Originally posted
here, I've made a slightly updated version.
---------
Is a supply-side PV disconnect a service disconnect?
'Yes'
Article 100 definitions of 'Service Conductors', 'Service Entrance Conductors' and 'Service Point.' Along with the requirements of 230.70, these logically entail that the conductors require what 230.70 calls 'a service disconnecting means'. Note that the definition of 'Service Point' is not negated even if the definition of 'Service' is not considered to apply. One would have to argue that the service has no 'Service Point' to avoid the requirements of 230.70.
230.2(A)(2) - allows an additional service for parallel power production systems. This code section calls this connection a service, even though that's not consistent with the article 100 definition for 'Service'.
230.40 Exception 5 - Refers (via reference to 230.82(6)) to the PV system using 'service entrance conductors', which along with 230.70 requires a service disconnecting means. Also uses the phrase 'supply side of the normal service disconnecting means', (emphasis added), which avoids the implication that all the service disconnecting means must be elsewhere, as opposed to just the 'normal' ones. (see below)
230.70 Titled 'Service Equipment Disconnecting Means,' it requires service entrance conductors to have a disconnecting means. It refers to this means with the phrase 'service disconnecting means' six times, as well as the phrase 'service disconnect' twice. Any installation with a 'Service Point' ends up having to meet these requirements. Any invocation of 230.40 Exception 5 to justify a supply side tap would also invoke 230.70. Notably, the Article 100 definition of 'Service Equipment' is not actually necessary for invoking the requirements of this section.
230.71 Note that nothing that can reasonably construed as applying to a PV system is included in 230.71(A)(1) thru (4).
'No'
Definition of a Service, which refers to 'delivering energy from the serving utility to the wiring system of the premises served.' [NOTE: changing in 2020 NEC to longer imply one direction.]
Definition of Service Equipment, which refers to 'load end of service conductors'.
230.82 and 705.12(A), 705.31: These sections use the phrase 'supply side of the service disconnecting means', which can be taken to imply that the service disconnecting means are elsewhere. (Note again that 230.40 Exception 5 avoids this implication with the additional of the word 'normal'.)
230.82(6): Notably this section does not include the same restrictions as 230.82(5).
All references are 2014 NEC.