Well here was the panel statements:
Statement of Problem and Substantiation for Public Comment
"This Public Comment is being submitted by a Correlating Committee Task Group that was created as a result of Correlating Committee Note No. 65. Members of the Task Group included Larry Ayer (Co-Chair), James Dollard, David Hittinger, Vince Saporita (Co-Chair), and David Williams. The Correlating Committee directed the Task Group to review the term “Emergency disconnect switches” and correlate it with the terminology used in FR-8642 (new Section 230.85), FR 7770 (Section 445.18(A)), and FR 8942 (Section 706.15).
The term “emergency disconnect switches” is changed to “emergency disconnects” in new 230.82(10) to correlate with the term in new 230.85.
The term “emergency disconnect(s)” is changed to “emergency disconnects”, “switch(es)” is changed to “switches”, and “breaker(s)” is changed to “breakers” in 230.85 to agree with the NEC Style Manual.
For FR 8874, the term “Emergency stop switch” is used correctly in title of 445.18 and therefore no changes are necessary.
For FR 7846 (Section 445.18(D)), the term “First Responder Shutdown” is changed to “Emergency Shutdown” for correlation with these other changes.
For FR 8942 (Section 706.15), the ESS disconnecting means, or its remote control, must be grouped with the emergency disconnects required in new 230.85, for the safety of first responders. Unless the ESS switch or its remote control is in close proximity when first responders try to de-energize the service of the dwelling unit by utilizing the outdoor emergency disconnects required by new 230.85, they will expect that the entire dwelling unit is totally de-energized. If the ESS switch, or its remote control, is not in close proximity, the first responders may not know that the dwelling unit is still energized. The revised requirement will help the first responders recognize that there is an additional disconnecting means that is necessary to totally de-energize the dwelling unit. The term “ESS disconnecting means” is used correctly in 706.15."
Also, keep in mind the original PC was submitted by someone representing the manufacturer who is also the Co-Chair but that's all I see so far. The old days where we have more information are long gone. Some say we get more detail these days but sadly I disagree as the old style yielding more in my humble opinion. Now I know that doesn't tell you anything but again I am not on that CMP so it's all I got.
Here is the info to look up from the FD Meeting:
Committee Statement
Committee Statement: | This revision recognizes the need for an outdoor disconnect for first responders. These requirements are practical, feasible and provide installers with multiple options. Today, first responders and utility personnel do not have a way to safely remove power from a structure unless there is a means to disconnect the electric utility supply that is located outside of said structure in a readily accessible location. |
Response Message: | FR-8462-NFPA 70-2018 |
Public Input No. 2740-NFPA 70-2017 [Section No. 230.82]
Public Input No. 1169-NFPA 70-2017 [Section No. 230.70(A)]
Public Input No. 3001-NFPA 70-2017 [New Section after 230.82]
Public Input No. 2677-NFPA 70-2017 [New Section after 230.8
IMO having said "emergency disconnect" for first responders is somewhat pointless if the general rule for placement is nothing more than in a readily accessible location, outdoors. If going to have such rule it needs to be in specific location that emergency responders will know where to find it. As worded there is a wide open range of places said disconnect might be found, that has only been narrowed down to "readily accessible" and "outdoors". As time goes by it may not even be all that readily accessible when time comes to need to use it. What if a bush gets planted and grows enough that it makes it difficult to find? Stating that a disconnect or at least a remote operating device be within a certain area such as within a certain distance adjacent to main entrance - at least gives first responders a location to know where they should find what they are looking for.
In past most of these single and two family dwellings were disconnected by first responders by pulling a meter. Only occasionally might you run into CT metering and that idea won't work.
On top of all that, there is no guarantee said switch will always interrupt all voltage in the facility, one really needs to test for voltage to be certain, then there could be automatic standby power that kicks in...
I'm still failing to see the need for such a rule especially it only is for one and two family dwellings.