I know this comment isn't helpful, but your inspector is an ignorant ass.
A battery is NOT an ESS.
The requirement is to disconnect the ESS from the the premises wiring.
As defined by 2020 NEC 706.2, an ESS is “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.” These systems can be mechanical or chemical in nature. In this post, we are most interested in the chemical variety used to store electrical energy (for example, lead-acid and lithium-ion batteries).
storing AND providing electrical energy into the premises wiring system.
AND not OR
Batteries connected to an inverter can't provide electrical energy into the premises wiring system if the inverter is disconnected from the wiring, i.e., the inverter output is disconnected from the premises wiring.
If you had a tesla powerwall with an integral inverter (a true ESS), would this inspector require that the battery inside the powerwall be disconnected at an external shutoff in addition to the shutoff between the powerwall and the house? No, but this is what he is requiring of you.
You need an external cut of in a lockable box that completely disconnects your system from the house. That's it.
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2020 Code Language:
706.15(A) ESS Disconnecting Means. A disconnecting means shall be provided for all ungrounded conductors derived from an ESS and shall be permitted to be integral to listed ESS equipment. The disconnecting means shall comply with all of the following:
(1) The disconnecting means shall be readily accessible.
(2) The disconnecting means shall be located within sight of the ESS. Where it is impractical to install the disconnecting means within sight of the ESS, the disconnect shall be installed as close as practicable, and the location of the disconnecting means shall be field marked on or immediately adjacent to the ESS. The marking shall be of sufficient durability to withstand the environment involved and shall not be handwritten.
(3) The disconnecting means shall be lockable open in accordance with 110.25.
For one-family and two-family dwellings, a disconnecting means or its remote control shall be located at a readily accessible location outside the building.
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2023 Code Language:
706.15 Disconnecting Means.
(A) ESS Disconnecting Means. Means shall be provided to disconnect the ESS from all wiring systems, including other power systems, utilization equipment, and its associated premises wiring.
N (B) Location and Control. The disconnecting means shall be readily accessible and shall comply with one or more of the following:
(1) Located within the ESS
(2) Located within sight and within 10 feet from the ESS
(3) Where not located within sight of the ESS, the disconnecting means, or the enclosure providing access to the disconnecting means, shall be capable of being locked in accordance with 110.25
Where controls to activate the disconnecting means of an ESS are used and are not located within sight of the ESS, the disconnecting means shall be lockable in accordance with 110.25, and the location of the controls shall be marked on the disconnecting means.
For one- and two-family dwellings, an ESS shall include an emergency shutdown function to cease the export of power from the ESS to premises wiring of other systems. An initiation device(s) shall be located at a readily accessible location outside the building and shall plainly indicate whether in the "off" or "on" position. The "off" position of the device(s) shall perform the ESS emergency shutdown function.
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