WireStu,
You are correct that the transformer itself does not require overcurrent protection on the secondary side, however the conductors feeding the panels may require overcurrent protection. See 240-21(c)(2).
Also this installation would be in violation of 384-15 if all 42 spaces are filled and some of the spaces have 1/2 space breakers in them.
Don(resqcapt19)


Don(resqcapt19)