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NC has an NEC interpretation problem that will affect all ESS systems

tortuga

Code Historian
Location
Oregon
Occupation
Electrical Design
Oh fer cryin' out loud.
At least 702 does not actually say 'listed' and 750.6(3) has some options.
The options all seem to imply UL 916
750.6 Listing
Energy management systems shall be one of the following:
1) Listed as a complete energy management system
2) Listed as a kit for field installation in switch or overcurrent device enclosures
3) Listed individual components assembled as a system

The standard Generac RXSW200A3 200A ATS often included with the generator in a package deal from from home improvement stores has a included "Smart A/C Module (SACM)" load management system for "up to four individual HVAC (24 VAC controlled) loads with no additional hardware" which does not appear to meet any of the above 2023 NEC 750.6 options, not an issue until your on the 2023 NEC and by then they will probably update the products. But its an issue here.
The pwrcell line is 916 listed and does have upgrades to the standard transfer switch.
 

AwgNC

New User
Location
Nc
Occupation
Electrician
I think we should also take into account that 2020 NEC 706.16F redirects to 710.15. Cant be much clearer than that.
 

Sunshine PDX

New User
Location
Oregon
Occupation
PV Designer, NABCEP PVIP
I think we should also take into account that 2020 NEC 706.16F redirects to 710.15. Cant be much clearer than that.
This is perfect and I am determined to use it to challenge a 702 correction requesting load calcs on a residential grid-tied battery system with an MID in Washington State.
 

jaggedben

Senior Member
Location
Northern California
Occupation
Solar and Energy Storage Installer
I think we should also take into account that 2020 NEC 706.16F redirects to 710.15. Cant be much clearer than that.
Thanks for pointing this out, I had not noticed it. Fortunately it is unmodified in the 2023 NEC so for myself in California it will be there another four years. Unfortunately, it is deleted in the 2026 First Draft with the justification that "This section does not modify other requirements and therefore is removed in accordance with 4.1.1 NEC Style Manual.".
 

shortcircuit2

Senior Member
Location
South of Bawstin
Thanks for pointing this out, I had not noticed it. Fortunately it is unmodified in the 2023 NEC so for myself in California it will be there another four years. Unfortunately, it is deleted in the 2026 First Draft with the justification that "This section does not modify other requirements and therefore is removed in accordance with 4.1.1 NEC Style Manual.".
So, I do not see any relief in 2026 for an ESS to not handle the full calculated load unless connected through an EMS?
2026 FD 702.4(A)(2)(b) through section 130.30
 

jaggedben

Senior Member
Location
Northern California
Occupation
Solar and Energy Storage Installer
So, I do not see any relief in 2026 for an ESS to not handle the full calculated load unless connected through an EMS?
2026 FD 702.4(A)(2)(b) through section 130.30
Actually I think when the Second Draft comes out you're going to see a new option in 702.4 for one and two family dwellings that will allow systems to be sized to the highest individual load if they meet certain requirements, namely require manual restart if overloaded. Saw this in a webinar the other day. Forgot about it earlier in this thread because I was focused on looking at the section in 706 that was mentioned.
 
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