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Solar Photovoltaic (PV) Systems
And Energy Storage Systems
Frequently Asked Questions and Answers
Revised May 14, 2024
(This document is subject to change as solar PV, energy storage and other alternative energy
and distributed energy technologies and codes continue to evolve)
The following frequently asked questions and answers are a compendium of existing statutes, rules
and National Electrical Code (NEC) provisions that are applicable to all electrical installations, with a
special emphasis related to the installation of solar photovoltaic systems and energy storage systems.
The general licensing, code, equipment approval, inspection and other provisions
that follow are applicable to all electrical work and all electrical systems.
Electrical Licensing
Statutes, Rules and Code
EL-1) Are solar PV systems, including photovoltaic modules, panels and arrays, and their associated
components, considered to be electrical equipment under the State Electrical Code?
Answer: Yes. The State Electrical Code adopts by reference the 2023 edition of the National Electrical
Code (NEC). Solar photovoltaic systems fall within the definition of “equipment” as it is defined in the
NEC. See NEC Articles 100, 690, 691, 705 and other applicable articles for all pertinent definitions.
Accordingly, solar PV systems, including the placement, positioning and securement of photovoltaic
modules, panels and arrays, and their associated components and all electrical wiring, are electrical
equipment under the State Electrical Code.
(Reference the Board of Electricity Final Interpretation dated July 8, 2009 available at
http://www.dli.mn.gov/sites/default/files/pdf/SPS.pdf )
EL-2) How is the term “electrical work” defined in state law?
Answer: Minnesota Statute 326B.31, Subdivision 17, defines “electrical work” as follows:
Electrical work. "Electrical work" means the installing, altering, repairing, planning, or
laying out of electrical wiring, apparatus, or equipment for electrical light, heat, power,
technology circuits or systems, or other purposes. The installing, altering, repairing,
planning, or laying out of electrical wiring, apparatus, or equipment for electrical light,
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heat, power, technology circuits or systems, or other purposes includes, but is not limited
to, the performance of any work regulated by the standards referred to in section
326B.35.
EL-3) Are the solar PV systems that are regulated by the National Electrical Code considered “electrical
work”, as the term is defined in Minnesota Statute 326B.31, Subdivision 17?
Answer: Yes. Unless specifically exempt in Minnesota Statute Chapter 326B, all electrical work installed
in Minnesota is required to be installed in accordance with all applicable electrical licensing and
inspection requirements.
EL-4) Are there any specific licensing requirements, other than an electrical contractor’s license,
required to install a residential rooftop solar system?
Answer: Yes. A new law effective July 1, 2023, requires companies that contract with residential
homeowners to install solar photovoltaic (PV) systems on homes in Minnesota be licensed as a
residential building contractor or remodeler. This license requirement will allow homeowners to make
claims to the Contractor Recovery Fund in the event a solar company goes out of business, bankrupt or
is otherwise unable to complete a solar PV installation project, resulting in an out-of-pocket loss to the
homeowner.
All electrical work that is performed as part of the installation of a solar PV system must be performed
by a Minnesota-licensed electrical contractor. This change will not impact Minnesota-licensed electrical
contractors that are subcontracted by licensed residential building contractors and remodelers to
perform the installation of solar PV systems on residential structures. In addition, integrated-grounding
elements of the support system (racking) are classified as electrical work and must be installed by a
licensed electrical contractor.
Jobsite Attendance Rosters
EL-5) Are electrical contractors required to complete jobsite daily attendance records?
Answer: Yes, if so requested by the department. The department reserves the right to implement a
jobsite daily attendance record to ensure personal licensing compliance on large projects. Copies of the
daily attendance record must be provided to the electrical inspector when requested. Jobsite daily
attendance forms are available online. They are also available as an Excel file upon request:
http://www.dli.mn.gov/sites/default/files/pdf/ele_record.pdf
Jobsite Electrical License and Registration Checks
EL-6) Do electrical inspectors routinely check electrical license or registration cards?
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Answer: Yes. Electrical inspectors and department staff routinely check the electrical license or
registration cards either randomly or for all electrical workers on the project site. Unlicensed registered
individuals are required to carry their registration card when performing electrical work and must
present it to electrical inspectors upon request. Licensed electricians are also advised to carry their
license cards when performing electrical work. If an individual fails to present a valid license or
registration card it may result in a cessation of electrical work.
Electrical Material Handling
EL-7) Do individuals handling, unloading, and transporting electrical materials on a jobsite need to be
licensed or registered by the department?
Answer: No. Minnesota Statute 326B.31, Subdivision 17, defines “electrical work” as follows:
Electrical work. "Electrical work" means the installing, altering, repairing, planning, or
laying out of electrical wiring, apparatus, or equipment for electrical light, heat, power,
technology circuits or systems, or other purposes. The installing, altering, repairing,
planning, or laying out of electrical wiring, apparatus, or equipment for electrical light,
heat, power, technology circuits or systems, or other purposes includes, but is not limited
to, the performance of any work regulated by the standards referred to in section
326B.35.
When electrical materials are being managed on the project site (i.e. transporting, moving, stacking,
storing, uncrating, etc.) it is not considered to be “electrical work” as defined by Minnesota Statute,
therefore no licensing and registration for individuals would be required.
Racking Systems
Non-electrical racking systems
EL-8) Solar PV systems are generally installed on some form of structural support system
(racking) on building roofs, on poles, on the ground and on a wide variety of structures. Are the
non-electrical structural support systems considered to be “electrical work”, as the term is
defined in Minnesota Statute 326B.31, Subdivision 17?
Answer: Generally, no. (See EL-9 below for integrated-grounding racking systems). Non-
electrical equipment and non-electrical structural support elements that consist of brackets,
racking, purlins, blocking, frames, poles, concrete, roofing ballast, skids, anchors and similar are
not considered electrical work. Such structural support systems usually require professional
design by a registered structural engineer; this type of professional design work is not within
the scope or authority of any classification of Minnesota electrical license. See the following
website for professional design requirements: https://www.revisor.mn.gov/statutes/cite/326
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Totally-enclosed racking systems (no exposed conductors)
EL-9) Some solar PV systems use a support system that incorporates enclosed electrical
wireways (channels) and interconnecting electrical conduits that are used to provide structural
support for the individual solar PV modules and they also serve as raceways for electrical circuit
conductors. Is this type of support system, or portions thereof, considered to be “electrical
work”, as the term is defined in Minnesota Statute 326B.31, Subdivision 17?
Answer: Yes. This type of support system, or the applicable portions thereof, is considered to
be “electrical work”, as the term is defined in Minnesota Statute 326B.31, Subdivision 17.
Portions of the support system that includes wireways, conduits, raceways or other enclosed
channels expressly intended for electrical circuit conductors, or the extension of electrical
circuitry is considered electrical work.
Integrated-grounding type racking systems
EL-10) Some solar PV support systems provide structural support for the solar PV modules and
the metallic support system (structure) is identified or listed as an equipment grounding
conductor (in accordance with UL 2703, UL 1703, UL 467, etc.). Is this type of support system or
structure, or portions thereof, considered to be “electrical work”, as the term is defined in
Minnesota Statute 326B.31, Subdivision 17?
Answer: Yes. NEC Article 690 has specific requirements for such support systems or structures.
Electrical bonding for metallic racking systems
EL-11) Some solar PV support systems provide structural support for the solar PV modules and
the metallic support system may also be bonded to a grounding electrode and a grounding
electrode conductor, where the metallic support system may serve as a path for electrical
ground-faults (e.g. structural steel for a carport canopy) (See the definition of “ground-fault
current path” in the NEC). Is this type of metallic support system, or portions thereof,
considered to be “electrical work”, as the term is defined in Minnesota Statute 326B.31,
Subdivision 17?
Answer: Generally, no. Metallic structural support systems such as carport canopies or similar
structures that may serve as a path for ground-fault current does not automatically mean that
the installation of such structural support system is considered electrical work. There are
numerous metallic systems and elements in the built environment that serve as paths for
ground-fault current or that may also serve as a means for other forms of electrical grounding
and bonding, yet they are not considered to be electrical work. They could include, but not be
limited to, structural steel for buildings, carport canopies, etc., reinforcing steel, metal building
components, water piping, gas piping, ductwork, electrical shielding and the earth itself.
Grounding and bonding conductors and components
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EL-12) Is the installation of any of the following items considered to be “electrical work”, as the
term is defined in Minnesota Statute 326B.31, Subdivision 17?; Grounding and bonding
adapters, bushings, clamps, clips, conductors, couplings, devices, electrodes, fittings, grids,
hubs, jumpers, locknuts, lugs, mesh, plates, rods, shunts, straps, wedges, wires and similar.
Answer: Yes. The installation of electrical grounding and bonding conductors, apparatus,
components and similar is considered to be “electrical work”, as the term is defined in
Minnesota Statute 326B.31, Subdivision 17. All such electrical grounding and bonding
conductors, apparatus, components and similar are required to be identified and listed for the
purpose and installed in accordance with the manufacturer’s installation instructions.
Professional Engineering
EL-13) With respect to electrical or structural systems, are there other statutes and rules that may be
applicable to solar PV installations?
Answer: Yes. Minnesota Statutes 326.02, Subdivision 1 contains provisions that require licensure of
persons who practice or offer to practice professional engineering. The practice of professional
engineering is further defined in Minnesota Statute 326.02, Subdivision 2.
EL-14) Are licensed electrical contractors allowed to plan and layout their own electrical work?
Answer: Yes. Minnesota Statutes 326.02, Subdivision 5 states in pertinent part:
“Subd. 5. Limitation. The provisions of sections 326.02 to 326.15 shall not apply to…the
planning for and supervision of the construction and installation of work by an
electrical…contractor…as defined in and licensed pursuant to chapter 326B, where such
work is within the scope of such licensed activity and not within the practice of
professional engineering...”
EL-15) If someone has additional questions related to professional design and licensure, who should
they contact with their questions?
Answer: Please contact the Minnesota Board of Architecture and Engineering at
https://mn.gov/aelslagid/index.html or 651-296-2388.
Electrical Code and Technical
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EC-1) National Electrical Code
(NEC
)
Section 690.9 requires overcurrent devices for PV source and PV
output conductors to be accessible but does not require them to be readily accessible. What does the
NEC require or allow when the PV system is on a rooftop or an elevated structure? See the applicable
definitions below.
Answer: NEC Article 100 definitions:
Accessible (as applied to equipment) Admitting close approach; not guarded by locked
doors, elevation, or other effective means.
Accessible (as applied to wiring methods) Capable of being removed or exposed
without damaging the building structure or finish or not permanently closed in by the
structure or finish of the building.
Accessible, Readily (Readily Accessible) Capable of being reached quickly for operation,
renewal, or inspections without requiring those to whom access is requisite to actions
such as to use tools, to climb over or remove obstacles, or to resort to portable ladders,
and so forth.
The definitions are not intended to mean that equipment may not be elevated where it can be reached
with a portable ladder or located behind locked doors, when qualified persons who need access have
the necessary means to do so. The requirement states only that locked doors, elevation or other
effective means must not “guard” against access.
The overcurrent devices mounted on or behind modules or structural members of a PV system shall be
accessible without damaging the PV modules or the structure in order to permit safe access for
installers, maintenance personnel and the electrical inspector.
EC-2) NEC Section 690.31(A)(2) requires readily accessible PV source and PV output conductors over 30
volts to be guarded or installed in a raceway. What methods will be acceptable in order to comply with
the requirements for guarding or protecting PV conductors that are installed in readily accessible
locations?
Answer: NEC Article 100 defines guarded as covered, shielded, fenced, enclosed, or otherwise
protected by means of suitable covers, casings, barriers, rails, screens, mats, or platforms to remove
the likelihood of approach or contact by persons or objects to a point of danger. Most PV systems do
not have means for attaching raceways. The conductors would be considered “not readily accessible”
by using any of the items mentioned in the NEC definition or by elevation or location, provided the
conductors are high enough or located in such a manner to remove the likelihood that individuals
could approach or come into contact with conductors. Installations will be considered guarded when
access is limited to qualified persons.
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EC-3) Does the 2023 NEC have specific color code requirements for the identification of PV
conductors?
Answer: Yes. NEC Section 690.31(B) and 215.12(C)(2) state that each ungrounded conductor of direct-
current (dc) PV circuits and feeders shall be identified by polarity at all terminations, connections and
splice points by color coding, marking tape, tagging and other approved means. See NEC Sections
690.31(B) and 215.12(C)(2) for the specific conductor color code requirements.
EC-4) Do the rules in NEC Article 225 for outside branch circuits and feeders apply to solar PV systems?
Answer: Yes. The scoping provisions in NEC 225.1 state that the article covers requirements for outside
branch circuits and feeders run on or between buildings, structures or poles on the premises. It also
covers electrical equipment and wiring for the supply of utilization equipment that is located on or
attached to the outside of buildings, structures or poles. NEC 225.3 and the accompanying table also
act as a reminder that Article 225 is specifically applicable to solar photovoltaic systems in Article 690.
See Article 100 for the definitions of Building and Structure. The definition of Structure has broad
applicability as determined by the Authority Having Jurisdiction (AHJ). It might not be obvious to solar PV
installers, but a ground-mounted solar PV array, located away from the building, is considered a
structure for the purpose of Article 225. However, when considering the disconnect requirements found
in Part II of Article 225, the DC conductors extended from a ground-mounted array would not be
considered to be “supplying power” to the array; therefore, the DC conductors would not be required to
comply with NEC 225.31. In addition to all of the rules in Article 690 for the solar PV system, all of the
general rules in NEC Chapters 1 through 4 are applicable, including Article 225, unless otherwise exempt.
EC-5) Do the requirements for surge protective devices (NEC 230.67) and emergency disconnects (NEC
230.85) apply to residential solar installations?
Answer: Generally, yes. If the connection of the PV disconnect is located on the supply side of the
service disconnect, you would be required to comply with both NEC 230.67 for the “surge protection”
and NEC 230.85 for the “emergency disconnect.” PV disconnect(s) connections on the supply side
service disconnect must be installed using the same NEC requirements for a service disconnect
(705.11(C)). Please review the entirety of NEC 705.11 for interconnected PV systems connected on the
supply side of the service disconnect.
EC-6) Do PV string inverters need to meet the working space requirements of NEC 110.26?
Answer: Generally, yes. NEC 110.26 states: “Working space for equipment operating at 600 volts,
nominal, or less to ground and likely to require examination, adjustment, servicing, or maintenance
while energized shall comply with the dimensions of 110.26(A)(1), (A)(2), and (A)(3) or as required or
permitted elsewhere in this Code”. The code is very clear; if the equipment is likely to be examined,
adjusted or serviced while energized, the requirements for height, depth and headroom would need to
be met according to NEC 110.26.
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However, if the inverter can be serviced while de-energized or if the inverter doesn’t have any exposed
live parts as defined in Article 100, the distance requirements would not apply.
If you have a questionable installation in the field regarding string inverter working clearances, please
check with your local AHJ prior to the installation.
EC-7) Can the CAB Support System (Messenger Supported Cable System) be installed at PV system
installations?
Answer: Generally, yes. The department will accept the use of the CAB system as a messenger support
system and apply the requirements given in Article 396 of the National Electrical Code. Article 396.12
clearly states the messenger support system can’t be subject to physical damage and will only be
considered at PV systems where protected by a fence or substantial structure that reduces access to
unqualified individuals.
The department understands that “subject to physical damage” could be a very subjective interpretation
among electrical inspectors in the field. That said, the department will accept the use of the CAB support
system at solar arrays under the following conditions:
• Installations are required to evaluated/approved by department staff prior to installation.
• The CAB support system is routed parallel to and under the long axis of the solar array; the array
will help in protecting the conductors and/or cables from physical damage. The height of the
conductors and/or cables must be installed as high as possible to the underside of the modules
when utilizing a fixed rack mounting system or as high as possible to the underside of the torque
tube for a single axis tracker systems.
• The department will accept incidental jumps of a reasonably short length between rows of arrays
(perpendicular to the long axis); such jumps shall be properly supported and protected from
physical damage. Additional signage may be required
The department will NOT accept the use of the CAB support system where the support system extends
beyond the array and routed any distance to the distribution equipment (e.g., inverter skids, combiners
or switchgear). It is our position that installing the CAB system in open areas for long distances will
subject the conductors and/or cables to physical damage. Physical damage could occur during snow
removal, grounds-keeping operations, maintenance or other operations.
Additionally, please provide the department installation instructions regarding the use of the CAB
system. Furthermore, if not specifically addressed in the installation instructions, provide information for
the following questions/concerns regarding the CAB support system installation parameters, such as;
• Hanger interval spacing,
• How often will the cables be secured to the system,
• How is tension controlled on the messenger cable, so the hanger height is maintained,
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• Provide documentation that allows the purlins and tensioning hardware of the racking system to
be used with the additional stress and tensioning force of the CAB system,
• How far off the ground will the hangers be installed,
• Will vegetation or rodents be a concern,
• Identify all equipment grounding specifications,
• List the number and size of the conductors that will be installed in each hanger,
• List the ampacities and overcurrent protection for all the conductors installed utilizing the CAB
system using NEC table 310.15(B)(16) and NEC table 310.15(B)(3)(a).
EC-8) When using 690.11 exception to forgo AFCI protection, would portions of the DC circuit that are
not protected by an approved conduit, cable, or direct buried, still be required to have AFCI protection?
Answer: Yes. Photovoltaic systems with PV system dc circuits operating at 80 volts dc or greater
between any two conductors would be required to have listed AFCI protection. The exception allows the
installer to forgo the AFCI protection for the dc circuits (changed from output circuits in the 2020 NEC)
that are installed in a specific raceway, cable or if they are direct buried. AFCI protection is required for
the above ground portion of the dc circuits that don’t provide any physical protection. These
conductors mainly include the string wires that are secured below the racking system or module frames.
Due to the lack of availability of the AFCI protection for 1500-volt systems under 5MW, the department
will allow a fire mitigation plan to be used in accordance with 691.10.
Inspection Fees and Procedures
EF-1) How are the department’s solar PV system inspection fees calculated?
Answer: The following inspection fees will be applicable to solar PV systems and installations:
(a) The inspection fee for the installation of solar PV systems, is
(1) 0 watts to and including 5,000 watts, $60; or
(2) 5,001 watts to and including 10,000 watts, $100 or
(3) 10,001 watts to and including 20,000 watts, $150 or
(4) 20,001 watts to and including 30,000 watts, $200 or
(5) 30,001 watts to and including 40,000 watts, $250 or
(6) 40,001 watts to and including 1,000,000 watts, $250, and $25 for each additional
10,000 watts over 40,000 watts or
(7) 1,000,000 watts to 5,000,000 watts, $2,650, and $15 for each additional 10,000
watts over 1,000,000 watts or
(8) 5,000,000 watts and larger, $8,650, and $10 for each additional 10,000 watts over
5,000,000 watts.
(b) For the purpose of paragraph (a), the watt rating is the total estimated alternating current
(ac) energy output of the solar system. The total dc energy output is not used.
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(c) The solar PV inspection fees shall include inverters, modules, panels, combiners, converters,
charge controllers, disconnecting means, electrical conductors and ancillary equipment
between the interactive inverter and the service equipment or another electrical production
and distribution network. For solar PV systems over 200 KW, the inspection fees will include all
of the electrical wiring and equipment for the solar PV system, to the service point or point of
connection to another electrical production and/or electrical distribution network whichever
occurs first. Please contact the department for clarification on complex projects.
(d) When a plan review is required or performed the plan review fee is $80 per hour.
Minnesota Solar PV System
Electrical Inspection Fee Chart
Solar PV System Rating*
Inspection Fees
0 – 5,000 watts
$60
5,000 – 10,000 watts
$100
10,001 – 20,000 watts
$150
20,001 – 30,000 watts
$200
30,001 – 40,000 watts
$250
40,001 – 1,000,000 watts
$250, and $25 for each
additional 10,000 watts
over 40,000 watts
1,000,000 - 5,000,000 watts
$2,650 and $15 for
each additional 10,000
watts over 1,000,000
watts
5,000,000 watts and larger
$8,650 and $10 for
each additional 10,000
watts over 5,000,000
watts
*The watt rating is the total estimated alternating current (ac) energy
output of the solar system. The total dc energy output is not used.
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The solar PV inspection fees shall include inverters, modules, panels,
combiners, converters, charge controllers, disconnecting means, electrical
conductors and ancillary equipment between the interactive inverter and
the service equipment or another electrical production and distribution
network. For solar PV systems over 200 KW, the inspection fees will include
all of the electrical wiring and equipment for the solar PV system, to the
service point or point of connection to another electrical production and/or
electrical distribution network whichever occurs first. Please contact the
department for clarification on complex projects.
When a plan review is required or performed the plan review fee is $80 per
hour.
EF-3) Is a plan review required prior to the installation of a solar PV system?
Answer: Not at this time. However, installers of solar PV systems are expected to be able to answer
any questions about the solar PV system posed by the Authority Having Jurisdiction (AHJ). The Solar
America Board for Codes and Standards (Solar ABCs) has developed a set of standardized plan
submittal and permit application documents that can be used to outline all of the plans, specifications
and details for various types of solar PV systems. Solar PV installers are strongly encouraged to utilize
these documents and make them available to the AHJ well in advance of the start of construction.
For large-scale solar PV projects, the department strongly encourages solar PV installers to contact the
department well in advance of the start of construction in order to schedule one or more project
review meetings. There is no plan review fee for these meetings. The purpose of the meetings is for
the exchange of information and to help ensure the successful completion of the solar PV project. The
department welcomes the opportunity to host these meetings.
EF-4) Upon request will the department perform a plan review prior to the installation of a solar PV
system?
Answer: Yes. Please contact the department at dli.electricity@state.mn.us for more information. The
department reserves the right to charge a plan review fee of $80 per hour when performing plan
reviews.
Solar America Board for Codes and Standards Expedited Permitting
http://www.solarabcs.org/about/publications/reports/expedited-permit/forms/index.html
• Standard String System
• http://www.solarabcs.org/about/publications/reports/expedited-permit/pdfs/Example1-
StandardStringSystem.pdf
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• Micro-Inverter System
• http://www.solarabcs.org/about/publications/reports/expedited-permit/pdfs/Example2-Micro-Inverter.pdf
• AC-Module System
• http://www.solarabcs.org/about/publications/reports/expedited-permit/pdfs/Example3-ACModule.pdf
• Supply-Side Connection System
• http://www.solarabcs.org/about/publications/reports/expedited-permit/pdfs/Example4-Supply-
SideConnection.pdf
Equipment Approval
EA-1) For electrical installations covered by the National Electrical Code (NEC), what is the difference
between “approved” and “listed” when it comes to the acceptability of electrical equipment?
Answer: In accordance with NEC 110.2, conductors and equipment required or permitted in the NEC
shall be acceptable only if they are approved. The term Approved is defined in Article 100 simply as
“Acceptable to the authority having jurisdiction” (AHJ). However, suitability of electrical equipment is
commonly required to be evidenced by Listing and Labeling. See the definitions of Listing and Labeling
in NEC Article 100. Listed and labeled equipment is required to be installed in accordance with any
instructions that are included in the listing and labeling. In North America there are several testing
laboratories that evaluate electrical equipment, list the equipment in published product directories
and label the equipment as evidence that the equipment meets all applicable safety standards. In the
U.S., the Department of Labor Occupational Safety & Health Administration (OSHA) administers the
program that is responsible for accrediting the Nationally Recognized Testing Laboratories (NRTLs)
(Examples of NRTLs include UL, ETL-ITSNA, MET, CSA, etc.) https://www.osha.gov/dts/otpca/nrtl/index.html
EA-2) Does the NEC require solar PV equipment to be listed?
Answer: Yes. Simple approval of solar PV equipment by an AHJ is not permitted in the NEC. There are
numerous examples in the NEC where electrical equipment is specifically required to be listed (e.g.
luminaries, wiring methods, automatic transfer switches, service equipment, hazardous locations, etc.).
NEC 690.4(B) specifically requires inverters, motor generators, PV modules, PV panels, ac PV modules,
dc combiners, dc-to-dc converters and charge controllers to be listed or field labeled for PV
applications.
EA-3) Does the U.S. Department of Labor Occupational Safety & Health Administration (OSHA) require
electrical equipment in the workplace to be listed and labeled?
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Answer: Yes. More information is available in Standards – 29 CFR, part 1910.303, Occupational Safety
and Health Standards.
EA-4) Does Minnesota have similar OSHA regulations requiring electrical equipment in the workplace
to be listed and labeled?
Answer: Yes. The Minnesota Department of Labor and Industry also enforces the Minnesota
Occupational Safety and Health Act (MNOSHA) and federal standards.
http://www.dli.mn.gov/business/safety-and-health-work
EA-5) In addition to the equipment approval requirements in the NEC, does Minnesota have overriding
statutes or rules related to the approval of electrical equipment?
Answer: Yes. Minnesota Rules Chapter (MRC) 3801.3619 and 3800.3620 contain provisions for the
approval of electrical equipment. MRC 3801.3619 contains definitions. MRC 3801.3620 contains the
provisions for the approval of electrical equipment. MRC 3801.3620, Subpart 1 essentially requires all
equipment used as part of or in connection with an electrical installation to be listed and labeled by a
nationally recognized testing laboratory.
EA-6) Does MRC 3801.3620 contain any alternatives to listing and labeling?
Answer: Yes. MRC 3801.3620, Subpart 2 outlines the provisions that can be utilized to obtain the
department’s approval of certain types of electrical equipment. The two most common methods for
third-party certification of non-listed equipment includes; 1) field evaluation by a nationally recognized
testing laboratory, or 2) field evaluation by a registered electrical engineer.
EA-7) Does the department have more information online related to equipment approval?
Answer: Yes. Approval requirements for electrical equipment are online at
http://www.dli.mn.gov/business/electrical-contractors/equipment-approval
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Removal and reinstallation of existing solar PV systems
RR-1) Is an electrical permit and inspection required for the reinstallation of the solar PV system, or
portions of the solar PV system?
Answer: Yes. The reinstallation of the solar PV support system (racking), modules and other equipment
and wiring would require an electrical permit and inspection, the same as it would for a new installation.
The inspection exemption for minor repair work, as defined in Minnesota Rules Chapter 3800.3500,
Subp. 10, is not applicable. Due to the complexity of the reinstallation of the solar PV system, and the
importance of maintaining and ensuring the equipment grounding and bonding path for the racking,
modules and other equipment, an electrical inspection will be required. A Request for Electrical
Inspection (permit) must be filed at or before commencement of the electrical installation with a
minimum inspection fee of $35. Additional inspection fees may be assessed if necessary due to
reinspection or other required inspections.
NOTE: UL 2703 states that for devices that are only to be utilized one time, such as torque fasteners or
single-use bonding and grounding devices, the installation instructions shall include the statement "For
single-use only", or the equivalent. In other words, devices, washers, fasteners, etc. that are only
approved for single-use must be discarded and replaced with new, unused devices, washers, fasteners,
etc.
RR-2) Is the reinstallation of the solar PV system required to comply with the currently adopted National
Electrical Code (NEC)?
Answer: Yes. All electrical installations must comply with the current code that is in effect at the time
the permit is issued. The reinstallation of the PV modules, PV support system (racking) and associated
equipment and wiring must comply with the requirements of the currently adopted NEC, including but
not limited to all grounding requirements, conductor sizing, wire management and module mounting.
RR-3) Would the replacement of solar PV modules require compliance with the rapid shutdown
requirements of NEC 690.12?
Answer: No. The existing Rapid Shutdown system technology installed at the time of the initial
installation of the solar PV system would be acceptable. NEC Section 690.12 addresses the Rapid
Shutdown requirements for “new” solar PV systems installed in or on a building, and not to existing solar
PV systems.
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Energy Storage Systems
ESS-1) Some energy storage systems or storage batteries are provided with metal support racks or
framework for batteries, capacitors and kinetic energy devices (e.g. flywheels and compressed air).
These systems can have ac or dc output for utilization and can include inverters and converters to
change stored energy into electrical energy. In some cases, the metal support rack or framework are
utilized and approved as the equipment grounding conductor (ground-fault current path). Is this type of
metal support system, or portions thereof, considered to be “electrical work”, as the term is defined in
Minnesota Statute 326B.31, Subdivision 17?
Answer: Yes. NEC Article 250 has specific requirements for ground-fault protection of systems.
Energy Storage System (ESS). A listed system with one or more components assembled together
capable of storing energy and providing electrical energy into the premises wiring system or an
electric power production and distribution network.
Storage Battery (Battery). A single or group of rechargeable cells connected together electrically in
series, in parallel, or a combination of both, and comprised of lead-acid, nickel-cadmium, or other
rechargeable electrochemical types. Storage batteries and battery management equipment shall be
listed. This requirement shall not apply to lead-acid batteries.
ESS-2) Are energy storage systems or storage batteries considered to be electrical equipment in
the National Electrical Code?
Answer: Yes. Energy storage systems or batteries fall within the definition of “equipment” as it is
defined in the NEC. See NEC Articles 100, 480, 706 and other applicable articles for all pertinent
definitions. Accordingly, energy storage systems, including the final placement, positioning and
securement of batteries, capacitors, and kinetic energy devices (e.g., flywheels and compressed air) and
all electrical wiring, are electrical equipment under the State Electrical Code.
ESS-3) How are the department’s inspection fees calculated for energy storage or battery systems?
Answer: The following inspection fees will be applicable to energy storage and battery system
installations:
(a) The inspection fee for the installation of a storage system is
(1) 0 watts to and including 5,000 watts, $60 or
(2) 5,001 watts to and including 10,000 watts, $100 or
(3) 10,001 watts to and including 20,000 watts, $150 or
(4) 20,001 watts to and including 30,000 watts, $200 or
(5) 30,001 watts to and including 40,000 watts, $250 or
(6) 40,001 watts to and including 1,000,000 watts, $250, and $8 for each additional
10,000 watts over 40,000 watts or
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(7) 1,000,000 watts to 5,000,000 watts, $1,518 and $5 for each additional 10,000
watts over 1,000,000 watts or
(8) 5,000,000 watts and larger, $3,518, and $2 for each additional 10,000 watts over
5,000,000 watts.
(b) For the purpose of paragraph (a), the watt rating is the total of the estimated energy
output (ac or dc) of the energy storage or battery system.
(c) The storage system inspection fees shall include batteries, capacitors, inverters,
combiners, converters, charge controllers, kinetic energy devices (e.g. flywheels and
compressed air), panelboards, disconnecting means and electrical conductors between the
interactive inverter and the service equipment or another electrical production and
distribution network. For a large ESS over 40 KW, the inspection fees will include all of the
electrical wiring and equipment for the ESS system to the service point or point of
connection to another electrical production and/or electrical distribution network,
whichever occurs first. Please contact the department for clarification on complex projects.
(d) When a plan review is required or performed the plan review fee is $80 per hour.
Minnesota Energy Storage System or Battery Storage
Electrical Inspection Fee Chart
Storage System Rating*
Inspection Fees
0 – 5,000 watts
$60
5,000 – 10,000 watts
$100
10,001 – 20,000 watts
$150
20,001 – 30,000 watts
$200
30,001 – 40,000 watts
$250
40,001 – 1,000,000 watts
$250, and $8 for each
additional 10,000 watts
over 40,000 watts
1,000,000 - 5,000,000 watts
$1,518 and $5 for each
additional 10,000 watts
over 1,000,000 watts
5,000,000 watts and larger
$3,518 and $2 for each
additional 10,000 watts
over 5,000,000 watts
*The watt rating is the total estimated alternating current (ac) energy
output of the solar system. The total dc energy output is not used.
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The storage system inspection fees shall include batteries, capacitors,
inverters, combiners, converters, charge controllers, kinetic energy devices
(e.g. flywheels and compressed air), panelboards, disconnecting means and
electrical conductors between the interactive inverter and the service
equipment or another electrical production and distribution network. For a
large ESS over 40 KW, the inspection fees will include all of the electrical
wiring and equipment for the ESS system to the service point or point of
connection to another electrical production and/or electrical distribution
network, whichever occurs first. Please contact the department for
clarification on complex projects.
When a plan review is required or performed the plan review fee is $80 per
hour.
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Building Code
BC-1) Does the Minnesota State Building Code contain provisions related to the installation of solar PV
systems?
Answer: Yes. The 2020 Minnesota Building Code contains provisions for the installation of solar PV
systems. The code provisions include rules related to roof access, pathways and spacing requirements
in an effort to mitigate hazards and to aid in firefighting operations.
The 2020 Minnesota Residential Code regulates solar PV systems on buildings classified as IRC-1 (one-
family), IRC-2 (two-family), IRC-3 (townhouses) and IRC-4 (accessory structures). The 2020 Minnesota
Building Code Section 3111 regulates solar PV systems installed on all other buildings (not classified as
IRC-1, IRC-2, IRC-3, or IRC-4), structures and appurtenances connected or attached to them.
Ground-mounted installations accessory to IRC-1, IRC-2, or IRC- 3 buildings are classified as IRC-4 and
are designed and installed in accordance with 2020 Minnesota Residential Code, Section R301.
Fact Sheet - Solar Photovoltaic Systems and the State Building Code
https://www.dli.mn.gov/sites/default/files/pdf/fs_res_solar.pdf
