Electric Vehicle Charging Stations, Accessibility: FAQs

MISCELLANEOUS QUESTIONS:

Can a disabled non-EV driver park in an ADA EVSE spot?

RESPONSE: The California Vehicle Code prohibits parking a vehicle in an EVCS. Vehicles left in EVCS spaces must be connected for charging purposes. DSA understands this applies to accessible EVCS too.

Will CALGreen be amended to require that some parking spaces are designed so that they can comply with Chapter 11B requirements when converted to EV charging spaces (i.e. slope, vertical clearance, path of travel)?

RESPONSE: DSA is not aware of any efforts to amend the California Green Code in this manner. While the California Green Code nonresidential mandatory measures require projects to identify an EV space, provide an electrical raceway to the service panel, and provide adequate capacity at the service panel for future EVCS; good design practice would be to incorporate appropriate ground surfaces and routes to facilitate the later installation of usable accessible EVCS. Plans and specifications must accurately describe the full extent of the work to be performed. Some enforcement jurisdictions (primarily city- and county building departments) may have additional requirements.

What accessibility requirements apply to EV charger installation outside of California?

RESPONSE: To the extent that EVCS are a public accommodation or commercial facility they are covered by the federal law of the Americans with Disabilities Act. Specific technical requirements for EVCS are not specified in the 2010 ADA Standards for Accessible Design. DSA is not familiar with state and municipal accessibility requirements for EVCS outside of California.

Has there been consideration for electric vehicles being parked in valet mode that could share EVSE and meet the equivalent EVSE option? This could reduce the cost of construction and major electrical upgrades.

RESPONSE: Electric vehicles may be parked by a valet just as any other car. CBC Chapter 11B does not contain specific accessibility provisions for situations where the valet service provides EV charging in addition to parking service. Absent specific requirements, this situation would require the building official to determine the extent of applicable accessibility requirements on a case-by-case basis. DSA encourages designers to consult with jurisdictional building officials (primarily city- and county building departments) whenever there is a question of code interpretation or application.

It appears that the accessibility standards may result in lots of chargers in ADA spaces not being used or “stranded assets.” Was this issue addressed in development of the standards?

RESPONSE: This issue was discussed extensively during development of the CBC Chapter 11B accessibility provisions for EVCS. The requirements were developed to provide full compliance with federal and California accessibility law without placing an excessive burden on the property owners.

Vehicle spaces which display the International Symbol of Accessibility (ISA), sometimes referred to as the wheelchair symbol, are generally understood to be reserved for the exclusive use of a disabled person displaying special license plates or a distinguishing placard. It is important to remember that a disability placard or special license plate with an ISA can be issued to a driver or passenger for a disability that does not necessitate the use of a wheelchair or mobility device; therefore it is incorrect to assume that an accessible EVCS will be underutilized, because disability placard holders may have an electric vehicle or may purchase one in the near future.

For EV with the charging port at rear of the vehicle, can EV be assumed to be able to back in the parking space for easy access to the charger at the head location?

RESPONSE: This practice is not regulated by the CBC Chapter 11B accessibility provisions. DSA is not aware of any restrictions on this practice.

Are the ADA spaces ADA-only? Vans only in Van accessible spaces?

RESPONSE: Standard accessible and van accessible EVCS vehicle spaces which display the International Symbol of Accessibility (ISA), sometimes referred to as the wheelchair symbol, are generally understood to be reserved for the exclusive use of a disabled person displaying special license plates or a distinguishing placard.

Van accessible EVCS vehicle spaces which display the ISA are not reserved for vans only. They may be used by a disabled person with a standard vehicle or van displaying special license plates or a distinguishing placard.

What is best way to provide accessible curb-side EVCS (like parallel parking)?

RESPONSE: Though the building code does not regulate EVCS in the public right-of-way, accessibility is still required under the federal Americans with Disabilities Act. Since there are no explicit regulations it will be up to you to provide an accessible solution which is acceptable to the jurisdictional authorities. You may wish to refer to the new CBC Chapter 11B provisions as “guidelines” because they were crafted to address vehicle spaces that are parallel to the vehicular way as well as the more traditional pull-in space. In this case, you would apply the general requirements to curbside locations. Note that an explicit exception is provided in Section 11B-812.10.4 Exception 3.