The impulse to want to fix the perceived market failure with a government mandate seems to me a bad general heuristic.
OP says there was a 2014 government regulation that made it difficult to design & manufacture these systems, and then there was a 2017 government regulation that made it even more difficult to design & manufacture these systems—so difficult that there were no legally-compliant systems on the market until 2021. And if a company does go through all the effort to make a legally-compliant system, they have zero assurance that the electrical code won’t just get even more strict next year, and then all that effort was wasted. So I think it’s at least not entirely a market failure. I think Jeff’s proposal could help, and I think tweeting at Elon could help too, and maybe there are other approaches as well.
I do think there are also externalities involved—“societal resiliency during an extended blackout” is a public good. (If people are desperate and dying, they can cause problems for everyone else too.) So there’s a government-should-help argument from that direction. Also, the government subsidies already exist, it’s just a question of who qualifies for them.
The OP didn’t refer to any government regulation. The National Electrical Code is created by a private trade organization, the National Fire Protection Association. Unsurprisingly, the National Fire Protection Association cares a lot more about protecting its members (a lot of them likely firemen) than about ends like resilient electricity production.
The increased regulatory burden is an important part of the Great Stagnation. The instinct to always want to fight problems by adding more regulation leads to stagnation even if you can find arguments that every regulation will help the public good.
As Steven says, the NEC is effectively a regulation since most states adopt it by reference (like the building code). If you want you could view my post as objecting to states adopting the 2014 and 2017 NEC without consideration of the effect on resiliency, instead of to the drafters of the NEC failing to consider this aspect? (I would prefer to have seen both.)
The instinct to always want to fight problems by adding more regulation leads to stagnation...
In this case I’m proposing adding a condition to a subsidy, which I think is an importantly less restrictive approach than a blanket regulation. People always have the escape hatch of skipping the subsidy if it’s overall too burdensome.
NEC 2020 brought more changes. The six simple sentences from 2014 have grown to a full page. Most of the addition is simply clarification of the requirements added in 2017. Since many states didn’t enforce the module level shutdown from 2017-2019, most people refer to 2020 as the release year that module level shutdown was added.
That does sound to me like some states decided it makes sense to not implement a part of the rules in 2017 because they considered the rules too burdensome/wanted to give companies more time.
While there is a 2020 edition of the NEC, California — along with 23 other states — is still using the 2017 NEC. If you want to check out where we’re at, and what other states are doing, you can look at this color-coded map. It’s published by the National Fire Protection Association (NFPA), the same organization that issues each edition of the NEC.
But, wait. Doesn’t the state have a more current electrical code? Yes, but the 2019 California Electrical Code (California Code of Regulations, Title 24, Part 3) is based on the 2017 NEC.
In fact, we’re probably sticking to the 2017 NEC for a while. We didn’t vote to adopt this code until January 2019. The codes weren’t published by the state until July 2019. Then, the state observed a six-month statutorily required waiting period, which means the 2017 NEC didn’t technically get enforced until January 2020.
Thanks! It seems like part of my beef is with Massachusetts being very eager to stay on the most current code. It looks like the 2020 NEC was adopted 12/27/2019, and the 2017 NEC 1/1/2017.
I hadn’t realized how atypically fast MA is doing this. MA was the only state on the 2017 NEC from January until June; CO adopted in June, ID, ND, SD, MN, WY, and WA in July, OR and VT in October, and ME in November. Everyone else not until 2018 or later (or still hasn’t).
Oh, thanks for clarifying. Indeed, NEC is not directly a government regulation. However, if essentially every part of the USA has a law that says “You must comply with NEC”, then NEC is effectively a government regulation.
(Some regions require NEC + amendments, but my impression is that the amendments tend to be more rules to follow on top of NEC, rather than allowing parts of NEC to be ignored. I could be wrong.)
It does seem problematic that a private trade organization, presumably with direct accountability only its own members, has the de facto ability to write laws that are binding on pretty much everybody. But I don’t know what to do about that. :-/
NEC 2020 brought more changes. The six simple sentences from 2014 have grown to a full page. Most of the addition is simply clarification of the requirements added in 2017. Since many states didn’t enforce the module level shutdown from 2017-2019, most people refer to 2020 as the release year that module level shutdown was added.
That does sound to me like some states decided it makes sense to not implement a part of the rules in 2017 because they considered the rules too burdensome/wanted to give companies more time.
OP says there was a 2014 government regulation that made it difficult to design & manufacture these systems, and then there was a 2017 government regulation that made it even more difficult to design & manufacture these systems—so difficult that there were no legally-compliant systems on the market until 2021. And if a company does go through all the effort to make a legally-compliant system, they have zero assurance that the electrical code won’t just get even more strict next year, and then all that effort was wasted. So I think it’s at least not entirely a market failure. I think Jeff’s proposal could help, and I think tweeting at Elon could help too, and maybe there are other approaches as well.
I do think there are also externalities involved—“societal resiliency during an extended blackout” is a public good. (If people are desperate and dying, they can cause problems for everyone else too.) So there’s a government-should-help argument from that direction. Also, the government subsidies already exist, it’s just a question of who qualifies for them.
The OP didn’t refer to any government regulation. The National Electrical Code is created by a private trade organization, the National Fire Protection Association. Unsurprisingly, the National Fire Protection Association cares a lot more about protecting its members (a lot of them likely firemen) than about ends like resilient electricity production.
The increased regulatory burden is an important part of the Great Stagnation. The instinct to always want to fight problems by adding more regulation leads to stagnation even if you can find arguments that every regulation will help the public good.
As Steven says, the NEC is effectively a regulation since most states adopt it by reference (like the building code). If you want you could view my post as objecting to states adopting the 2014 and 2017 NEC without consideration of the effect on resiliency, instead of to the drafters of the NEC failing to consider this aspect? (I would prefer to have seen both.)
In this case I’m proposing adding a condition to a subsidy, which I think is an importantly less restrictive approach than a blanket regulation. People always have the escape hatch of skipping the subsidy if it’s overall too burdensome.
One of the links in the OP says:
That does sound to me like some states decided it makes sense to not implement a part of the rules in 2017 because they considered the rules too burdensome/wanted to give companies more time.
https://www.renewableenergyworld.com/solar/evaluating-the-case-for-module-level-shutdown/ is an interesting article arguing that the rules that require the expensive module-level shutdown are essentially security theater.
I wonder whether this means that they added explicit exceptions, or that they just didn’t adopt the new revision immediately?
https://up.codes/viewer/california/ca-electric-code-2022 seems to be the Californian version. In it they seem to have “adopt/adopt with amendment/adopt expect”
https://www.tradesmance.com/career-central/current-california-electrical-code also writes:
Thanks! It seems like part of my beef is with Massachusetts being very eager to stay on the most current code. It looks like the 2020 NEC was adopted 12/27/2019, and the 2017 NEC 1/1/2017.
I hadn’t realized how atypically fast MA is doing this. MA was the only state on the 2017 NEC from January until June; CO adopted in June, ID, ND, SD, MN, WY, and WA in July, OR and VT in October, and ME in November. Everyone else not until 2018 or later (or still hasn’t).
Oh, thanks for clarifying. Indeed, NEC is not directly a government regulation. However, if essentially every part of the USA has a law that says “You must comply with NEC”, then NEC is effectively a government regulation.
(Some regions require NEC + amendments, but my impression is that the amendments tend to be more rules to follow on top of NEC, rather than allowing parts of NEC to be ignored. I could be wrong.)
It does seem problematic that a private trade organization, presumably with direct accountability only its own members, has the de facto ability to write laws that are binding on pretty much everybody. But I don’t know what to do about that. :-/
One of the links in the OP says:
That does sound to me like some states decided it makes sense to not implement a part of the rules in 2017 because they considered the rules too burdensome/wanted to give companies more time.
https://www.renewableenergyworld.com/solar/evaluating-the-case-for-module-level-shutdown/ is an interesting article arguing that the rules that require the expensive module-level shutdown are essentially security theater.