The IEEE Committee developing the 2017 National Electrical Safety Code responded to our comments on the public review draft as shown below:

On Wed, Apr 6, 2016 at 2:00 PM, Sue Vogel <s.vogel@ieee.org> wrote:

Dear Mike,

Thank you for your review of the draft NESC 2017 edition and submission of comments resulting from the ANSI public review period. I did leave a voicemail for you yesterday, and would welcome the opportunity to discuss your comments. These have been reviewed by members of the NESC Executive Subcommittee, and the following responses are offered.

Section 014: Consider that the National Electrical Code sets the definition of “temporary installation” at 90 days.

Response: Thank you for sharing this information regarding the NEC. Please consider submitting a relevant change proposal for the NESC, for the 2022 edition.

Section 2 Definitions: A definition of “impedance grounding” would be helpful in identifying some grounding regimes are safer for electricians to perform their work.   It is noteworthy that “ungrounded system” appears in this section.

Response: Please consider submitting a relevant change proposal for the definition of “impedance grounding” for the NESC 2022 edition.

Section 3 References: While almost all of the content in this standard deals with line side of the service standards, please be aware that the IEEE Industrial Applications Society has re-crafted its “color books” into the 3000s-series of recommended practices.  These documents can make service point engineering and maintenance safer.

Response: Thank you for providing information regarding the IEEE “color books” 3000-series relevant to the NESC. It might be helpful to provide more specific information regarding the relevant 3000-series standards and where it relates to specific sections and rules of the NESC. Please consider submitting relevant change proposals for the NESC2022 edition.

Section 110.  Page 40.  Recommend that you add the word “written” at the end of the enclosure section.   Very often services do not change over decades and some paper evidence of the agreement is very helpful in the long run; for ownership and R.O.W. purposes.

Response: NESC ExSC members could not identify a specific place in Section 110 where your suggestion refers to.  Please consider submitting a relevant change proposal for theNESC, for the 2022 edition.

Section 31; There are so many changes to the rules for underground lines that they are beyond our ability to comment in the appropriate time frame.   They seem reasonable at first glance but they may require significant training.

Response: Thank you for your comment.

Three  overarching considerations: (Note that two overarching considerations are provided below)

A. The absence of renewable energy sources is noted.

Response: Your important point is noted. The NESC Main Committee established a Task Force on Emerging Technologies for the NESC in April 2015 to consider the development of change proposals regarding renewable energy sources for the NESC 2022 edition. The TF is led by members representing the Solar Energy Industries Association (SEIA) and includes representation from wind, energy storage, etc. If you have additional questions, or would like to consider participating in the TF, please let me know.

B.  Placement of IEEE C2 on a shorter revision cycle — maybe in on ANSI’s “continuous maintenance” platform might help to meet safety objectives more effectively.

Response: This is an important point, and no small matter. The NESC Main Committee also established a Task Force on an NESC Streamlined Process at its April 2015 meeting. Several ideas are being considered, which would allow a more timely review of technical matters and flexibility for the NESC between revision cycles.

Also, as a general response, the NESC is holding its second event, as a follow up to theNESC Summit held in April 2015 (http://standards.ieee.org/events/nesc-summit.html). We’ll be announcing an NESC Workshop: Changes for the Future, within the next week or so, and I’ll be sure to forward the information to you, in the hopes that you can attend. The NESC will continue to examine issues and topics for consideration in the 2022 edition and beyond. The Workshop will be held 18-19 October 2016 in San Antonio, TX. We would welcome your participation in the workshop, and within the NESC committee structure, as well.

One last item–as I am about to submit the final “paperwork” to ANSI for approval of theNESC 2017 edition, I would like to confirm that the comments you have submitted are not considered an “unresolved objection” to the NESC draft and process as a result of theNESC public review period, and are intended to inform the NESC leadership of your thoughts going forward.

I hope we are able to touch base soon. In the meantime, please give my regards to my long-time colleague from many IAS meetings, Jim Harvey.

Sincerely,

Sue Vogel