70 a2016 nec-p04 sd ballotcircmemo - nfpa€¦ · the january 15, 2016 date for receipt of the nec...

51
National Fire Protection Association 1 Batterymarch Park, Quincy, MA 02169-7471 Phone: 617-770-3000 • Fax: 617-770-0700 • www.nfpa.org M E M O R A N D U M TO: NEC ® Code-Making Panel 4 FROM: Kimberly Shea, Administrator, Technical Projects DATE: January 18, 2016 SUBJECT: NFPA 70 Second Draft TC Ballot Circulation (A2016) The January 15, 2016 date for receipt of the NEC Second Draft Ballots has passed. 17 Principal Members 14 Members Eligible to Vote on All Revisions 3 Member Vote Limited – (see attached report) 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, January 22, 2016. 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. Page 1 of 51

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Page 1: 70 A2016 NEC-P04 SD ballotcircmemo - NFPA€¦ · The January 15, 2016 date for receipt of the NEC Second Draft Ballots has passed. ... since additional redundancy is provided in

National Fire Protection Association 1 Batterymarch Park, Quincy, MA 02169-7471 Phone: 617-770-3000 • Fax: 617-770-0700 • www.nfpa.org

M E M O R A N D U M TO: NEC® Code-Making Panel 4 FROM: Kimberly Shea, Administrator, Technical Projects DATE: January 18, 2016 SUBJECT: NFPA 70 Second Draft TC Ballot Circulation (A2016)

The January 15, 2016 date for receipt of the NEC Second Draft Ballots has passed. 17 Principal Members

14 Members Eligible to Vote on All Revisions 3 Member Vote Limited – (see attached report)

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, January 22, 2016. 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.

Page 1 of 51

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Eligible to Vote: 14

Not Returned : 0

Vote Selection Votes Comments

Affirmative 14

Affirmative with Comment 0

Negative 0

Abstain 0

Eligible to Vote: 17

Not Returned : 0

Vote Selection Votes Comments

Affirmative 17

Affirmative with Comment 1

Wendell R. Whistler The term "Microgrid" being introduced into the 2017 NEC is also

used by "Regulated Utilities" as has a very different meaning

which may lead to confusion. This may lead to the "Regulated

Utilities" being named in litigation for which they have no

Negative 1

SR-1005, Detail, See SR-1005

NEC-P04_SD_Ballot Circulation_1_18_16

SR-916, Global Comment, See SR-916

Page 2 of 51

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Roger D. McDaniel I am in agreement with the removal of the term “Stand-Alone”

from the title as these requirements are covered elsewhere in the

NEC. I disagree with using the term “microgrid” in the title. The

term “Microgrid” is a jargon and non-specific term. The NEC

consistently encourages using terminology that provides clarity.

The term “Intentionally Islanded System” provides this clarity. To

ensure that we maintain fundamental separation between utility

wiring and premises wiring, we need to use terminology that

provides clear separation between the two systems (NEC and

NESC). The electric utility type microgrid systems are still in the

R&D phase and still being discussed in standards committees that

are outside of the NFPA. Therefore, as this technology continues

to emerge, we need to ensure that the lines do not become

blurred between the two systems. We are mixing two different

systems; therefore keeping different terms in the NEC will best

serve the industry. Using the term Intentionally Islanded System is

consistent with the current IEEE 1547 Series of standards,

recommended practices and guides with are currently published.

Abstain 0

Eligible to Vote: 17

Not Returned : 0

Vote Selection Votes Comments

Affirmative 15

Affirmative with Comment 2

Robert H. Wills This may be considered editorial, but I think DC rather than Dc

better clarifies the intent here, despite the philosophy behind the

Ward I. Bower There is an inconsistency in capitalization of on or in

Negative 0

Abstain 0

Eligible to Vote: 17

Not Returned : 0

Vote Selection Votes Comments

Affirmative 17

Affirmative with Comment 0

Negative 0

SR-918, Definition: Field Labeled (as applied to evaluated products..., See SR-918

SR-960, Detail, See SR-960

Page 3 of 51

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Abstain 0

Eligible to Vote: 14

Not Returned : 0

Vote Selection Votes Comments

Affirmative 14

Affirmative with Comment 0

Negative 0

Abstain 0

Eligible to Vote: 14

Not Returned : 0

Vote Selection Votes Comments

Affirmative 14

Affirmative with Comment 0

Negative 0

Abstain 0

Eligible to Vote: 14

Not Returned : 0

Vote Selection Votes Comments

Affirmative 14

Affirmative with Comment 0

Negative 0

Abstain 0

Eligible to Vote: 14

Not Returned : 0

Vote Selection Votes Comments

Affirmative 13

Affirmative with Comment 0

Negative 1

SR-902, Section No. 225.30, See SR-902

SR-908, Section No. 225.19(D)(2), See SR-908

SR-907, Section No. 225.18, See SR-907

SR-901, Section No. 225.10, See SR-901

Page 4 of 51

Page 5: 70 A2016 NEC-P04 SD ballotcircmemo - NFPA€¦ · The January 15, 2016 date for receipt of the NEC Second Draft Ballots has passed. ... since additional redundancy is provided in

David J. Picatti The IEC supports multiple –feeders to one or Two Family

dwellings. However, the main issue with SR-1002 is that no

substantiation has been provided to require a minimum feeder

size of #1/0 when installing multiple feeders. The code allows a

transformer to have multiple sets of unprotected service

conductors installed from the transformer to a building in sizes

well below the 1/0 requirement of this section. The code allows

unprotected overhead services to be installed to buildings well

below any 1/0 requirement. The code allows unprotected feeder

conductors when tapped of the secondary of a transformer well

below the 1/0 requirement. The code allows protected feeder

conductors to be installed within any building at any size, well

below the 1/0 requirement. Only section 310.15 requires at least

a 1/0 size when paralleling conductors and even this requirement

is many decades old with no technical substantiation. In the

Greater Houston area, utilities provide power to dwellings from a

pedestal meter base located away from the home. A pedestal

meter base will also include two 125-amp service disconnects. A

direct buried feeder is installed from each service disconnect to

the home. This has been done in certain areas such as Houston

since additional redundancy is provided in the event one direct

buried cable fails. By the adoption of the revised language this

area of the country along with others will be mandated to

increase the size of the conductor to the home above and beyond

what is presently required. In addition, statistics are available

from local utility companies in which they have estimated the

actual demand load for residential dwellings. For these

occupancies a typical demand load for a 2000 square foot home is

calculated by the utilities at 7 kw or less. For the standard Abstain 0

Eligible to Vote: 14

Not Returned : 0

Vote Selection Votes Comments

Affirmative 14

Affirmative with Comment 0

Negative 0

Abstain 0

Eligible to Vote: 14

Not Returned : 0

Vote Selection Votes Comments

Affirmative 14

SR-904, Section No. 225.38(C), See SR-904

SR-903, Section No. 225.32, See SR-903

Page 5 of 51

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Affirmative with Comment 0

Negative 0

Abstain 0

Eligible to Vote: 14

Not Returned : 0

Vote Selection Votes Comments

Affirmative 16

Affirmative with Comment 0

Negative 0

Abstain 0

Eligible to Vote: 14

Not Returned : 0

Vote Selection Votes Comments

Affirmative 14+B13

8

Affirmative with Comment 0

Negative 0

Abstain 0

Eligible to Vote: 14

Not Returned : 0

Vote Selection Votes Comments

Affirmative 16

Affirmative with Comment 0

Negative 0

Abstain 0

Eligible to Vote: 14

Not Returned : 0

Vote Selection Votes Comments

Affirmative 14

Affirmative with Comment 0

Negative 1

SR-910, Section No. 230.42(A), See SR-910

SR-909, Section No. 230.29, See SR-909

SR-906, Section No. 230.9(B), See SR-906

SR-905, Section No. 230.7, See SR-905

Page 6 of 51

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Malcolm Allison The Listing requirement for busway is under the purview of CMP-8

and Article 368 does not require busway to be Listed. Therefore

the existing language that permits Listing "or" Labelled is

appropriate.

Abstain 0

Eligible to Vote: 14

Not Returned : 0

Vote Selection Votes Comments

Affirmative 13

Affirmative with Comment 0

Negative 1

Malcolm Allison Type TC has no provisions for being listed or evaluated as a

service entrance conductor, and should not be included in this list.

Abstain 0

Eligible to Vote: 14

Not Returned : 0

Vote Selection Votes Comments

Affirmative 14

Affirmative with Comment 0

Negative 0

Abstain 0

Eligible to Vote: 14

Not Returned : 0

Vote Selection Votes Comments

Affirmative 13+A66

4

Affirmative with Comment 1

James J. Rogers The exception should be changed by adding the word by after the

word purchased so that the sentence reads properly and who

purchases the subject meter socket is defined

Negative 0

Abstain 0

Eligible to Vote: 14

Not Returned : 0

SR-1004, New Section after 230.70(A)(3), See SR-1004

SR-913, Section No. 230.66, See SR-913

SR-912, Section No. 230.54(C), See SR-912

SR-911, Section No. 230.44, See SR-911

Page 7 of 51

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Vote Selection Votes Comments

Affirmative 8

Affirmative with Comment 3

Wendell R. Whistler This change will allow for disconnection of power to a dwelling

unit where the MAINS disconnect is located inside the structure.

During Hurricane Katrina and Super Storm Sandy flooding in

basements and cellars where the MAINS disconnect was located

posed a serious hazard to individual that was trying to disconnect

the power while wading through the flooded area or where a gas

leak has occurred in this same area. This proposal was requested

by the Fire Service. In the Western United States the external

disconnect is a common requirement of the serving utility of state

or local jurisdiction.

Matthew Paiss This provision will close a gap for allowing an NFPA70E compliant

method for the emergency disconnection of service from outside

the structure. Where hazardous conditions exist within a

basement such as smoke, gas leaks, flooding, this will provide the

safe operation by both occupant or responder to mitigate further

hazards. The challenges presented to the adoption of this code

are regional in nature, and as such should not be justification to

adopt this as a national model code.

Bill F. Brooks While it is understandable that the fire service would like a

national approach to service entrances on one- and two-family

dwellings, there are significant parts of the U.S. where this will

pose problems. Particularly problematic are existing homes that

need a service upgrade. This new provision could require much

more expensive rework to an existing old service. The downside

to this new requirement is that many homeowners in dire need of

a service upgrade may postpone indefinitely that upgrade

because of the increased cost. This may actually create fire

hazards rather than mitigate them.

Negative 5

Thomas E. Buchal I do not believe that this requirement belongs in a National

Standard and has potential negative ramifications with regards to

premise security and ability to install a service in urban, high

density areas.

Page 8 of 51

Page 9: 70 A2016 NEC-P04 SD ballotcircmemo - NFPA€¦ · The January 15, 2016 date for receipt of the NEC Second Draft Ballots has passed. ... since additional redundancy is provided in

David J. Picatti No supporting data has been provided by the original submitter to

support a change of this magnitude. This change will require that

either 1) the main disconnecting means be relocated outside a

one and two family dwelling or 2) a shunt trip mechanism be

installed outside the home in order that the button can be used to

quickly trip open a remote disconnect. One would think that if a

significant hazard exists the fire department would also be

concerned about all occupancies including multi-family,

commercial and industrial facilities but this has been ignored by

the committee and the submitter. This requirement simply adds

another point of failure and significant added cost to the

residential electrical system with little to no added benefit. There

are many reasons why this requirement should not be placed into

the NEC. First, disconnects with an “On-Off” marking will be an

invitation for nuisance opening and closing of the disconnect in

higher crime areas that are subject to vandals and other nefarious

activities. The exterior equipment will be subject to weather

degradation. Large scale homes (more than 10,000 square feet)

sometimes have services that are upward of 1000 amps or more.

Requiring an exterior disconnect in these cases will not be

welcome sight to many homeowners. The unsubstantiated

addition of 230.70(A), will increase the cost of installation, and

affect low-income housing the most. On a Habitat for Humanity

house, if this device costs $500, it would add approximately 8% to

the cost of the electrical system. Also, the wording of this section

could be interpreted to allow the service disconnect inside the

building due to the wording “or at the nearest point of entrance

of the service conductors”. The service conductors have not

entered the building if they are on the outside. Houston and other

Page 9 of 51

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James J. Rogers This comment should never have been accepted. There was no

statistical analysis or technical substantiation to support changing

this long standing code section. It was simply changed on the basis

that it would enhance firefighter safety. One of the problems with

this is that it wasn’t even submitted with support from the

majority of firefighter representation. This comment was

submitted on behalf of IAFF which is the International Association

of Firefighters which is the union representation for full time

firefighters. In fact, the overwhelming majority of firefighters in

the United States are call and volunteer firefighters, 69%

according to the NFPA website, and they were not involved in this

submittal at all. In addition, the majority of IAFF represented

firefighters are located in larger metropolitan areas of 25,000

people or more, 71% according to the NFPA website. This change

if it goes into effect will only apply to 1 and 2 family dwellings the

majority of which are located away from larger metropolitan

areas. So in essence the IAFF has brought forward a proposed

change with no statistical data that will have little effect for its

members. This section of the NEC has worked very well for many

decades because it allows the service disconnect to be either

inside or outside whichever is better for the prevailing conditions.

There are many areas of the country that mandate the service

disconnect to be outside because it works best in that given area

and that is fine. This change however would mandate that the

service disconnect always be located outside and there are many

areas of the country where this does not work. That again is why

the existing language has been so successful as it is permissive to

allow either not restrictive to mandate one over the other. There

are many installations where it is in fact safer to install the service

Page 10 of 51

Page 11: 70 A2016 NEC-P04 SD ballotcircmemo - NFPA€¦ · The January 15, 2016 date for receipt of the NEC Second Draft Ballots has passed. ... since additional redundancy is provided in

Malcolm Allison This SR is intended to (1) protect firefighters by allowing them to

safely and easily disconnect power from the exterior of one and

two family dwellings, and (2) provide service entrance conductor

protection before the conductors enter the dwelling. NEMA

agrees with the concepts of those goals in general, but the text, as

written, does not provide the required practical safeguarding as

described in 90.1. (1) The language permits a remote disconnect

to be placed outside the dwelling and remotely trip the breaker in

the load center. The communication conductors from the remote

control device to the service disconnect could be involved in the

fire and place the emergency responders unnecessarily in harm’s

way. The remote-controlled disconnect therefor should not be an

option. In its place, (2) and (3) below will provide the needed

relief. (2) As written, and because of the economics, the text

would encourage the entire branch-circuit panelboard to be

installed outdoors, where it is not in the best interest of the

homeowner in many parts of the country. It is the branch-circuit

circuit breakers that the homeowner normally needs to reach,

whether tripping occurred due to an overcurrent, a ground-fault,

or an arcing-fault. A requirement needs to be added for the

enclosure containing the branch-circuit overcurrent protective

devices to be located indoors. (3) For ease of local disconnection,

the panelboard containing the branch-circuit circuit breakers (in

(2) above) should not be a main lug-only panelboard, but rather

have a main circuit breaker, a main non-fused disconnect switch,

or a fused main switch. The homeowner should be able to

disconnect his or her entire panelboard from inside their home,

while the first responder should be able to disconnect entire

service, including the service entrance conductors and the Roger D. McDaniel Statement: We understand the benefits provided by a

requirement for the service disconnect to be located outside of

the structure. However, there are negative consequences such as

security issues and no available space for installation with some

types of construction. Therefore, we believe the requirement

should be addressed in local codes and ordinances and not the

NEC.

Abstain 0

Eligible to Vote: 14

Not Returned : 0

Vote Selection Votes Comments

Affirmative 16

Affirmative with Comment 0

SR-914, Section No. 230.71(A), See SR-914

Page 11 of 51

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Negative 0

Abstain 0

Eligible to Vote: 14

Not Returned : 0

Vote Selection Votes Comments

Affirmative 16

Affirmative with Comment 0

Negative 0

Abstain 0

Eligible to Vote: 17

Not Returned : 0

Vote Selection Votes Comments

Affirmative 16

Affirmative with Comment 0

Negative 0

Abstain 0

Eligible to Vote: 17

Not Returned : 0

Vote Selection Votes Comments

Affirmative 16

Affirmative with Comment 0

Negative 0

Abstain 0

Eligible to Vote: 17

Not Returned : 0

Vote Selection Votes Comments

Affirmative 16

Affirmative with Comment 0

Negative 0

Abstain 0

Eligible to Vote: 17

SR-931, Definition: Photovoltaic System Voltage., See SR-931

SR-930, Definition: Generating Capacity., See SR-930

SR-929, Definition: Engineering Supervision., See SR-929

SR-928, Section No. 690.1, See SR-928

SR-915, Section No. 230.95(C), See SR-915

Page 12 of 51

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Not Returned : 0

Vote Selection Votes Comments

Affirmative 17

Affirmative with Comment 0

Negative 0

Abstain 0

Eligible to Vote: 17

Not Returned : 0

Vote Selection Votes Comments

Affirmative 15

Affirmative with Comment 2

Wendell R. Whistler The term "Functional Grounded PV System" has a few different

meanings depending upon what part of the United States you are

working in. This term is also being used in Europe with a different

meaning and could possibly lead to some confusion within the

industry.

Ward I. Bower This panel member believes retaining the term PV in ac PV

modules provides clarity

Negative 0

Abstain 0

Eligible to Vote: 17

Not Returned : 0

Vote Selection Votes Comments

Affirmative 17

Affirmative with Comment 0

Negative 0

Abstain 0

Eligible to Vote: 17

Not Returned : 0

Vote Selection Votes Comments

Affirmative 15

Affirmative with Comment 2

SR-935, Section No. 690.7 [Excluding any Sub-Sections], See SR-935

SR-934, Section No. 690.4(D), See SR-934

SR-933, Section No. 690.4(B), See SR-933

Page 13 of 51

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Ward I. Bower This panel member believes that the term "or less" used two

places in the section is not necessary. The paragraph is defining

the maximum voltage allowed. In the paragraph with a reference

to Article 490 the terminology "or less" does provide clarity and

should be retained.

Stephen P. Wurmlinger The term "or less" is used when describing systems with a

"maximum voltage of 600V" and "maximum voltage of 1000V".

The use of the term "or less" in two locations is not needed.

Negative 0

Abstain 0

Eligible to Vote: 17

Not Returned : 0

Vote Selection Votes Comments

Affirmative 16

Affirmative with Comment 1

Wendell R. Whistler This change to 690.7 (A) precludes a Master Electrician form doing

these calculations unless they are additionally licensed as a

Registered Professional Electrical engineer (PE).

Negative 0

Abstain 0

Eligible to Vote: 17

Not Returned : 0

Vote Selection Votes Comments

Affirmative 17

Affirmative with Comment 0

Negative 0

Abstain 0

Eligible to Vote: 17

Not Returned : 0

Vote Selection Votes Comments

Affirmative 16

Affirmative with Comment 1

Ward I. Bower The term functional ground reference is ambiguous since the

definition of functional ground needs to be clarified in this Article.

SR-938, Section No. 690.7(C), See SR-938

SR-937, Section No. 690.7(B), See SR-937

SR-936, Section No. 690.7(A), See SR-936

Page 14 of 51

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Negative 0

Abstain 0

Eligible to Vote: 17

Not Returned : 0

Vote Selection Votes Comments

Affirmative 15

Affirmative with Comment 2

Wendell R. Whistler This change to 690.8 (A)(1) precludes a Master Electrician form

doing these calculations unless they are additionally licensed as a

Registered Professional Electrical engineer(PE).

Ward I. Bower The numbering for this section is allowed according the style

manual, but invites confusion here. There is no 690.8(A)(1)(a) as

written in this SR and approved by the panel. This panel member

suggests the correlating committee consider changing the

designation of 690.8(A)(1)(1) be changed to 690.8(A)(1)(a) and

that 690.8(A)(1)(2) be changed to 690.8(A)(1)(b.

Negative 0

Abstain 0

Eligible to Vote: 17

Not Returned : 0

Vote Selection Votes Comments

Affirmative 17

Affirmative with Comment 0

Negative 0

Abstain 0

Eligible to Vote: 17

Not Returned : 0

Vote Selection Votes Comments

Affirmative 16

Affirmative with Comment 1

Ward I. Bower This panel member believes it appropriate to shorten the term

Photovoltaic to PV in the Informational Note as is being practiced

through this article except where used as a title.

Negative 0

SR-941, Section No. 690.9(A), See SR-941

SR-940, Section No. 690.8(B), See SR-940

SR-939, Section No. 690.8(A)(1), See SR-939

Page 15 of 51

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Abstain 0

Eligible to Vote: 17

Not Returned : 0

Vote Selection Votes Comments

Affirmative 16

Affirmative with Comment 1

Ward I. Bower This panel member believes the structure of this sentence can be

improved to read "...., shall be labeled and or rated in accordance

with the following:" It is also noted there is an extra space before

the period in 690.9(B)(3). Along the same lines the entire Article

690 is not consistent in its use of periods in numbered paragraphs

and sentences/phrases.

Negative 0

Abstain 0

Eligible to Vote: 17

Not Returned : 0

Vote Selection Votes Comments

Affirmative 17

Affirmative with Comment 0

Negative 0

Abstain 0

Eligible to Vote: 17

Not Returned : 0

Vote Selection Votes Comments

Affirmative 14

Affirmative with Comment 3

Ward I. Bower There is an extra "to a" in this sentence. The second "to a" should

be deleted.

SR-944, Section No. 690.10, See SR-944

SR-943, Section No. 690.9(C), See SR-943

SR-942, Section No. 690.9(B), See SR-942

Page 16 of 51

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Bill F. Brooks This SR is inaccurate. The CMP voted to remove 690.10(A)

through (D) and this SR has those sections. This panel member

requests that the correlating committee fix this clerical error as it

makes no logical sense for the code to make a reference and then

state exactly what is in the referenced section. While TerraView

has been very helpful in addressing the logistics of code changes

for the NEC, it must be recognized that sometimes the coding of

TerraView makes mistakes, of which this is one, which is why the

panel must approve what comes out of TerraView. Please rectify

this error so it does not have to be addressed in an errata.

Stephen P. Wurmlinger "to a" is repeated in the first sentence.

Negative 0

Abstain 0

Eligible to Vote: 17

Not Returned : 0

Vote Selection Votes Comments

Affirmative 13

Affirmative with Comment 3

Matthew Paiss Just being a ground mounted array does not preclude the

potential for significant property or life loss in the event of a fire

due to an arc fault. It would be a reasonable safety enhancement

in the next cycle to include ground mount systems within WUI or

suburban settings.

Ward I. Bower It is suggested that the word Photovoltaic be changed to PV to

maintain consistency throughout the Article. The change is

needed in the section and in the Informational note. This panel

member also believes the Info note should specify the reference

rather than just to refer to the Annex A. UL1699b is not a standard

yet, it is a outline of investigation. There is a concentrated effort

to address deficiencies but in the meantime there has been false

trips and failures reported in field installations. This panel

member has serious concerns about the reliability of the sensors

and devices that will be used and there are no methods yet

available to determine if the detectors work once installed.

Stephen P. Wurmlinger The informational note refers to 1699b as a "Standard" when it is

actually an "Outline of Investigation".

Negative 1

SR-945, Section No. 690.11, See SR-945

Page 17 of 51

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Wendell R. Whistler The exception may pose a risk of fire or shock when individuals

are working in close proximity to these installations as the DC arc

fault protection has been allowed to not be installed for ground

mounted PV systems. The cable tray system may be installed

above ground and does not require a ground fault protection

system that would provide equivalent protection for the workers.

Abstain 0

Eligible to Vote: 17

Not Returned : 0

Vote Selection Votes Comments

Affirmative 9

Affirmative with Comment 5

David J. Picatti The 80 Volts is not a safe voltage, however the new version is

specific in saying that the “function to reduce shock hazard for

emergency responders”. My Concern with this is the “perception”

that the system would be “safe” after a rapid shutdown, rather

than “safer”. The “Off” designation that is included in this SR is

misleading in that, to me, “Off” means “Off”, not safer. One of my

concerns, is some unqualified person/homeowner hits the “off”

button, gets on the roof and gets shocked. Maybe the designation

should be “On” – “Shutdown “ .

Wendell R. Whistler 690.12 (B)(2)(b) allows 80 volts within the array which is NOT a

touch safe voltage as defined by NFPA 70E and OSHA. It appears

that during a rapid shutdown event the solid state [IGBT, MOSFET

or IGFET] devices that are being proposed may fail in the closed

state rather than in the open state. If one or more fail in the

closed state the voltage that is present could be greater than 80

volts as these modules are series connected and could have

voltages at 160 volts or greater. I respectfully request that the

Correlating Committee review the change in 690.12 (B)(2)(c) as I

appears that this revision did not go through the appropriate

hearing process. I was not able to locate the PI or FR supporting

documentation for this change to be made during the second

revision.

SR-1002, Section No. 690.12, See SR-1002

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Matthew Paiss The informational note under 690.12(B)2(a) is incorrect and does

not communicate that the standard for a "listed" RSS array be

equal or lower hazard than the (B)(2)(b) option of 80V max. The

committee statement confirms this by stating, "The fire service

has expressed concern that the lack of a rapid shutdown PV array

standard may result in lesser safety than the 80 volts required in

690.12(B)(2)(b). To further clarify that the intent of this listing

process is for fire fighter safety, the informational note clarifies

the intent that a listed product will equivalent or lesser hazard

than a system built in accordance with 690.12(B)(2)(b). This

clearly signals to the relevant standards committees, what the

code intent is for this new standard." Option (B)(2)(c) was added

to the SR with limited discussion of the CMP members. It is this

panel members opinion that this option will not be required to be

listed, nor a reduced voltage. It does not offer any guarantee that

it will provide any increase in safety under abnormal conditions.

Timothy P. Zgonena UL understands the desired intention of the 80V limit to reduce

shock hazards. Unfortunately, 80V can be a lethal electric shock

hazard in this application. Further, for this role it would be most

appropriate to use a listed system consistent with the concept of

690.4(B), rather than some assemblage of equipment not

specifically listed as a system, to limit the voltage. UL firmly

believes that PV Rapid Shutdown equipment specifically listed for

this intended purpose is the best solution to provide this type of

protection. We have made good progress since the first revision

of 690.12 for the 2017 NEC. UL understands and supports the

development of a science-based solution as the basis for the

upcoming standard for 2017 PV rapid shutdown systems and

equipment which is intended to reduce the likelihood of PV

system shock hazards for fire fighters.

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Bill F. Brooks There is one very minor editorial error in SR-1002 that occurred as

a result of transferring the text of the SR from Word to TerraView.

That error is in the first sentence of 690.12(C). The word "all" was

removed from the FR when developing the SR, but the word did

not get properly deleted. The first sentence of SR-1002 should

read, "The initiation device(s) shall initiate the rapid shutdown

function of the PV system." This heavily revised section represents

a compromise position between two major proposals from the

International Association of Fire Fighters (IAFF) and the Solar

Energy Industries Association (SEIA). A collaborative task group set

up by NFPA, entitled the NFPA Fire Fighter Safety and PV Systems

Task Group deliberated for over six months on these two

proposals and put forth a proposal that is very similar to what was

approved in SR-1002. While SEIA and IAFF still do not agree on a

few details in this SR, it represents the best position from a

collaborative point of view. The SEIA concerns that an 80-volt

option for controlling conductors inside the array would limit

innovation and control products is no longer valid since there are

now three different methods for compliance inside the PV array.

While the informational note was generalized to not specifically

mention level of hazard relative to 80-volts, it remains that the

standards process for developing listed PV arrays should start

from the position that a PV array should have no greater

electrocution hazard than if components are allowed to be at 80-

volts or less. This new version of 690.12 is a significant step in PV

system safety that will be difficult for the PV industry to master in

the first several years of enforcement. While products are

commonly available and used in the residential market that can

meet this new requirement, the more difficult market is the Negative 3

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Robert H. Wills 690.12(B)(2) (rapid shutdown inside the array boundary) should

not be included in the 2017 NEC for the following reasons: 1.

There was little technical justification given for this extreme step

of requiring active voltage control at each PV module. There was

not even a simple analysis of under what conditions hazardous

currents could impact responder safety, or a clear presentation

that hazardous current flow requires two connections to the

body. 2. No cases of actual harm or fatality were described. 3. The

reliability of module-scale electronics was not considered. The

end-result of this requirement could be many fires due to

electronics failures and many more rooftop accidents during

service. 4. It is impossible to guarantee proper operation of such

equipment under firefighting conditions, and as such it ultimately

cannot be assumed to be working anyway. Firefighters will have

to adopt practices that assure their safety regardless of array

electronics. I do agree that rapid shutdown outside the array

boundary is appropriate (i.e. 690.12(B)(1)). The effort to consider

a PV array as a system in 690.12(B)(2)(a) is a step in the right

direction, but the work needed to define the risk and to justify any

additional requirements beyond 690.12(B)(1) has not been

demonstrated. The requirements of 690.12(B)(2) should be tabled

until the 2020 code cycle, and then subject to proper technical

analysis and justification. -------------- Other comments: The

informational note to 690.12(C) incorrectly references

690.12(C)(3) but should be 690.12(C)(c), or the list above should

be numeric. -------------- The last paragraph of 690.12(C) does not

address the issue of a single service feeding premises with

multiple buildings such as a campus. The requirement should be

for all PV systems serving a particular building, not a service.

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Ward I. Bower This panel member votes negative on SR1002 for Article 690.12,

but does not believe a negative ballot for the entire 690.12

section is in the best interest of the NFPA or fire fighters. SR1002

unfortunately combines all seventeen of the substantive public

comments related to Article 690.12 into a single SR. This was not

the case for most of the other sections of Article 690, and this

panel member believes it certainly should not have been done for

Article 690.12. It is noted Article 690.12 received more public

comments than any other section of Article 690. It is obvious to

this panel member and evidenced by the extraordinary number of

proposed changes from the first revision to the second revision

that the first revision is unacceptable to the NFPA Fire Fighter

Safety and PV Systems (FFSPVS) Task Group and a majority of

public commenters. FR1008 would not reflect the desires of the

firefighters, public or panel members. Given the dilemma, this

panel member respectfully requests consideration of

segmentation of 690.12. Further, should it get to the point of

FR1008 being considered for the 2017NEC, this panel member

requests that the extensive changes from FR to SR for 690.12 be

evaluated before accepting for the inclusion in the 2017NEC. The

substantiations submitted with PCs by industry experts should

also be seriously addressed. This panel member notes that at least

80% of this SR represents deletions, changes or new requirements

over the FR. This panel member believes that, for the most part,

the resulting SR is reasonable, but 690.12(B)(2)(b) is overly

prescriptive with the 80Vdc requirement. The 80V value is not a

touch-safe voltage and is not proven safe by any credible

research. The 80V condition will only be possible should ALL

isolation functions work. The brutal rooftop environment will

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Stephen P. Wurmlinger This panel member and the industry represented supports the

need to reduce the risk of electric shock to firefighters performing

firefighting duties on a building that contains a PV system. Many

of the requirements that have been included in SR1002 are

improvements over the 2014 Code and need to be included in the

2017 Code. However, I must vote negative due to the wording of

this section and the possible safety and inspection issues this

could create. The industry members represented believe that all

equipment performing this function needs to be listed and labeled

as Rapid Shutdown to a product safety standard. Neither

690.12(B)(2)(b) nor 690.12(B)(2)(c) include requirements to be

listed and labeled as rapid shutdown. Removing 690.12(B)(2)(b)

and 690.12(B)(2)(c) would eliminate the lack of listing concern and

other inadequate wording that could result in safety and

inspection issues. With industry and firefighter members working

together to develop a rapid shutdown listing standard, adequate

requirements can be established in conjunction with firefighter

procedures and expected conditions to provide a more reliable

reduction in shock hazard. The last minute editing to this section

resulted in language which implies there would be no risk of shock

within the array boundary and is likely to result in safety and

inspection issues. The proposed language of SR1002 for

690.12(B)(2)(b) and 690.12(B)(2)(c) will also create confusion with

NRTL’s, AHJ’s, suppliers and installers. This panel member believes

that SR1002 is a significant improvement over the FR1008-NFPA-

70-2015 and over the 2014 Code with the exception of the

requirements of 690.12(B)(2)(b) and 690.12(B)(2)(c).

Abstain 0

Eligible to Vote: 17

Not Returned : 0

Vote Selection Votes Comments

Affirmative 17

Affirmative with Comment 0

Negative 0

Abstain 0

Eligible to Vote: 17

Not Returned : 0

Vote Selection Votes Comments

Affirmative 17

SR-947, Section No. 690.13(B), See SR-947

SR-946, Section No. 690.13(A), See SR-946

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Affirmative with Comment 0

Negative 0

Abstain 0

Eligible to Vote: 17

Not Returned : 0

Vote Selection Votes Comments

Affirmative 16

Affirmative with Comment 1

Ward I. Bower This panel member casts an affirmative vote but believes the text

needs to be changed to "sufficient for the maximum available

circuit current" and delete "available short-circuit current". This

sentence is ok if there is a comma after circuit current.

Negative 0

Abstain 0

Eligible to Vote: 17

Not Returned : 0

Vote Selection Votes Comments

Affirmative 16

Affirmative with Comment 1

Robert H. Wills The "Line and Load" marking is not sufficient to define

applicability. DC breakers with magnetic arc quenching are

DIRECTIONAL. So a breaker marked Line and Load could be

suitable for reverse current flow (with respect to a panel) if

properly connected.

Negative 0

Abstain 0

Eligible to Vote: 17

Not Returned : 0

Vote Selection Votes Comments

Affirmative 16

Affirmative with Comment 0

Negative 1

SR-951, Section No. 690.15(A), See SR-951

SR-949, Section No. 690.13(F), See SR-949

SR-948, Section No. 690.13(E), See SR-948

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Wendell R. Whistler This change appears to not comply with the requirements set

forth in 110.25. The isolating device needs to comply with the

requirements of 110.25. This device needs to be lockable in the

open position as a contactor or relay does not appear to meet the

requirements of a disconnecting means.

Abstain 0

Eligible to Vote: 17

Not Returned : 0

Vote Selection Votes Comments

Affirmative 17

Affirmative with Comment 0

Negative 0

Abstain 0

Eligible to Vote: 17

Not Returned : 0

Vote Selection Votes Comments

Affirmative 14

Affirmative with Comment 2

Bill F. Brooks This SR is completely out of order as it belongs in the definitions

section. The term "functional" replaces "reference" to

differentiate between reference grounding in Article 517 which

may be a different concept to the methods of grounding used

with PV systems. Functional grounding is a term that simply

differentiates from safety grounding and is commonly used

internationally in the PV industry.

Stephen P. Wurmlinger Changing "reference" to "functional" creates a new term from the

first revision that has not been reviewed outside of panel 4 task

group.

Negative 1

SR-932, Definition: Reference Grounded PV System., See SR-932

SR-950, Section No. 690.15(C), See SR-950

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Ward I. Bower Reference Ground was defined and approved in the first revision.

The term "Functional Ground" has not been seen by the public

outside of the Panel 4 task group and the panel members. This

panel member believes that adding new terminology without an

opportunity for public comment is a stretch of the rules for

making code changes. Note also that, although the term appears

to be a reasonable alternative to reference ground, the term

functionality as already used throughout the code refers to

operations and not grounding and the two uses will likely create

some confusion when trying to understand functional ground.

This short description of functional grounded PV system appears

to be an inadequate and ambiguous description and describes

what it may be. Since grounding is one of the least understood

concepts in the code, this panel member requests the correlating

committee consider asking the panel to include a more complete

definition of functional ground if it is to be included as an

installation method in Article 690. This panel member notes that

the term "functional ground" is used in other systems where

some devices such as antennas require a connection to the mass

of earth to function correctly. Conversely the IEC definition for

functional ground or functional equipotential bonding in IEC-

60617 with alternative names of functional bonding conductor

and functional bonding terminal is referred to bonding. IEC 60364

also refers to functional earthing as related to equipotential

bonding but also defines the hardware to be used for potential

earthing. To complicate the issue even more, Wikipedia claims

that the most important example of a functional earth is the

neutral in an electrical supply system. Note also this SR does not

refer to 690.2.Abstain 0

Eligible to Vote: 17

Not Returned : 0

Vote Selection Votes Comments

Affirmative 16

Affirmative with Comment 1

SR-952, Section No. 690.15(D), See SR-952

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Robert H. Wills The requirement to "disconnect all current-carrying conductors

that are not solidly grounded" in 690.15(D) first sentence raises

the question: "is functionally grounded equal to solidly

grounded"? I think the answer is "no", and so multi-pole

disconnects will be required in 2017 where single-pole

disconnects were commonly used in the past. This is a correlating

issue. I suggest that the word "solidly" be modified to "solidly or

functionally" grounded.

Negative 0

Abstain 0

Eligible to Vote: 17

Not Returned : 0

Vote Selection Votes Comments

Affirmative 17

Affirmative with Comment 0

Negative 0

Abstain 0

Eligible to Vote: 17

Not Returned : 0

Vote Selection Votes Comments

Affirmative 17

Affirmative with Comment 0

Negative 0

Abstain 0

Eligible to Vote: 17

Not Returned : 0

Vote Selection Votes Comments

Affirmative 14

Affirmative with Comment 2

SR-955, Section No. 690.31(C), See SR-955

SR-954, Section No. 690.31(B)(1), See SR-954

SR-953, Section No. 690.31(A), See SR-953

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Wendell R. Whistler I respectfully request that the Correlating committee review the

changes made to 690.31(C)(1) where Type USE-2 was added in.

The following issue creates serious safety concerns and will create

serious confusion due to lack of correlation with other applicable

NEC requirements. Type USE-2 is not sunlight resistant unless it

bears the appropriate markings. The UL 854 standard shows that

USE-2 typically is tested with a 300 hour exposure test rather than

the 720 hour test that results in the Sunlight Resistant rating. I

have included the information for Sunlight Resistant testing from

UL 854 for your review. 30 Sunlight-Resistance Tests 30.1 The

outer surface of finished Type SE cables, jacketed multiple-

conductor Type USE and USE-2 cables, and single conductor Type

USE and USE-2 that are surface marked (see 40.7) for sunlight-

resistant use shall comply with the Carbon-Arc and Xenon-Arc

Tests, Section 1200 of UL 1581, after conditioning for 720 h of

carbon-arc or xenon-arc exposure. 30.3 With the exception that

any overall covering from a submersible-pump cable is not to be

tested, any overall covering and the individuals from all cables

that are not marked for sunlight-resistant use or for sunlight-

resistant use in cable trays shall comply with the following

sunlight-resistance requirements (see marking 40.8). The ratio of

the average tensile strength and ultimate elongation of five

conditioned (300 h) specimens of the individual thermoset jacket

or unjacketed insulation or the individual nylon or similar jacket

and PVC insulation of a Type THHN or THWN conductor and either

any overall thermoset jacket or the PVC finish to the average

tensile strength and ultimate elongation of five unconditioned

specimens of the same individual jacket or insulation and overall

jacket or PVC finish shall be 0.85 or more (see 30.4) when the Ward I. Bower This panel member believes the sunlight resistant label should be

included.

Negative 1

Roger D. McDaniel Type USE-2 is suitable for use where exposed to sunlight, however

the cable is not suitable inside the premises nor above ground

other than to terminate at service or metering equipment.

Abstain 0

Eligible to Vote: 17

Not Returned : 0

Vote Selection Votes Comments

Affirmative 17

Affirmative with Comment 0

SR-956, Section No. 690.31(D), See SR-956

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Negative 0

Abstain 0

Eligible to Vote: 17

Not Returned : 0

Vote Selection Votes Comments

Affirmative 15

Affirmative with Comment 1

Wendell R. Whistler In some cases these cables may need to be evaluated for use in

ambient conditions outside or normal testing requirements where

they are installed in conditions below -25 C. I have included an

excerpt for the UL Standard for flexible cable. 5.1.6 Cold bend – all

types The insulation (including any nylon or other covering) and

jacket (if applicable) shall show no cracks when a specimen of the

finished cord or cable is conditioned at the temperature specified

in Table 42 for 4 h and, while still at the specified temperature,

wound the required number of turns around the mandrel having a

diameter as specified in Table 43. Compliance shall be determined

in accordance with the test, Cold Bend, in CAN/CSA-C22.2 No.

2556, UL 2556, or NMX-J-193-ANCE. 5.1.7 Weather resistance – all

Ç WÇ cords and electric vehicle cables After conditioning for 720 h

in a xenon arc weatherometer as described in the test, Weather

(sunlight) resistant, in CAN/CSA-C22.2 No. 2556, UL 2556, or NMX-

J-553-ANCE, the insulation on a specimen of the individual

conductor of Types CXWTc and CXTWu and on finished Types

PXWTc , SPT-1Wc,u , SPT- 2Wc,u , and XTWu and the jacket of

other Type Ç WÇ cords shall: (a) Show no cracks when wound one

complete turn around a mandrel having a diameter as shown in

Table 43 while at a temperature of –30°C ± 1°C for a period of 1 h.

During the bending, the conditioned surface shall be opposite the

surface contacting the mandrel. The specimen shall be allowed to

rest 16 h to 96 h at room temperature before conducting the

coldbend test. (b) Retain an average tensile strength and

elongation of not less than 80%. Conditioned and un-aged sets

(five specimens each) shall be allowed to rest 16 h to 96 h at room

temperature, followed by physical properties testing. Conditioned

surfaces required to be die cut shall not be buffed or skived away.Negative 1

SR-957, Section No. 690.31(E), See SR-957

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Malcolm Allison SR 957 is proposing to use PV wire on moving parts of tracking PV

modules where jacketed flexible cord, suitable for extra hard

usage, is presently permitted for use. However, PV wire is a single

conductor and flexible cord is a jacketed multi-conductor cable.

Considering that the jacket provides additional mechanical, flame

and chemical resistance, why use a single conductor wire? In an

attempt to ensure that PV wire is flexible enough for this

application Table 690.31(E) was created to include a required

minimum number of strands. However, the minimum number of

strands listed in the table is fewer than is required for a flexible

cord. As an example, the minimum number of strands permitted

by the UL standard for 4 AWG cord is 133 not 49 as listed in the

table. ASTM B 173 lists 427 as the least number of strands for a

rope-lay 1000 MCM, which is much more than 130 listed in the

table. How was it determined that the minimum number of

strands listed in the table is sufficient to handle this flexible

application? Base on this, section 690.31(E) should not be revised

as proposed.

Abstain 0

Eligible to Vote: 17

Not Returned : 0

Vote Selection Votes Comments

Affirmative 17

Affirmative with Comment 0

Negative 0

Abstain 0

Eligible to Vote: 17

Not Returned : 0

Vote Selection Votes Comments

Affirmative 17

Affirmative with Comment 0

Negative 0

Abstain 0

Eligible to Vote: 17

Not Returned : 0

Vote Selection Votes Comments

Affirmative 17

SR-962, Section No. 690.31(G)(4), See SR-962

SR-961, Section No. 690.31(G)(3), See SR-961

SR-959, Section No. 690.31(G) [Excluding any Sub-Sections], See SR-959

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Affirmative with Comment 0

Negative 0

Abstain 0

Eligible to Vote: 17

Not Returned : 0

Vote Selection Votes Comments

Affirmative 17

Affirmative with Comment 0

Negative 0

Abstain 0

Eligible to Vote: 17

Not Returned : 0

Vote Selection Votes Comments

Affirmative 17

Affirmative with Comment 0

Negative 0

Abstain 0

Eligible to Vote: 17

Not Returned : 0

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Affirmative 17

Affirmative with Comment 0

Negative 0

Abstain 0

Eligible to Vote: 17

Not Returned : 0

Vote Selection Votes Comments

Affirmative 16

Affirmative with Comment 1

SR-966, Sections 690.41(A), 690.41(B), See SR-966

SR-965, Section No. 690.33(C), See SR-965

SR-964, Section No. 690.33 [Excluding any Sub-Sections], See SR-964

SR-963, Section No. 690.31(J), See SR-963

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Ward I. Bower This panel member ballots affirmative on the SR but feels the use

of the functional grounding terminology is dependent upon the

term being accepted and better defined for use in Article 690.

Better yet would be an opportunity for public review and

comments since other definitions and uses are already

established. This panel member ballots affirmative with a

comment. The "ground reference" used in 690.41(B)(2)(2) is not a

clear statement. What is the ground reference in this situation.

Earlier ground reference was referred to as the center tap of a

transformer. This panel member believes the ground reference

referred to here is the system ground in a functional grounded

system but is unclear if that connection is on the earth side or the

system side.

Negative 0

Abstain 0

Eligible to Vote: 17

Not Returned : 0

Vote Selection Votes Comments

Affirmative 17

Affirmative with Comment 0

Negative 0

Abstain 0

Eligible to Vote: 17

Not Returned : 0

Vote Selection Votes Comments

Affirmative 16

Affirmative with Comment 1

Wendell R. Whistler By not requiring the size of the equipment grounding conductor to

be increased to for voltage drop as required in 250.122 the fault

return path may not have a sufficiently low impedance to allow

for tripping of the overcurrent protective device

SR-968, Section No. 690.45, See SR-968

0

SR-967, Section No. 690.42, See SR-967

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Negative 0

Abstain 0

Eligible to Vote: 17

Not Returned : 0

Vote Selection Votes Comments

Affirmative 16

Affirmative with Comment 1

Robert H. Wills The use of the word "may" in the informational note to 690.47 (A)

could be considered permissive language.

Negative 0

Abstain 0

Eligible to Vote: 17

Not Returned : 0

Vote Selection Votes Comments

Affirmative 17

Affirmative with Comment 0

Negative 0

Abstain 0

Eligible to Vote: 17

Not Returned : 0

Vote Selection Votes Comments

Affirmative 17

Affirmative with Comment 0

Negative 0

Abstain 0

Eligible to Vote: 17

Not Returned : 0

Vote Selection Votes Comments

Affirmative 14

Affirmative with Comment 3

SR-1003, Section No. 690.56(C), See SR-1003

SR-971, Section No. 690.55, See SR-971

SR-970, Section No. 690.53, See SR-970

SR-969, Section No. 690.47(A), See SR-969

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Wendell R. Whistler I respectfully request that the Correlating committee review the

placards in Figures 690.56(C)(1)(a) and 690.56(C)(1)(b). The

following issue creates serious safety concerns and will create

serious confusion due to lack of correlation with other applicable

NEC requirements. These placards direct the user to turn the

switch to the "OFF" position to shut down the PV system. This

appears that it could provide a false sense to the individual that

the PV system is in an Electrically Safe condition when this is NOT

the case. I would like to suggest that an additional statement be

added that the conductors of the PV system are still "Energized"

on the output terminals of the PV array.

Ward I. Bower Affirmative but dependent on the possibility that 690.12(B)(2)(b)

may not be included in the 2017 NEC.

Bill F. Brooks The last sentence of the SR did not make it into TerraView when

the text was moved from the Word document to TerraView. That

last sentence reads, "The label shall be reflective, with all letters

capitalized and having a minimum height of 9.5 mm (3/8 in.), in

white on red background." While this sentence does not alter the

requirement for a label, it does provide needed parameters for

the label that were deemed important by CMP4. This panel

member requests that the correlating committee fix this clerical

error.

Negative 0

Abstain 0

Eligible to Vote: 17

Not Returned : 0

Vote Selection Votes Comments

Affirmative 17

Affirmative with Comment 0

Negative 0

Abstain 0

Eligible to Vote: 17

Not Returned : 0

SR-973, Section No. 690.72, See SR-973

SR-972, Sections 690.57, 690.60, 690.61, 690.63, 690.64, See SR-972

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Vote Selection Votes Comments

Affirmative 16

Affirmative with Comment 1

Ward I. Bower This change is referring to 706.23 and must be correlated with the

final Article 706

Negative 0

Abstain 0

Eligible to Vote: 17

Not Returned : 0

Vote Selection Votes Comments

Affirmative 17

Affirmative with Comment 0

Negative 0

Abstain 0

Eligible to Vote: 14

Not Returned : 0

Vote Selection Votes Comments

Affirmative 11

Affirmative with Comment 2

Wendell R. Whistler I would like to suggest that the term " Independent Power

Producer " be included in the Scope of Article 691 for the purpose

of clarifying to whom this new Article applies to as in many cases

the developers of these facilities try to excluded themselves by

claiming they are a utility when in fact they are an independent

power producer that is connecting to a regulated utility

SR-975, Section No. 691.1, See SR-975

SR-974, Section No. 690.74, See SR-974

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Roger D. McDaniel Statement: There are several terms used in this article 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

found in Article 705. It is common for 2000kW large Solar PV

Systems to be interconnected to primary voltage utility systems.

Negative 1

James G. Cialdea Article – 691 Large Scale Photovoltaic (PV) Electric Supply Stations

is a new article for 2017. The Scope for 691 (691.1) describes a

generating station. Generating stations are not covered by the

NEC. In fact, 90.1 states that “The purpose of this Code is the

practical safeguarding of persons and property from hazards

arising from the use of electricity.” A generating station creates

electricity. 90.2(B)(5)b states "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 from the first revision justifying the addition of the

article states that "...power plants... were not historically

contemplated by the NEC and UL." This is a 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 Abstain 0

Eligible to Vote: 14

Not Returned : 0

SR-976, Definition: Engineering Supervision., See SR-976

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Vote Selection Votes Comments

Affirmative 14

Affirmative with Comment 0

Negative 0

Eligible to Vote: 14

Not Returned : 0

Vote Selection Votes Comments

Affirmative 14

Affirmative with Comment 0

Negative 0

Abstain 0

Eligible to Vote: 14+A791

Not Returned : 0

Vote Selection Votes Comments

Affirmative 14

Affirmative with Comment 0

Negative 0

Abstain 0

Eligible to Vote: 14

Not Returned : 0

Vote Selection Votes Comments

Affirmative 14

Affirmative with Comment 0

Negative 0

Abstain 0

SR-979, Definition: Utility Distribution System., See SR-979

SR-978, Definition: Generating Capacity., See SR-978

SR-977, Definition: Field Labeled (as applied to evaluated products..., See SR-977

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Eligible to Vote: 14

Not Returned : 0

Vote Selection Votes Comments

Affirmative 11

Affirmative with Comment 2

Stephen P. Wurmlinger 691.4(1) Should state Electrical circuits and equipment "are"

maintained and operated only by qualified personnel.

Roger D. McDaniel Statement: There are several terms used in this article 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

found in Article 705.

Negative 1

James G. Cialdea See comment SR-975

Abstain 0

Eligible to Vote: 14

Not Returned : 0

Vote Selection Votes Comments

Affirmative 12

Affirmative with Comment 1

Roger D. McDaniel Statement: There are several terms used in this article 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

found in Article 705.

Negative 1

James G. Cialdea See comment SR-975

Abstain 0

0

SR-981, Section No. 691.6, See SR-981

SR-980, Section No. 691.4, See SR-980

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Eligible to Vote: 14

Not Returned : 0

Vote Selection Votes Comments

Affirmative 11

Affirmative with Comment 2

Stephen P. Wurmlinger The reference to complying with the code in this section

incorrectly implies that all sections of the code are applicable. The

purpose of 691 is to clarify that all requirements in 690 do not

apply to large scale PV systems. The statement that "Additional

stamped independent engineering reports detailing the

construction conforms with this Code, applicable standards and

industry practice...." should be changed to: "Additional stamped

independent engineering reports detailing the construction

conforms with sections of the Code referenced by this article,

applicable standards and industry practice...."

Roger D. McDaniel Statement: There are several terms used in this article 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

found in Article 705.

Negative 1

James G. Cialdea See comment SR-975

Abstain 0

Eligible to Vote: 14

Not Returned : 0

Vote Selection Votes Comments

Affirmative 12

Affirmative with Comment 1

SR-983, Section No. 691.8, See SR-983

SR-982, Section No. 691.7, See SR-982

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Roger D. McDaniel Statement: There are several terms used in this article 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

found in Article 705.

Negative 1

James G. Cialdea See comment SR-975

Eligible to Vote: 14+A835

Not Returned : 0

Vote Selection Votes Comments

Affirmative 13

Affirmative with Comment 0

Negative 1

James G. Cialdea See comment SR-975

Abstain 0

Eligible to Vote: 14

Not Returned : 0

Vote Selection Votes Comments

Affirmative 12+A88

1

Affirmative with Comment 1

Wendell R. Whistler Informational note referencing IEEE-80 for fence grounding might

be helpful

Negative 1

James G. Cialdea See comment SR-975

Abstain 0

Eligible to Vote: 16

Not Returned : 0

SR-919, Section No. 692.1, See SR-919

SR-985, Section No. 691.11, See SR-985

0

SR-984, Section No. 691.10, See SR-984

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Vote Selection Votes Comments

Affirmative 16

Affirmative with Comment 0

Negative 0

Abstain 0

Eligible to Vote: 16

Not Returned : 0

Vote Selection Votes Comments

Affirmative 16

Affirmative with Comment 0

Negative 0

Abstain 0

Eligible to Vote: 15

Not Returned : 0

Vote Selection Votes Comments

Affirmative 16

Affirmative with Comment 0

Negative 0

Abstain 0

Eligible to Vote: 15+A927

Not Returned : 0

Vote Selection Votes Comments

Affirmative 15

Affirmative with Comment 0

Negative 0

Abstain 0

SR-923, Definition: Guy., See SR-923

SR-922, Section No. 694.1, See SR-922

0

SR-920, Section No. 692.6, See SR-920

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Eligible to Vote: 15

Not Returned : 0

Vote Selection Votes Comments

Affirmative 15

Affirmative with Comment 0

Negative 0

Abstain 0

Eligible to Vote: 15

Not Returned : 0

Vote Selection Votes Comments

Affirmative 15

Affirmative with Comment 0

Negative 0

Abstain 0

Eligible to Vote: 15

Not Returned : 0

Vote Selection Votes Comments

Affirmative 15

Affirmative with Comment 0

Negative 0

Abstain 0

Eligible to Vote: 15

Not Returned : 0

Vote Selection Votes Comments

Affirmative 14

Affirmative with Comment 0

Negative 1

SR-921, New Section after 694.7(F), See SR-921

SR-926, Section No. 694.7(F), See SR-926

SR-925, Section No. 694.7(B), See SR-925

SR-924, Definition: Tower., See SR-924

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Wendell R. Whistler This change in working clearances is not in the best interest of

worker safety. When the voltage was changed to up to 1000 volts

the distances for working clearance increased. This change allows

the voltage to increase however it keeps the working clearances

at the 600 volt level in direct conflict with the requirements

Article 110

Abstain 0

Eligible to Vote: 15

Not Returned : 0

Vote Selection Votes Comments

Affirmative 15

Affirmative with Comment 0

Negative 0

Abstain 0

Eligible to Vote: 15

Not Returned : 0

Vote Selection Votes Comments

Affirmative 14

Affirmative with Comment 0

Negative 1

SR-988, Definition: Intentionally Islanded System., See SR-988

SR-927, Section No. 694.15(C), See SR-927

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Roger D. McDaniel I disagree with using the term “microgrid” in the title of the

definition and the changes made to the text of the definition. I

disagree with the deletion of the text of the informational note,

but I am in agreement with the additional new second sentence of

the Information Note. The term “Microgrid” is a jargon and non-

specific term. The NEC consistently encourages using terminology

that provides clarity. The term “Intentionally Islanded System”

provides this clarity. To ensure that we maintain fundamental

separation between utility wiring and premises wiring, we need to

use terminology that provides clear separation between the two

systems (NEC and NESC). The electric utility type microgrid

systems are still in the R&D phase and still being discussed in

standards committees that are outside of the NFPA. Therefore, as

this technology continues to emerge, we need to ensure that the

lines do not become blurred between the two systems. We are

mixing two different systems; therefore keeping different terms in

the NEC will best serve the industry. Using the term Intentionally

Islanded System is consistent with the current IEEE 1547 Series of

standards, recommended practices and guides with are currently

published. The addition of the new second sentence to the

information note expresses the differences between the utility

systems and the premises wiring systems.

Abstain 0

Eligible to Vote: 17

Not Returned : 0

Vote Selection Votes Comments

Affirmative 16

Affirmative with Comment 0

Negative 1

SR-989, Definition: Island Interconnection Device (IID)., See SR-989

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Roger D. McDaniel I disagree with using the term “microgrid” in the title of the

definition and the changes made to the text of the definition. The

definition is correct as it appears in the First Revision. The term

“Microgrid” is a jargon and non-specific term. The NEC

consistently encourages using terminology that provides clarity.

The term “Island Interconnection Device (IID)” provides this

clarity. To ensure that we maintain fundamental separation

between utility wiring and premises wiring, we need to use

terminology that provides clear separation between the two

systems (NEC and NESC). The electric utility type microgrid

systems are still in the R&D phase and still being discussed in

standards committees that are outside of the NFPA. Therefore, as

this technology continues to emerge, we need to ensure that the

lines do not become blurred between the two systems. We are

mixing two different systems; therefore keeping different terms in

the NEC will best serve the industry. Using the term Intentionally

Islanded System is consistent with the current IEEE 1547 Series of

standards, recommended practices and guides with are currently

published.

Abstain 0

Eligible to Vote: 17

Not Returned : 0

Vote Selection Votes Comments

Affirmative 17

Affirmative with Comment 0

Negative 0

Abstain 0

Eligible to Vote: 17

Not Returned : 0

Vote Selection Votes Comments

Affirmative 17

SR-991, Definition: Stand-Alone System., See SR-991

SR-990, Definition: Multimode Inverter., See SR-990

0

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Affirmative with Comment 0

Negative 0

Abstain 0

Eligible to Vote: 17

Not Returned : 0

Vote Selection Votes Comments

Affirmative 17

Affirmative with Comment 0

Negative 0

Abstain 0

Eligible to Vote: 17

Not Returned : 0

Vote Selection Votes Comments

Affirmative 16

Affirmative with Comment 1

Ward I. Bower This panel member believes the following for use of

"interconnection service" would be better understood if the use

of "interconnected service" were to be used.

Negative 0

Eligible to Vote: 17

Not Returned : 0

Vote Selection Votes Comments

Affirmative 17

Affirmative with Comment 0

Negative 0

Abstain 0

Eligible to Vote: 17

Not Returned : 0

Vote Selection Votes Comments

Affirmative 16

Affirmative with Comment 0

Negative 1

SR-996, Section No. 705.12 [Excluding any Sub-Sections], See SR-996

SR-994, Section No. 705.8, See SR-994

SR-993, Section No. 705.6, See SR-993

SR-992, Section No. 705.3, See SR-992

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Roger D. McDaniel Provisions for Integrated Electrical Systems and for large

interconnections greater than 100 kW are necessary to keep

Article 705 consistent with the requirements of the IEEE 1547

family of standards, recommended practices and guides.

Abstain 0

Eligible to Vote: 17

Not Returned : 0

Vote Selection Votes Comments

Affirmative 16

Affirmative with Comment 0

Negative 1

Roger D. McDaniel Provisions for Integrated Electrical Systems and for large

interconnections greater than 100 kW are necessary to keep

Article 705 consistent with the requirements of the IEEE 1547

family of standards, recommended practices and guides.

Abstain 0

Eligible to Vote: 17

Not Returned : 0

Vote Selection Votes Comments

Affirmative 12

Affirmative with Comment 1

Ward I. Bower The definition for Engineering supervision has been deleted. A

suggested alternative sentence in 705.12(D)(3) is "...where

designed by a licensed electrical professional engineer with

documentation that includes..."

Negative 4

Malcolm Allison It is not clear whether or not the warnings are put on in the field

or by the OEM. Such labels should be field installed.

SR-997, Section No. 705.12(D), See SR-997

SR-995, Sections 705.12(B), 705.12(C), See SR-995

0

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Wendell R. Whistler 705.12 d This change is allowing a connection at either end of the

center fed panel. It would appear that this connection should only

be made at the bottom of the panel. Thermal energy rises and

testing appears to show a thermal increase towards the top of the

busbar. Changes in 705.12 e do NOT appear to be documented in

the committee statement and the term "engineering supervision"

is not defined. This term was deleted in Article 690 and 691.

Busbar calculations should be done only by properly trained

individuals as this is a critical component in these installations.

Perhaps a "Qualified person or Registered Professional Electrical

engineer would be more appropriate terminology

Timothy P. Zgonena There is no technical justification for allowing the bus in a center

fed panelboard to operate at 120% of its rating. The proposed

allowance could cause the panelboard to operate at temperatures

exceeding the maximum allowable temperatures in UL 67.

Roger D. McDaniel Provisions for Integrated Electrical Systems and for large

interconnections greater than 100 kW are necessary to keep

Article 705 consistent with the requirements of the IEEE 1547

family of standards, recommended practices and guides. Revisions

to the technical requirements 705.12(D) relax the needed safety

requirements for conductors and panel boards against overload

and relaxes the requirement for higher short circuit current back

fed breakers to have the additional fastening means.

Abstain 0

Eligible to Vote: 17

Not Returned : 0

Vote Selection Votes Comments

Affirmative 16

Affirmative with Comment 1

Ward I. Bower The sentence using manually is grammatically more correct than

the change to manual. If manual is used then the term operable

should be changed to operated.

Negative 0

Abstain 0

Eligible to Vote: 17

SR-999, Section No. 705.23, See SR-999

SR-998, Section No. 705.22, See SR-998

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Not Returned : 0

Vote Selection Votes Comments

Affirmative 17

Affirmative with Comment 0

Negative 0

Abstain 0

Eligible to Vote: 17

Not Returned : 0

Vote Selection Votes Comments

Affirmative 15

Affirmative with Comment 1

Ward I. Bower The committee statement does not appear to match the changes

made.

Negative 1

James J. Rogers This language is unnecessary and confusing. 705.60 already

defines the ampacity and over-current protection for an inverter

output circuit no matter where it terminates. The reference to

240.21(B) makes no sense as there 5 different options to choose

from and they are all based on the fact that the feeder over-

current device is providing the protection for the tap conductors.

In this instance the over-current protection for these conductors

is either built into the inverter or adjacent to it. Perhaps in the

next code cycle 705.30 should be enhanced to better define

where the over-current protection is required to be located but

this language would be difficult to interpret and enforce.

Abstain 0

Eligible to Vote: 17

Not Returned : 0

Vote Selection Votes Comments

Affirmative 14

Affirmative with Comment 2

SR-1000, Sections 705.150, 705.155, 705.160, 705.165, 705.170, See SR-1000

SR-1001, New Section after 705.65(B), See SR-1001

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Wendell R. Whistler The term "Microgrid" being introduced into the 2017 NEC is also

used by "Regulated Utilities" as has a very different meaning

which may lead to confusion. This may lead to the "Regulated

Utilities" being named in litigation for which they have no

responsibility

Ward I. Bower This panel member suggests that "microgrid controller" be added

to the list since the controller and the MID could be different

hardware or devices.

Negative 1

Roger D. McDaniel I disagree with using the term “microgrid” in these sections. I also

disagree with the addition of the new Informational Note. The

text of these sections should revert back to the text of the First

Revision. The term “Microgrid” is a jargon and non-specific term.

The NEC consistently encourages using terminology that provides

clarity. The terms in these sections provide this clarity. To ensure

that we maintain fundamental separation between utility wiring

and premises wiring, we need to use terminology that provides

clear separation between the two systems (NEC and NESC). The

electric utility type microgrid systems are still in the R&D phase

and still being discussed in standards committees that are outside

of the NFPA. Therefore, as this technology continues to emerge,

we need to ensure that the lines do not become blurred between

the two systems. We are mixing two different systems; therefore

keeping different terms in the NEC will best serve the industry.

Using the term Intentionally Islanded System, Island

Interconnection Device (IID) and Stand-alone system are

consistent with the current IEEE 1547 Series of standards,

recommended practices and guides with are currently published. I

am opposed to the addition of the Informational Note as the

functionality as described does not exist nor does this particular

equipment exist using the term MID.

Abstain 0

Eligible to Vote: 17

Not Returned : 0

SR-987, Section No. 705.175, See SR-987

0

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Vote Selection Votes Comments

Affirmative 15

Affirmative with Comment 1

Robert H. Wills This new Article extends the safety requirements for stand-alone

systems that have been in 690 for many cycles to all power

sources. It is an important addition to the Code. Stand-alone

systems will become more prevalent due to emerging technology

in energy storage and local generation.

Negative 1

Roger D. McDaniel This new proposed Article is new material and has not had the

public review as a separate Article. It should be held until the

2020 edition of the NEC. Further, Stand-Alone systems are

currently covered elsewhere in the NEC and I do agree with the

removal of these sections on Stand-Alone systems from Article

705.

Abstain 0

0

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