Submit A Private Comment

Josh111

Senior Member
Location
USA
Is there ever a way to submit a comment on a public input for an NEC revision without having to identify the things they asked for such as the company you work for? I happen to work for a company but this does not mean that whatever I think about proposed revisions to the NEC is representative of what my company thinks. I’d rather not be putting all that information on a public comment and I don’t understand why I would need to.
 

don_resqcapt19

Moderator
Staff member
Location
Illinois
Occupation
retired electrician
Is there ever a way to submit a comment on a public input for an NEC revision without having to identify the things they asked for such as the company you work for? I happen to work for a company but this does not mean that whatever I think about proposed revisions to the NEC is representative of what my company thinks. I’d rather not be putting all that information on a public comment and I don’t understand why I would need to.
If you have an account with NFPA, and you sign in with that account, I believe the system will automatically enter the information from your profile. If you don't have an account, when you set it up, just enter your name without any other information. If you already have an account with a profile containing information you don't want, you may be able to set up a new account with a different email address.
 

Josh111

Senior Member
Location
USA
If you have an account with NFPA, and you sign in with that account, I believe the system will automatically enter the information from your profile. If you don't have an account, when you set it up, just enter your name without any other information. If you already have an account with a profile containing information you don't want, you may be able to set up a new account with a different email address.
Thanks. Isn't it the case too that at this stage, you can only submit a proposed revision for a vote on your exact text? Meaning you can't make a comment on the problem with something, make a suggestion on the text, and expect that if the committee members can't agree to your text but agree there's an issue to be addressed with the draft text, that they will consider an alternate text revision? If this is true, can you make multiple public comments on the same thing, so if they can't agree to one option they can consider the other?

Separate to this question: it looks like the move to have all the definitions to article 100 has lead to in some cases the same definition appearing twice, each time with its relevant committee posted there. This seems a little problematic. Example: first draft report has 2 definitions for Grounded, Functionally. I don't know why they want all definitions in one place if the definition means something different, and you have to look at the committee that wrote that definition, and then find out what articles they write vs the other committee and its articles, for the second occurrence of the same word. Or maybe the NFPA made one editorial/typo mistake here.
 

don_resqcapt19

Moderator
Staff member
Location
Illinois
Occupation
retired electrician
Thanks. Isn't it the case too that at this stage, you can only submit a proposed revision for a vote on your exact text? Meaning you can't make a comment on the problem with something, make a suggestion on the text, and expect that if the committee members can't agree to your text but agree there's an issue to be addressed with the draft text, that they will consider an alternate text revision? If this is true, can you make multiple public comments on the same thing, so if they can't agree to one option they can consider the other?

Separate to this question: it looks like the move to have all the definitions to article 100 has lead to in some cases the same definition appearing twice, each time with its relevant committee posted there. This seems a little problematic. Example: first draft report has 2 definitions for Grounded, Functionally. I don't know why they want all definitions in one place if the definition means something different, and you have to look at the committee that wrote that definition, and then find out what articles they write vs the other committee and its articles, for the second occurrence of the same word. Or maybe the NFPA made one editorial/typo mistake here.
You can suggest changes that do not introduce new concepts of ideas at this point. You can modify a rejected PI to make it clear, or to address the concerns addressed in the panel statement, but you can't add new ideas.

As far as the definitions being in one place, I understand this is driven by the NFPA. The NEC is the only NFPA document that does not have all of the definitions in on place. I think it will be somewhat confusing especially for those terms with more than one definition. Those multiple terms will have an article number at the end of the definition just before the CMP number. Where there is an article number, that tells you that the definition only applies within that article.
 

Josh111

Senior Member
Location
USA
I think if they are going to do this they should be employing something like underlining any specifically defined term everywhere where it shows up in the code. There’s some things that all of us know the definition of. Things like “within sight” or “service point.” Usually during training and during work, these are reviewed maybe at the beginning of a program and then as you begin to study or do work involving multiple articles of the code they come up again and again. There’s other areas where in special conditions or occupancies, electricians if doing work in those would study the relevant articles beforehand and if they have to pick and choose from the definition section each time It makes it more time consuming and more likely that when someone who is working with the special condition looks through the code article for that work, unless it’s obvious that a term would need to be specifically defined, they may tend not to realize that they actually need to refer to the definition of a word in order to use it properly.

Some people have the PDF version or maybe a search could be done but not everyone does. I’m not sure if it’s something like this could even be addressed via a public comment.
 

pv_n00b

Senior Member
Location
CA, USA
Is there ever a way to submit a comment on a public input for an NEC revision without having to identify the things they asked for such as the company you work for? I happen to work for a company but this does not mean that whatever I think about proposed revisions to the NEC is representative of what my company thinks. I’d rather not be putting all that information on a public comment and I don’t understand why I would need to.
In my NFPA account, I leave the Organization blank so when I submit comments it is blank there.
 

pv_n00b

Senior Member
Location
CA, USA
Thanks. Isn't it the case too that at this stage, you can only submit a proposed revision for a vote on your exact text? Meaning you can't make a comment on the problem with something, make a suggestion on the text, and expect that if the committee members can't agree to your text but agree there's an issue to be addressed with the draft text, that they will consider an alternate text revision? If this is true, can you make multiple public comments on the same thing, so if they can't agree to one option they can consider the other?
At the Public Comment stage, you can in theory only comment on the changes that have been proposed in the first draft. In your comment there is a place to provide the input you are commenting on, that can be a PI, FN, CN, etc. While technically you cannot introduce new information at this stage, if there is already a comment on what you want to provide a new input on you can often write your comment in such a way that it introduces new information while commenting on an existing input. I see this pretty often. Then of course there are all kinds of internal task groups and the CMP itself who can introduce new changes at this stage.
 

don_resqcapt19

Moderator
Staff member
Location
Illinois
Occupation
retired electrician
At the Public Comment stage, you can in theory only comment on the changes that have been proposed in the first draft. In your comment there is a place to provide the input you are commenting on, that can be a PI, FN, CN, etc. While technically you cannot introduce new information at this stage, if there is already a comment on what you want to provide a new input on you can often write your comment in such a way that it introduces new information while commenting on an existing input. I see this pretty often. Then of course there are all kinds of internal task groups and the CMP itself who can introduce new changes at this stage.
If you introduce something totally new, the CMP should not accept it. Sometimes that happens, but then when they do, that sometimes gets reversed by the Correlating Committee.

The task groups and CMPs are not permitted to introduce new material at this stage.
 

don_resqcapt19

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Staff member
Location
Illinois
Occupation
retired electrician
I've seen it happen many times in past revisions. Changes are made after the comment stage by the CMP and just show up in the final code.
Some times that has happened, but it is not permitted. Sometimes the change is based on something that happened with the actual vote at the annual meeting, or actions by the correlating committee or standards council, but even there there should be no new material introduced. Some of these actions the come out of the annual meeting result in the text reverting back to what was in the previous code.
 

pv_n00b

Senior Member
Location
CA, USA
I've been involved in NEC revisions since 2005 and I don't think under the new system that did away with the ROP and ROC that individual inputs are really valued that much anymore. It's all group inputs from code groups like SEIA and the PV Industry Forum that get heard or internal groups in NFPA 70 that write the code for the most part now.
If late changes were not permitted they would not happen. I have seen substantive changes in the past and when I went to the record to look at how it got in, there was nothing in the PIs or PCs. Talking to people on the CMP they would tell me that the change just showed up out of nowhere and was put in. Maybe I'm a bit jaded.
 
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don_resqcapt19

Moderator
Staff member
Location
Illinois
Occupation
retired electrician
I've been involved in NEC revisions since 2005 and I don't think under the new system that did away with the ROP and ROC that individual inputs are really valued that much anymore. It's all group inputs from code groups like SEIA and the PV Industry Forum that get heard or internal groups in NFPA 70 that write the code for the most part now.
If late changes were not permitted they would not happen. I have seen substantive changes in the past and when I went to the record to look at how it got in, there was nothing in the PIs or PCs. Talking to people on the CMP they would tell me that the change just showed up out of nowhere and was put in. Maybe I'm a bit jaded.
Don't care if they happened or not...they are not permitted by the NFPA rules and by the ANSI rules governing consensus standards. I have been told that lots of strange things have happened since they went to TerraView.

I listened in on a lot of the CMP task group meetings as well as the First Revision meetings. There was ample discussion of the PIs in the ones I listened to.
 

Josh111

Senior Member
Location
USA
I don't think under the new system that did away with the ROP and ROC that individual inputs are really valued that much anymore. It's all group inputs from code groups like SEIA and the PV Industry Forum that get heard or internal groups in NFPA 70 that write the code for the most part now.
I think that’s the problem. It seems like the code in a lot of ways is being written to be more confusing nowadays and it’s surprising to me the number of times when they supposedly revise something to clarify something and end up with a piece of text and the final version that doesn’t clarify it at all, communicates something else, and then has to be revised again the next time. There’s a lot of people on the committees it seems pushing for changes just to drive more business to their company and there’s a lot of people that submit public inputs for that purpose as well. Just look at the mess with definitions this time around. It seems there was little to no public input on that one. The committee that accepted the proposal to do so put in a statement that it was not within its jurisdiction to reject it. Therefore any public comments that were made concerning that weren’t even considered because they didn’t even debate it.
 

don_resqcapt19

Moderator
Staff member
Location
Illinois
Occupation
retired electrician
I think that’s the problem. It seems like the code in a lot of ways is being written to be more confusing nowadays and it’s surprising to me the number of times when they supposedly revise something to clarify something and end up with a piece of text and the final version that doesn’t clarify it at all, communicates something else, and then has to be revised again the next time. There’s a lot of people on the committees it seems pushing for changes just to drive more business to their company and there’s a lot of people that submit public inputs for that purpose as well. Just look at the mess with definitions this time around. It seems there was little to no public input on that one. The committee that accepted the proposal to do so put in a statement that it was not within its jurisdiction to reject it. Therefore any public comments that were made concerning that weren’t even considered because they didn’t even debate it.
Other than changing the actual text of a definition, or combining definitions of the same or similar terms, the move to place all definitions in Article 100 was not from a public input.

That was directed by a higher authority in the NFPA.

It is not a technical change and is not subject to public input or public comment, and the code making panel is correct that they have no choice on making that change.
 

Josh111

Senior Member
Location
USA
Other than changing the actual text of a definition, or combining definitions of the same or similar terms, the move to place all definitions in Article 100 was not from a public input.

That was directed by a higher authority in the NFPA.

It is not a technical change and is not subject to public input or public comment, and the code making panel is correct that they have no choice on making that change.
Yes yes yes exactly. The NFPA decided it wasn’t for public input. I’d point out that adoption of NFPA standards is voluntary. If they don’t care about user friendliness for the code, then they might pay for that one day. Other countries sometimes decide to adopt it and they are more likely than US states to decide to adopt something else if they fine the standard less relevant or user friendly. Eventually trades people won’t rely on having a copy of the code and will instead rely on heavily engineered designs and guidelines about electrical work that may include how to follow the code. The code will become some high and lofty document that only engineers have, just like the other IEEE standards that they may have. In time there will be even less industry input. If enough time persist with it becoming less and less user-friendly and thereby less and less user relevant perhaps the day will come when jurisdictions in the US will adopt a different standard.
 

don_resqcapt19

Moderator
Staff member
Location
Illinois
Occupation
retired electrician
Yes yes yes exactly. The NFPA decided it wasn’t for public input. I’d point out that adoption of NFPA standards is voluntary. If they don’t care about user friendliness for the code, then they might pay for that one day. Other countries sometimes decide to adopt it and they are more likely than US states to decide to adopt something else if they fine the standard less relevant or user friendly. Eventually trades people won’t rely on having a copy of the code and will instead rely on heavily engineered designs and guidelines about electrical work that may include how to follow the code. The code will become some high and lofty document that only engineers have, just like the other IEEE standards that they may have. In time there will be even less industry input. If enough time persist with it becoming less and less user-friendly and thereby less and less user relevant perhaps the day will come when jurisdictions in the US will adopt a different standard.
Every other NFPA standard, and many other standards, have the definitions set up like the NEC is going to be in the 2023 edition.

In some ways the listing in one location alphabetically will be more user friendly, as they did a lot of work so that related things will be next to each other. For example the listing will not be by AC Cable, MC cable and other cable types, but rather all of the cable types will be together listed as "cable, xx type".

I often found the use of Article 100 in the 2020 code to be frustrating because of the 3 parts and their separate alphabetic listing. Getting rid of the parts is a big improvement for me.

As far as building off or heavily engineered designs that is very unlike as the costs of such designs exceeds the budget for most projects....I bet that over the time I have worked in this industry, the amount of information provided in the engineering documents for commercial and industrial projects has decreased by at least 50%.
 

pv_n00b

Senior Member
Location
CA, USA
I think moving all the definitions to 100 is going to uncover some glaring issues in how the same terms have been defined multiple ways in various NEC articles for decades. That should be good for everyone. But while the 2023 revision will uncover the problem, the problem probably won't be fixed until the 2026 revision. Article 100 in 2023 will probably be a little rough.
 

don_resqcapt19

Moderator
Staff member
Location
Illinois
Occupation
retired electrician
I think moving all the definitions to 100 is going to uncover some glaring issues in how the same terms have been defined multiple ways in various NEC articles for decades. That should be good for everyone. But while the 2023 revision will uncover the problem, the problem probably won't be fixed until the 2026 revision. Article 100 in 2023 will probably be a little rough.
The correlating committee looked at that before the first draft was published, and there were task groups assigned to work on public comments that would eliminate some of the multiple definitions of the same term. If the changes needed to fix things are editorial and not technical or if there was a PI to make a change in the definition, some of these will be completed for the 2023 cycle.

Ones that cannot be resolved will have an article number at the end of the definition, telling you that it only applied to that specific article.
 
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