That's one question, and I think the answer would be found in the product standard for PV wire or USE-2. I'm not entirely sure.
PV wire is not a Chapter 3 category, so its NEC use, beyond the allowance in 690.31(C), is limited to what other ratings the wire has, to my understanding. The one example I looked up is also rated RHW-2.
I don't believe Article 338 allows USE-2 single conductor cables to be run exposed above ground without a raceway. And RHH certainly can't be used that way in general. So that means that a raceway is required for the wires in the picture in the OP outside of "the PV array".
As such, the metal pipe in the picture is a raceway and is subject to fill limits and the conductors are subject to derating.
Now if the wires were some type that is allowed to be run exposed above ground, say UF cable, then I'd say the metal pipe in the picture is a sleeve and could be any material, not listed conduit. It still is obviously causing bundling for over 24", so derating would apply. But there would be no fill limits.
And no, beyond the allowances for nipples up to 24" in length, there's nothing in the NEC (*) that would relax the fill and derating requirements for conductors in conduit in that application. But you could put a box in the middle of the conduit run to take advantage of the 24" allowance on either side of it. Or just use a large box instead of conduit. Or check the allowances for wireways and/or cable trays.
Cheers, Wayne
(*) Not based on reading cover to cover but I think I've read all the possibly relevant sections, and no mention of it has ever come up here that I've seen in the last decade (and a half?)