On October 22, the National Fire Protection Association published six Tentative Interim Amendments (TIA Nos. 1951 through 1956) to the National Electrical Code, and opened them for public comment until November 20.
GismoPower wrote and filed all six. Two legendary electrical engineers who pioneered today’s solar standards UL 1741 and IEEE 1547 decades ago, Ward Bower and Dr. Robert Wills, signed to advance them to a vote.
If Code-Making Panel 4 and the Correlating Committee approve them, Plug-In Photovoltaic (PIPV) systems will have, for the first time, a defined place in the National Electrical Code of the country that invented them.
A category Europe has and America lost
Europeans know the category as Balcony Solar: panels on balconies, garden fences and terraces, feeding a few hundred watts into an ordinary household socket under rules that treat the generator like an appliance. Germany alone has more than a million registered systems. The appeal is plain: no contractor, no roof penetration, no permitting purgatory, and a price that puts personal electricity generation within reach of renters, apartment dwellers and moderate-income households, exactly the people rooftop solar has never served.
The United States had a head start and squandered it. Starting in 2012, under the U.S. Department of Energy’s SunShot Initiative, Fraunhofer USA’s Center for Sustainable Energy Systems published a complete Plug and Play PV standards portfolio in 2016. The system architecture, the connection device, a code-compliance verification framework keyed to the NEC, and an electronic permitting and interconnection model. It documented a 3 kW system commissioned in 75 minutes by people with no solar experience.
A decade later, Plug-In Solar still has no defined term in the National Electrical Code. An inspector has nothing to cite, a utility processing an interconnection request has no Code-defined product type to assess, and an implicit inclusion that cannot be cited is no inclusion at all.
What the six amendments do
Why now and not in 2029
Three things have converged since Article 705 was last revised:
Waiting for the 2029 edition means three more years in which the laws, the product standards and the permitting software all point at a Code that cannot answer.
Watts are the wrong variable
Most state legislation, and the federal bill, defines Plug-In Solar by a wattage ceiling, usually 1,200 W, and a 120 V outlet. Our amendments do not, for reasons of physics.
The hazard that wattage caps are meant to address is breaker masking: an inverter feeding a receptacle on a shared branch circuit adds current the panel breaker never sees, so loads on that circuit can draw more than the conductor is rated for without a trip. The conductor does not overheat because of Watts; it overheats because of Amperes relative to its ampacity.
A wattage figure is a current figure at one assumed voltage on one assumed circuit; 391 W, the number in a safety statement now circulating in state capitals, is simply 3.26 A at 120 V. And on a dedicated circuit, with no other loads downstream of the receptacle, the masking mechanism does not exist at any wattage. That is why TIA 1952 is written in amperes and defined circuit types, with a tier for dedicated 240 V circuits where every electric vehicle charger, range and dryer in an American home already connects. A Plug-In Solar carport on such a circuit can power a home and charge an EV through the same split-phase receptacle the EV charger would use.
The same point holds for shock. Lethality depends on voltage, body resistance and duration, not on source wattage. Touch safety is therefore specified in volts and milliseconds, and UL 3700’s own Annex A does exactly that: accessible contacts must de-energize below 15 Vac and 30 Vdc within half a second of the plug being pulled, or within 160 milliseconds when tied to the inverter’s voltage protection, with two levels of isolation and single-fault tolerance.
The connector contradiction
Having accepted functional touch protection in Annex A, UL 3700 has prohibited standard connectors outright since its first issue in December 2025, in Section 6.4.1.3: no NEMA, no IEC 60320, no IEC 60309-2, proprietary configurations only.
No technical reason or incident report has been offered by UL for the hazard the NEMA connector prohibition prevents. Meanwhile the SAE J3400 connector, the one now on every new electric vehicle in North America, relies entirely on electronic touch protection of the kind UL3700 Annex A describes, at currents far above anything a residential receptacle carries. The Electric Vehicle industry’s NACS connector is accepted on functional protection; the Plug-In PV connectors are banned by shape.
And the proposed federal PIPV Bill H.R. 10851, as introduced, requires a device that plugs into a standard 120-volt outlet and is certified by a nationally recognized testing laboratory. Under UL 3700 as written, no such device can exist. Either the standard changes, or the bill does, or the Consumer Product Safety Commission standard the bill also mandates displaces UL 3700. TIA 1952’s designated, field-marked receptacle is the Code-side answer; a standard-connector pathway in UL 3700, with Annex A as the touch-safety condition, is the product-side answer, and we are preparing that proposal now.
An appliance, not a structure
There is a second front, and it decides whether the larger, appliance-class systems scale: the mobile 240 V units that can power a home and charge an EV. A balcony kit raises no siting question; a carport on wheels does. In Las Vegas, a household has operated a 240 V Plug-In Solar carport under NV Energy’s net-metering approval since December 2024. The county’s Building Official determined in writing that no building permit applies, because the unit is on wheels, unanchored, and connected only by cord and plug. The county’s planners nonetheless classify it as a structure, and on October 16 Clark County Code Enforcement ordered it removed from the driveway as a setback violation. The units are now registered trailers with license plates. A vehicle may stand on a driveway; a structure may not.
The only legal category that protects a movable appliance wherever it is parked is “vehicle,” and anything in a national standard that makes the appliance depend on a hardwired premises-side device converts it back into a structure. That is why we have objected, in the IEEE P1547 Annex K drafting and in our comments on a forthcoming PNNL and LBNL report, to language describing plug-connected equipment as “stationary, permanently installed.” A mobile source whose onboard inverter is listed to UL 1741 SB meets IEEE 1547 at its terminals. It does not need a box on the wall to be a DER, and the Code should not require one to be an appliance.
The stakes reach past one product category. Plug-In Solar is the deployment path for the households rooftop solar cannot serve: renters, residents of buildings with inadequate or shaded roofs, and families priced out of contractor-installed systems. These appliances are set up on a balcony, patio or driveway without modifying the building, and they give people a direct stake in their own energy supply and resilience. A few hundred watts at a balcony socket, or a few kilowatts at the 240V EV receptacle, is the most accessible on-ramp to the energy transition that exists, and the communities carrying the heaviest energy burdens stand to gain the most from it.
How to add your voice
A PNNL interim report that was filed in Nevada’s PUCN docket 26-09004 in September lays out the regulatory gaps in order: classification, connection method, touch safety, breaker masking, bidirectional GFCI, export control, relocation. The six proposed NEC amendments close the installation-side gaps and leave the product-side ones to UL, which is the right division of labor. They change nothing about anti-islanding, ground-fault protection, or utility authority over export. They give the Plug-In Solar a name, a receptacle, a disconnect, a label, a calculation, and a notification rule.
Open any of the six amendments on NFPA’s NEC page (nfpa.org, NFPA 70 standard development, under Tentative Interim Amendments). Each is short.
Write a comment that says who you are: engineer, installer, inspector, utility planner, renter, homeowner. Address both ballot questions, technical merit and emergency nature: why the provisions are sound, and why waiting for the 2029 edition is too long when ten states have acted, Congress has its first bill, certified products are on the market, and automated permitting cannot issue a permit for a category the Code does not contain.
Email it to the Secretary of the Standards Council at [email protected], citing the TIA numbers, before November 20, 2026. One specific comment from someone who installs, inspects, sells or lives with PIPV systems outweighs a hundred identical form letters, and the record this month is the record the Code will be written from.
Achim Ginsberg-Klemmt is Principal Investigator under DOE award DE-SC0022708 and a named inventor on GismoPower’s patents. Erika Ginsberg-Klemmt is GismoPower’s co-founder and VP of Operations. Antonia Ginsberg-Klemmt is GismoPower’s CEO. GismoPower LLC, Sarasota, Florida, manufactures the MEGA Plug-In Solar carport appliance.
The views and opinions expressed in this article are the author’s own, and do not necessarily reflect those held by pv magazine.
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