Hi Rebekah;

Thanks for pointing out the changes to the diagrams.  I especially appreciate Note (2). /The PV system disconnect in these diagrams separates the PV system from all other systems./

That seems simple enough for defining the boundaries of RSS, until you think about off grid, and look at the last diagram of 690.1(b) titled "Stand Alone System".  The charge controller is not shown at all.  Then Figure 690.1(a) shows a /DC to DC Converter (optional location)/, shows a fuse after, shows the power going with an arrow to no where, on a line labeled /PV or DC to DC converter output circuit...../ But finally, the cause of my greatest confusion: it does not show the *PV System Disconnect* anywhere.

I have several questions:
Is a charge controller a *DC to DC converter*?  What about non MPPT controllers that don't convert voltage? Is a charge controller considered *DC* *utilization Equipment* mentioned in the definition of *PV Output Circuit*, or is the inverter and DC loads the utilization equipment? All of which leads to the $20 thousand dollar question: Is the *PV System Disconnect* before or after the charge controller? If before the charge controller, where can the PV Disconnect be? Could it be outside, at the pole, or does it need to be within 3 ft of the building entry?

Even with all the changes made in 2017, it seems that we still are left with too much uncertainty about where a PV circuit ends, or what constitutes the "PV Disconnect" in an off grid system.  Not such a big deal, until we are required to apply 690.12.

Thanks everyone for your answers and opinions,

Ray Walters
Design Engineer
Remote Solar

On 4/17/18 7:15 AM, Rebekah Hren wrote:
Hi everyone,

I strongly recommend looking at the figures that were added in NEC 2017 at the beginning of Article 690 in 690.1(b).

What they show is equipment that is part of the PV system (to the left of the PV system disconnect called out in the diagrams), and equipment that is not part of the PV system (to the right of the PV system disconnect). These are really helpful diagrams, in terms of figuring out where the requirements of Article 690 apply.

Equipment *not* part of the PV system is not a "PV system circuit" and thus is *not* subject to rapid shutdown requirements per 690.12.

In every type of system you will see that energy storage is *not *part of the PV system, and neither is the multimode inverter for a system with energy storage. So rapid shutdown requirements shouldn't affect any of the loads, multimode inverter, or batteries in an off-grid system.

In the 2017 NEC, the PV system disconnect, as shown on the diagrams, is required to be readily accessible per 690.13(A). For a system without batteries, the PV system disconnect is *always *an AC disconnect, not a DC disconnect. It can be the backfed breaker per 690.13(F)(1). For a system with batteries the PV system disconnect is always before the batteries.


Equipment disconnects, like the DC inverter disconnect, are not required to be readily accessible, but must be within 10 feet of the equipment, per 690.15(A).

Also note that the boundary for rapid shutdown shrank to *one foot* from the perimeter of the array in the 2017 NEC, so the inverter must be positioned within one foot of the array if there is not going to be any other RS equipment. The PV system disconnect (backfed breaker) or the service disconnect can serve as the rapid shutdown initiation device in that case.

Best,
Rebekah Hren, Member of NEC CMP-4 for Solar Energy International

--
Tel: 336.266.8800
NABCEP Certified Solar PV Installation Professional™ 091209-85
NC Licensed Electrical Contractor


On Mon, Apr 16, 2018 at 9:00 PM, Ray <r...@solarray.com <mailto:r...@solarray.com>> wrote:

    For GT using Solar edge or Enphase, its not so hard to comply, but
    If you are looking at off grid systems, it's not just someone's
    opinion, its $1,000s of dollars extra to comply with 690.12. It
    also results in a system that is less reliable, which is less safe
    off grid where lives depend on that power for heat, light,
    refrigeration, and even breathing machines.

    Ray Walters

    Remote Solar


    On 4/16/18 7:44 AM, Brian Mehalic wrote:
    Hey y'all, I'm going to disagree about the NEC getting "worse and
    worse when it comes to PV," (see disconnect and grounding
    requirements, for instance!), but as with previous posters,
    that's just an opinion.

    Regarding location - the 2014 version had very little to say
    about the location of any rapid shutdown initiation device; 2017
    adds the requirement [690.12(C)] that RS initiation devices for
    one- and two-family dwellings be readily accessible (defined in
    Article 100), AND outside the building. Seems reasonable for a
    device that is intended to control energized conductors to make
    it more safe to enter a building.

    Cheers,


    Brian Mehalic
    NABCEP Certified Solar PV Installation Professional™ R031508-59
    520.204.6639

    Solar Energy International
    http://www.solarenergy.org

    SEI Professional Services
    http://www.seisolarpros.com <http://www.seisolarpros.com>


    On Mon, Apr 16, 2018 at 12:04 AM, Mark Frye
    <ma...@berkeleysolar.com <mailto:ma...@berkeleysolar.com>> wrote:

        Thanks Darryl.

        I guess I can add that I am in CA and so looked only at the
        2014. I also looked at the 2017 article. Man, I have to say,
        my impression remains that really starting with 2008 the code
        has just gotten worse and worse when it comes to PV, but that
        is just me.

        Not really sure what might need to be "Outside readily
        accessible". Is there something other than 690.12 that I need
        to look at?

        Mark

        On 4/15/2018 8:26 PM, Darryl Thayer wrote:
        I think the code says Outside readily accessible,

        On Sun, Apr 15, 2018 at 12:22 PM, Mark Frye
        <ma...@berkeleysolar.com <mailto:ma...@berkeleysolar.com>>
        wrote:

            Folks,

            As I recall, an inverter and it's integrated DC
            disconnect need only be placed in an accessible
            location. I am thinking of putting an inverter high up
            on the wall inside a garage. That would be OK vis-a-vis
            the location of the disconnect (still accessible for
            maintenance).

            If I do put the inverter high up on the wall, I can
            limit my DC conductors to less that 10 feet total from
            the array and less that 5 feet inside the garage.

            That means I get the exemption from the rapid disconnect
            requirement, right?

            There is nothing in the Code linking the accessibility
            of the DC disconnect to the exemption from rapid
            shutdown, right?

            Mark Frye


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