I'm not convinced that's true because the issue has been conductors which are energized EVEN WHEN something like the main disconnect is opened. That's what firefighters have dealt with, since I believe it's common practice to de-energize a building when they start firefighting.
Sorry, what's the contradiction between what I said and what you're saying here?
I am not sure that is true:
(A) Controlled Conductors. Requirements for controlled conductors shall apply to PV circuits supplied by the PV system.
...logically, it makes sense to be concerned with the conductors that are NOT de-energized by turning off the service disconnect.
To be clear, while this is a bit vague in the language you're quoting from 2017, it's clear in subsequent codes, which better cover what I understand to have always been the intent of 690.12.
Under the 2017 you can argue, if you like, about whether microinverter output circuits are subject to the requirements. But if you decide they are, then the test for compliance simply requires voltage between conductors and to ground be limited within 30secs etc.. At that point the requirement purely deals with voltage and not where that voltage comes from. In no case would a 1-pole disconnect for a circuit with 2 hots in a 120/240V ever create compliance for such a circuit. Either no additional disconnect was needed in the first place, or a 2-pole disconnect is required.
There is a double intent behind 690.12 and its companion labeling requirements
1) To reduce shock hazard for firefighters working on or around PV arrays or the wiring to/from them
2) To signal to firefighters that the PV arrays and their wiring can be made safe enough to work in, on, or around, so that they won't just let the building burn down.
An argument for applying 690.12 to micro-inverter output circuits under the 2017 is that it costs less than $10 to slap labels on the service disconnect to encourage the firefighters not to let the building burn down for fear of being shocked by PV circuits. (Okay, if the service disconnect is not outside on a one or two family dwelling it costs a little more.) The firefighter was going to kill the service disco anyway, but they see RS switch label (hopefully) and tell their comrades that the array is safe to operate around. But this is moot with your ground mount because if the ground mount is on fire already you are not still needing the firefighters to save a building. Bluntly, it's less of a problem if they let it burn.