NEC Code-Making Panel 9. Second Draft Meeting Agenda. November 9-11, San Diego, CA Introduction of Members and Guests

Transcription

1 National Fire Protection Association 1 Batterymarch Park, Quincy, MA Phone: Fax: NEC Code-Making Panel 9 Second Draft Meeting Agenda November 9-11, 2015 San Diego, CA Item No. Subject Call to Order Introduction of Members and Guests Approval of A2016 First Draft Meeting Minutes Review of Meeting Procedures and Revision Schedule Task Group Reports Process Public Comments and Develop Second Revisions Fire Protection Research Foundation Requests Old Business New Business Adjournment

2 Public Comment No , Substation. Public Comment No , Substation. Public Comment No , Substation. Public Comment No Section No Public Comment No Section No (B) Public Comment No. 376 Section No (C) Public Comment No Section No (A) Public Comment No Section No (A) Public Comment No Section No (A) Public Comment No Section No Public Comment No Section No Public Comment No Section No Public Comment No Section No Public Comment No Section No Public Comment No Section No Public Comment No Section No Public Comment No Section No Public Comment No. 606 Section No Public Comment No. 977 Section No Public Comment No. 507 Section No (A) Public Comment No Section No (B) Public Comment No Section No (B) Public Comment No Section No (B) Public Comment No Section No (B) Public Comment No Section No (B) Public Comment No Section No (B) Public Comment No Section No (B) Public Comment No Section No (B) Public Comment No Section No (B) Public Comment No Section No (B) Public Comment No Section No (B) Public Comment No Section No (B) Public Comment No Section No (B) Public Comment No Section No (B) Public Comment No Section No (B) Public Comment No Section No (B) Public Comment No Section No (B) Public Comment No Section No (B) Public Comment No. 960 Section No (B) Public Comment No. 377 Section No Public Comment No Section No (B)(1) Public Comment No. 779 Section No (B)(1) Public Comment No. 830 Section No (B)(1) Public Comment No. 669 Section No Public Comment No. 831 Section No Public Comment No Section No (A) [Excl Public Comment No Section No (A)(3)

3 Public Comment No Section No (E)(1) Public Comment No Section after (B) Public Comment No Section No [Excludi Public Comment No. 463 Section No (C) Public Comment No. 504 Section No (C) Public Comment No. 948 Section No (C) Public Comment No. 465 Section No (B) Public Comment No Section No Public Comment No Section No Public Comment No. 485 Section No Public Comment No. 770 Section No Public Comment No. 832 Section No Public Comment No , Outlet Box Hood. Public Comment No. 168 Section No (A)(2) Public Comment No Section No (B) Public Comment No Section No (C) Public Comment No. 264 Section No (C) Public Comment No. 272 Section No Public Comment No. 287 Section No Public Comment No. 803 Section No (B) Public Comment No Section No (A) Public Comment No Section No (B) Public Comment No. 429 Section No (B) Public Comment No. 804 Section No Public Comment No Section No (D) Public Comment No Section No (D) Public Comment No Section No (E) Public Comment No Article 490 Public Comment No. 207 Section No Public Comment No Section No Public Comment No Section No (B)

4 4 of /1/ :02 AM Public Comment No. 428-NFPA [ Definition: Substation. ] Substation. An assemblage of equipment containing (e.g., switches, interrupting devices, protection relays circuit breakers, buses, transformers, switchgear, motor control centers, etc and transformers) through which electric energy is passed for the purpose of switching distribution, switching, or modifying characteristics. A substation is generally of such size or complexity that it incorporates one or more buses and a multiplicity of electrical equipment; is usually the receiving point for more than one supply circuit to transform power from one voltage to another or from one system to another. its characteristics. The wording of this definition as presented in the First Draft does not reflect the final action of CMP 9 on the revision. Numerous comments submitted by Panel Members during balloting highlight this issue, as well as the Committee Statement which is inconsistent with the First Revision as recorded. This Public Comment is intended to restore the Code text to the panel action established during the First Revision meeting. First Revision No NFPA [Definition: Substation.] Submitter Full Name: ROBERT OSBORNE Organization: UL LLC Submittal Date: Mon Aug 24 13:33:28 EDT 2015

5 5 of /1/ :02 AM Public Comment No. 687-NFPA [ Definition: Substation. ] Substation. An assemblage of equipment containing switches, interrupting devices, protection relays, buses, transformers, switchgear, motor control centers, etc etc., through which electric energy is passed for the purpose of switching or modifying characteristics. A substation is generally of such size or complexity that it incorporates one or more buses and a multiplicity of electrical equipment; is usually the receiving point for more than one supply circuit to transform power from one voltage to another or from one system to another. Add Informational Note: While substations typically contain voltages greater than 1000V, voltages less than 1000V may be present. Add definition of Power Distribution Center in Part I of Art. 100 to replace the removal of Substation. Additional Proposed Changes File Name Description Approved PDC_definition.docx This is a new definition to cover those instances where Substation doesn't apply due to voltage level. I was part of the task group that removed the term "Substation" from Part I. While I'm in agreement with this change, this has left a void for large enclosures, similar to a building and substations, that are found throughout the world containing voltages less than 1000V. If "Substation" is now going to mean that voltages greater than 1000V must exist within the enclosure or outdoor installation, then we need to fill the void left by removing the term from Part I of Art There are "Power Distribution Centers" also known in the industry as substations that only contain voltages less than 1000V. Also, it's a little misleading by placing the term "Substation" in Part II, as there are typically other voltages present such as SCADA, DCS, Instrumentation, station control power, lighting and HVAC circuits that are less than 1000V. Adding the informational note to the new definition of Substation in Part II would clarify that voltages less than 1000V may be present in addition to the medium and high voltages. First Revision No NFPA [Definition: Substation.] Submitter Full Name: Paul Guidry Organization: Fluor Enterprises, Inc. Affilliation: Associated Builders and Contractors Submittal Date: Thu Sep 17 09:53:46 EDT 2015

6 Art. 100 Definitions Power Distribution Center- An assemblage of equipment containing switches, interrupting devices, protection relays, buses, transformers, switchgear, motor control centers, etc., through which electric energy is passed for the purpose of switching or modifying characteristics. A Power Distribution Center is generally of such size or complexity that it incorporates one or more buses and a multiplicity of electrical equipment; is usually the receiving point for more than one supply circuit to transform power from one voltage to another or from one system to another. Informational Note: A Power Distribution Center differs from a Substation in that there are no voltages over 1000V present inside the enclosure.

7 3 of /1/ :02 AM Public Comment No NFPA [ Definition: Substation. ] Substation. An assemblage of equipment containing switches, interrupting devices, protection relays, buses, transformers, switchgear, motor control centers, etc through which electric energy is passed for the purpose of switching or modifying characteristics. A substation is generally of such size or complexity that it incorporates one or more buses and a multiplicity of electrical equipment; is usually the receiving point for more than one supply circuit to transform power from one voltage to another or from one system to another. The Correlating Committee directs the panel to give further consideration to the comments expressed in voting on FR First Revision No NFPA [Definition: Substation.] Submitter Full Name: CC on NEC-AAC Organization: NFPA Submittal Date: Mon Sep 28 14:32:04 EDT 2015

8 92 of /1/ :02 AM Public Comment No NFPA [ Section No ] Scope. This article covers the installation and construction specifications of cabinets, cutout boxes, and meter socket enclosures. It does not apply to equipment operating at over 1000 volts, except as specifically referenced elsewhere in the Code. The Correlating Committee directs the panel to give further consideration to the comments expressed in voting on FR First Revision No NFPA [Section No ] Submitter Full Name: CC on NEC-AAC Organization: NFPA Submittal Date: Mon Sep 28 15:55:25 EDT 2015

9 93 of /1/ :02 AM Public Comment No NFPA [ Section No (B) ] (B) Metal Cabinets, Cutout Boxes, and Meter Socket Enclosures. Where metal enclosures within the scope of this article are installed with messenger-supported wiring, open wiring on insulators, or concealed knob-and-tube wiring, conductors shall enter through insulating bushings or, in dry locations, through flexible tubing extending from the last insulating support and firmly secured to the The device or equipment is listed and evaluated for installation within any listed enclosure. The addition of (B) would limit the installation of devices and equipment to only those enclosures that they were specifically assessed within by qualified test labs. Due to the large number of enclosures currently on the market, and the even greater number of discontinued enclosures already in the field, this requirement is so burdensome as to be completely impractical, and would result in the elimination of any 3rdparty devices from the market. These 3rdparty devices have proven to be the only viable way of addressing the current install base of enclosures across the US. 3rdparty devices fill a critical role in the growth of renewable energy by providing the necessary sensor data to optimally manage a home s participation on the grid. Lack of such information will hinder the deployment of technologies such as solar, battery storage, microgrid and demand response which are key to achieving a stable, sustainable grid. In their statement regarding this proposed change, CMP9 references an earlier proposal to allow the installation of utilization equipment which was rejected in the 2011 cycle. We recognize that the wide variety of existing devices classified as utilization equipment and not designed for installation inside enclosures could result in obstruction and hazard. However, we propose that a device specifically designed for installation within any listed enclosures and evaluated by qualified test lab for installation inside any listed enclosures can be safely installed. In order to provide clarity, we suggest the NEC specifies that a device may only be installed inside an enclosure if it is listed and approved for installation inside any listed enclosure by a qualified test lab. The installation of the device must not force any components (e.g. splices, taps, conductors) out of compliance with the NEC. To address CMP9 s concerns about obstructions in the enclosure, we propose a limit on the amount of space that can be occupied by the device, splices, taps and conductors in any crosssectional area. Evaluation of this limit should should be performed by the Inspector during the standard inspection process. A field evaluation would not be practical as no network of evaluators exists that could handle the required volume.

10 94 of /1/ :02 AM First Revision No NFPA [Section No ] Submitter Full Name: Jarl Meagher Organization: [ Not Specified ] Submittal Date: Fri Sep 25 14:41:35 EDT 2015

11 95 of /1/ :02 AM Public Comment No. 376-NFPA [ Section No (C) ] (C) Cables. Where cable is used, each cable shall be secured to the cabinet, cutout box, or meter socket enclosure. Exception: Cables with entirely nonmetallic sheaths shall be permitted to enter the top of a surface-mounted enclosure through one or more nonflexible raceways not less than 450 mm (18 in.) and not more than 3.0 m (10 ft) in length, provided all of the following conditions are met: (a) (b) Each cable is fastened within 300 mm (12 in.), measured along the sheath, of the outer end of the raceway. The raceway extends directly above the enclosure and does not penetrate a structural ceiling. (c) A fitting is provided on each end of the raceway to protect the cable(s) from abrasion and the fittings remain accessible after installation. (d) The raceway is sealed or plugged at the outer end using approved means so as to prevent access to the enclosure through the raceway. (e) The cable sheath is continuous through the raceway and extends into the enclosure beyond the fitting not less than 6 mm ( 1 4 in.). (f) The raceway is fastened at its outer end and at other points in accordance with the applicable article. (g) Where installed as conduit or tubing, the cable fill does not exceed the amount that would be permitted for complete conduit or tubing systems by Table 1 of Chapter 9 of this Code and all applicable notes thereto. Note 2 to Chapter 9, Table 1, Note 2 Tables does not apply to this condition. Informational Note: See Table 1 in Chapter 9, including Note 9, for allowable cable fill in circular raceways. See (B)(3) (a) for required ampacity reductions for multiple cables installed in a common raceway. The notes in Chapter 9, do not apply to Table 1, they apply to the tables contained in Chapter 9. First Revision No NFPA [Section No (C)] Submitter Full Name: MIKE HOLT Organization: MIKE HOLT ENTERPRISES INC Submittal Date: Tue Aug 04 19:48:03 EDT 2015

12 96 of /1/ :02 AM Public Comment No NFPA [ Section No (A) ] (A) Width of Wiring Gutters. Conductors shall not be deflected within a cabinet or cutout box unless a gutter having a width in accordance with Table 312.6(A) is provided. Conductors in parallel in accordance with (H) shall be judged on the basis of the number of conductors in parallel. Table 312.6(A) Minimum Wire-Bending Space at Terminals and Minimum Width of Wiring Gutters Wire Size (AWG or kcmil) Wires per Terminal All Other Conductors Compact Stranded AA-8000 Aluminum Alloy Conductors (see Note 2) mm in. mm in. mm in. mm in. mm in Not specified / / /0 2/0 3/0 4/ /0 4/ Note: Bending space at terminals shall be measured in a straight line from the end of the lug or wire connector (in the direction that the wire leaves the terminal) to the wall, barrier, or obstruction. 2. This column shall be permitted to be used to determine the required minimum wire-bending space for compact stranded aluminum conductors in sizes up to 1000 kcmil and manufactured using AA-8000 series electrical grade aluminum alloy conductor material in accordance with (B). The minimum width of the wire gutter space shall be determined using the all other conductors value in this table. The NEMA wire bending study to validate the inclusion of AA-8000 AL wire bending allowances to this table is well underway. The results will be available by the second draft meeting. First Revision No NFPA [Section No (A)] Submitter Full Name: Chad Kennedy Organization: Schneider Electric Submittal Date: Wed Sep 23 10:45:17 EDT 2015

13 97 of /1/ :02 AM Public Comment No NFPA [ Section No (A) ]

14 98 of /1/ :02 AM (A) Width of Wiring Gutters.

15 99 of /1/ :02 AM Conductors shall not be deflected within a cabinet or cutout box unless a gutter having a width in accordance with Table 312.6(A) is provided. Conductors in parallel in accordance with (H) shall be judged on the basis of the number of conductors in parallel. Table 312.6(A) Minimum Wire-Bending Space at Terminals and Minimum Width of Wiring Gutters Wire Size (AWG or kcmil) All Other Conductors Compact Stranded AA-8000 Aluminum Alloy Conductors (see Note 2) /0 1 2/ /0 4/ Wires per Terminal mm in. mm in. mm in. mm in. mm in. Not specified /0 2/0 3/0 4/ Note: Bending space at terminals shall be measured in a straight line from the end of the lug or wire connector (in the direction that the wire leaves the terminal) to the wall, barrier, or obstruction.

16 00 of /1/ :02 AM 2. This column shall be permitted to be used to determine the required wire-bending space for compact stranded aluminum conductors in sizes up to 1000 kcmil and manufactured using AA-8000 series electrical grade aluminum alloy conductor material in accordance with (B). The minimum width of the wire gutter space shall be determined using the all other conductors value in this table. The concept presented has merit, but lacks substantiation. This Public Comment is to restore Table 312.6(A) to the text in the 2014 NEC First Revision No NFPA [Section No (A)] Submitter Full Name: Robert Osborne Organization: UL LLC Submittal Date: Fri Sep 25 14:20:46 EDT 2015

17 01 of /1/ :02 AM Public Comment No NFPA [ Section No (A) ] (A) Width of Wiring Gutters. Conductors shall not be deflected within a cabinet or cutout box unless a gutter having a width in accordance with Table 312.6(A) is provided. Conductors in parallel in accordance with (H) shall be judged on the basis of the number of conductors in parallel. Table 312.6(A) Minimum Wire-Bending Space at Terminals and Minimum Width of Wiring Gutters Wire Size (AWG or kcmil) Wires per Terminal All Other Conductors Compact Stranded AA-8000 Aluminum Alloy Conductors (see Note 2) mm in. mm in. mm in. mm in. mm in Not specified / / /0 2/0 3/0 4/ /0 4/ Note: Bending space at terminals shall be measured in a straight line from the end of the lug or wire connector (in the direction that the wire leaves the terminal) to the wall, barrier, or obstruction. 2. This column shall be permitted to be used to determine the required wire-bending space for compact stranded aluminum conductors in sizes up to 1000 kcmil and manufactured using AA-8000 series electrical grade aluminum alloy conductor material in accordance with (B). The minimum width of the wire gutter space shall be determined using the all other conductors value in this table. The Correlating Committee directs the panel to give further consideration to the comments expressed in voting on FR First Revision No NFPA [Section No (A)] Submitter Full Name: CC on NEC-AAC Organization: NFPA Submittal Date: Mon Sep 28 15:56:21 EDT 2015

18 02 of /1/ :02 AM Public Comment No NFPA [ Section No ] (A) Switch and Overcurrent Device Enclosures. The wiring space within enclosures for switches and overcurrent devices shall be permitted for other wiring and equipment only as provided in (A) and (B). with Splices, Taps, and Feed-Through Conductors. The wiring space of enclosures for switches or overcurrent devices shall be permitted for conductors feeding through, spliced, or tapping off to other enclosures, switches, or overcurrent devices where all of the following conditions are met: (1) The total of all conductors installed at any cross section of the wiring space does not exceed 40 percent of the crosssectional area of that space. (2) The total area of all conductors, splices, taps, devices and equipment installed taps installed at any cross section of the wiring space does not exceed 75 percent of the cross-sectional area of that space. (3) A warning label complying with (B) is applied to the enclosure that identifies the closest disconnecting means for any feed-through conductors. (B) Devices and Equipment. The wiring space of enclosures for switches or overcurrent devices shall be permitted for devices and equipment where all of the following conditions are met: (1) The device or equipment is identified as a field installable accessory as part of the listed equipment, or is a listed kit evaluated for field installation in the specific equipment (2) The total area of all conductors, splices, taps, devices, and equipment at any cross section of the wiring space does not exceed 75 percent of the cross-sectional area of that space. As originally worded, this proposal appears to prohibit the field installation of truly an infinite number of flange and/or surface mounted devices whereby terminations must protrude into the interior panel enclosure space. Specific to electrical wiring devices, potentially affected products could include manual controllers, flanged straight blade and locking inlets and outlets, cam-type panel mount devices and IEC 309 pin & sleeve receptacles. In each case, the device terminations protrude inside of the enclosure if they are panel mounted on the exterior of the panelboard or motor control center. These are not atypical applications; similarly, it places a completely unreasonable burden on the manufacturers of these devices to ensure that replacement kits or the flange/surface mounted devices themselves are listed to the (once again) infinite number of panelboard and/or motor control center products offered by industry. The request here is to revert to the existing 2014 NFPA 70 text for NEC Thank you. Public Input No NFPA [Section No ] First Revision No NFPA [Section No ] Submitter Full Name: Stephen Rood Organization: Legrand North America Submittal Date: Wed Sep 23 11:31:54 EDT 2015

19 03 of /1/ :02 AM Public Comment No NFPA [ Section No ] (A) Switch and Overcurrent Device Enclosures. The wiring space within enclosures for switches and overcurrent devices shall be permitted for other wiring and equipment only as provided in (A) and (B). Enclosures with Splices, Taps, and Feed-Through Conductors, and Power Monitoring Equipment. The wiring space of within enclosures for switches or and overcurrent devices shall be permitted for listed power monitoring equipment, conductors feeding through, spliced, or tapping off to other enclosures, switches, or : overcurrent overcurrent devices where all of the following conditions are met. (1) The total of all conductors installed at any cross section of the wiring space does not exceed 40 percent of the crosssectional area of that space. (2) The total area of all conductors, splices, taps, devices and equipment installed and listed power monitoring equipment installed at any cross section of the wiring space does not exceed 75 percent of the cross-sectional area of that space. (3) A warning label complying with (B) is applied to the enclosure that identifies the closest disconnecting means for any feed-through conductors. (B) Devices and Equipment. The wiring space of enclosures for switches or overcurrent devices shall be permitted for devices and equipment where all of the following conditions are met: (1) The device or equipment is identified as a field installable accessory as part of the listed equipment, or is a listed kit evaluated for field installation in the specific equipment (2) The total area of all conductors, splices, taps, devices, and equipment at any cross section of the wiring space does not exceed 75 percent of the cross-sectional area of that space. The inclusion of devices and equipment is too broad and verification that all safety aspects were addressed would be very difficult. Power monitoring equipment could be installed using the general rules of this section without impacting the performance of the overcurrent devices installed in the enclosure. First Revision No NFPA [Section No ] Submitter Full Name: Chad Kennedy Organization: Schneider Electric Submittal Date: Wed Sep 23 12:26:31 EDT 2015

20 05 of /1/ :02 AM Public Comment No NFPA [ Section No ] Switch and Overcurrent Device Enclosures. The wiring space within enclosures for switches and overcurrent devices shall be permitted for other wiring and equipment only as provided in (A) and (B). (A) Splices, Taps, and Feed-Through Conductors. The wiring space of enclosures for switches or overcurrent devices shall be permitted for conductors feeding through, spliced, or tapping off to other enclosures, switches, or overcurrent devices where all of the following conditions are met: (1) The total of all conductors installed at any cross section of the wiring space does not exceed 40 percent of the crosssectional area of that space. (2) The total area of all conductors, splices, taps, devices and equipment installed at any cross section of the wiring space does not exceed 75 percent of the cross-sectional area of that space. (3) A warning label complying with (B) is applied to the enclosure that identifies the closest disconnecting means for any feed-through conductors. (B) Devices and Equipment. The wiring space of enclosures for switches or overcurrent devices shall be permitted for devices and equipment where all of the following conditions are met: (1) The device or equipment is identified as a field installable accessory as part of the listed equipment, or is a listed kit the device or equipment is listed as being evaluated for field installation in the specific equipment switch or overcurrent device enclosures. (2) The total area of all conductors, splices, taps, devices, and equipment installed at any cross section of the wiring space does not exceed 75 percent of the cross-sectional area of that space. As noted in the substantiation to FR 2404, this revisions is intended to limit the inclusion of devices and equipment in a wiring space to those that are identified as field installable accessories as part of the listed equipment, or as a listed kit evaluated for field installation in the specific equipment. The phrase "listed kit evaluated for field installation in the specific equipment" may be interpreted as requiring a kit to include an itemized list of the "specific equipment" with which the kit is compatible. Additionally, this equipment may be provided in designs which are not considered a "kit". As the original submitter of the Public Input which generated the First Revision, I am providing a Public Comment which is intended to clarify a portion of this requirement in a way that is consistent with my original intent. The substantive change to the wording in 312.8(B)(1) ("...the device or equipment is listed as being evaluated for field installation in switch or overcurrent device enclosures.") would meet the original intent, which is to ensure the added device or equipment is listed equipment that has been evaluated for field installation in the application. The UL category for "Energy-Monitoring Current Transformers" (XOBA) is an example of equipment that would satisfy this requirement. First Revision No NFPA [Section No ] Submitter Full Name: Robert Osborne Organization: UL LLC Submittal Date: Thu Sep 24 09:56:30 EDT 2015

21 06 of /1/ :02 AM Public Comment No NFPA [ Section No ] Switch and Overcurrent Device Enclosures. The wiring space within enclosures for switches and overcurrent devices shall be permitted for other wiring and equipment only as provided in (A) and (B). (A) Splices, Taps, and Feed-Through Conductors. The wiring space of enclosures for switches or overcurrent devices shall be permitted for conductors feeding through, spliced, or tapping off to other enclosures, switches, or overcurrent devices where all of the following conditions are met: (1) The total area of all conductors installed at any cross section of the wiring space does not exceed 40 percent of the crosssectional area of that space. (2) The total area of all conductors, splices, taps, devices and equipment installed at any cross section of the wiring space does not exceed 75 percent of the cross-sectional area of that space. (3) A warning label complying with (B) is applied to the enclosure that identifies the closest disconnecting means for any feed-through conductors. (B) Devices and Equipment. The wiring space of enclosures for switches or overcurrent devices shall be permitted for to be occuplied by devices and equipment where all of the following conditions are met: (1) The device or equipment is identified as a field installable accessory as part of the listed equipment, or is a listed kit evaluated for field installation in the specific equipment switch and overcurrent device enclosures, and (2) The total area of all conductors, splices, taps, devices, and equipment installed at any cross section of the wiring space does not exceed 75 percent of the cross-sectional area of that space. As originally worded, it appears this proposal would prohibit the installation of current transformers or meters for energy monitoring in any switch and overcurrent device enclosures unless every possible current transformer or meter was evaluated and listed for use in every possible enclosure. If this interpretation is correct, it puts a financially insurmountable burden on the submetering industry. The industry as a whole has an excellent safety record with respect to recognized and listed metering devices placed within switch and overcurrent device enclosures. The success of such applications over multiple decades of use, together with the originally proposed wording for [Part B] seems, in practice, to effectively limit devices permitted within switch and overcurrent device enclosures to only those made by the enclosure manufacturer and could thus be perceived within the context of restraint of trade as anti-competitive. First Revision No NFPA [Section No ] Submitter Full Name: Christopher Dent Organization: [ Not Specified ] Submittal Date: Thu Sep 24 10:25:02 EDT 2015

22 07 of /1/ :02 AM Public Comment No NFPA [ Section No ] Switch and Overcurrent Device Enclosures. The wiring space within enclosures for switches and overcurrent devices shall be permitted for other wiring and equipment only as provided in (A) and (B). (A) Splices, Taps, and Feed-Through Conductors. The wiring space of enclosures for switches or overcurrent devices shall be permitted for conductors feeding through, spliced, or tapping off to other enclosures, switches, or overcurrent devices where all of the following conditions are met: (1) The total area of all conductors installed at any cross section of the wiring space does not exceed 40 percent of the crosssectional area of that space. (2) The total area of all conductors, splices, taps, devices and equipment installed at any cross section of the wiring space does not exceed 75 percent of the cross-sectional area of that space. (3) A warning label complying with (B) is applied to the enclosure that identifies the closest disconnecting means for any feed-through conductors. (B) Devices and Equipment. The wiring space of enclosures for switches or overcurrent devices shall be permitted for to be occuplied by devices and equipment where all of the following conditions are met: (1) The device or equipment is identified as a field installable accessory as part of the listed equipment, or is a listed kit evaluated for field installation in the specific equipment switch and overcurrent device enclsoures, and (2) The total area of all conductors, splices, taps, devices, and equipment installed at any cross section of the wiring space does not exceed 75 percent of the cross-sectional area of that space. As originally worded, it appears this proposal would prohibit the installation of current transformers or meters for energy monitoring in any switch and overcurrent device enclosures unless every possible current transformer or meter was evaluated and listed for use in every possible enclosure. If this interpretation is correct, it puts a financially insurmountable burden on the submetering industry. The industry as a whole has an excellent safety record with respect to recognized and listed metering devices placed within switch and overcurrent device enclosures. The success of such applications over multiple decades of use, together with the originally proposed wording for [Part B] seems, in practice, to effectively limit devices permitted within switch and overcurrent device enclosures to only those made by the enclosure manufacturer and could thus be perceived within the context of restraint of trade. First Revision No NFPA [Section No ] Submitter Full Name: Alexei Holstein Organization: Veris Industries Submittal Date: Thu Sep 24 10:33:56 EDT 2015

23 08 of /1/ :02 AM Public Comment No NFPA [ Section No ] (A) Switch and Overcurrent Device Enclosures. The wiring space within enclosures for switches and overcurrent devices shall be permitted for other wiring and equipment only as provided in (A) and (B). with Splices, Taps, and Feed- Through Though Conductors. The wiring space of enclosures for switches or overcurrent devices shall be permitted for conductors feeding through, spliced, or tapping off to other enclosures, switches, or overcurrent devices where all of the following conditions are met: (1) The total of all conductors installed at any cross section of the wiring space does not exceed 40 percent of the crosssectional area of that space. (2) The total area of all conductors, splices, taps, devices and equipment installed at any cross section of the wiring space does not exceed 75 percent of the cross-sectional area of that space. (3) A warning label complying with (B) is applied to the enclosure that identifies the closest disconnecting means for any feed-through conductors. (B) Devices and Equipment. The wiring space of enclosures for switches or overcurrent devices shall be permitted for devices and equipment where all of the following conditions are met: (1) The device or equipment is identified as a field installable accessory as part of the listed equipment, or is a listed kit evaluated for field installation in the specific equipment (2) The total area of all conductors, splices, taps, devices, and equipment at any cross section of the wiring space does not exceed 75 percent of the cross-sectional area of that space. This FR should be revised to delete the new 312.8(B) and revert back to the NEC 2014 language with only the addition of "devices and equipment". The original PI3091 cited "proliferation of devices and equipment" as substantiation for the change, however, the PI did not include any data that can be substantiated as saftey concerns and how the PI would address those concerns. This proposal would effectively prohibit the installation of LISTED current transformers or meters for energy monitoring in any switch and overcurrent device enclosures, unless every possible current transformer or meter was evaluated and listed for use in every posible enclosure in their every possible internal, both factory and field installed, configurations. this will put a financially insurmountable burden and a vitrually impossible requirement on, but not limited to, the submetering industry, and to effectively limit all devices within switch and overcurrent device enclosures to only those made by the enclosure manufacturer and could thous be percieved within the context of restraint of trade. Additionally, this proposal will slow the introduction of new enclosure models as well as prohibiting entry of new enclosure manufacturers/suppliers, because all new enclosures will lack products "listed" for use with/within them. Bust most of all, the submetering industry as a whole has had an excellent safety record with respect to recognized and listed metering devices placed within switch and overcurrent device enclosured, and the original PI had provided no evidence to prove otherwise. It seems that if the committee was concernd with maintaining adequate wiring space, the solution would be to include "devices and equipment" as part of the cross section calculations, as proposed in 312.8(A)(@) of FR2404. First Revision No NFPA [Section No ] Submitter Full Name: Andrew Kriegman Organization: Leviton Manufacturing Company, Submittal Date: Fri Sep 25 13:25:03 EDT 2015

24 09 of /1/ :02 AM Public Comment No NFPA [ Section No ] Switch and Overcurrent Device Enclosures with Splices, Taps, Feed-Through Conductors, and Power Monitoring or measuring Equipment. The wiring space within enclosures for switches and overcurrent devices shall be permitted for other wiring and equipment only as provided in (A) and (B). listed power monitoring or measuring equipment, conductors feeding through, spliced, or tapping off to other enclosures, switches, or overcurrent devices where all of the following conditions are met. (A) Splices, Taps, and Feed-Through Conductors. The wiring space of enclosures for switches or overcurrent devices shall be permitted for listed power monitoring or measuring equipment, conductors feeding through, spliced, or tapping off to other enclosures, switches, or overcurrent devices where all of the following conditions are met: (1) The total of all conductors installed at any cross section of the wiring space does not exceed 40 percent of the crosssectional area of that space. (2) The total area of all conductors, splices, taps, devices and equipment installed listed power monitoring or measuring equipment installed at any cross section of the wiring space does not exceed 75 percent of the cross-sectional area of that space. (3) A warning label complying with (B) is applied to the enclosure that identifies the closest disconnecting means for any feed-through conductors. (B) Devices and Equipment. The wiring space of enclosures for switches or overcurrent devices shall be permitted for devices and equipment where all of the following conditions are met: (1) The device or equipment is identified as a field installable accessory as part of the listed equipment, or is a listed kit evaluated for field installation in the specific equipment (2) The total area of all conductors, splices, taps, devices, and equipment at any cross section of the wiring space does not exceed 75 percent of the cross-sectional area of that space. Section in the NEC-2014 permits Splices, Taps, and Feed-Through Conductors in the wiring space. The installation of listed monitoring or measuring equipment in industrial buildings, multiuse commercial, university campus buildings and Government facilities is vital to determine their energy usage and develop programs to reduce their energy consumption and carbon footprint. Components of the listed monitoring or measuring equipment may need to be in the wire bending space of the equipment that is already installed to accomplish this. The current section does not address this equipment and does not provide any guidance to the AHJ. With no guidance it may prevent the installation of equipment needed to meet this important emerging need or lead to unsafe installation. FR 2404 as written can be confusing because of the use of devices and equipment. It is unclear if the requirement applies to all equipment in the enclosure and how one would distinguish the wiring space from the equipment space for some types of enclosures, particularly those used for industrial control equipment. This proposal specifically addresses energy management or measuring equipment that is installed in the wiring space. It is the addition of this equipment that is the issue at present and is what the FR should address. Adding the requirement for Listed equipment and applying the same area limitation will enhance the safety of the installation. The language of the proposal also establishes enforceable guidelines for the AHJ through the Listing and specific area requirements. This proposal also supports the important trend of energy measurement enabling conservation and reduction of carbon footprint. Many municipalities are in process of or are considering legislating energy measurement. The code should be aligned with this emerging need while providing the guidance for safe installations. Public Input No NFPA [Section No ] Submitter Full Name: THOMAS PAPALLO Organization: SIEMENS Affilliation: Siemens

25 10 of /1/ :02 AM Submittal Date: Fri Sep 25 15:09:41 EDT 2015

26 11 of /1/ :02 AM Public Comment No NFPA [ Section No ] Switch and Overcurrent Device Enclosures. The wiring space within enclosures for switches and overcurrent devices shall be permitted for other wiring and equipment only as provided in (A) and (B). (A) Splices, Taps, and Feed-Through Conductors. The wiring space of enclosures for switches or overcurrent devices shall be permitted for conductors feeding through, spliced, or tapping off to other enclosures, switches, or overcurrent devices where all of the following conditions are met: (1) The total of all conductors installed at any cross section of the wiring space does not exceed 40 percent of the crosssectional area of that space. (2) The total area of all conductors, splices, taps, devices and equipment installed at any cross section of the wiring space does not exceed 75 percent of the cross-sectional area of that space. (3) A warning label complying with (B) is applied to the enclosure that identifies the closest disconnecting means for any feed-through conductors. (B) Devices and Equipment. The wiring space of enclosures for switches or overcurrent devices shall be permitted for devices and equipment where all of the following conditions are met: (1) The device or equipment is identified as a field installable accessory as part of the listed equipment, or is a listed kit listed and evaluated for field installation in the specific equipment installation within any listed enclosure (2) The total area of all conductors, splices, taps, devices, and equipment at any cross section of the wiring space does not exceed 75 percent of the cross-sectional area of that space. The addition of (B) would limit the installation of devices and equipment to only those enclosures that they were specifically assessed within by qualified test labs. Due to the large number of enclosures currently on the market, and the even greater number of discontinued enclosures already in the field, this requirement is so burdensome as to be completely impractical, and would result in the elimination of any 3rdparty devices from the market. These 3rdparty devices have proven to be the only viable way of addressing the current install base of enclosures across the US. 3rdparty devices fill a critical role in the growth of renewable energy by providing the necessary sensor data to optimally manage a home s participation on the grid. Lack of such information will hinder the deployment of technologies such as solar, battery storage, microgrid and demand response which are key to achieving a stable, sustainable grid. In their statement regarding this proposed change, CMP9 references an earlier proposal to allow the installation of utilization equipment which was rejected in the 2011 cycle. We recognize that the wide variety of existing devices classified as utilization equipment and not designed for installation inside enclosures could result in obstruction and hazard. However, we propose that a device specifically designed for installation within any listed enclosures and evaluated by qualified test lab for installation inside any listed enclosures can be safely installed. In order to provide clarity, we suggest the NEC specifies that a device may only be installed inside an enclosure if it is listed and approved for installation inside any listed enclosure by a qualified test lab. The installation of the device must not force any components (e.g. splices, taps, conductors) out of compliance with the NEC. To address CMP9 s concerns about obstructions in the enclosure, we propose a limit on the amount of space that can be occupied by the device, splices, taps and conductors in any crosssectional area. Evaluation of this limit should should be performed by the Inspector during the standard inspection process. A field evaluation would not be practical as no network of evaluators exists that could handle the required volume. First Revision No NFPA [Section No ] Submitter Full Name: Doug Brouwer Organization: EKM Metering Inc

27 12 of /1/ :02 AM Submittal Date: Fri Sep 25 16:40:39 EDT 2015

28 13 of /1/ :02 AM Public Comment No. 606-NFPA [ Section No ] Switch and Overcurrent Device Enclosures. The wiring space within enclosures for switches and overcurrent devices shall be permitted for other wiring and equipment only as provided in (A) and (B). (A) Splices, Taps, and Feed-Through Conductors. The wiring space of enclosures for switches or overcurrent devices shall be permitted for conductors feeding through, spliced, or tapping off to other enclosures, switches, or overcurrent devices where all of the following conditions are met: (1) The total of all conductors installed at any cross section of the wiring space does not exceed 40 percent of the crosssectional area of that space. (2) The total area of all conductors, splices, taps, devices and equipment installed at any cross section of the wiring space does not exceed 75 percent of the cross-sectional area of that space. (3) A warning label complying with (B) is applied to the enclosure that identifies the closest disconnecting means for any feed-through conductors. (B) Devices and Equipment. The wiring space of enclosures for switches or overcurrent devices shall be permitted for to be occupied by devices and equipment where all of the following conditions are met: (1) The device or equipment is identified as a field installable accessory as part of the listed equipment, or is a listed kit kit evaluated for field installation in the specific equipment switch and overcurrent device enclosures and (2) The total area of all conductors, splices, taps, devices, and equipment at any cross section of the wiring space does not exceed 75 percent of the cross-sectional area of that space. As originally worded, it appears this would prohibit the installation of current transformers or meters for energy monitoring in any switch and overcurrent device enclosures unless every possible current transformer or meter was evaluated and listed for use in every possible enclosure. If this interpretation is correct, it puts a financially insurmountable burden on the submetering industry. The industry as a whole has an excellent safety record with respect to recognized and listed metering devices placed within switch and overcurrent device enclosures. The success of such applications over multiple decades of use, together with the originally proposed wording for [Part B] seems, in practice, to effectively limit devices permitted within switch and overcurrent device enclosures to only those made by the enclosure manufacturer and could thus be perceived within the context of restraint of trade. First Revision No NFPA [Section No ] Submitter Full Name: Ryan Fetgatter Organization: Davidge Controls Submittal Date: Fri Sep 11 13:10:11 EDT 2015

29 14 of /1/ :02 AM Public Comment No. 977-NFPA [ Section No ] (A) Switch and Overcurrent Device Enclosures. The wiring space within enclosures for switches and overcurrent devices shall be permitted for other wiring and equipment only as provided in (A) and (B)., with Splices, Taps and Feed-Through Conductors. The wiring space of enclosures for switches or overcurrent devices shall be permitted for conductors feeding through, spliced, or tapping off to other enclosures, switches, or overcurrent devices where all of the following conditions are met: (1) The total of all conductors installed at any cross section of the wiring space does not exceed 40 percent of the crosssectional area of that space. (2) The total area of all conductors, splices, and taps, devices and equipment installed at any cross section of the wiring space does not exceed 75 percent of the cross-sectional area of that space. (3) A warning label complying with (B) is applied to the enclosure that identifies the closest disconnecting means for any feed-through conductors. (B) Devices and Equipment. The wiring space of enclosures for switches or overcurrent devices shall be permitted for devices and equipment where all of the following conditions are met: (1) The device or equipment is identified as a field installable accessory as part of the listed equipment, or is a listed kit evaluated for field installation in the specific equipment (2) The total area of all conductors, splices, taps, devices, and equipment at any cross section of the wiring space does not exceed 75 percent of the cross-sectional area of that space. As proposed, this First Revision FR 2404 (and the Public Input PI 3091) revision to NEC is neither enforceable as worded, practicable in application, nor sufficiently justified to warrant these changes. Revert to existing 2014 text for NEC FIELD-INSTALLABLE ACCESSORIES AS PART OF LISTED EQUIPMENT and LISTED KITS Public Input PI 3091 that served as the basis for First Revision FR 2404 rationalized these changes: There is a proliferation of devices and equipment intended by non-oem s to be installed in enclosures containing PANELBOARDS. Article 408 covers panelboards; Article 312, by contrast, covers CABINETS. These are typically EMPTY enclosures that are populated by equipment that the electrician provides at the installation. Firstly, NEC Article 312 has no requirement that cabinets, as defined in Article 100, be listed. Indeed, such cabinets presently may be field-fabricated for the installation. Yet NEC as revised by FR 2404 mandates that these devices and equipment be either LISTED accessories or LISTED kits in relation to these enclosures. Even those electrical enclosures that are listed do so in accordance with UL Standard UL 50. These are empty enclosures, typically listed by ENCLOSURE manufacturers who do NOT make any of the devices or equipment that go inside or are attached to such UL 50 enclosures. Those devices and equipment are manufactured by manufacturers with specialization and competence to manufacture such devices and equipment. As such, there has ALWAYS been a proliferation of devices and equipment made by OTHER THAN the cabinet enclosure manufacturers. If there are specific hazards for panelboards, identify exactly what they are and address them in Article 408, not in Article 312. To now require that manufacturers of such devices and equipment get them listed for EACH and EVERY enclosure manufacturer s cabinets is fundamentally unachievable. Certainly, the enclosure manufacturers do not have the resources or desire to list as an accessory or kits EACH and EVERY device and equipment that could potentially go in or on their enclosures. As proposed, the 312.8(B)(1) wording of PI 3091 and FR 2404 is not remotely achievable, especially when cabinets onto themselves are not required by Article 312 to be listed. ENCLOSURE GEOMETRY NEC 312.6(A) and Table 312.6(A) establish the width of passages for conductors called wiring gutters. The width requirement is