Open Letter to Mike Holt NEC Trainer

Dear Mr. Holt,

Thank you for your important work in teaching the NEC (National Electric Code for those reading this letter who may not know).  I have watched many of your videos and found them to be very effective and beneficial to all electricians.  I respect the work you do to help increase safety and understanding as well as compliance.

It is nice to see our understanding of electricity continually increase as well as our technology and the NEC.  I see how far it has advanced in just the last few decades, so I am hopeful for the future.  Like electrical and electronic technology and knowledge has been advancing, so has our understanding of how fields, radiation, and current inside the body affect health.  Tens of thousands of papers have been published, many of which show biological effects that are significant from today's "normal" exposure.  The fields and radiation we generate today do not at all resemble what humans have experienced throughout all of human history.  They are different in format or configuration (eg. pulsed/modulated) and magnitude (exponentially-higher levels).  You and I undoubtedly have very different perspectives on this topic, but I will defer to the World Health Organization which has classified electromagnetic fields and radiation in their International Association for the Research of Cancer (IARC) carcinogen list as Group 2B agents.

For the purpose of this letter, I will only stick to electrical discussion.  I will leave human health out of this for the most part, except perhaps to provide a little anecdotal information from my firsthand experience.  You may recall the video I made showing the disconnection of the ground bond to the city water network.  The ground bond to the home's internal metal plumbing remained intact.  This video caused quite the stir, and continues to do so.  I plan to update it with some information to help people do it in a more prudent manner.  However, the discussion from the video has been very beneficial.

I would greatly appreciate to have a thoughtful public discussion with you on this topic.  I have been respectfully arguing with a number of electricians on YouTube.  They cannot answer a number of questions and points I have brought up regarding city water network bonding.  I hope that you may discuss this with me for the benefit of all.  It is my sincere belief based on my education, knowledge and experience.

1) City metal water pipe networks create countless low-impedance paths for primary and secondary neutral grounded conductor current to traverse and measurably act as current-carrying conductors in circuits 24/7/365.

2) To my knowledge the NEC requires conductors to be approved electrical conductors only - pipes and other objects are not allowed to be used as current-carrying conductors in circuits.

3) Parallel conductors are allowed but only in circuit circumstances and with restrictions.  Pipes being used as parallel primary and secondary neutral current-carrying conductors do not meet this either. (Violation of 310.10(H) and/or 366.20?)

4) All conductors of a circuit must be in the same cable/raceway/conduit/etc.  Pipes used as current-carrying conductors would be in violation of this as well. 300.3(B)(1) through (B)(4).

5) The NEC mentions objectionable current (250.6), and we know about the transformer affect with induced current, heating, and voltage potentials caused by the electromagnetic fields.  Why is this circuit current traversing the city water network considered objectionable?  Is there a threshhold for what is considered objectionable and if so upon what is that based?

6) In one or more of your videos you discuss ground rods and auxiliary ground rods.  In particular you mention having distant ground rods far away and lengthy wires going to them as being undesirable.  Also, if I am not mistaken, you mention that it's best when all the ground rods are in one location near to one another.  This matches my knowledge as well, as rods with greater separation may encourage lightning to travel the wire between the rods.  Not that this necessarily causes issues, but there is not an advantage to remote rods spread far apart and there only seems to be disadvantages.  The city water pipe is a remote ground rod in most circumstances separate from the ground rods driven near the service/meter/panel(s) and far away.

7) Many of the electricians who have insisted it is extremely important to bond to the city network have completely disregarded the fact that many homes now don't even have a metal pipe coming in.  Are these homes inherently less safe?  To my knowledge there is no safety advantage of a house with a metal water pipe.  From a health standpoint I contend there are disadvantages based on working with a vast number of clients and knowing many others who have worked with countless clients and reported the same.

8) I understand (and have personally seen, tested, and helped resolve on multiple instances) that service neutrals do become disconnected at times and cause dangerous situations.  But I do not think it is acceptable to simply allow the water pipe to become the only neutral for a building when its electrical service neutral fails for some reason.  This causes a dangerous situation to plumbers in the house, on the street, and even in neighboring buildings in some cases.  Ultimately, it creates more potential for electrocution by electrifying objects that should not be electrified.

I submit these questions/talking points respectfully and earnestly would like to understand more and see what you have to say about the matter.  My believe is that the practice of bonding to the city water network actually violates NEC as pointed out above.  Not only does it violate NEC, which has conflicted codes on the matter, but I believe it is an outdated practice that causes problems.  It violates the correct practice of keeping electrical current on electrical cables/wires and off of other objects.  It creates issues that should be avoided and are bad practice.

I contend that this practice of bonding to city water networks is harmful, hazardous, outdated, and should be rectified.  I can back this up with the fact that I have measured and recorded images/video of  measurements of countless water service pipes whereupon they enter the building.  I have measured everywhere from a few milliamperes to over 20 amperes of AC current traversing the city network at the point of entrance into a building.

My proposal is that the NEC be updated as follows: 1) An electrical break such as plastic water meter, portion of PEX tubing, or 2 dielectric unions be installed where water service enters a building if not installed at the street as in some locales.  Breaking the connection to the city network will raise the impedance and remove large amounts of current from the water supply pipe. 2) The internal metal pipe network must be bonded as usual. 3) The incoming metal pipe should be insulated, or there should be safe distance (eg. 6 feet) from the buildings internal metal network or other grounded metal objects to the incoming metal water pipe that is still connected to the city water pipe network.

We have dedicated the website KeepItOnWires.org to return electrical current to current-carrying electrical conductors.  Too much current is present on pipes, and even on the surface of the earth.  This causes a number of concerns and should be avoided, as electricity should be confined to wiring as much as possible, except in temporary fault conditions which should be promptly cleared/rectified.  I hope you will assist us in pushing to resolve this issue with water pipes being used as current-carrying conductors.  I am certainly open to discussion if you disagree.  I am open to being corrected, but I believe the points I've made and the questions I've raised are, respectively, accurate and substantial.