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I'm familiar with NEC service clearances but I don't think they say anything about disconnects being installed outside next to grade.

Do any panel manufacturer's say anything about where to locate their products other than what the NEC says?

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I'm familiar with NEC service clearances but I don't think they say anything about disconnects being installed outside next to grade.

Do any panel manufacturer's say anything about where to locate their products other than what the NEC says?

No. But the NEC says not to locate the panel behind a condenser like that.

As far as I know, there's no required *minimum* height above grade.

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