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Permit Number: TC-COM-0423-01049
Parcel: 11619376C

Review Status: Requires Resubmit

Review Details: COMMERCIAL REVIEW - FULL v.4

Permit Number - TC-COM-0423-01049
Review Name: COMMERCIAL REVIEW - FULL v.4
Review Status: Requires Resubmit
Review Date Reviewer's Name Type of Review Description Status Comments
09/25/2023 Bldg Permits - Post Review PENDING ASSIGNMENT
09/25/2023 Commercial Electrical REQUIRES RESUBMIT Please address the electrical plan review comments and provide a written response. Please provide a response letter signed by the person responding.

Plan review summary;

This is the 4th formal electrical plan review. On 6-28-29, an in-person office meeting took place with ABCO Solar Company Owner and supervision personnel to discuss NEC Code and design issues for this project in an effort to provide an acceptable, Code compliant PV rooftop solar upgrade design and installation to an existing PV system. It was agreed that ABCO Solar Co would obtain the services of an Electrical Engineer to assess the electrical plans and seal the plans as required by the City of Tucson. The PV installation per this project was performed without the required permits and plan review per the City of Tucson Commercial Permit/ Plan Review and Submittal Requirements and Tucson Electric Power Utility Co policy for Interactive PV Inverter output interconnection and operation utilizing the Utility's Power Grid. These plan review submittals are an effort on ADCO Solars part to resolve the issues mentioned.

4th electrical plan review; There are still unresolved issues concerning Code compliance in the design and installation of the resubmitted plans.

1. The response letter submitted per this submittal did not address plan review comments #1 and #2 and started with a responses to plan review comment # 3. Review comment #3 is resolved.

2. Review comment #4 not resolved. 4. The existing 2000 amp service is equipped with Ground Fault Protection via the 2000 amp main breaker. The NEC requires the PV Interconnection to be a Supply Side Tap. The exception allows a ‘Load Side Interconnection, provided he 400 amp PV Back fed breaker be equipped with Ground Fault Interrupting capability per NEC 705.32. The “Designed Interconnection” does not meet the requirements of 705.12(B)(2) as stated due to the requirements of NEC 705.32.

Per the response Dated on 8-24-2023; Response #2; “ Ground fault protection is built into the inverter. Please see the documentation”. The “Technical "document mentioned in the response does not address ‘Ground Fault Protection’ on the AC Output side of the inverters. The Reference to NEC art 690.5 was relocated from the 2014 NEC to art 690.41 in the 2017 NEC and addresses ‘Ground Fault Protection’ on the DC part of PV arrays, not AC. The Reference to 690.35(C) was deleted from the 2017 NEC entirely. Both of these references are from the 2014 NEC. The currently adopted electrical Code (City of Tucson) is the 2017 NEC. Hence, the requirement for a supply side PV interconnection on ‘Ground Fault Protected’ service equipment. The Exception to this rule is to provide ‘Ground Fault Protection’ on the back fed device when utilizing a ‘Load side Interconnection’ per NEC art 705.32.

Please provide for a supply side PV interconnection as required per NEC art 705.32 and installed per NEC art 705.12(A),(B) and 705.31, or if utilizing a ‘Load Side interconnection’ per the exception of 705.32, the dedicated overcurrent device must be equipped with ‘Ground Fault Interrupting Capability’, or provide documentation from the manufacturer of the Inverter that it is indeed equipped with ‘Ground Fault Interrupting Capability’ on the AC Output circuit of the Inverter. The provided specifications on the plans did not provide this information. For Ground Fault Detection or Listing of the equipment as required per NEC 690 and plan specifications. Be advised. The supply side tap/ interconnection will require a field inspection and approval by an NRTL agency in order to maintain listing. A load side interconnection will require ‘Selective Coordination’ between Ground Fault devices to ensure proper operation. Either scenario will require the plans to be revised and clouded as per prior requests.

Ref; 2018 IBC section 107.1, 107.2.1, 2017 NEC, City of Tucson Commercial Permit/ Plan Submittal Requirements.
08/31/2023 PDSD Application Completeness REVIEW COMPLETED