I did consult with Jeff Sargent of NFPA about this. Yes, we must derate (as common sense would tell us) for the number of conductors in the conduit, including the conductors in the cables.
The phrase: "and not installed in raceways" was intended to clarify the cables were stacked or bundled, not to confuse the requirement for derating of conductors in confined conditions. Who among us would like to submit clearer language for the next code? Ryan?
