The interpretation I see most often, and I agree with, is that the conductors and connectors need to be made not readily accessible, not just the connectors. There are many ways to do this, but not all are universally accepted outside of actually running raceway to the module junction box.
The problem with using a fence is that if personnel not involved with the electrical operation of the PV array can get access to the area inside the fence then the conductor has not been rendered not readily accessible. From what I have seen with landscaping maintenance and trash collection there are a lot of people inside the fence that the NEC is trying to keep away from the exposed conductors. That being said, most people are using a fence to satisfy the requirement, particularly since a fence will be installed anyway. The first time a landscaper gets killed from cutting a live conductor while inside the fence I expect this will all change.
The best way to address this would be conduit to the junction box, but that would require using different junction boxes and losing the connectors. Second best would be mounting a shield that runs across the back of the modules, covers the junction boxes and conductors, and prevents a person from touching the conductors without removing the shield. I have seen these in use but there is an extra cost that most are not willing to add in and risk loosing the job to someone who only puts in a fence.