In the situations where you would normally use IPCs, presumably sometimes (depending on layout and POCO requirements) you could instead set a bussed service gutter and make the splices there. If I understand correctly, power distribution blocks have been subject to the 230.46 requirements for a while, and so there are listed products available to use on the supply side of the service?
Cheers, Wayne
Yes I does seem like there are other ways. Granted there is the vagueness we have been discussing about what exactly constitutes a splice or tap and if pressure connectors supplied with equipment count.... But other options include
1. Reorganizing the service to look like or be a 230.40 exception #2 install, with the PV connected to the load side of a new panel using the sum of all breakers rule.
2. Maybe add a customer owned CT cabinet and mounting base and say it's needed for customer metering (if asked).
3. Come off the power company CT cabinet/handhole/transformer with your new set if there are lugs available there and they don't have an issue with "PV taps" there (if so, try calling it a regular 230.40 ex #2 install per idea #1).
4. Could always just swap out a panelboard for something big enough to handle a load side connection.