NEC 705 interconnection method for Feeder-Intercept microgrid controllers (Tesla GW3 / Enphase, etc.)

aborja

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Context: The existing meter-main (service disconnect) feeds a Microgrid Controller (MGC)—e.g., Tesla Gateway 3, Enphase IQ Controller, etc. PV and ESS outputs land inside the MGC. The existing main-breaker load center becomes a protected/backup (or whole-home) panel downstream of the MGC.

We’re trying to choose the correct NEC 705 interconnection method for this topology. We see two plausible readings:

Option 1 — Busbar method: 705.12(B)(3), typically (B)(3)(3) “sum of all OCPDs”


Interpretation:
The power-source output connections (PV/ESS inverter outputs) land on the MGC’s internal bus via dedicated breakers. Therefore, evaluate that bus under 705.12(B)(3). The common path is (B)(3)(3): the sum of the ampere ratings of all OCPDs mounted on that bus (supply + load devices), excluding the OCPD that protects that bus, shall not exceed the bus rating.
  • If the MGC is lugged-out (no load/output breaker on the MGC bus): the sum is typically just PV + ESS breakers (often well ≤ 200 A), so (B)(3)(3) passes.
  • If the MGC does have a load/output breaker on the same bus, that breaker counts in the sum. In some whole-home cases, PV + ESS + load breaker can exceed the 200 A bus rating → (B)(3)(3) fails.
  • PCS path: When the controller is listed as a PCS and configured to limit current, we would instead claim 705.13 (PCS) compliance—treating the PCS setting as the “power-source output current” for 705.12 calcs. That’s a separate compliance path (not making (B)(3)(3) true).

Why this seems right to us:
705.12 creates distinct methods for busbars vs feeders/taps. In this topology, the DER outputs don’t splice into feeder conductors; they terminate on the MGC bus. Thus the busbar method applies at the equipment where sources parallel the EPS.

Option 2 — Feeder / Feeder-Tap method: 2023 705.12(A)


Interpretation:
Define the Point of Interconnection (POI) as the feeder landing at the MGC—i.e., “where the new equipment (the microgrid system) connects to the home's electrical system” Treat the microgrid system (MGC + PV + ESS) as a composite source exporting to the premises at that point. Because the POI is on the feeder, apply feeder/tap rules: ampacity ≥ 125% of source output current, or protect the downstream feeder segment with OCPD at the connection per the subsection options, etc.

Why this seems plausible to others:
Verbiage like “Where the power-source output connection is made to a feeder…” could be read as including a microgrid controller interface at the feeder as the “power-source output connection,” since the microgrid as a system exports at that point—even though the individual PV/ESS outputs terminate on an internal bus.




Main Question
For applying 705.12, should “power-source output connection” be understood as the DER output(s) landing point (i.e., the MGC bus), or can the microgrid controller’s feeder interface itself be considered the “power-source output connection” for feeder methods?
 
For the 2023 and 2026 NEC, 705.12(B) starts off: "For power source connections to distribution equipment with no specific listing and instructions for combining multiple sources . . ." The microgrid controller presumably has specific listing and instructions for combining multiple sources. That listing suffices; the rest of 705.12(B) does not apply.

Cheers, Wayne
 
What Wayne said. In fact I've been relying on the appeal to listed equipment since the 2017 code. I just don't call out an item like the Enphase System Controller as being a panel or a panelboard. So far, so good.

The only thing I'll add is that one should account for 705.12(A) [2023 reference]. The feeder to the backup loads should be protected either by rating or with an overcurrent device. Some equipment (e.g. Enphase System Controller) has a provision for the overcurrent device, but if it doesn't you can add one (e.g. put a main breaker in the backup subpanel). I don't think listings cover this as it isn't internal to the equipment.
 
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For the 2023 and 2026 NEC, 705.12(B) starts off: "For power source connections to distribution equipment with no specific listing and instructions for combining multiple sources . . ." The microgrid controller presumably has specific listing and instructions for combining multiple sources. That listing suffices; the rest of 705.12(B) does not apply.

Cheers, Wayne
Thanks for your response, Wayne.
That is correct, pretty much all Microgrid Controllers will have a specific listing (i.e. a Gateway 3 will have these listings: UL 67, UL 869A, UL 916, UL 1741) And correct, it does have instructions for combining multiple power sources, found in the equipment's installation manual documentation.
So, according to NEC 2023 and 2026, this interconnection configuration would not qualify under 705.12(B) due to it's first clause, and therefore the rest of the clause cannot qualify either.
 
What Wayne said. In fact I've been relying on the appeal to listed equipment since the 2017 code. I just don't call out an item like the Enphase System Controller as being a panel or a panelboard. So far, so good.

The only thing I'll add is that one should account for 705.12(A) [2023 reference]. The feeder to the backup loads should be protected either by rating or with an overcurrent device. Some equipment (e.g. Enphase System Controller) has a provision for the overcurrent device, but if it doesn't you can add one (e.g. put a main breaker in the backup subpanel). I don't think listings cover this as it isn't internal to the equipment.
Thank you for your response.

Would you mind sharing which NEC interconnection method you reference on plan sets that follow this specific configuration?

From my understanding, it seems that the Microgrid Controller's compliance is handled by its listings, but the feeder to the backup loads panel has to meet 705.12(A). What about the feeder from the Main Disconnect to the Microgrid Controller?
 
So, according to NEC 2023 and 2026, this interconnection configuration would not qualify under 705.12(B) due to it's first clause, and therefore the rest of the clause cannot qualify either.
This phrasing seem to imply that there is a requirement for the microgrid controller to "qualify" under some portion of 705.12; there is not. Rather, 705.12 imposes no requirements on the microgrid controller.

From my understanding, it seems that the Microgrid Controller's compliance is handled by its listings, but the feeder to the backup loads panel has to meet 705.12(A). What about the feeder from the Main Disconnect to the Microgrid Controller?
705.12(A) would apply to both feeders, but 705.12(A)(2) only imposes conditions on the feeder to the backup loads panel. The feeder between the service disconnect and the microgrid controller does not meet the predicate of 705.12(A)(2), the two source connections are at opposite ends.

Cheers, Wayne
 
This phrasing seem to imply that there is a requirement for the microgrid controller to "qualify" under some portion of 705.12; there is not. Rather, 705.12 imposes no requirements on the microgrid controller.


705.12(A) would apply to both feeders, but 705.12(A)(2) only imposes conditions on the feeder to the backup loads panel. The feeder between the service disconnect and the microgrid controller does not meet the predicate of 705.12(A)(2), the two source connections are at opposite ends.

Cheers, Wayne
Why would 705.12(A)(2) only impose conditions on the feeder to the back up loads panel?

According to Article 100, the definition of feeder is: "
All circuit conductors between the service equipment, the source of a separately derived system, or other power supply source and the final branch-circuit overcurrent device.
Would that make all circuits in between the meter-main and the load panel be considered feeders?
 
Why would 705.12(A)(2) only impose conditions on the feeder to the back up loads panel?

...

That's just all it happens to do, if you read the requirements it imposes. It's not that it couldn't impose requirements on the upstream portion of the feeder, but it only imposes requirements on the load side.
 
Why would 705.12(A)(2) only impose conditions on the feeder to the back up loads panel?
As I alluded to, because 705.12(A)(2) limits itself to "Where the power-source output connection is made at a location other than the opposite end of the feeder from the primary source overcurrent device." The feeder between the service disconnect and the microgrid controller has the two power sources connected at opposite ends.

Or if you prefer, you can consider that there is a single feeder from the service disconnect to the back up loads panel, and that the power-source output connection is made in the middle, at the microgrid controller. Then 705.12(A)(2) only provides requirements for "that portion of the feeder on the load side of the power source output connection." Which excludes the portion of the feeder between the service disconnect and the microgrid controller.

Cheers, Wayne
 
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