I would like to suggest that interested WRENCHES form their own "subcommittee" so that we can have an somewhat organized approach to this issue.  I do know Fronius has been working on this, and we should seek them out.  I will volunteer to help organize the subcommittee.  I have done similar work on other issues.  I think this will have to be done by email so I will set up a process if there is interest.  Chris

On 8/30/2021 2:40 PM, Brian Mehalic wrote:
The process is very regimented. Here's a link with the details: https://www.nfpa.org/Codes-and-Standards/Standards-Development/How-the-process-works <https://www.nfpa.org/Codes-and-Standards/Standards-Development/How-the-process-works>

A few things to note:

All submitted public inputs (PIs) are addressed by the relevant Code Making Panel (CMP); the NFPA has transitioned so that all this documentation is online (there used to be a PDF) - it can be viewed on the "Next Edition" tab of NFPA 70 here: https://www.nfpa.org/codes-and-standards/all-codes-and-standards/list-of-codes-and-standards/detail?code=70&tab=nextedition <https://www.nfpa.org/codes-and-standards/all-codes-and-standards/list-of-codes-and-standards/detail?code=70&tab=nextedition>

The first draft of 2023, based on all the PIs submitted, came out on 6/28/21; comments on that document were due about 12 days ago, and the second draft meeting is scheduled for late October. The product of that meeting, which will post in March 2022, will be, for the most part, the 2023 NEC.

Sooo, it is going to be tough to "repeal" or get rid of RS based on the current state of things. There is the NITMAM process (ugh, so many acronyms), which you can read about here https://www.nfpa.org/techsession <https://www.nfpa.org/techsession> and which I'm not very familiar with.

Please keep in mind that CMP-4 (which I am a voting-alternate on, and which has jurisdiction over 690, 705, 710, and a few other Articles) is composed of a wide range of folks, from the enforcement (AHJ) community, the IBEW, various manufacturing trade organizations, utility organizations, the fire fighting/first responder community, and solar-specific organizations. Folks have widely varying degrees of interest in – and experience with – PV, but they all bring technical expertise from across the electrical industry. You may be surprised to hear it, but requirements in regards to RS could have been a lot more stringent, a lot more quickly, without key representation from the panel members that are most dedicated to the solar industry. Furthermore this is a consensus process, and is often the case rarely does anyone get exactly what they want.

Many of these same folks have been very active participants in the PV Industry Forum, sponsored by SEIA, and comprised of something like 60-80 industry stakeholders that work together to craft and submit consensus Public Inputs for the first draft. In this latest cycle we submitted dozens of PIs, and the vast majority of them were accepted and became part of the first draft. This process is key to jump-starting the new Code cycle - without a Public Input to address, the code-making panel cannot "touch" a section of the code. And of course there are plenty of PIs from individuals and other organizations that are addressed by the panel.

Cheers,

Brian Mehalic
NABCEP Certified Solar PV Installation Professional™ R031508-59
National Electrical Code® CMP-4 Member
(520) 204-6639

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

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



On Sun, Aug 29, 2021 at 5:28 AM Christopher Warfel <cwar...@entech-engineering.com <mailto:cwar...@entech-engineering.com>> wrote:

    Brian, I think you serve on a CMP.  (if not, anyone with knowledge
    on the process would be helpful.) What is the process for
    receiving and acknowledging input from non CMP members?  Every
    time I submitted comment, I received no response (as far as I can
    remember). Thank you, Chris

    On 8/28/2021 11:09 AM, Brian Mehalic wrote:
    Movement? Maybe, but as far as I can tell it’s just a forum to
    complain as I see no activity that could actually impact the NEC®
    via the clearly defined and delineated process. Also there are a
    few flat-out false claims on the site, along with a call to
    action to fix module level shutdown by…having module level
    shutdown in the junction box? Most of the complaints seem to come
    down to connector standardization (which obviously was not the
    issue with the APS meltdown that started this thread).

    Brian

    On Aug 28, 2021, at 7:07 AM,
    drake.chamber...@redwoodalliance.org
    <mailto:drake.chamber...@redwoodalliance.org> wrote:

    

    There is a movement to do away with module level shutdown.

    
https://www.fixmlsd.com/?utm_campaign=solarbuilder_comment&utm_medium=email&utm_source=fixmlsd
    
<https://www.fixmlsd.com/?utm_campaign=solarbuilder_comment&utm_medium=email&utm_source=fixmlsd>

    FixMLSD has convincing arguments that MLSD is less safe than
    safe than an arc fault protective device with a standard string
    configuration. Given the many problems with MLSD devices, it
    seems likely that this is true.

    Drake


    Drake Chamberlin

    Athens Electric LLC

    Ohio Electrical Contractor’s License 44810

    CO Master Electrician’s License 4526

    NABCEP Certified PV Installation Professional


    ---


    On 2021-08-27 09:02, Tump wrote:

    I would once again say that; we as an industry can influence
    not only the writing of the code but with what we are /buying/
    OR /not buying./
    If the devices we are required to install to make things "more
    safe & reliable", at the cost of our livelihoods & reputations,
    we all need to make the folks that are building the RSD crap
    and those who require installation of questionably safe &
    reliable crap aware of these problems.
    WE can thru either going to the code development  meetings AND
    NOT buying or installing this stuff. Not too easy when a huge
    amount of solar is rooftop installs. As many of the installers
    in the NE know its not a single level ranch were installing
    this stuff on, short season & man lift required.
    Tell your supplier why you are not buying that brand, let  your
    supplier & folks on the list what manufacture has good reliable
    products AND tech support that we can understand, who we can
    get in a timely fashion, and get the satisfaction of a prompt
    replacement.  IF we don't sell it they won't have a job or a
    market.
    On Aug 26, 2021, at 2:09 PM, Jeremy Coxon
    <jco...@sunwindpowerinc.com
    <mailto:jco...@sunwindpowerinc.com>> wrote:

    Carl,
    Did you get any kind of joy out of APSmart on that failure?
    I will say that their tech support guy did at least try to be
    helpful, but the language barrier was really really steep and
    their distribution channels are less than ideal.  Their
    response to a request for compensation was that they would not
    be profitable if they had to pay for truck rolls for such a
    low cost item.  I really don't think they GET IT. We've been
    in business for over 16yrs and this one failure could easily
    have ended that run.
    I cannot imagine we're alone here.  I was told by AP that
    their failure rate was 0.2%. Now, I come from a reliability
    engineering background in petro chemical/ big pharma where a
    0.2% failure rate would be catastrophic.  Can you imagine that
    2 out of every 1000 pills made could cause death?  We
    engineered secondary systems and multiple quality checks to
    contain catastrophic consequences for components that had know
    failure rates higher than acceptable values.  A simple
    solution to this fire initiation issue would be a metal
    enclosure instead of plastic casing.  That still doesn't
    really solve the problem of extra connections though.

    Best Regards,
    Jeremy Coxon NABCEP # 091308-21
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