Recently, the Washington State Department of Labor & Industries (the "Department") announced in its Electrical Currents newsletter (Vol. 19 No. 5 May 2015) that, "[a]fter extensive research into product availability, and feedback from stakeholders, in accordance with National Electrical Code® (NEC®) 90.4, I have made the decision to extend the delay in implementation of three requirements for Solar Photovoltaic (PV) systems until July 1, 2016," which include (1) 690.11 Arc-Fault Circuit Protection (Direct Current), (2) 690.12 Rapid Shutdown of PV Systems on Buildings and (3) 705.12(D)(6) Wire Harness and Exposed Cable Arc-Fault Protection. (Emphasis added).

The Department further confirms that, due to the delay in implementation of 690.12 Rapid Shutdown requirements, "the 2011 NEC® 690.31(E)(1) requirement to route Direct-Current PV source and output circuits at least 10 inches below roof decking or sheathing when installed inside a building will be enforced until the Rapid Shutdown requirement takes effect on July 1, 2016."

The Department also noted that Oregon has announced a similar delay in implementation of these rules. Oregon Electrical Specialty Code ("OESC") § 690.11 Arc-Fault Circuit Protection (Direct Current) becomes effective April 1, 2016 and OESC § 690.12 Rapid Shutdown of PV Systems on Buildings becomes effective October 1, 2017.