The process of change in the
NEC requires technical justification. This proposal to change 690.12 (e.g. PI 2272) lacks significant technical justification for such a major
revision. Adequate justification should include documented, actual safety-related incidents and analysis of a likely increase in safety.
None of this was provided. In fact, it is probable that the addition of electronic circuit boards in every module would DECREASE fire
safety, as we can expect many more junction box fires from failed electronics. The essence of PV power generation is that it is simple,
passive and reliable. Adding electronics to every module removes all of these attributes. This proposed change to 690.12 is actually likely
to put more first responders in harm’s way. Making PV less reliable will also lead to more service people on roofs, and ultimately more
accidents – an undesirable outcome. The proposed language is difficult to understand and poorly drafted. For example (A) starts with
“Controlled Conductors” without defining what “Controlled Conductors” are. The Task Group dealing with 690.12 is nowhere near
consensus, and has not properly explored and resolved all issues. It needs to be reformed with less influence from solar electronics
manufacturers, and more representation of the solar industry in general. Finally, this change is very short-sighted. Ten years ago, we
expected that thin-film, high-voltage PV modules would become the norm, beating “sliced silicon” technology on cost and performance.
That is finally coming to pass, with thin film, HV CdTe modules now offering lowest installed cost. The future of PV, and electrical systems
in general, is moving to higher voltage operation due to increasing costs of copper and energy. This is evidenced by the recent changes
from 600 to 1000V in the NEC. Writing limiting code language based on a subset of the PV modules available today, and ignoring current
and future trends is bad policy, and bad code.
Abstain
0
FR-1014, Section No. 690.13, See FR-1014
Eligible to Vote: 15
Not Returned : 0
Vote Selection
Affirmative
Affirmative with Comment
James J. Rogers
Votes Comments
11
4
I voted in favor of this but I remain concerned as I always have that the basic requirement for a disconnecting means where the
conductors enter the building should remain intact whether the conductors are encased in metal wiring methods or not. Other onsite
power production sources such as an onsite generator is required to have such a disconnecting means why shouldn't a PV system be
treated the same way. We should look at this again in the comment period
18 of 40
Panel 4 First Draft Ballot Circulation
Ward I. Bower
The following was omitted from the FR. Please reinstate it. Informational Note: Dc-rated enclosed switches, open-type switches, and lowvoltage power circuit breakers are suitable.
Ronald Todd Fries
What is the intent of 590.12(F)(1) compliance, meaning is this new label also reflective, 3/8" tall white text on red background? Also
690.12(F) we should spell out the word Photovoltaic when they mention the label text.
Matthew Paiss
The elimination of a requirement of an external PV system disconnect presents challenges for emergency responders. For example,
when the main service disconnect is in a basement with no access due to fire, not only is the de-energizing of the AC to the structure not
possible, but the initiation of rapid shutdown is also denied presenting additional areas of hazard on a structure. The fire service is asking
for an ability to secure utility control from the exterior of a structure for one & two family residences. This panel member would like to
see this addressed in the comment period.
Negative
0
Abstain
0
FR-1013, Section No. 690.12, See FR-1013
Eligible to Vote: 15
Not Returned : 0
Vote Selection
Votes Comments
Affirmative
11
Affirmative with Comment
2
19 of 40
Panel 4 First Draft Ballot Circulation
Wendell R. Whistler
690.12 Disconnection of Photovoltaic Equipment. MeansIsolating devices shall be provided to disconnect equipment, such as inverters,
batteries,isolate PV modules, ac PV modules, fuses, dc-to-dc converters inverters, and charge controllers, from all ungrounded
conductors of all sources. If the equipment is energized from more than one source, the disconnecting means shall be grouped and
identified. conductors that are not solidly grounded. An equipment disconnecting means or a PV system disconnecting means shall be
permitted in place of an isolating device. Where the maximum circuit current is greater than 30 amperes for the output circuit of a dc
combiner or the input circuit of a charge controller or inverter, an equipment disconnecting means shall be provided for isolation. Where
a charge controller or inverter has multiple input circuits, a single equipment disconnecting means shall be permitted to isolate the
equipment from the input circuits. Informational Note: The purpose of these isolating devices are for the safe and convenient
replacement or service of specific PV system equipment without exposure to energized conductors. A single disconnecting means in
accordance with 690.17 shall be permitted for the combined ac output of one or more inverters or ac modules in an interactive system.
(A) Utility-Interactive Inverters Mounted in Not Readily Accessible Locations. Location. Utility-interactive inverters shall be permitted to
be mounted on roofs or other exterior areas that are not readily accessible and shall comply with 690.12(A)(1) through (4): (0)A dc PV
disconnecting means shall be mounted within sight of or in each inverter. (0)An ac disconnecting means shall be mounted within sight of
or in each inverter. (0)The ac output conductors from the inverter and an additional ac disconnecting means for the inverter shall comply
with 690.13(A). (0)A plaque shall be installed in accordance with 705.10. Isolating devices or equipment disconnecting means shall be
installed at a location within the equipment, or within sight and within 10 feet of the equipment AND SHALL BE LOCKABLE PER 110.25.
An equipment disconnecting means shall be permitted to be remote from the equipment where the equipment disconnecting means
can be remotely operated from within 10 feet of the equipment and shall be lockable per 110.25.
Matthew Paiss
This language is not correcting a safety issue in the field, and may add additional confusion. If the use of isolation devices is desirable, a
better definition may be useful here.
Negative
Timothy P. Zgonena
James J. Rogers
2
The requirements as written require either an isolating means or a disconnecting means, and allow a contactor or relay to act as a
disconnecting means. It must be noted that contactors and relays may provide a disconnecting function, but generally do not provide
adequate air gaps to be considered an isolating means. As written, there is an implication that they can be used in place of an isolating
means, which could result in an possible shock hazard. Since the purpose of allowing a remote disconnecting means is to provide the
isolation needed to work safely on the equipment, the use of contactors or relays should not be allowed. Suggest revising item (4) to
read as follows: "A remote controlled circuit breaker or other approved isolating means, that is operable locally and opens automatically
when control power is interrupted."
This language should remain as it was in 2014 requiring a disconnecting means as that is clearly understood in the field as to what that
means. If it is desired to recognize isolation devoices as meeting this requirement in certain instances then that is fine and they should
be defined here.
Abstain
0
FR-1009, Sections 690.16, 690.17, 690.18, See FR-1009
Eligible to Vote: 15
20 of 40
Panel 4 First Draft Ballot Circulation
Not Returned : 0
Vote Selection
Votes Comments
Affirmative
15
Affirmative with Comment
0
Negative
0
Abstain
0
FR-974, Section No. 690.31(A), See FR-974
Eligible to Vote: 15
Not Returned : 0
Vote Selection
Votes Comments
Affirmative
14
Affirmative with Comment
1
Wendell R. Whistler
(A) Wiring Systems. All raceway and cable wiring methods included in this Code, other wiring systems and fittings specifically listed for
use on PV arrays, and wiring as part of a listed system shall be permitted. Where wiring devices with integral enclosures are used,
sufficient length of cable shall be provided to facilitate replacement. Where PV source and output circuits operating at maximum system
voltages greater than 30 volts are installed in readily accessible locations, circuit conductors shall be guarded or installed in Type MC
cable WITH A OUTER POLYMERIC JACKET LISTED FOR WET LOCATIONS or in an APPROC+VED CHAPTER 3 raceway.
Negative
0
Abstain
0
FR-975, Section No. 690.31(B), See FR-975
Eligible to Vote: 15
Not Returned : 0
Vote Selection
Votes Comments
Affirmative
12
Affirmative with Comment
1
Ward I. Bower
The following was erroneously deleted and moved to (B)(2). It should be reinstated in 690.31(B) Identification and Grouping. PV source
circuits and PV output circuits shall not be contained in the same raceway , cable tray, cable, outlet box, junction box, or similar fitting as
conductors, feeders, branch circuits of other non-PV systems, or inverter output circuits unless the conductors of the different systems
are separated by a partition. The same language should then be deleted from 690.31(B)(2) Grouping
Negative
James J. Rogers
2
If multiple PY system conductors are installed in the same raceway or enclosure then they should be separately identified
Matthew Paiss
If multiple PV system conductors are installed in the same raceway, they should be separately identified.
Abstain
0
FR-976, Section No. 690.31(C), See FR-976
Eligible to Vote: 15
Not Returned : 0
Vote Selection
Votes Comments
Affirmative
14
Affirmative with Comment
1
21 of 40
Panel 4 First Draft Ballot Circulation
Thomas E. Buchal
A comma should be added after the term 'listed' such that the labeling is intended to communicate the type of wire and not to imply
that the labeling is requisite with the listing.
Negative
0
Abstain
0
FR-977, Section No. 690.31(D), See FR-977
Eligible to Vote: 15
Not Returned : 0
Vote Selection
Votes Comments
Affirmative
13
Affirmative with Comment
1
Thomas E. Buchal
A comma should be added after the term 'listed' such that the labeling is intended to communicate the type of cable and not to imply
that the labeling is requisite with the listing.
Negative
1
Malcolm Allison
The language "Jacketed multi-conductor cable assemblies listed and labeled for the application" makes it unclear whether the cables are
limited to those specifically for PV installations or whether other cable wiring methods that are suitable for the location are acceptable.
Additionally "cable assemblies" is not defined in the code.
Abstain
0
FR-998, Section No. 690.31(E), See FR-998
Eligible to Vote: 15
Not Returned : 0
Vote Selection
Votes Comments
Affirmative
11
Affirmative with Comment
2
Wendell R. Whistler
Where cables are used in low temperature ambient conditions these cables need to be listed for those ambient temperature conditions.
Most electrical equipment is listed for use at -25 C to +40 C. Outside of these parameters the equipment needs additional testing by an
NRTL for the ambient temperatures it is going to be used in and certified by the listing agency with those ambient markings
Ward I. Bower
Negative
Malcolm Allison
The last sentence "Allowable ampacities shall be in accordance with 400.5. For ambient temperatures exceeding 30°C (86°F), the
ampacities shall be derated by the appropriate factors given in Table 690.31(E). was deleted from the PI transfer to the FR. Please
consider reinstating it.
2
The language "flexible PV wire" introduces a product that is undefined in the code and in product standards.
22 of 40
Panel 4 First Draft Ballot Circulation
Timothy P. Zgonena
Comment : Not all PV wire is suitable for connection to moving parts since the number of strands can vary from PV wire to PV wire. The
proposed table below matches the minimum number of strands required for other wires allowed in the NEC for connection to moving
parts. The following revised text is intended to replace the FR998. Additionally the reference to the derating table 690.31(E) and the
Table 690.31(E) should be maintained. Proposed Text Flexible cords and flexible cables, where connected to moving parts of tracking PV
arrays, shall comply with Article 400 and shall be of a type identified as a hard service cord or portable power cable; they shall be
suitable for extra-hard usage, listed for outdoor use, water resistant, and sunlight resistant. For ambient temperatures exceeding 30°C
(86°F), the ampacities shall be derated by the appropriate factors given in Table 690.31(E). PV Wire shall also be permitted to be
connected to moving parts of tracking PV arrays provided it has the minimum number of strands specified in table 690.31 (X). Table
690.31(X) PV Wire Conductor Size Minimum Strands 18 AWG 17 16-10 AWG 19 8 – 4 AWG 49 2 AWG 130 1 AWG - 1000MCM 259
Abstain
0
FR-990, Section No. 690.31(G) [Excluding any Sub-Sections], See FR-990
Eligible to Vote: 15
Not Returned : 0
Vote Selection
Votes Comments
Affirmative
15
Affirmative with Comment
0
Negative
0
Abstain
0
FR-978, Section No. 690.31(I), See FR-978
Eligible to Vote: 15
Not Returned : 0
Vote Selection
Votes Comments
Affirmative
15
Affirmative with Comment
0
Negative
0
Abstain
0
FR-979, Section No. 690.31(J), See FR-979
Eligible to Vote: 15
Not Returned : 0
Vote Selection
Votes Comments
Affirmative
15
Affirmative with Comment
0
Negative
0
Abstain
0
FR-980, Section No. 690.33 [Excluding any Sub-Sections], See FR-980
Eligible to Vote: 15
Not Returned : 0
Vote Selection
Votes Comments
23 of 40
Panel 4 First Draft Ballot Circulation
Affirmative
15
Affirmative with Comment
0
Negative
0
Abstain
0
FR-981, Section No. 690.33(C), See FR-981
Eligible to Vote: 15
Not Returned : 0
Vote Selection
Votes Comments
Affirmative
13
Affirmative with Comment
1
Thomas E. Buchal
The term opening is a little confusing for a connector. Perhaps better terms would be engagement and disengagement.
Negative
Timothy P. Zgonena
1
Abstain
0
FR-982, Section No. 690.35, See FR-982
Eligible to Vote: 15
Not Returned : 0
Vote Selection
Votes
Affirmative
15
Affirmative with Comment
0
Negative
0
Abstain
0
FR-991, Section No. 690.41, See FR-991
Eligible to Vote: 15
Not Returned : 0
Vote Selection
Votes
Affirmative
14
Affirmative with Comment
1
Ward I. Bower
Negative
0
Abstain
0
FR-1048, Section No. 690.42, See FR-1048
Eligible to Vote: 15
Not Returned : 0
Vote Selection
Votes
Affirmative
15
Affirmative with Comment
0
Negative
0
Abstain
0
FR-993, Section No. 690.43, See FR-993
The proposed text conflicts with the existing wet location shock hazard limits which are different between AC and DC circuits Propose
revise text to "over 30 volts dc or 12 volts ac"
Comments
Comments
In 690.41(B)(2) the word "two" is not necessary.
Comments
24 of 40
Panel 4 First Draft Ballot Circulation
Eligible to Vote: 15
Not Returned : 0
Vote Selection
Affirmative
Affirmative with Comment
James J. Rogers
Thomas E. Buchal
Negative
Abstain
FR-984, Section No. 690.45, See FR-984
Eligible to Vote: 15
Not Returned : 0
Vote Selection
Affirmative
Affirmative with Comment
Timothy P. Zgonena
James J. Rogers
Ward I. Bower
Negative
Abstain
FR-985, Section No. 690.46, See FR-985
Eligible to Vote: 15
Not Returned : 0
Vote Selection
Affirmative
Affirmative with Comment
Negative
Abstain
FR-995, Section No. 690.47, See FR-995
Eligible to Vote: 15
Not Returned : 0
Vote Selection
Affirmative
Affirmative with Comment
Matthew Paiss
Negative
James J. Rogers
Votes Comments
13
2
Some of this language needs to be changed during the comment period for clarity
The term labeled does not belong in the text as long as the requirement for the identification of the device is present. The merit of the
prescriptive requirement outweighs the presence of the term labeled, which implies a certification requirement that does not belong in
an installation code, hence a positive ballot on this issue.
0
0
Votes Comments
12
3
Editorial Revision - Revise "...in rating in accordance with..." to read "... rated in accordance with ...
This does not read properly and needs to be fixed during the comment period
The terms "in rating" should be changed to "rated" to clarify the sentence
0
0
Votes Comments
15
0
0
0
Votes Comments
13
1
This section may need clarification of the EGC to the GEC systems.
1
This needs to be reworded during the comment period and clarity needs to be added relative to equipment connection to the grounding
electrode system versus PV system connection to the grounding electrode system. The auxiliary grounding electrode language needs to
25 of 40
be monitored for public comments although this additional connection could create problems with a dc ground fault protection device
Panel 4 First Draft Ballot Circulation
Abstain
0
FR-986, Sections 690.48, 690.49, See FR-986
Eligible to Vote: 15
Not Returned : 0
Vote Selection
Votes Comments
Affirmative
15
Affirmative with Comment
0
Negative
0
Abstain
0
FR-996, Section No. 690.53, See FR-996
Eligible to Vote: 15
Not Returned : 0
Vote Selection
Votes Comments
Affirmative
13
Affirmative with Comment
1
Ronald Todd Fries
For 690.53, I wanted to reference the fact that a small dc disconnect is under 30 amps. What we are saying is that smaller disconnects
under 30 amps wold not need this sign or label put on it. It does not state this anywhere in the code so how do we define what is a small
dc disconnect? Does this relate at all to the new NEC690.12(B)?
Negative
Malcolm Allison
1
Maximum voltage and maximum current appear as informational notes and as such are non- enforceable. It is our belief that the panel
intended these values to be enforceable.
Abstain
0
FR-987, Section No. 690.55, See FR-987
Eligible to Vote: 15
Not Returned : 0
Vote Selection
Votes Comments
Affirmative
14
Affirmative with Comment
1
Thomas E. Buchal
A definition for equalization voltage is needed. I could not find one in the Code.
Negative
0
Abstain
0
FR-997, Section No. 690.56(A), See FR-997
Eligible to Vote: 15
Not Returned : 0
Vote Selection
Votes Comments
Affirmative
15
Affirmative with Comment
0
Negative
0
Abstain
0
FR-988, Section No. 690.56(B), See FR-988
26 of 40
Panel 4 First Draft Ballot Circulation
Eligible to Vote: 15
Not Returned : 0
Vote Selection
Votes Comments
Affirmative
15
Affirmative with Comment
0
Negative
0
Abstain
0
FR-989, Section No. 690.56(C), See FR-989
Eligible to Vote: 15
Not Returned : 0
Vote Selection
Votes Comments
Affirmative
10
Affirmative with Comment
3
Ward I. Bower
This panel member believes this requirement for the permanent plaque or directory is totally inadequate. The proposed language is
"Buildings or structures with both utility service and a PV system, complying with 690.12, shall have a permanent plaque or directory
including that includes the following wording: PHOTOVOLTAIC SYSTEM EQUIPPED WITH RAPID SHUTDOWN" What does this mean to a
person who sees it for the first time? Likely it has many meanings depending on the wide range of knowledge of the individuals that will
be first responders or working on the roof. This plaque can further create a false sense of safety. Please consider there is already one
type of rapid shutdown required in the 2014 NEC that uses exactly the same plaque or directory. The 2014 and proposed 2017 rapid
shutdown systems are not the same in that 2014 allows full array voltage to exist in the array while the new 2017 language is proposing
a limit of 80V within the array. Both systems retain possibly lethal voltages. This plaque requirement does not distinguish between the
two. If the proposed 2017 rapid shutdown (690.12) is adopted then there must be distinction between old code and new code, and it
must provide an indication that possibly voltage remains with either rapid shutdown requirement. Rapid Shutdown will have many
meanings to individuals with different levels of technical backgrounds and widely varying knowledge about electrical systems. Rapid
Shutdown does not mean touch safe therefore the concept provides a false sense of security and safety to the wide range of individuals
that may be near to the PV array in its 30-plus years of operation. Additionally, the signage does not consider the extremely likely failures
of electronic components and connectors associated with rapid shutdown that must remain fully functional and fail-safe over a 30-plus
year lifetime. This is a safety function that must be fail-safe. The language recommended for deletion is (C) Facilities with Rapid
Shutdown. Buildings or structures with both utility service and a PV system, complying with 690.12, shall have a permanent plaque or
directory includingthat includes the following wording: PHOTOVOLTAIC SYSTEM EQUIPPED WITH RAPID SHUTDOWN The plaque or
directory shall be reflective, with all letters capitalized and having a minimum height of 9.5 mm (3?8 in.), in white on red background.
The plaque or directory shall be located on, or no more than 1 m (3 ft) from, the service disconnecting means to which the PV systems
are connected, or in accordance with 690.56(A) or (B), as applicable, and shall indicate the location of the rapid shutdown initiator if not
at the same location.
27 of 40
Panel 4 First Draft Ballot Circulation
Ronald Todd Fries
Is the label suggested in 690.56(C) just supposed to indicate that the system is in compliance? What about simply using the label defined
in 690.56(E)(1)? Are we saying they have to use both labels? Maybe it should be one and keep it simple.
Matthew Paiss
There needs to be some differentiation between the 2014 version and this cycle. With the IAFF proposal requiring a curtailment of 80Vdc
within the array, there must be a equal modification to the marking. The marking should clearly identify areas of the system that are not
at 80Vdc after shutdown. These markings must be graphic and simple to understand.
Negative
James J. Rogers
Robert H. Wills
2
This language needs to be changed, the task group that is working on firefighter safety is currently working on new language
The proposed language change is too restrictive. It may be impossible or less than optimal to install a plaque as specified. We should rely
on 110.12 and the skill and knowledge of the AHJ, rather than spelling out where labels should be located.
Abstain
0
FR-1003, Section No. 690.60, See FR-1003
Eligible to Vote: 15
Not Returned : 0
Vote Selection
Votes Comments
Affirmative
14
Affirmative with Comment
0
Negative
1
Thomas E. Buchal
The term labeled should be removed. The requirement for labeling is a certification requirement as determined by the NRTL and does
not belong in an installation code. The concept of field labeling an inverter or module is also dubious.
Abstain
0
FR-1004, Section No. 690.61, See FR-1004
Eligible to Vote: 15
Not Returned : 0
Vote Selection
Votes Comments
Affirmative
13
Affirmative with Comment
1
28 of 40
Panel 4 First Draft Ballot Circulation
Ward I. Bower
Negative
Robert H. Wills
Although this paragraph of this proposal is old code language, this panel member believes the first paragraph of this section is be related
entirely to the listing of the hardware and should also be considered for deletion from 690. The amount of time delay before
disconnecting will be determined during the listing of inverters. The new inverters are going to be required to provide new smart grid
functionalities by 2017. The reaction of inverters to loss of utility is best handled during the listing and certification processes and with
new interoperability requirements not in the NEC. I do agree this is something that can be tested by an AHJ and is a function that will
very likely be fail-safe. But changes are in the works today for utility requirements for low voltage ride through and ramp rate
requirements of PV inverters indicate the listing process is best. Please consider this a listing issue and not an installation requirement.
The deletion of second paragraph is ok as is.
1
The justification for the removal of the second sentence is that it relates to stand-alone systems and loads. I disagree - I think it
significantly clarifies the 690.61 requirement, and should remain even if this issue is addressed in a stand-alone article (eg 710).
Abstain
0
FR-7511, New Section after 690.74(A), See FR-7511
Eligible to Vote: 15
Not Returned : 0
Vote Selection
Votes Comments
Affirmative
10
Affirmative with Comment
4
Wendell R. Whistler
691.1 Scope. This article covers the installation of large-scale PV electric supply stations operated BY AN INDEPENDENT POWER
PRODUCER for the sole purpose of providing electric supply to the transmission or distribution system OF A REGULATED UTILITY with a
generating capacity of no less than 5,000 kW. Electric supply stations are locations containing the generating stations and substations,
including their associated generator, storage battery, transformer, and switchgear areas. Facilities covered by this article have specific
design and safety features unique to large-scale PV facilities. 691.2 Definitions. Engineering Supervision. Designed,approved and
STAMPED (or certified) by a licensed professional engineer ENGAGED IN THE DESIGN OR MAINTENANCEOF THE PHOTOVOLTAIC
INSTALLATION AND competent BY LICENSURE in the specific area under THEIR DESIGN supervision. Do not agree with the deletion of the
DC Arc Fault requirements unless ground fault detection is included for these installations, even though they are ground mounted as
vegetation is a source of fuel during fault conditions.
Ward I. Bower
The following section “Field Labeled (as applied to evaluated products). Equipment or materials to which has been attached a label,
symbol, or other identifying mark of an field evaluation body (FEB) indicating the equipment or materials were evaluated and found to
comply with requirements as described in an accompanying field evaluation report. [ 790, 2012]” is unclear with its reference to [ 790,
2012].
Thomas E. Buchal
691.5(1) should be amended to remove labeled as specifying a label on a listed product is a certification issue.
29 of 40
Panel 4 First Draft Ballot Circulation
Roger D. McDaniel
Negative
1.)There are several terms used in the article that are taken from the National Electrical Safety Code (NESC) which provides requirements
for generating, transmission, distribution, and metering assets of electric utilities. One such term is “Supply Station” and for this article, is
best replaced with “Power Production Facility” to be consistent with terminology found in the National Electrical Code (NEC) associated
with premises wiring in Article 705. 2.)It is common for 2000kW large Solar PV systems to be interconnected to primary voltage utility
systems. 3.) “Solar Photovoltaic Power Production Facility” is more appropriately defined and used in this article for premises wiring
systems than “Generating Station” which is a utility term. 4.) The definition and use of “Utility Distribution System” and “Utility
Transmission System” is not necessary for premises wiring as these systems are specific to utilities. It would be more appropriate to
make references to Article 225- Outside Branch Circuits and Feeders and Article 230- Services from the NEC. 5.)Equipment used for
interconnection with an electric utility shall also be approved by the electric utility. 6.)I provided a marked up version of new article 691
that incorporates the concerns expressed in the comments above
1
James G. Cialdea
Abstain
FR-1007, Section No. 692.1, See FR-1007
Eligible to Vote: 15
Not Returned : 0
The Scope for 691 (691.1) describes a generating station. Generating stations, are not covered by the NEC as described in 90.2(B)(5)b.
"This Code does not cover the following:... Installations under exclusive control of an electric utility where such installations... Are on
property owned or leased by the electric utility for the purpose of... generation, control, transformation,...of electric energy..." In fact,
even the Committee statement says that "...power plants... were not historically contemplated by the NEC and UL." This is a true
statement and why 90.2(B)(5)b. is in the NEC. One argument that has circulated is that a 'utility' is only a regulated monopoly. This would
mean that inclusion in the NEC depends on ownership, not use, which does not make sense. A utility provides services, a power plant
provides electricity and has always been considered a utility if it connects directly to distribution or transmission to provide service.
Deregulation does not change this, nor does it matter how the electricity is created. While the intent of this new article is to help AHJ's
with guidelines for these installations, a better approach is to make it clear that these power plants are not covered by the NEC. The
power industry has developed independently of the NEC. Power plants - whether solar or other – are already regulated by the Federal
Energy Regulatory Commission (FERC) and regional interconnecting system operators (ISO). Designs are based on many industry
standards (ANSI, IEEE, etc.). Local distribution and transmission companies perform engineering reviews before allowing interconnection
to their systems. Substation equipment that is proven and has been used for many years is not necessarily "listed and labeled". This
equipment is manufactured to well accepted and proven industry standards. This new article will only add confusion and additional costs
to a process that has worked successfully for over 100 years. The Committee needs to clearly state that these power plants are not
covered by the NEC within the Scope of 690 to make sure that we do not put AHJ's in a position to inspect what is clearly a power plant
and outside the scope of the NEC. This will remove the necessity of an electrical permit and eliminate the first main driver stated by the
Committee for the creation of 691 - “Due to the complexity of these systems it is unlikely that the AHJ will have expertise in the design
and construction of multi-megawatt PV power plants.”. This also solves the second main driver that 690 was not written for large scale
PV power plants. The NEC has never been a Code for grid tied electrical generating stations and this should not change.
0
30 of 40
Panel 4 First Draft Ballot Circulation
Vote Selection
Votes Comments
Affirmative
15
Affirmative with Comment
0
Negative
0
Abstain
0
FR-946, Section No. 692.3, See FR-946
Eligible to Vote: 15
Not Returned : 0
Vote Selection
Votes Comments
Affirmative
15
Affirmative with Comment
0
Negative
0
Abstain
0
FR-1012, Section No. 692.6, See FR-1012
Eligible to Vote: 15
Not Returned : 0
Vote Selection
Votes Comments
Affirmative
14
Affirmative with Comment
0
Negative
1
Thomas E. Buchal
The text should be amended to remove labeled as specifying a label on a listed product is a certification issue and does not belong in an
installation code.
Abstain
0
FR-912, Section No. 692.80, See FR-912
Eligible to Vote: 15
Not Returned : 0
Vote Selection
Votes Comments
Affirmative
15
Affirmative with Comment
0
Negative
0
Abstain
0
FR-7516, Global Input, See FR-7516
Eligible to Vote: 13
Not Returned : 0
Vote Selection
Votes Comments
Affirmative
12
Affirmative with Comment
1
Thomas E. Buchal
Last entry is repeated.
Negative
0
Abstain
0
31 of 40
FR-943, Section No. 694.1, See FR-943
Eligible to Vote: 13
Panel 4 First Draft Ballot Circulation
Not Returned : 0
Vote Selection
Affirmative
Affirmative with Comment
Robert H. Wills
Votes Comments
12
1
The word to the right of the Inverter box in Figure 694.1A was changed to "outlet". This is incorrect. It should be changed to the NEC
defined term "Electric Power Production and Distribution Network", as has also been done in the intro figures to Art. 690.
Negative
0
Abstain
1
Ward I. Bower
FR-914, Section No. 694.3, See FR-914
Eligible to Vote: 13
Not Returned : 0
Vote Selection
Votes
Affirmative
13
Affirmative with Comment
0
Negative
0
Abstain
0
FR-944, Section No. 694.7(D), See FR-944
Eligible to Vote: 13
Not Returned : 0
Vote Selection
Votes
Affirmative
13
Affirmative with Comment
0
Negative
0
Abstain
0
FR-912, Section No. 694.7(F), See FR-912
Eligible to Vote: 13
Not Returned : 0
Vote Selection
Votes
Affirmative
12
Affirmative with Comment
0
Negative
1
Thomas E. Buchal
Abstain
0
FR-917, Section No. 694.10(A), See FR-917
Eligible to Vote: 13
Not Returned : 0
Vote Selection
Votes
Affirmative
13
Affirmative with Comment
0
Negative
0
Vote limited
Comments
Comments
Comments
The term 'labeled' does not belong in the text as this is a certification issue and not an installation issue.
Comments
32 of 40
Panel 4 First Draft Ballot Circulation
Abstain
0
FR-1021, Section No. 694.12(C), See FR-1021
Eligible to Vote: 13
Not Returned : 0
Vote Selection
Votes
Affirmative
12
Affirmative with Comment
0
Negative
1
Thomas E. Buchal
Abstain
0
FR-916, Section No. 694.18, See FR-916
Eligible to Vote: 13
Not Returned : 0
Vote Selection
Votes
Affirmative
11
Affirmative with Comment
1
Robert H. Wills
Comments
The term 'labeled' does not belong in the text as this is a certification issue and not an installation issue.
Comments
I support removing requirements for Stand-Alone systems ONLY if they are stated globally as now proposed for Article 705, or more
sensibly, in a new Article 710, Stand-Alone Systems.
Negative
0
Abstain
1
Thomas E. Buchal
I am unaware of CMP 13 action
FR-999, Section No. 694.60, See FR-999
Eligible to Vote: 13
Not Returned : 0
Vote Selection
Votes Comments
Affirmative
12
Affirmative with Comment
0
Negative
1
Thomas E. Buchal
The term 'labeled' does not belong in the text as this is a certification issue and not an installation issue.
Abstain
0
FR-1042, Definition: Utility-Interactive Inverter Output Circuit., See FR-1042
Eligible to Vote: 15
Not Returned : 0
Vote Selection
Votes Comments
Affirmative
15
Affirmative with Comment
0
Negative
0
Abstain
0
FR-1046, New Definition after Definition: Multimode Inverter., See FR-1046
Eligible to Vote: 15
Not Returned : 0
Vote Selection
Votes Comments
33 of 40
Panel 4 First Draft Ballot Circulation
Affirmative
Affirmative with Comment
Timothy P. Zgonena
13
2
The grammar in the definition is incorrect and confusing. Suggest changing it to read: "A system that has generation and/or energy
storage and load(s), that includes the ability to be operated in parallel with, or intentionally disconnected from the primary source."
Robert H. Wills
As microgrids can either be interactive or stand-alone, it would be less confusing to have the informational note say "An electrical system
that separates from the primary source and can operate individually or interconnected is sometimes referred to as an interactive
microgrid". (the word "interactive" added before microgrid). Also, if the term microgrid is ultimately used in both 705 and a new Article
710 (Stand-alone systems), a generic definition of microgrid should be included in Article 100. Considering its audience, the NEC should
use emerging common terms like microgrid rather than standards jargon. The proposed definition for Microgrid from the WG was
"Microgrid. A group of interconnected electric loads and power production sources that comprise an electric power system with a clearly
defined electrical boundary. A microgrid may include portions of an electric power system that are normally operated by a utility.
Microgrids are also known as minigrids."
Negative
0
Abstain
0
FR-1016, Section No. 705.3, See FR-1016
Eligible to Vote: 15
Not Returned : 0
Vote Selection
Votes Comments
Affirmative
15
Affirmative with Comment
0
Negative
0
Abstain
0
FR-1039, Section No. 705.4, See FR-1039
Eligible to Vote: 15
Not Returned : 0
Vote Selection
Votes Comments
Affirmative
13
Affirmative with Comment
2
Ward I. Bower
705.6 Equipment Approval. ….. Utility-interactive inverters for interconnection systems interactive equipment intended to operate in
parallel with the electric power system …. This is a confusing and an incomplete sentence. The words “interactive equipment” should be
deleted.
Thomas E. Buchal
Negative
0
The term labeled in conjunction with listed should be dropped from the text as this implies that an installation code is specifying terms of
certification. I would vote negative on this except that the overall prescriptive requirement has more merit than the errant use of the
term labeled.
34 of 40
Panel 4 First Draft Ballot Circulation
Abstain
0
FR-1040, Section No. 705.6, See FR-1040
Eligible to Vote: 15
Not Returned : 0
Vote Selection
Votes Comments
Affirmative
14
Affirmative with Comment
1
Timothy P. Zgonena
Incorrect grammar. Suggest changing to read "Installation of one or more electrical power production sources operating in parallel with a
primary source(s) of electricity shall be performed only by qualified persons."
Negative
0
Abstain
0
FR-1043, Section No. 705.10, See FR-1043
Eligible to Vote: 15
Not Returned : 0
Vote Selection
Votes Comments
Affirmative
15
Affirmative with Comment
0
Negative
0
Abstain
0
FR-1019, Section No. 705.12(C), See FR-1019
Eligible to Vote: 15
Not Returned : 0
Vote Selection
Votes Comments
Affirmative
14
Affirmative with Comment
1
Robert H. Wills
I support the concept, but there seems to be something missing in the wording; e.g. "fed simultaneously by a primary source of
electricity" - add "and an interactive source", then continue with "and where this distribution equipment is capable" ...
Negative
0
Abstain
0
FR-1025, Section No. 705.12(D), See FR-1025
Eligible to Vote: 15
Not Returned : 0
Vote Selection
Votes Comments
Affirmative
12
Affirmative with Comment
2
Malcolm Allison
NEMA disagrees with the deletion of item 6, as it removes any requirements for available AFCI protection at ratings below 240V, 30A.
NEMA believes that this list item 6 should be designated as a ballot-able subsection in the Comment phase
35 of 40
Panel 4 First Draft Ballot Circulation
Ward I. Bower
Negative
0
Abstain
1
Timothy P. Zgonena
FR-1026, Section No. 705.21, See FR-1026
Eligible to Vote: 15
Not Returned : 0
Vote Selection
Votes
Affirmative
15
Affirmative with Comment
0
Negative
0
Abstain
0
FR-1047, New Section after 705.22, See FR-1047
Eligible to Vote: 15
Not Returned : 0
Vote Selection
Votes
Affirmative
15
Affirmative with Comment
0
Negative
0
Abstain
0
FR-1027, Section No. 705.30(D), See FR-1027
Eligible to Vote: 15
Not Returned : 0
Vote Selection
Votes
Affirmative
15
Affirmative with Comment
0
Negative
0
Abstain
0
FR-1022, Section No. 705.32, See FR-1022
Eligible to Vote: 15
Not Returned : 0
Vote Selection
Votes
Affirmative
15
Affirmative with Comment
0
Negative
0
Abstain
0
FR-1036, Sections 705.40, 705.42, See FR-1036
Eligible to Vote: 15
The proposed exception for dwellings for location of the inverter breaker in 705.12(D) should not have been removed as proposed by
the Article 705 Task Group. This exception simply returns the requirement for dwellings to what was required prior to the 2008 NEC. No
field issues have been reported on residential panels as a result of breaker location. The proposal to increase the 120% rule to 120% has
initiated a research project that will provide comments to CMP4 on this subject as well.
We chose to abstain from voting on this FR.
Comments
Comments
Comments
Comments
36 of 40
Panel 4 First Draft Ballot Circulation
Not Returned : 0
Vote Selection
Votes
Affirmative
15
Affirmative with Comment
0
Negative
0
Abstain
0
FR-1037, Section No. 705.65(B), See FR-1037
Eligible to Vote: 15
Not Returned : 0
Vote Selection
Votes
Affirmative
15
Affirmative with Comment
0
Negative
0
Abstain
0
FR-1038, Section No. 705.70, See FR-1038
Eligible to Vote: 15
Not Returned : 0
Vote Selection
Votes
Affirmative
15
Affirmative with Comment
0
Negative
0
Abstain
0
FR-1033, Section No. 705.82, See FR-1033
Eligible to Vote: 15
Not Returned : 0
Vote Selection
Votes
Affirmative
14
Affirmative with Comment
1
Thomas E. Buchal
Negative
0
Abstain
0
FR-1034, Section No. 705.95(B), See FR-1034
Eligible to Vote: 15
Not Returned : 0
Vote Selection
Votes
Affirmative
15
Affirmative with Comment
0
Negative
0
Abstain
0
FR-1035, Section No. 705.100(A), See FR-1035
Eligible to Vote: 15
Not Returned : 0
Comments
Comments
Comments
Comments
Hybrid System is lacking a definition
Comments
37 of 40
Panel 4 First Draft Ballot Circulation
Vote Selection
Affirmative
Affirmative with Comment
Negative
Abstain
FR-1030, Part II., See FR-1030
Eligible to Vote: 15
Not Returned : 0
Vote Selection
Affirmative
Affirmative with Comment
Negative
Abstain
Votes Comments
15
0
0
0
Vote Selection
Affirmative
Affirmative with Comment
Robert H. Wills
Votes Comments
13
2
Please see file Wills-CommentOnFR-1045.docx which has been emailed to [email protected]. The file is > the 4000 character limit.
Roger D. McDaniel
Votes Comments
15
0
0
0
1. Title of 705.175. Currently the title of 705.175 is "Wiring Systems". However, the title should be revised to: 705.175 Stand-alone
Wiring Systems. 2. First two sentences of 705.175. The first two sentences of 705.175 should be merged together into one sentence to
comply with the NEC Manual of Style. The revised sentence should read as follows: "Premises wiring systems of stand-alone systems
shall be adequate to meet the requirements of this Code for similar installations supplied by a feeder or service." 3. EDITORIAL Subsections of 705.175. The sub-sections of 705.175 will need to be lettered (A) through (F) instead of (1). The extra spaces between words
in a few parts of this section should be removed. Words such as Sizing and WARNING need to be re-joined and the spacing around
punctuation marks needs to be fixed. 4. Scope of Article 705. With the inclusion of the new Part IV, Intentionally Islanded and StandAlone Systems, these topics need to be added to the scope of Article 705. The revised scope as recommended to the Correlating
Committee should read as follows: 705.1 Scope. This article covers installation of one or more electric power production sources
operating in parallel with a primary source(s) of electricity or operating as an Intentionally Islanded system or operating as a stand-alone
system.
Negative
0
Abstain
0
FR-1010, Sections Part IX., 690.80, 690.81, 690.85, See FR-1010
Eligible to Vote: 15
Not Returned : 0
Vote Selection
Votes Comments
Affirmative
15
Affirmative with Comment
0
Negative
0
38 of 40
Panel 4 First Draft Ballot Circulation
Abstain
0
FR-983, Part V., See FR-983
Eligible to Vote: 15
Not Returned : 0
Vote Selection
Votes
Affirmative
15
Affirmative with Comment
0
Negative
0
Abstain
0
FR-1024, Sections Part V., 694.40, See FR-1024
Eligible to Vote: 13
Not Returned : 0
Vote Selection
Votes
Affirmative
13
Affirmative with Comment
0
Negative
0
Abstain
0
FR-913, Part VIII., See FR-913
Eligible to Vote: 15
Not Returned : 0
Vote Selection
Votes
Affirmative
15
Affirmative with Comment
0
Negative
0
Abstain
0
FR-1012, Sections Part VIII., 690.71, See FR-1012
Eligible to Vote: 15
Not Returned : 0
Vote Selection
Votes
Affirmative
14
Affirmative with Comment
1
Ward I. Bower
Comments
Comments
Comments
Comments
The FR does not cover the rest of 690.71. It misses 690.72, 690.73, and 690.74. All except the first sentence of 690.71, 72,73 and 74
were proposed to and accepted to be deleted.
Negative
0
Abstain
0
FR-918, Sections Part VIII., 694.80, 694.85, See FR-918
Eligible to Vote: 13
Not Returned : 0
Vote Selection
Votes Comments
Affirmative
13
Affirmative with Comment
0
Negative
0
39 of 40
Panel 4 First Draft Ballot Circulation
Abstain
0
FR-1011, Sections Part X., 690.90, 690.91, See FR-1011
Eligible to Vote: 15
Not Returned : 0
Vote Selection
Votes Comments
Affirmative
15
Affirmative with Comment
0
Negative
0
Abstain
0
40 of 40