I don't have any problems with nailing directly into plywood sheathing or using NDS nail withdrawal values, but I do have a problem with the actual nail withdrawal values themselves. If you nail directly into plywood sheathing without any regard for trusses or framing members below, then in the calculations you must assume that supports will be anchored into ONLY plywood. I don't have the NDS in front of me, but the withdrawal values are PER INCH of penetration. For a 1/2 or 5/8 inch piece of plywood and nail withdrawal values on the order of 35 pounds per inch of penetration, you have only about 17 pounds of withdrawal per nail. I don't know the exact circumstances of your particular project, nor do I know the layout of the PV panel array or the anchor point layout of the racking/mounting system, but even in the lightest of conditions, I can't imagine each standoff having less than 200 pounds of uplift force. It's probably more like 400 to 600 pounds. I just can't see how the stamping engineer justified using nails with 17 pounds of uplift resistance to anchor 200-1000 pounds of uplift force.