AGENDA. NEC Code-Making Panel 12. Report on Comment Meeting. Dates: November 28 December 1, Redondo Beach, CA

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1 National Fire Protection Association 1 Batterymarch Park, Quincy, MA Phone: Fax: AGENDA NEC Code-Making Panel 12 Report on Comment Meeting Dates: November 28 December 1, 2012 Redondo Beach, CA Panel 12 will have four Task group meetings on Wednesday, November 28, 2012 with the full panel meeting starting on Thursday, November 29, Article 646 Task Group 8am to 10 am Article 645 Task Group 10am to 12pm Article 625 Task Group 1pm to 3pm Editorial Task Group 3pm to 5pm Item No. Subject Call to Order Chair Timothy M. Croushore Introduction of Members and Guests Chair - Croushore Review of Meeting Procedures and Revision Schedule NFPA Staff Comments/Questions from Committee Members and/or Guests Task Group Reports 1. Article 646 Modular Data Centers Task Group John Kovacik 2. Article 645 Information Technology Equipment Re-organization Task Group Stan Kauffman 3. Article 625 Electric Vehicle Task Group Gery Kissel 4. Editorial Task Group Tim Croushore Processing of Comments for NEC 2014 (Order Determined by Editorial Task Group) Fire Protection Research Foundation Requests NFPA Staff

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9 12-1 Log #165 NEC-P12 Technical Correlating Committee on National Electrical Code, The Correlating Committee directs that the panel clarify the panel action with regard to the specific text that is to be added and deleted in This is a direction from the National Electrical Code Technical Correlating Committee in accordance with and of the Regulations Governing Committee Projects Log #1031 NEC-P12 Mike Holt, Mike Hold Enterprises 12-15a Reject the addition of the second informational note. This informational note is unnecessary. Do we really need a note that tells me that a different note is a note? When does it end? Should we add this note in front of all of the informational notes in the Code? 12-3 Log #611 NEC-P12 James F. Williams, Fairmont, WV 12-15a Includes audible and visual equipment such as chimes, gongs, lights, and displays, and voice output that convey information to the user. A lot of modern (and not so modern) elevator equipment uses recorded or generated speech to alert passengers Log #604 NEC-P12 James F. Williams, Fairmont, WV 12-15a Informational Note No. 1: The motor controller, motion controller, and operation controller are located in a single enclosure or a combination of enclosures. Informational Note No. 2: Informational Note Figure is for information only. If the reader doesn't understand that is informational only, then how does this Informational Note help? 1 Page 8 of 75

10 12-5 Log #748 NEC-P12 James T. Dollard, Jr., IBEW Local Continue to Accept. This comment is submitted on behalf of the high voltage task to provide additional substantiation as directed by the Correlating Committee. The High Voltage Task Group (HVTG) was charged with developing recommendations throughout the NEC to provide the code user with prescriptive requirements for high voltage installations. The task group charge was to identify holes in the code with respect to installations operating at over 600-volts and address them with recommended requirements to allow for uniform installation and enforcement. Small Wind Electric Systems and Solar Photovoltaic (PV) Systems are currently being installed at DC voltages over 600V up to and including 1000V, 1200V, 1500V, and 2000V DC. These DC systems are expanding and have become a more integral part of many structures. Small Wind Electric Systems and Solar Photovoltaic (PV) Systems are employed regularly in, and on all types of structures from dwellings units, to large retail and high rise construction. The first direction that the HVTG took was to simply suggest revisions in Chapter 6 for Special Equipment. It is extremely important to fully understand the outline form of the NEC. Section 90.3 mandates that Chapters 1 through 4 apply generally and Chapters 5, 6 and 7 are special and serve only to modify or supplement the rules in Chapters 1 through 4. The HVTG quickly realized that it was not feasible to address all of the installation requirements in Chapter 6. The work needs to be done throughout the NEC. The special systems in Chapter 6 are built primarily upon Chapters 1 through 4 with the Chapter 6 requirements providing only modifications or supplemental requirements. A quick review of the UL White-book for electrical products will uncover that UL has many products that are utilized in these systems rated at and above 600-volts including but not limited to, 600Vdc terminal blocks, 1000Vdc PV switches, 1500Vdc PV fuses, and 2000V PV wiring. Product listings provide permitted uses and restrictions on a given product. The NEC must recognize those products through installation requirements. Electrical safety in the home, workplace and in all venues depends upon installation requirements to ensure that all persons and property are not exposed to the hazards of electricity. The success of this code hinges on three things (1) product standards, (2) installation requirements and (3) enforcement. The NEC needs to recognize emerging technologies that are operating at over 600-volts. Everyone needs to play a role in this transition. The present NEC requirements would literally require that a PV system operating at 750-volts DC utilize a disconnecting means rated at 5 kv. The manufacturers, research and testing laboratories and the NEC must work together to develop installation requirements and product standards to support these emerging technologies. Moving the NEC threshold from 600 volts to 1000 volts will not, by itself, allow the immediate installation of systems at 1000-volts. Equipment must first be tested and found acceptable for use at the higher voltage(s). The testing and listing of equipment will not, by itself, allow for the installation of 1000 volt-systems. The NEC must include prescriptive requirements to permit the installation of these 1000-volt systems. It will take both tested/listed equipment and an installation code to meet the needs of these emerging technologies that society demands. The installation code should be the NEC. Moving the NEC to 1000 volts is just the beginning. The desire to keep increasing efficiencies will continue to drive up the system voltages. We are beginning to see 1200, 1500, and 2000-volt systems volts cannot be far down the road. Most equipment standards are still at 600 volts and will need to be upgraded also. If the NEC does not adequately address systems over 600 volts, some other standard will. If we want to control the future safety of installations over 600 volts we need to address these issues today. 2 Page 9 of 75

11 12-6 Log #749 NEC-P12 James T. Dollard, Jr., IBEW Local Continue to Accept in Principle. This comment is submitted on behalf of the high voltage task to provide additional substantiation as directed by the Correlating Committee. The High Voltage Task Group (HVTG) was charged with developing recommendations throughout the NEC to provide the code user with prescriptive requirements for high voltage installations. The task group charge was to identify holes in the code with respect to installations operating at over 600-volts and address them with recommended requirements to allow for uniform installation and enforcement. Small Wind Electric Systems and Solar Photovoltaic (PV) Systems are currently being installed at DC voltages over 600V up to and including 1000V, 1200V, 1500V, and 2000V DC. These DC systems are expanding and have become a more integral part of many structures. Small Wind Electric Systems and Solar Photovoltaic (PV) Systems are employed regularly in, and on all types of structures from dwellings units, to large retail and high rise construction. The first direction that the HVTG took was to simply suggest revisions in Chapter 6 for Special Equipment. It is extremely important to fully understand the outline form of the NEC. Section 90.3 mandates that Chapters 1 through 4 apply generally and Chapters 5, 6 and 7 are special and serve only to modify or supplement the rules in Chapters 1 through 4. The HVTG quickly realized that it was not feasible to address all of the installation requirements in Chapter 6. The work needs to be done throughout the NEC. The special systems in Chapter 6 are built primarily upon Chapters 1 through 4 with the Chapter 6 requirements providing only modifications or supplemental requirements. A quick review of the UL White-book for electrical products will uncover that UL has many products that are utilized in these systems rated at and above 600-volts including but not limited to, 600Vdc terminal blocks, 1000Vdc PV switches, 1500Vdc PV fuses, and 2000V PV wiring. Product listings provide permitted uses and restrictions on a given product. The NEC must recognize those products through installation requirements. Electrical safety in the home, workplace and in all venues depends upon installation requirements to ensure that all persons and property are not exposed to the hazards of electricity. The success of this code hinges on three things (1) product standards, (2) installation requirements and (3) enforcement. The NEC needs to recognize emerging technologies that are operating at over 600-volts. Everyone needs to play a role in this transition. The present NEC requirements would literally require that a PV system operating at 750-volts DC utilize a disconnecting means rated at 5 kv. The manufacturers, research and testing laboratories and the NEC must work together to develop installation requirements and product standards to support these emerging technologies. Moving the NEC threshold from 600 volts to 1000 volts will not, by itself, allow the immediate installation of systems at 1000-volts. Equipment must first be tested and found acceptable for use at the higher voltage(s). The testing and listing of equipment will not, by itself, allow for the installation of 1000 volt-systems. The NEC must include prescriptive requirements to permit the installation of these 1000-volt systems. It will take both tested/listed equipment and an installation code to meet the needs of these emerging technologies that society demands. The installation code should be the NEC. Moving the NEC to 1000 volts is just the beginning. The desire to keep increasing efficiencies will continue to drive up the system voltages. We are beginning to see 1200, 1500, and 2000-volt systems volts cannot be far down the road. Most equipment standards are still at 600 volts and will need to be upgraded also. If the NEC does not adequately address systems over 600 volts, some other standard will. If we want to control the future safety of installations over 600 volts we need to address these issues today. 3 Page 10 of 75

12 12-7 Log #166 NEC-P12 Technical Correlating Committee on National Electrical Code, 12-18a The Correlating Committee directs that be rewritten in mandatory language to comply with the NEC Style Manual. In addition, the text as proposed conflicts with the Article 100 definition of "Exposed Live Parts" since exposed live parts are not suitably guarded or insulated. This is a direction from the National Electrical Code Technical Correlating Committee in accordance with and of the Regulations Governing Committee Projects Log #348 NEC-P12 Andy Juhasz, Kone, Inc a Working Clearances. Working space shall be provided about controllers, disconnecting means, and other electrical equipemnt. The mimimum working space shall be not less thant hat specified in (A). The clearance requirements of (A) shall be waived Wwhere conditions of maintenance and supervision ensure that only qualified persons examine, adjust, service and maintain the equipment, the clearance requirements of (A) shall be waived as permitted in 620.5(A) through (D) and: (A) Flexible Connections to Equipment. Electrical equipment in (A)(1) through (A)(4) shall be permitted to be is provided with flexible leads to all external connections so that it can be repositioned to meet the clear working space requirements of (A): (1) Controllers and disconnecting means for dumbwaiters, escalators, moving walks, platform lifts and stairway chairlifts installed in the same space witht he driving machine (23) Controllers and disconnecting means for elevators installed in the hoistway or on the care (3) Controllers for door operators (4) Other electrical equipment installed in the hoistway or on the car; or (B) Guards. Live parts of the electrical equipment are suitably guarded, isolated, or insulated, and the equipment can be examined, adjusted, serviced, or maintained while energized without removal of this protection. or Informational Note: See definition of Exposed in Article 100 (C) Examination, Adjusting, and Servicing. Electrical equipment is not required to be examined, adjusted, serviced, or maintained while energized. or (D) Low Voltage. Uninsulated parts are at a voltage not greater than 30 volts rms, 42 volts peak, or 60 volts dc has been rewritten in mandatory language to comply with the NEC Style Manual and has not added the word "exposed" so as not to create any conflicts with the definitions in Article 100. This is being submitted on behalf of Andy Juhasz and Tim Croushore to address the comments of the TCC. 4 Page 11 of 75

13 12-9 Log #612 NEC-P12 James F. Williams, Fairmont, WV 12-19a Conductors shall have an ampacity in accordance with (A) through (D). With generator field control, the conductor ampacity shall be based on the nameplate current rating of the driving motor of the motor-generator set that supplies power to the elevator motor. Informational Note No. 1: The heating of conductors depends on root-mean-square current values, which, with generator field control, are reflected by the nameplate current rating of the motor-generator driving motor rather than by the rating of the elevator motor, which represents actual but short-time and intermittent full-load current values. Conductors supplying a single motor shall have an ampacity not less than the percentage of motor nameplate current determined from (A) and (E). Informational Note: Some elevator motor currents, or those of similar functions, exceed the nameplate value, but because they are inherently intermittent duty and the heating of the motor and conductors is dependent on the root-mean-square (rms) current value, conductors are sized for duty cycle service as shown in Table (E). Conductors supplying a single motor controller shall have an ampacity not less than the motor controller nameplate current rating, plus all other connected loads. Motor controller nameplate current rating shall be permitted to be derived based on the rms value of the motor current using an intermittent duty cycle and other control system loads, if present. Conductors shall have an ampacity in accordance with (A) through (D). With generator field control, the conductor ampacity shall be based on the nameplate current rating of the driving motor of the motor-generator set that supplies power to the elevator motor. Informational Note No. 1: The heating of conductors depends on root-mean-square rms current values, which, with generator field control, are reflected by the nameplate current rating of the motor-generator driving motor rather than by the rating of the elevator motor, which represents actual but short-time and intermittent full-load current values. Conductors supplying a single motor shall have an ampacity not less than the percentage of motor nameplate current determined from (A) and (E). Informational Note: Some elevator motor currents, or those of similar functions, exceed the nameplate value, but because they are inherently intermittent duty and the heating of the motor and conductors is dependent on the root-mean-square (rms) current value, conductors are sized for duty cycle service as shown in Table (E). Conductors supplying a single motor controller shall have an ampacity not less than the motor controller nameplate current rating, plus all other connected loads. Motor controller nameplate current rating shall be permitted to be derived based on the rms value of the motor current using an intermittent duty cycle and other control system loads, if present 'rms' is never referenced in the rest of the text in connection with current, only with voltage. 'rms' is not really related to duty cycle as suggested in (A). OR The dominate form of reference to root-mean-square is rms in the rest of the text. 5 Page 12 of 75

14 12-10 Log #349 NEC-P12 Andy Juhasz, Kone, Inc b Add an asterisk in the second column title as follows "Demand Factor*" and revise the Information Note as follows: Informational Note: *Demand factors are based on 50 percetn duty cycle (i.e., half time on and half time off) The note to Table has been clarified as shown in the proposal. This is being submitted on behalf of Andy Juhasz and Tim Croushore to address the comments of the TCC Log #167 NEC-P12 Technical Correlating Committee on National Electrical Code, 12-19b The Correlating Committee directs the panel clarify the note based upon and of the NEC Style Manual with respect to mandatory text. This is a direction from the National Electrical Code Technical Correlating Committee in accordance with and of the Regulations Governing Committee Projects Log #168 NEC-P12 Technical Correlating Committee on National Electrical Code, The Correlating Committee directs that the panel write the Exception in a complete sentence to comply with the last sentence in of the NEC Style Manual. This is a direction from the National Electrical Code Technical Correlating Committee in accordance with and of the Regulations Governing Committee Projects. 6 Page 13 of 75

15 12-13 Log #347 NEC-P12 Andy Juhasz, Kone, Inc Revise text to read as follows: Wiring Methods. Conductors and optical fibers located in hoistways, in escalator and moving walk wellways, in platform lifts, stairway chairlift runways, machinery spaces, control spaces, in or on cars, in machine rooms and control rooms, not including the traveling cables connecting the car or counterweight and hoistway wiring, shall be installed in rigid metal conduit, intermediate metal conduit, electrical metallic tubing, rigid nonmetallic conduit, or wireways, or shall be Type MC, MI, or AC cable unless otherwise permitted in (A) through (C). Exception: Cords and cables of Llisted cord and plug connected equipment shall not be required to be installed in a raceway. (A) Elevators. (1) Hoistways. (a) Cables used in Class 2 power-limited circuits shall be permitted to be installed between risers and signal equipment and operating devices, provided the cables are supported and protected The exception to has been written as a complete sentence. This is being submitted on behalf of Andy Juhasz and Tim Croushore to address the comments of the TCC Log #613 NEC-P12 James F. Williams, Fairmont, WV Conductors and optical fibers located in hoistways, in escalator and moving walk wellways, in platform lifts, stairway chairlift runways, machinery spaces, control spaces, in or on cars, in machine rooms and control rooms, not including the traveling cables connecting the car or counterweight and hoistway wiring, shall be installed in rigid metal conduit, intermediate metal conduit, electrical metallic tubing, rigid nonmetallic conduit, or wireways, or shall be Type MC, MI, or AC cable unless otherwise permitted in (A) through (C). The new exception is the size of a barn door. It would allow microwaves, curling irons, and blenders in elevator shafts with standard cordage. It is completely out of line with the almost 3 pages of requirements for wiring in Page 14 of 75

16 12-15 Log #750 NEC-P12 James T. Dollard, Jr., IBEW Local Continue to Accept. This comment is submitted on behalf of the high voltage task to provide additional substantiation as directed by the Correlating Committee. The High Voltage Task Group (HVTG) was charged with developing recommendations throughout the NEC to provide the code user with prescriptive requirements for high voltage installations. The task group charge was to identify holes in the code with respect to installations operating at over 600-volts and address them with recommended requirements to allow for uniform installation and enforcement. Small Wind Electric Systems and Solar Photovoltaic (PV) Systems are currently being installed at DC voltages over 600V up to and including 1000V, 1200V, 1500V, and 2000V DC. These DC systems are expanding and have become a more integral part of many structures. Small Wind Electric Systems and Solar Photovoltaic (PV) Systems are employed regularly in, and on all types of structures from dwellings units, to large retail and high rise construction. The first direction that the HVTG took was to simply suggest revisions in Chapter 6 for Special Equipment. It is extremely important to fully understand the outline form of the NEC. Section 90.3 mandates that Chapters 1 through 4 apply generally and Chapters 5, 6 and 7 are special and serve only to modify or supplement the rules in Chapters 1 through 4. The HVTG quickly realized that it was not feasible to address all of the installation requirements in Chapter 6. The work needs to be done throughout the NEC. The special systems in Chapter 6 are built primarily upon Chapters 1 through 4 with the Chapter 6 requirements providing only modifications or supplemental requirements. A quick review of the UL White-book for electrical products will uncover that UL has many products that are utilized in these systems rated at and above 600-volts including but not limited to, 600Vdc terminal blocks, 1000Vdc PV switches, 1500Vdc PV fuses, and 2000V PV wiring. Product listings provide permitted uses and restrictions on a given product. The NEC must recognize those products through installation requirements. Electrical safety in the home, workplace and in all venues depends upon installation requirements to ensure that all persons and property are not exposed to the hazards of electricity. The success of this code hinges on three things (1) product standards, (2) installation requirements and (3) enforcement. The NEC needs to recognize emerging technologies that are operating at over 600-volts. Everyone needs to play a role in this transition. The present NEC requirements would literally require that a PV system operating at 750-volts DC utilize a disconnecting means rated at 5 kv. The manufacturers, research and testing laboratories and the NEC must work together to develop installation requirements and product standards to support these emerging technologies. Moving the NEC threshold from 600 volts to 1000 volts will not, by itself, allow the immediate installation of systems at 1000-volts. Equipment must first be tested and found acceptable for use at the higher voltage(s). The testing and listing of equipment will not, by itself, allow for the installation of 1000 volt-systems. The NEC must include prescriptive requirements to permit the installation of these 1000-volt systems. It will take both tested/listed equipment and an installation code to meet the needs of these emerging technologies that society demands. The installation code should be the NEC. Moving the NEC to 1000 volts is just the beginning. The desire to keep increasing efficiencies will continue to drive up the system voltages. We are beginning to see 1200, 1500, and 2000-volt systems volts cannot be far down the road. Most equipment standards are still at 600 volts and will need to be upgraded also. If the NEC does not adequately address systems over 600 volts, some other standard will. If we want to control the future safety of installations over 600 volts we need to address these issues today. 8 Page 15 of 75

17 12-16 Log #169 NEC-P12 Technical Correlating Committee on National Electrical Code, The Correlating Committee directs that this proposal be reconsidered and correlated with the action taken on Proposal This is a direction from the National Electrical Code Technical Correlating Committee in accordance with and of the Regulations Governing Committee Projects Log #350 NEC-P12 Andy Juhasz, Kone, Inc Revise text to read as follows: (1) On Elevators Without Generator Field Control. On elevators without generator field control, the disconnecting means shall be located within sight of the motor field controller. Where the motor controller is located in the elevator hoistway, the disconnecting means required by (A) shall be located in a machinery space, machine room, control space or control room outside the hoistway; and an additional, fused or non-fused externally operable motor circuit switch that is lockable open in accordance with capable of being locked in the open position to disconnect all ungrounded main power-supply conductors shall be located within sight of the motor controller. The additional switch shall be a listed device and shall comply with (C). The provision for locking or adding a lock to the disconnecting means, required by this section, shall be installed on or at the switch or circuit breaker used as the disconnecting means and shall remain in place with or without the lock installed. Portable means for adding a lock to the switch or circuit breaker shall not be permitted. Driving machines or motion and operation controllers not within sight of the disconnecting means shall be provided with a manually operated switch installed in the control circuit to prevent starting. The manually operated switch(es) shall be installed adjacent to this equipment. Where the driving machine of an electric elevator or the hydraulic machine of a hydraulic elevator is located in a remote machine room or remote machinery space, a single means for disconnecting all ungrounded main power supply conductors shall be provided and be lockable open in accordance with capable of being locked in the open position. Proposal has been correlated with proposal to show the complete final wording. This is being submitted on behalf of Andy Juhasz and Tim Croushore to address the comments of the TCC Log #1235 NEC-P12 Richard E. Loyd, Sun Lakes, AZ 2-46 Reconsider and Accept this proposal or accept in part. accept The disconnecting means shall be an enclosed externally operable fused motor circuit switch or circuit breaker capable of being locked in the open position and shall be located in the machine room or control room for that elevator car. While attending the Southern section IAEI meeting this change was explained and it seems the proposed text from the submitter is much clearer than the wording revised by the committee. 9 Page 16 of 75

18 12-19 Log #796 NEC-P12 Joseph M. Bablo, UL LLC Revise text to read as follows: Informational Note No. 2: UL ,, is a safety standard for Electric Vehicle Supply Equipment. UL ,, is a safety standard for Electric Vehicle Charging Equipment. The referenced date in the proposal would not be correct. The actual date for the standard would be Log #776 NEC-P12 Gregory C. Nieminski, Gregory C. Nieminski, LLC Revise text to read as follows: An apparatus designed to control and organize unused lengths of cable or cord at electric vehicle charging sites. The term "cable management system has been used in the new Article (C) but is not defined. The term is presently used and defined in Article 626. It is proposed that the same definition be added to or, alternatively, that the term be defined commonly in Article 100. This comment is submitted on behalf of the EPRI Electric Transportation Infrastructure Working Council's NEC Task Force. 10 Page 17 of 75

19 12-21 Log #480 NEC-P12 Marcelo M. Hirschler, GBH International Revise text to read as follows: An automotive-type vehicle for on-road use, such as passenger automobiles, buses, trucks, vans, neighborhood electric vehicles, electric motorcycles, and the like, primarily powered by an electric motor that draws current from a rechargeable storage battery, fuel cell, photovoltaic array, or other source of electric current. Plug-in hybrid electric vehicles (PHEV) are considered electric vehicles. For the purpose of this article, off-road, self-propelled electric vehicles, such as industrial trucks, hoists, lifts, transports, golf carts, airline ground support equipment, tractors, boats, and the like, are not included. Plug-in hybrid electric vehicles (PHEV) shall be considered electric vehicles. For the purpose of this article, off-road, self-propelled electric vehicles, such as industrial trucks, hoists, lifts, transports, golf carts, airline ground support equipment, tractors, boats, and the like, are not included. Both the electric vehicle connector and the electric vehicle inlet shall be considered a part of the electric vehicle coupler. For the purposes of this Code, the electric vehicle inlet shall be considered to be part of the of the electric vehicle and not part of the electric vehicle supply equipment. I accept the concept that NEC definitions are not required to be in single sentences. However this definition contains a list of examples and such examples are not usually contained in definitions. Moreover, the information included should really be considered a requirement. If the CMP agrees that this is a requirement it should be placed somewhere else in Article 625, and a new section 625.3, on general requirements, is the perfect location, since NEC definitions shall not contain requirements. Moreover, the NEC manual of style does not permit the definition to contain the defined term and the second sentence of the definition contains the term electric vehicle. The sections in and are associated with the comments to proposals and The NEC Manual of Style states as follows: Definitions. Definitions shall be in alphabetical order and shall not contain the term that is being defined. Definitions shall not contain requirements or recommendations. 11 Page 18 of 75

20 12-22 Log #481 NEC-P12 Marcelo M. Hirschler, GBH International Revise text to read as follows: A device that, by insertion into an electric vehicle inlet, establishes an electrical connection to the electric vehicle for the purpose of power transfer and information exchange. This device is part of the electric vehicle coupler. Plug-in hybrid electric vehicles (PHEV) shall be considered electric vehicles. For the purpose of this article, off-road, self-propelled electric vehicles, such as industrial trucks, hoists, lifts, transports, golf carts, airline ground support equipment, tractors, boats, and the like, are not included. Both the electric vehicle connector and the electric vehicle inlet shall be considered a part of the electric vehicle coupler. For the purposes of this Code, the electric vehicle inlet shall be considered to be part of the of the electric vehicle and not part of the electric vehicle supply equipment. I accept the concept that NEC definitions are not required to be in single sentences. However this definition contains a requirement. If the CMP agrees that this is a requirement it should be placed somewhere else in Article 625, and a new section 625.3, on general requirements, is the perfect location, since NEC definitions shall not contain requirements. Moreover, the NEC manual of style does not permit the definition to contain the defined term. The sections in through are associated with the comments to proposals and also. The NEC Manual of Style states as follows: Definitions. Definitions shall be in alphabetical order and shall not contain the term that is being defined. Definitions shall not contain requirements or recommendations Log #774 NEC-P12 Gregory C. Nieminski, Gregory C. Nieminski, LLC Revise text to read as follows: Electric Vehicle Connector Electric Vehicle Connector It appears that the term was crossed out inadvertently in the NEC Committee Report on Proposals, A2013 (page ,printed version), and should remain. This comment is submitted on behalf of the EPRI Electric Transportation Infrastructure Working Council's NEC Task Force. 12 Page 19 of 75

21 12-24 Log #482 NEC-P12 Marcelo M. Hirschler, GBH International Revise text to read as follows: The device on the electric vehicle into which the electric vehicle connector is inserted for power transfer and information exchange. This device is part of the electric vehicle coupler. For the purposes of this the electric vehicle inlet is considered to be part of the electric vehicle and not part of the electric vehicle supply equipment. Plug-in hybrid electric vehicles (PHEV) shall be considered electric vehicles. For the purpose of this article, off-road, self-propelled electric vehicles, such as industrial trucks, hoists, lifts, transports, golf carts, airline ground support equipment, tractors, boats, and the like, are not included. Both the electric vehicle connector and the electric vehicle inlet shall be considered a part of the electric vehicle coupler. For the purposes of this Code, the electric vehicle inlet shall be considered to be part of the of the electric vehicle and not part of the electric vehicle supply equipment. I accept the concept that NEC definitions are not required to be in single sentences. However this definition contains a set of requirements. If the CMP agrees that this is a requirement it should be placed somewhere else in Article 625, and a new section 625.3, on general requirements, is the perfect location, since NEC definitions shall not contain requirements. Moreover, the NEC manual of style does not permit the definition to contain the defined term and the second sentence of the definition contains the term electric vehicle inlet. The sections in through are associated with the comments to proposals and also. The NEC Manual of Style states as follows: Definitions. Definitions shall be in alphabetical order and shall not contain the term that is being defined. Definitions shall not contain requirements or recommendations Log #1375 NEC-P12 Vince Baclawski, National Electrical Manufacturers Association (NEMA) Add new definition: Fastened In Place: equipment attached to a structure but removable without the use of tools, where the fastening means are specifically designed to facilitate the following: a. Ready removal for interchange b. Facilitate maintenance and repair c. Repositioning to another location The term or phrase fastened in place is not defined and subject to misinterpretation. The definition is needed for consistency throughout article Page 20 of 75

22 12-26 Log #775 NEC-P12 Gregory C. Nieminski, Gregory C. Nieminski, LLC Revise text to read as follows: An assembly consisting of an attachment plug cap and length of flexible cord that connects the equipment (E SE) to a receptacle. The term "attachment plug cap" appears only once in Article 625 in this definition. The primary term "attachment plug" is used everywhere else in Article 625 and should be used here for consistency. It is also the predominant term used in the NEC and defined in Article 100: Attachment Plug (Plug Cap) (Plug). A device that, by insertion in a receptacle, establishes a connection between the conductors of the attached flexible cord and the conductors connected permanently to the receptacle. Attachment plug cap is a term referring to an older design of an attachment plug that permitted the flexible cord to be knotted for strain relief purposes and covered by a "cap" that was part of the attachment plug assembly. The term is not used in LZ 191. Standard for Attachment Plugs and Receptacles, nor is the method of using a knot for strain relief purposes included in the Standard. This comment is submitted on behalf of the EPRI Electric Transportation Infrastructure Working Council's NEC Task Force Log #797 NEC-P12 Joseph M. Bablo, UL LLC Revise text to read as follows: The electric vehicle coupler shall comply with (A) through (F). The electric vehicle coupler shall be polarized unless part of a listed electric vehicle charging system or an electric vehicle supply equipment system. Exception: A coupler that is listed as part of the electric vehicle supply equipment. The intent of this clause would be that the coupler shall be polarized, but a non-polarized version is acceptable if part of a system that is listed. The word unless as indicated in the original proposal would infer that the coupler shall be polarized if part of a system that is not listed and non-polarized if part of a listed system. That is not the intent of the requirement. The proposed wording eliminates this possible interpretation of the clause by adding an exception that is identical to the format used in other parts of the article (see (A)(1) for example). 14 Page 21 of 75

23 12-28 Log #515 NEC-P12 Ken Jensen, Portland, OR Revise as follows: " Rating. Electrical vehicle supply equipment shall have sufficient rating to supply the load served. Electric vehicle charging loads shall be considered to be continuous loads for the purposes of this article. Where an automatic load management system is used, the maximum electric vehicle supply equipment load on a service or feeder or branch circuit shall be the maximum load permitted setting in use or communicated by the automatic load management system. The original TIA sentence in question is copied below: "Where an automatic load management system is used, the maximum electric vehicle supply equipment load on a service or feeder shall be the maximum load permitted by the automatic load management system." The first use of the word "maximum" is clear but, the second use of the word "maximum" is confusing when applied to Electric Vehicle Supply Equipment. Replacing the words "maximum load permitted" with "setting in use or communicated" clarify the intent of the NEC. I found there are two (2) ways of understanding or interpreting this "maximum load permitted" wording within TIA 1038 for NEC Today many EVSEs on-board chargers are built to use the standard called "Society of Automotive Engineers J1772". This standard addresses the problem that different premises EVSEs will have different rated ampacities and different electric vehicles will have different loads. SAE J1772 allows many combinations to interconnect with each other by having the premises EVSE communicate or provide to the electric vehicle on-board charger how much ampacity is available from that premises EVSE. Then the electric vehicle on-board charger must adjust or regulate the load so that is less than or equal to the available premises EVSE ampacity. The following text is copied from two (2) revisions of that standard. SAE J "5.3.5 EVSE Current Capacity - The EVSE provides the maximum available continuous current capacity, and by inference the rating of the protective circuit breaker, to the EV by modulating the pulse width..." SAE J "5.3.5 EVSE Current capacity - The EVSE communicates the maximum available continuous current capacity to the EV/HEV by modulating the pilot duty cycle..." Some EVSEs are built to offer a single fixed large communicated available current. However many EVSEs offer multiple or adjustable settings of communicated available current. One common EVSE I know of offers 15amp or 8amp settings. A second common EVSE I know of offers 12 amp, 16 amp, 24 amp, or 30 amp settings. Every single one of these different values is a maximum current value. So an EVSE with multiple settings has a group of maximum current values. The group also has a maximum of all the maximum current values. Which meaning does TIA 1038 NEC maximum mean? Is the maximum electric vehicle supply equipment load the real setting of the EVSE? Is the maximum electric vehicle supply equipment load the largest possible, worst case setting of the EVSE? Replacing "maximum load permitted" with "setting or communicated" means the NEC will allow a versatile installation of low demand low ampacity or medium demand medium ampacity, or high demand high ampacity. Adding the wording "or branch circuit" to NEC text simply reflect a common practice. EVSEs are often installed on a branch circuit. 15 Page 22 of 75

24 12-29 Log #798 NEC-P12 Joseph M. Bablo, UL LLC Revise text to read as follows: The electric vehicle supply equipment shall comply with (A) through (C). Where marking is required by (C) (A), the electric vehicle supply equipment shall be clearly marked by the manufacturer as follows: VENTILATION NOT REQUIRED The marking shall be located so as to be clearly visible after installation. The reference given is part of the old text and was not updated to the new renumbering structure of the rewritten article. The proposed reference would point to the correct clause Log #359 NEC-P12 Vince Baclawski, National Electrical Manufacturers Association (NEMA) Delete the exception. A power supply cord that is listed as a part of the electric vehicle supply equipment. There is no reason to deviate from the requirements of this section. There are already some instances of product not performing and there is not enough experience to be granting exceptions at this time. In addition the product standard is not clear as to this topic. Any and all equipment issues will reflect poorly on the industry and harm the efforts to promote this product Log #363 NEC-P12 Vince Baclawski, National Electrical Manufacturers Association (NEMA) Delete the article: Electric vehicle supply equipment that is rated 250 volts maximum and complies with all of the following: 1. It is part of a listed system meeting the requirements of , , and (B)(1) is redundant and could imply that these requirements do not apply to all EVSE, which they do. 16 Page 23 of 75

25 12-32 Log #360 NEC-P12 Vince Baclawski, National Electrical Manufacturers Association (NEMA) Delete the exception. A power supply cord that is listed as a part of the electric vehicle supply equipment. There is no reason to deviate from the requirements of this section. There are already some instances of product not performing and there is not enough experience to be granting exceptions at this time. In addition the product standard is not clear as to this topic. Any and all equipment issues will reflect poorly on the industry and harm the efforts to promote this product Log #361 NEC-P12 Vince Baclawski, National Electrical Manufacturers Association (NEMA) Revise text to read as follows: (C)(2) Where the electric vehicle supply equipment or charging system is fixed in place, the useable length of the output cable shall be measured from the cable exit of the electric vehicle supply equipment or charging system to the face of the electric vehicle connector. The term fixed in place shall include devices that are permanently wired as well as devices that are cord and plug connected and fastened in place where the fastening means are specifically designed to facilitate any of the following a. Ready removal for interchange b. Facilitate maintenance and repair c. Repositioning to another location The existing language could cause confusion. Adding this wording will clarify that the term fixed in place can include cord and plug connected devices and that they are not necessarily restricted by (C)(1) Log #170 NEC-P12 Technical Correlating Committee on National Electrical Code, The Correlating Committee directs that the panel clarify the panel statement on this proposal with respect to revised definitions for "Electric Vehicle Coupler" and "Electric Vehicle Interlock." This is a direction from the National Electrical Code Technical Correlating Committee in accordance with and of the Regulations Governing Committee Projects. 17 Page 24 of 75

26 12-35 Log #516 NEC-P12 Ken Jensen, Portland, OR A revised as follows: " Overcurrent Protection. Overcurrent protection for feeders and branch circuits supplying electric vehicle supply equipment shall be sized for continuous duty and shall have a rating of not less than 125 percent of the maximum load of the electric vehicle supply equipment. Where noncontinous loads are supplied from the same feeder or branch circuit, the overcurrent device shall have a rating of not less than the sum of the noncontinous loads plus 125 percent of the continuous loads. Where an automatic load management system is used to time shift multiple loads into sequential loads, the maximum load of the electric vehicle supply equipment shall be the maximum sequential load, for the purposes of this article. NEC article 100 defines "Continuous Load" to be 3 hours or more. Real world examples of electric vehicle charge times are more than 3 hours, but less than 24 hours. NEC 625 should clarify these questions. May an automatic load management system apply and use time of day control, to prevent multiple simultaneous continuous loads and instead create a single sequential non over lapping (time shipping) continuous load? Should all EVSE loads plan to be simultaneous loads? Here is an example of these two (2) questions Assume the following: A) Two electric vehicles in one garage B) Two EVSEs with automatic load management C) Both EVSEs are rated 30 amps available D) Both EVSEs are on the same circuit E) Both EVSE have time of day controls F) One EVSE is adjusted or set to only provide current from 10 PM to 2 AM (4 hours only) G) One EVSE is adjusted or set to only provide current from 2 AM to 6 AM (4 hours only) The time of day controls are set to never over lap, so the maximum load permitted by the automatic load management will be a single sequential 30 amp continuous load. So plan for a 30 amp continuous load. The real measured load is 30 amps for 8 hours. The time of day controls may be reset to enable two simultaneous 30 amp continuous loads. So plan for a 60 amp continuous load. Which of these is the intent of NEC ? 18 Page 25 of 75

27 12-36 Log #783 NEC-P12 Gregory C. Nieminski, Gregory C. Nieminski, LLC Revise text to read as follows: Personnel Protection System. The electric vehicle supply equipment shall have a listed system of protection against electric shock of personnel. The personnel protection system shall be composed of listed personnel protection devices and constructional features. Where cord-and-plug-connected electric vehicle supply equipment is used, the interrupting device of a listed personnel protection system shall be provided and shall be an integral part of the attachment plug or shall be located in the power supply cable not more than 300 mm (12 in.) from the attachment plug. (A) Where cord-and-plug-connected electric vehicle supply equipment, that is intended to be carried from charging location to charging location, is used, the interrupting device of a listed personnel protection system shall be provided and shall be an integral part of the attachment plug or shall be located in the power supply cable cord not more than 300 mm (12 in.) from the attachment plug. (B) Where cord-and-plug-connected electric vehicle supply equipment is intended to be installed in a dedicated location for the purpose of charging a vehicle, has a means for temporary mounting and can be dismounted without the use of a tool, the interrupting device of a listed personnel protection system shall be provided and shall be an integral part of the attachment plug or shall be located in the power supply cable cord not more than 1.2 m (4 ft) from the attachment plug. The panel statement recognizes there are conditions where a longer cord can be used safely. EVSEs other than portable units are generally intended to be installed in a dedicated location in order to charge a vehicle. Some may be moved or relocated after installation without the use of tools (cf. UL 2594), using a mounting means similar to that used for relocatable power taps described in UL 1363, Standard for Relocatable Power Taps. Since these units would typically be mounted m (2-3 feet) from the floor when in use, this would allow the safe use of a longer than 1 foot unprotected power supply cord yet provide adequate physical protection for the power supply cord against damage. The term power supply cable should be changed to power supply cord to align with the new definitions. This comment is submitted on behalf of the EPRI Electric Transportation Infrastructure Working Council's NEC Task Force. 19 Page 26 of 75

28 12-37 Log #799 NEC-P12 Joseph M. Bablo, UL LLC Revise text to read as follows: The electric vehicle supply equipment shall have a listed system of protection against electric shock of personnel. Where cord-and-plug connected electric vehicle supply equipment is used, the interrupting device of a listed personnel protection system shall be provided and shall be an integral part of the attachment plug or shall be located in the power supply cord not more than 300 mm (12 in.) from the attachment plug, unless the EVSE complies with (B), in which case the interrupting device may be located within the overall device enclosure. There is a disconnect between three clauses in the article, and this disconnect causes a problem in the interpretation of the wording in (B)(4). In order to clarify this intent, the wording is proposed to be added to Rationale is as follows: The intent of (B)(4) was to allow constructions where the interrupting device of the personnel protection system required by was located within the device enclosure, but the power cord was allowed to be longer than the 12 inches required by (A)(3)(a), due to the other requirements within (B) (A)(3)(a) limits the cord length to 12 inches because the interrupting device of the personnel protection system required by is located within the device enclosure (A)(3)(b) allows the cord length to be 6 feet minimum, 15 feet maximum, provided the interrupting device of the personnel protection system required by is located at the attachment plug or within 12 inches of the attachment plug. The current wording in supports this (B) states that a product can be cord connected provided it meets all the subclauses (1) through (5). Subclause 4 states that the power cord shall be maximum 6 feet. All this does is limit the overall length of the power cord to 6 feet. However, the intent of this proposal was to allow for a 6 foot cord length when the interrupting device of the personnel protection system required by was located within the enclosure. This would be a direct violation to (A)(3)(a) based on the current wording. The rationale for the wording in (B)(4) was that a device fixed in place, as required by (B)(3), would protect the cord by limiting the cord to 6 feet thereby keeping it off the floor and protected from abuse. In so doing, the need to protect the cord by limiting it to 12 inches is no longer required. Therefore, (B)(4) was proposed to allow a 6 foot cord length on products where the interrupting device of the personnel protection system was located within the device enclosure, but the device was wall mounted and fixed in place. In order to clarify this intent and allow constructions that were intended to be acceptable, the wording in is needed. 20 Page 27 of 75