70 a2016 nec-p04 sd ballotcircmemo - nfpa€¦ · the january 15, 2016 date for receipt of the nec...
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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.
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Eligible to Vote: 14
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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
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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.
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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
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SR-918, Definition: Field Labeled (as applied to evaluated products..., See SR-918
SR-960, Detail, See SR-960
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Affirmative 13
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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
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
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Affirmative 14
SR-904, Section No. 225.38(C), See SR-904
SR-903, Section No. 225.32, See SR-903
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Affirmative with Comment 0
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Affirmative 16
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Affirmative 14+B13
8
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Affirmative 14
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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
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
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Affirmative 13
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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.
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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
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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
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
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
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
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
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Affirmative 16
Affirmative with Comment 0
SR-914, Section No. 230.71(A), See SR-914
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Negative 0
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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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Affirmative 17
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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
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Affirmative 17
Affirmative with Comment 0
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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
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
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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
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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
Negative 0
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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
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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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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
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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
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
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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
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.
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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
Page 18 of 51
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.
Page 19 of 51
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
Page 20 of 51
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.
Page 21 of 51
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
Page 22 of 51
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
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Affirmative 17
Affirmative with Comment 0
Negative 0
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Affirmative 17
SR-947, Section No. 690.13(B), See SR-947
SR-946, Section No. 690.13(A), See SR-946
Page 23 of 51
Affirmative with Comment 0
Negative 0
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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
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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
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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
Page 24 of 51
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.
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Affirmative 17
Affirmative with Comment 0
Negative 0
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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
Page 25 of 51
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
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Affirmative 16
Affirmative with Comment 1
SR-952, Section No. 690.15(D), See SR-952
Page 26 of 51
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
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Affirmative 17
Affirmative with Comment 0
Negative 0
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Affirmative 17
Affirmative with Comment 0
Negative 0
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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
Page 27 of 51
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
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Affirmative 17
Affirmative with Comment 0
SR-956, Section No. 690.31(D), See SR-956
Page 28 of 51
Negative 0
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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
Page 29 of 51
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
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Affirmative 17
Affirmative with Comment 0
Negative 0
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Affirmative 17
Affirmative with Comment 0
Negative 0
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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
Page 30 of 51
Affirmative with Comment 0
Negative 0
Abstain 0
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Affirmative 17
Affirmative with Comment 0
Negative 0
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Affirmative 17
Affirmative with Comment 0
Negative 0
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Affirmative 17
Affirmative with Comment 0
Negative 0
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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
Page 31 of 51
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
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Affirmative 17
Affirmative with Comment 0
Negative 0
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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
Page 32 of 51
Negative 0
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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
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Affirmative 17
Affirmative with Comment 0
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Affirmative 17
Affirmative with Comment 0
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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
Page 33 of 51
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
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Affirmative 17
Affirmative with Comment 0
Negative 0
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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
Page 34 of 51
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
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Affirmative 17
Affirmative with Comment 0
Negative 0
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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
Page 35 of 51
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
Page 36 of 51
Vote Selection Votes Comments
Affirmative 14
Affirmative with Comment 0
Negative 0
Eligible to Vote: 14
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Affirmative 14
Affirmative with Comment 0
Negative 0
Abstain 0
Eligible to Vote: 14+A791
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Affirmative 14
Affirmative with Comment 0
Negative 0
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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
Page 37 of 51
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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
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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
Page 38 of 51
Eligible to Vote: 14
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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
Page 39 of 51
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
Page 40 of 51
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
Page 41 of 51
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
Page 42 of 51
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
Page 43 of 51
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
Page 44 of 51
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
Page 45 of 51
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
Page 46 of 51
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
Page 47 of 51
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
Page 48 of 51
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
Page 49 of 51
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
Page 50 of 51
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
Page 51 of 51