Getting around 120% rule without line side tap

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GoldDigger

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To avoid the expense of installing a dedicated AC combiner panel?
Just for a two inverter system.
For inverters in separate buildings to avoid the need to run an inverter output circuit from one building to the other.
 
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GoldDigger

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Then what does the rule apply to?(705.12(D)(1)

It appears to apply to everything, including the cases where it seems inconvenient or even absurd.
The only open question, AFAIK, is what is meant by one system. I would hope that one or more inverters installed in one building would be a system, but perhaps they are considering all inverters hooked to the same service to be one system. I have not looked at the 2014 Handbook to see if there is any clarification (without standing) there.
 

jaggedben

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From an article in the IAEI magazine written by John Wiles who wrote the code, "This section has been revised to specifically require that multiple inverters in a single PV system shall be connected to the existing premises wiring system at a single dedicated circuit breaker or fusible disconnecting means. This section no longer allows multiple connections to a load center or panelboard where there are multiple inverters involved. Multiple inverters must first be combined in an AC combining panel and the output of the panelboard is then connected to the single point of connection in the distribution equipment through one circuit breaker or fusible disconnection means."

I'll be blunt: It really bothers me that Wiles is writing nonsense in IAEI magazine.

It's nonsense on the face of it, because the code makes no distinction between combiner panelboards and other panelboards. So if this section is supposed to prohibit multiple breakers in a service panelboard, then in effect it prohibits combiner panels as well, and therefor in effect prohibits multiple inverters at all in many situations.

It's also nonsense because nowhere in the Report on Proposals or Report on Comments is there any talk of multiple breakers in a panel presenting any kind of issue or of any intent to require combiner panels. As best I can tell, the change in the 2014 code was due to Bill Brooks' proposal 4-394 Log #2647 NEC-P04 (see page 813 at the first link above). The purpose of which was "to clarify that the interconnection point of a utility-interactive inverter must not contain loads between the inverter output and the overcurrent protection device", and to allow "Multiple inverters [to] be connected to the same circuit, as with micro-inverters or ac modules." So somehow a proposal intended to allow multiple inverters to be on the same branch OCPD gets flipped around to require all inverters to be on the same feeder OCPD? Again, nonsense. I'd say the CMP botched it up, but what's really botching it is people (including Wiles, apparently) not carefully reading either the plain language of the code or the ROP or ROC.

Yes, John Wiles wrote the original version of 690 many, many years ago. That doesn't make the final authority on code interpretation. Lately the CMP has been rejecting most of his proposals. Ask Bill Brooks about this one. He's just as much an authority, and it was his proposal which was accepted in principle.

To avoid the expense of installing a dedicated AC combiner panel?
Just for a two inverter system.
For inverters in separate buildings to avoid the need to run an inverter output circuit from one building to the other.

Thank you. These are important cost considerations in a competitive business, especially the latter. (The former is not trivial either, saving time and money on a 20/20 quad vs a subpanel for an 18 panel micro-inverter system where both the extra expense and the profit are measured in the hundreds.). We don't need onerous and clearly erroneous code interpretations adding costs when there is no safety issue.

Then what does the rule apply to?(705.12(D)(1)

The purpose of the rule is to prohibit loads and sources from being on the same branch circuit. That's really the entire purpose, IMO.
 
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GoldDigger

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The purpose of the rule is to prohibit loads and sources from being on the same branch circuit. That's really the entire purpose, IMO.
And you deduce this from the commentary? Or some other source, since this is clearly not what it says.
I can accept that there may have been some concern about how multiple PV backfeed breakers could all be at the opposite end of the bus from the main breaker, but if that is what it was meant to address, it clearly misfired.

With regard to the application of that section to combiner panels, I would argue that it only applies to that particular breaker which connects the inverter system directly to the "source", whatever that may be. And on that basis, it only applies to the furthest upstream OCPD (closest to the service conductors).
 

jaggedben

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And you deduce this from the commentary?

Yes. Short of interviewing the CMP members personally, it's the most valid means for interpreting vague language.

Or some other source, since this is clearly not what it says.

What it says is grossly unclear, as already discussed, mainly because "one system" is completely vague. I don't at all agree that my interpretation is 'clearly not what it says'.

I can accept that there may have been some concern about how multiple PV backfeed breakers could all be at the opposite end of the bus from the main breaker, but if that is what it was meant to address, it clearly misfired.

Again, I believe Brooks intended to ensure that micro-inverter systems are allowed, but I agree that the revision clearly misfired. I wish this forum topic had come up a couple months ago because I would have certainly submitted a revision proposal for the next cycle.

With regard to the application of that section to combiner panels, I would argue that it only applies to that particular breaker which connects the inverter system directly to the "source", whatever that may be. And on that basis, it only applies to the furthest upstream OCPD (closest to the service conductors).

The 'source' in this context is the inverter or inverters. Thus your second two sentences make no sense.
 

jaggedben

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A couple further comments...

I have always maintained that one inverter constitutes 'one system' since any inverter is capable of meeting the 690 definition for a system on its own regardless of how many other inverters are installed at a site. Apply this to 705 is a bit tricky because 705 covers other non-solar systems and doesn't have its own definition of those systems, except for the confusing 'Hybrid System', but overall its the best to go on with current code definitions.

The wrinkle to this is micro-inverters and AC modules, which are designed to have multiple inverters connected to the same output conductors and which fit the common sense usage of the word 'system' when installed as such.

In my opinion, the word 'source' in 705.12(D)(1) should be replaced with 'inverter', and the section otherwise reverted back to the 2011 language, while an exception should be added aimed at micro-inverters, along the lines of their being 'identified' for such use. It would clear up the meaning and fit what I believe is the real intent.
 

Smart $

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... I wish this forum topic had come up a couple months ago because I would have certainly submitted a revision proposal for the next cycle.

...In my opinion, the word 'source' in 705.12(D)(1) should be replaced with 'inverter', and the section otherwise reverted back to the 2011 language, while an exception should be added aimed at micro-inverters, along the lines of their being 'identified' for such use. It would clear up the meaning and fit what I believe is the real intent.
Keep in mind the comment stage is coming up (anyone know when it starts?). If someone made an 'input' for the section, you may be able to "squeeze" in some other wording.
 

jaggedben

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Keep in mind the comment stage is coming up (anyone know when it starts?). If someone made an 'input' for the section, you may be able to "squeeze" in some other wording.

Thanks.

Someone did submit a revision with the explicit intention of 'minimizing' the interpretation I'm arguing against.
 

jaggedben

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John, out of curiosity, what do you/your utility consider to be the difference between a "line side tap" and what I proposed in post #10?

I suspect he is overstating the utility's policy. See page 29 here. (Found with Google).

I never thought I would say this, but thank goodness I get to work with PG&E. :roll:
 

GoldDigger

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I suspect he is overstating the utility's policy. See page 29 here. (Found with Google).

I never thought I would say this, but thank goodness I get to work with PG&E. :roll:
Interesting. The utility seems to assume that the only way to attach a line side tap is to double lug to the input side of the main breaker. Inserting a disconnect between meter and main or even using Polaris connectors before the main breaker do not involve any modification to the existing switchgear at all.
 

shortcircuit2

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Interesting. The utility seems to assume that the only way to attach a line side tap is to double lug to the input side of the main breaker. Inserting a disconnect between meter and main or even using Polaris connectors before the main breaker do not involve any modification to the existing switchgear at all.

I noticed that too.
 

shortcircuit2

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Interesting. The utility seems to assume that the only way to attach a line side tap is to double lug to the input side of the main breaker. Inserting a disconnect between meter and main or even using Polaris connectors before the main breaker do not involve any modification to the existing switchgear at all.

Although option #2 could be interpreted from different angles...

2. A document from the manufacturer of the existing panel indicating that the proposed modification or connection to the source side of that panel does not compromise the UL rating of the panel.

Even a Polaris connection would need to be approved by the panel manufacturer?
 

Smart $

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...

Even a Polaris connection would need to be approved by the panel manufacturer?
If SCE wanted to push it, yes. For starters, from a purely technical perspective, adding a terminal block may infringe upon the wire bending space required per the UL listing standard.

jaggedben pointed to page 29 directly, but I suspect only as a verification line side taps are permitted by SCE. The form on page 29 (and 30) would only be used where service switch gear is modified or altered. I see no indication (though I only glanced through the publication) unaltered service switch gear needs such 3rd party approval.
 

jaggedben

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Another thing worth pointing out is that a supply-side connection that consists only of installing a new circuit breaker as a service disconnect (in a panel that allows such a thing) would not be modifying the switchgear either.

All of which is besides the fact that this stuff should be the business of the AHJ and not the utility.
 

Smart $

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Location
Ohio
Another thing worth pointing out is that a supply-side connection that consists only of installing a new circuit breaker as a service disconnect (in a panel that allows such a thing) would not be modifying the switchgear either.

All of which is besides the fact that this stuff should be the business of the AHJ and not the utility.
Which supports what I said back in post #15... http://forums.mikeholt.com/showthread.php?t=166397&p=1618812#post1618812

... and as far the single dedicated breaker requirement goes, regardless of interpretation, 705.12(D)(1) does not apply to line side connections.
 
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