Connection of back-upgenerator to TN-C-S domestic installation

Hi All. I'm a medically retired electrician with additional strings to the bow throughout my career. From contracting on commercial electrical installations to building/designing large industrial containerised generators to managing landfill gas generator installations and finishing at building maintenance engineer covering alot of variable skills with HVAC and BMS.

I try to keep the mind busy and do what I can. 

Appreciate your viewing my question I'll try to be as descriptive as possible. 

My home is TN-C-S supply with no extraneous parts ( water supply is plastic pipe and no gas supply).

Approximately 5 years ago I installed a large metal garage/workshop 7.5m by 4.5m(concrete floor with metal box section frame bolted to the concrete pad) 

I supplied the garage with a 6mm armoured  via 30ma RCD and 40amp MCB ,armour being connected to house distribution board and isolated at the garage termination so as not to export the earth as per regulation,I installed 2m deep electrode and additional 1m deep electrode both wired back to garage DB. So in effect garage is on a TT system.

The house distribution boards (8 way mem bs88 and 4 way mem2000 RCD mcb) I want to change out for 1 large regulation DB , one in looking at is MK dual 100amp 30ma isolator with type 2 SPD rest populated with mcb's.

To the nub of my question. I want to install back up generator (7.5kva peak 6.25kva constant)which will be sited out the back of the metal garage( outside garage building not inside)some approx 12m from house. I'll give you my thoughts on what I'm thinking of installation to ensure complete separation from incoming mains supply to remove chance of any back feed especially under fault condition.

1. Install a single phase 32amp incomer socket ( will be supplied from generator in event of outage)to the exterior of house.

2.Wired back to a 20amp double pole rcbo enclosure in distribution cupboard.

3.From rcbo into a manual 3 pole  transfer switch.

4.The network supply wired the manual 3 pole transfer switch then from transfer switch to new distribution board (dB).

5. The generator chassis will be connected to garage earth electrodes when in use.

6.. 3 pole manual transfer switch? My thinking is to switch L. N. and the earth. 

My thinking on this: when mains is in use garage supply has isolated earth DB side connected only  as previously discussed to protect cable/circuit going to garage rest of house still using supplier earth path . 

When generator supply is used the whole installation house including garage would be effectively TT system this way no chance of back feed to the supplier network including under fault conditions from my/consumer end giving earthing is also switched at the manual transfer switch, i

Q.1.is this 3 pole manual transfer idea (switching earths) idiotic/unnecessary/ not advisable ?

Q. 2. Should I include a type 1 SPD to the 20amp 30ma generator supply enclosure inside distribution cupboard given large metal shed and lighting strikes ? 

Sorry for long winded pre log just trying to ensure you've all the information needed. Would be grateful for your thoughts and indeed advice.

Parents
  • 2.Wired back to a 20amp double pole rcbo enclosure in distribution cupboard.

    20A RCBO for a generator that can supply 7.5kVA.  Shouldn't that be 32A?

  • Hi Dave , valuable contribution, i appreciate your taking the time. I agree interpretation when reading and understanding regs/legislation  can lean/interpreted to making it work for individuals requirements. My intention in raising the questions was to remove my individual bias if you like, have good open discussion with better minds than my own frankly and reach overall consensus. Grateful to all contributions. 

  • Hi Mike, what you refer was my initial train of thought.

    Which id replied to gkenyou broadly saying i believe regs in G99/NI and ESQCR didn't apply/out of scope to my installation (back up emergency supply only designed for owners property/ Island mode only as it referred) this was because for the most part they reference "export" ,"paralleling" and syncing and such like onto DNO/grid/network..

    gkenyou, rightly pointed out that they do apply and kindly reference me back on some of them, my intent dismissing them originally wasn't to say i hadn't taken them into consideration before posing the question, more that in the small area i had to consider within them, that my proposed install would be meeting requirements. That said was glad gkenyon did so helped in retracing areas i may have failed to consider. 

    Your train of thought seems was similar to my own that once "double pole" "break before make" bypass/change-over was in place conditions has been met and that my generator was no longer a "source or Energy" which had the ability to connect in parallel to dist network

    From that thinking and as below from ESQCR.

    Regulations 26(1) and 26(2) of the ESQCR require the consumer’s installation to be:"...so constructed, installed, protected and used or arranged for use so as to prevent, so far as is reasonably practicable, danger or interference with the distributor’s network or with supplies to  others." 

    "Danger and interference", to my thought process , if my generator is operating during a power failure (which majority is due to a line fault) and im connected still to the DNO earth, and potentially my generator/installation could develop a fault and i introduce fault current .......so thoughts then went on to eliminate this why not just switch the earth in the same "break before make" bypass switch.

    Prosumer Electrical Installation 4.1 Earthing

    "An electricity supply company may provide an earth at the point of connection but its primary function is protection of the network upstream from the installation. Under the requirements of the Electricity Supply Quality and Continuity Regulations (ESQCR), the consumer is responsible for ensuring that the installation is satisfactorily earthed"

    My thoughts here when operating in PEI and in grid terms "island mode" ,"consumer to responsible own earthing" , "earthing arrangement using a transfer switching device to facilitate the connection to the earthing arrangement of the local star/mid-point or the local exposed conductive parts" and by using a switched earth to customers own earthing system (in emergency use /island mode) whilst isolated from DNO. regulation is fulfilled "reasonably practicable, danger or interference with the distributor’s network or with supplies to  others." as i am only generating during mains failure tbh 99% time is this is due to a network fault, earth switching would prevent fault current back feed from DNO and indeed if i have a fault when in "grid terms" "island mode" no chance of me introducing earth fault onto DNO grid

    Hopefully a consensus from and by others on what id originally proposed and the correctness of such can either be agreed or indeed rebutted..

  • To further muddy the water in this case when the "domestic client" is also the contractor....

  • To further muddy the water in this case when the "domestic client" is also the contractor....

    Yes, I had that in mind too ... nowhere to run and hide?

  • Hi gkenyon, could i ask for your thoughts . Much appreciated.

    Hi Andy, Thankyou for you help , I've had a lot to mull over last few days .

    If you could indulge me and hopefully offer a little clarity on my way forward.

    1. Install generator behind metal garage outside of the building, with neutral earth link in windings and chassis/engine/alt connected to earth pit electrode (one of the two pits of electrodes linked together currently to garage db for metal garage TT set up from house TN-C-S supply, supply cable earthed at house db isolated at garage).

    2. Install 32amp inlet socket to corner of house to an individual (separate to what will be new db) 20amp rcbo /spd encloser in distribution cupboard.

    3. Then into 2 pole "break before make isolator/bypass" along with DNO supply connecting all earths to MET.

    4. From "break before make isolator/bypass" to new bs7671 compliant db.

    5. supply cable to house inlet will obviously be a temp affair if and when generator is to be used.

    So in normal DNO power usage garage installation is still effectively TT.

    During mains fail and gen hook up (inno over kill for 20amp from generator but was going to use 6mm hi-tuff or the like temp cable about 14m run to house inlet). Meaning in this scenario all earths are linked at MET in house and any fault current would be linked via temp lead to earth electrodes. 

    Do you think this sounds better than my original switching earths at bypass so as to isolate from DNO earthing in cases of network fault/mains failure?

    I'm still of the thought that all relevant regulations (reviewed and highlighted) that do apply would allow for switched earth, but appreciate I may be interpreting different to others and if consensus is not to ill go with that.

    Appreciate all your input and advice, p.s don't know how these forum things work will everyone that's contributed see this or do i need to send to them individually . Thanks again. 

  • Hi gkenyon, could i ask for your thoughts . Much appreciated.

    Sure ... and apologies for not having time to reply for a few days.

    So, from item 1 and items 1 and 3, if I've understood correctly what you are describing, with the generator plugged in, the garage is connected to the PME earthing arrangement through its earth electrode ... which we don't want?

    Also, I guess this would require the generator cable cpc, and the link to the earth electrode, to be sized as cpc for the PME system?

    Which is why, a good few posts back, I was assuming the generator would be connected TT back to the house via the garage?

    I'm not seeing a way round that at the moment.

  • hang on - up thread it says the generator is not in the garage, but is connected direct into the house. As described it will therefore provide a TNS supply to the house. And perhaps that supplies a TT to the garage or also TNS,depending what is done with the interconnection of the genset CPC and the garage earth electrode.

    To supply the house as TT would require a 2 wire feed (just L and N) from the genset into the house and yet another independent electrode - which given what has been said about the available space, won't actually be very independent.

    Mike

  • hang on - up thread it says the generator is not in the garage, but is connected direct into the house.

    Indeed, but with the generator located close to (within reach) of the outside the garage/workshop - which has steel frame/cladding bonded to the TT system. Off grid the genny may well be TN-S of itself, but it'll (normally) still be bonded to the DNO's earth terminal - so still subject to all the usual worries of PME (hence we don't want to export it to the workshop, I would have thought).

      - Andy.

  • hang on - up thread it says the generator is not in the garage, b

    No, 'behind the garage' ...

    nstall generator behind metal garage outside of the building,

    perhaps next to, the garage, but connected into the house when plugged in, more importantly.

    411.3.1.1 applies even outdoors ...

    And the PME issue, bonding size etc, still there when the generator is plugged in.

    To supply the house as TT would require a 2 wire feed (just L and N) from the genset into the house and yet another independent electrode - which given what has been said about the available space, won't actually be very independent.

    BUT, ignoring PME bonding requirements is against ESQCR?

    AND, ignoring 411.3.1.1 (if relevant) means there is a safety issue?

    Indeed, but with the generator located close to (within reach) of the outside the garage/workshop - which has steel frame/cladding bonded to the TT system. Off grid the genny may well be TN-S of itself, but it'll (normally) still be bonded to the DNO's earth terminal - so still subject to all the usual worries of PME (hence we don't want to export it to the workshop, I would have thought).

    Quite so !

  • Hi gkenyon, don't worry ref time we've all things to be doing, thanks for getting back.

    So, from item 1 and items 1 and 3, if I've understood correctly what you are describing, with the generator plugged in, the garage is connected to the PME earthing arrangement through its earth electrode ... which we don't want?

    Yes. Just for overall clarity, so. forgetting about generator/earthing for now. As it sits the metal garage has supply from house db via 6mm armoured glanded/earthed to house MET , when supply gets to garage the armour/earth is isolated to a plastic enclosure, For the garage db earthing ive 2 no. earth pits up the side of the garage one has 6ft earth electrode other 1 has 3ft electrode all in soft ground, from each earth pit is 2 no.10mm earthing cables run back to the garage MET( esco) from this earth to garage db and then from  esco to metal garage frame. Now (TT) why such earthing cable from earth electrodes  .....usual i had a roll lol. 

    So introduce Emergency generator, the frame/chassis/earthing point will have a 10mm earth cable going to nearest existing earth pit electrode  mentioned previous. The metal garage and the generator are within touching of each other.

    So far so good? all still within the TT garage arrangement when DNO supply is feeding house.

    In event of mains failure. The temporary generator supply cable (6mm)run to the house inlet socket which is only plugged in when supply from DNO is off . So earth pit electrodes are connected via cables to garage db and also from earth pit to generator via cable then earthing is within supply cable to house MET, given equipotential throughout the house and garage from generator when DNO supply is off,

    Temporary supply cable (generator to house inlet) earth would be ample for any fault current should it occur when generator is running 6mm, bearing in mind this a supply coming in "direct" from generator not "from the house out" or connected through the garage to house., any lightning strikes/ faults to exposed conducive parts outside (garage and generator casing) have direct 10mm earthing cable to earth electrodes  

    Which is why, a good few posts back, I was assuming the generator would be connected TT back to the house via the garage?

    This was the reason from the outset i wanted/thought towards switching the earths when generator was running via 3 pole break before make , DNO supply would be in fault, and when generator all earthing house and outside would be TT (inno TN-S given neutral earth link in generator winding but you get what i mean) and any fault currents on my side would be ref to earthing electrodes. Do you not think earth switching is permitted within regs from what was reviewed?, seems simplest answer to me and maintains integrity with both supplies while providing correct earthing.  

    Thanks Ken

Reply
  • Hi gkenyon, don't worry ref time we've all things to be doing, thanks for getting back.

    So, from item 1 and items 1 and 3, if I've understood correctly what you are describing, with the generator plugged in, the garage is connected to the PME earthing arrangement through its earth electrode ... which we don't want?

    Yes. Just for overall clarity, so. forgetting about generator/earthing for now. As it sits the metal garage has supply from house db via 6mm armoured glanded/earthed to house MET , when supply gets to garage the armour/earth is isolated to a plastic enclosure, For the garage db earthing ive 2 no. earth pits up the side of the garage one has 6ft earth electrode other 1 has 3ft electrode all in soft ground, from each earth pit is 2 no.10mm earthing cables run back to the garage MET( esco) from this earth to garage db and then from  esco to metal garage frame. Now (TT) why such earthing cable from earth electrodes  .....usual i had a roll lol. 

    So introduce Emergency generator, the frame/chassis/earthing point will have a 10mm earth cable going to nearest existing earth pit electrode  mentioned previous. The metal garage and the generator are within touching of each other.

    So far so good? all still within the TT garage arrangement when DNO supply is feeding house.

    In event of mains failure. The temporary generator supply cable (6mm)run to the house inlet socket which is only plugged in when supply from DNO is off . So earth pit electrodes are connected via cables to garage db and also from earth pit to generator via cable then earthing is within supply cable to house MET, given equipotential throughout the house and garage from generator when DNO supply is off,

    Temporary supply cable (generator to house inlet) earth would be ample for any fault current should it occur when generator is running 6mm, bearing in mind this a supply coming in "direct" from generator not "from the house out" or connected through the garage to house., any lightning strikes/ faults to exposed conducive parts outside (garage and generator casing) have direct 10mm earthing cable to earth electrodes  

    Which is why, a good few posts back, I was assuming the generator would be connected TT back to the house via the garage?

    This was the reason from the outset i wanted/thought towards switching the earths when generator was running via 3 pole break before make , DNO supply would be in fault, and when generator all earthing house and outside would be TT (inno TN-S given neutral earth link in generator winding but you get what i mean) and any fault currents on my side would be ref to earthing electrodes. Do you not think earth switching is permitted within regs from what was reviewed?, seems simplest answer to me and maintains integrity with both supplies while providing correct earthing.  

    Thanks Ken

Children
  • In event of mains failure. The temporary generator supply cable (6mm)run to the house inlet socket which is only plugged in when supply from DNO is off .

    But unplugging the cable isn't interlinked with the changeover switch.  There's nothing to stop someone leaving it plugged in all the time.

  • This was the reason from the outset i wanted/thought towards switching the earths when generator was running via 3 pole break before make , DNO supply would be in fault, and when generator all earthing house and outside would be TT (inno TN-S given neutral earth link in generator winding but you get what i mean) and any fault currents on my side would be ref to earthing electrodes. Do you not think earth switching is permitted within regs from what was reviewed?, seems simplest answer to me and maintains integrity with both supplies while providing correct earthing. 

    The issue you can't get around with the arrangement you describe, if using the metal outbuilding's earth electrode, is that when the generator is in use, you will be connecting it to PME (even if it's only through extraneous-conductive-parts in the main building) without suitably-sized main bonding conductors.

    Conflicting requirements I'm afraid.

    o you not think earth switching is permitted within regs from what was reviewed?,

    A multipole linked switch is permitted to switch protective conductors, but this won't change the fact that the DNO's neutral (often outer layer or, sometimes, copper covering of the cable, and the DNO's earthing conductor, will not be connected to the building. This can present a danger in itself. Regulation 411.3.1.1 requires that 'Simultaneously-accessible exposed-conductive-parts are connected to the same earthing system' because of the possible danger.

    The published guidance on 'island mode operation' is clear in this regard, and DNO requirements (G99 for this aspect, Figure 8.9) clearly show DNO means of earthing for TN systems  unswitched and remaining connected to MET during island mode ... G99 effectively describes the 'distributor's requirements' for Regulation 21 (22 in NI) of ESQCR for 'switched alternative supplies' and G98 and G99 (whichever applies based on current rating and type test of generators) covers the technical requirements for Regulation 22 (23 in NI) of ESQCR.


    I'm not saying your proposed arrangement will not work, just that I'm not sure it would be considered safe (or compliant) by the DNO under all circumstances.

  • Hi Simon , thanks for your thoughts.

    But unplugging the cable isn't interlinked with the changeover switch.  There's nothing to stop someone leaving it plugged in all the time.

    ? the supply cable from the genset plugs into the inlet socket mounted on the outer wall or the house , from that socket cable runs inside the house then connects to the "break before make" bypass. so effectively the temp genset supply cable to house is directly linked to the bypass switch.           So when on normal DNO supply your correct L + N is disconnected in the bypass from genset temp supply cable , but the earth would be still connected with the temp cable left in.  By removing the temp cable it leaves outside garage on its originally designed TT system in "normal operation". 

    "Instruction" stops the cable being left in place during normal DNO supply operation, all back up systems/generator have switch over procedure either automated or manual and that process is followed before energising.

    If you think on it what's to stop anyone doing something within their installation ? example: maybe someone doesn't like the look of an earth bond at their sink and they want to remove they then discover "safety electrical connection do not remove" (instruction) look at a distribution board  "switch off before removing cover " "danger of electric shock" when cover is removed there is then further instruction on the bus bar cover informing that behind the cover is still live .

    During mains failure the "genset temp supply cable" plugged in links the outside electrodes to MET in the house, keeping everything inside and outside the installation at equipotential.

    With the DNO TN-C-S supply being off line, how can plugging in the temp supply cable From genset be classed as exporting the earth From DNO TN-C-S , is it not rather bonding a separate supplies earthing  electrodes(genset) to an extraneous conductive part (DNO MET) to achieve an equipotential in the genset supply ?., im just throwing out thoughts, playing devils advocate.

    I still believe that switching the earths at same time as L + N within the "break before make" bypass allows for total separation between both supplies, including removing a possible earth fault (from genset when running) current back feeding to the earth of DNO supply, from the regs allows for switching earths from my reading, within which it also says :

    Prosumer Electrical Installation 4.1 Earthing

    "An electricity supply company may provide an earth at the point of connection but its primary function is protection of the network upstream from the installation. Under the requirements of the Electricity Supply Quality and Continuity Regulations (ESQCR), the consumer is responsible for ensuring that the installation is satisfactorily earthed".

    Fully appreciate my thinking may not be correct so i do welcome all thoughts to the contrary. 

  • An electricity supply company may provide an earth at the point of connection but its primary function is protection of the network upstream from the installation.

    This statement is to reinforce Regulation 551.4.3.2.1 of BS 7671 for your private generator (on the basis that when the DNO supply goes iff, they may be working on the cable in the street, and their own earth may not be 100 % effective as an N-PE connection for your generator, or connection to a suitably low resistance earth electrode) ... 411.3.1.1 still applies.

  • With the DNO TN-C-S supply being off line, how can plugging in the temp supply cable From genset be classed as exporting the earth From DNO TN-C-S , is it not rather bonding a separate supplies earthing  electrodes(genset) to an extraneous conductive part (DNO MET) to achieve an equipotential in the genset supply ?., im just throwing out thoughts, playing devils advocate.

    Diverted neutral currents can still exist in PME networks, even if your supply is "off" (might just be your phase or distribution run). Hence, sizing of main bonding still applies.

    Diverted neutral currents available on a 'floating DNO earth' not connected to your MET can translate to hazardous touch voltages or touch currents.

    There has been a lot of technical debate and discussion to produce the existing requirements and guidance.

  • During mains failure the "genset temp supply cable" plugged in links the outside electrodes to MET in the house, keeping everything inside and outside the installation at equipotential.

    But not equipotential between the workshop and the ground around it - i.e. the reason PME was avoided for the workshop in the first place.

    Edges of equipotential zones are tricky at the best of times. The zones work best when they're entirely contained within something substantially insulating (e.g. dry walls, floors etc of conventional buildings). Using PME outdoors is full of contradictions - it'll actually illegal for boats and caravans, against BS 7671 for electric cars (without mitigating measures e.g. open-PEN detection), frowned upon (and against some DNO rules) for steel buildings, but used without a second thought for street lighting, domestic outside lights and heat pumps outdoors. Often it's a fine balance of risk against mitigating features - generally people grab hold of car doors much more often than lampposts for instance.

    I suppose the next question is whether connecting the frame of a small generator, stood on open ground, to PME - with the intention that someone will have to manually start it during a power outage - is a good idea?

       - Andy.

  • Hi gkenyon, Thanks again for your input i do appreciate it.

    The issue you can't get around with the arrangement you describe, if using the metal outbuilding's earth electrode, is that when the generator is in use, you will be connecting it to PME (even if it's only through extraneous-conductive-parts in the main building) without suitably-sized main bonding conductors.

    Conflicting requirements I'm afraid.

    If im understanding correctly, Yes the earth electrode would be bonded via 10mm cable to genset, then earth within the genset supply cable to house.  I was proposing 6mm 3 core for the temp supply cable, if used a 4 core 6mm (using 2 cores for earth)? or 3 core 10mm? as per <35mm main conductor size ? sorry if I'm not fully following ,understanding as two separate supplies DNO and Genset.

    In normal operation using DNO supply.

    The DNO PEN conductor gets split to MET in consumers meter cupboard there in all earthing within the customers house installation is referenced back to said MET and in turn PEN conductor. Agree?         

    From the main house db a supply circuit to the external metal garage is run underground via 6mm armoured, earth from armoured is only terminated/grounded at the house db and armour/earth is isolated at garage, the garage earthing is via earthing electrodes. Garage is on TT arrangement supplied from house db circuit via DNO TN-C-S, the earth of which protection to garage supply cable only in case of damage to supply cable  Agree?

    When a fault/break occurs on DNO supply and the PEN conductor is broken = no earthing to house installation from DNO PEN. Agree?

    So DNO TN-C-S supply now offline, completely isolated, and with it the regulations covering the same TN-C-S supply within customers installation, different supply different regulations now apply

    Now setting up for new supply into house from the genset 

    The genset windings 0volt /centre tap reference have a neutral earth link fitted, (this doesn't make any genset outgoing supply circuits "neutral" a PEN conductor) then engine/frame/chassis cabled with 10mm to earth electrode 4 metres away, so if the neutral was broken within the genset itself you still have a direct connection to earth its not lost The genset in and of itself is producing a TN-S supply to all outgoing circuits the earth of which is bonded to extraneous conductive part along the way.       

    This is no different to a DNO TN-S supply, where they would generate power up the line from a generator (with a neutral earth link fitted then grounded to earth) then supplies from which to consumers would be in form of TN-S.

    That's all I've got for now will try address rest later. Thanks again.

  • When a fault/break occurs on DNO supply and the PEN conductor is broken = no earthing to house installation from DNO PEN. Agree?

    So DNO TN-C-S supply now offline, completely isolated, and with it the regulations covering the same TN-C-S supply within customers installation, different supply different regulations now apply

    A DNO's broken PEN event is quite "interesting"... note that there's no guarantee that the corresponding line conductors will be broken at the same time (and very often they're not) - which means consumers' loads downstream of the break (in your or neighbouring installations) effectively connect the PEN to line(s). The resulting voltage on the PEN can vary (especially on 3-phase systems where loads on different phases can pull against each other), but in the worst case it can reach full line voltage (230V+10% say). So your installation sees the same 230V on L, N and PE - or in other words 0V difference between L and N - so you think you have a simple power cut ... but your MET is at anything up to 230V nominal above true Earth. As long as you're indoors with all bonding in place you should be fine (as you're inside the equipotential zone). Outdoors it's a bit different - standing on damp soil and touching an exposed- or extraneous-conductive-part can be decidedly risky. Insulating shoes help, as does paintwork, but still the risk is there.

    Having an elevated voltage on PE also means you can have some considerable currents flowing back to Earth via bonding (or even c.p.c.s to Class I items in contact with extraneous-conductive-parts that have some path back to true Earth) - hence the chunky sizes need for PME bonding rather than the 2.5mm2 or 6mm2 previous generations would have used.

    Notice that the risk doesn't go away during a power cut or if you disconnect L & N - as long as there's a connection to the PME system there's a risk - and so "PME conditions" continue to apply.

       - Andy.

      

  • So DNO TN-C-S supply now offline, completely isolated, and with it the regulations covering the same TN-C-S supply within customers installation, different supply different regulations now apply

    Not always, you may be connected through extraneous-conductive-parts (gas, water, structural parts of the building, either via direct connection, or due to their proximity to the PME supply cable underground).

    different supply different regulations now apply

    No, ESQCR applies still, you would be operating 'switched alternative' supply to the DNO supply according to Regulation 21 of ESQCR (or Regulation 22 of the ESQCR NI), for which G99 applies, as well as BS 7671. 

    The reason the DNOs support this approach, is there may well be other installations "live" in your area, even if yours is islanded and you have no grid power.

    If I thought there was a way you could argue round this, or some magic of taking away the fact that if your main building has extraneous-conductive-parts, you'd still be connected to PME, I would say so. 

    As I said above, these permutations have been debated.