Electric Vehicle Charging Stations, Accessibility: FAQs

TECHNICAL QUESTIONS:

For small parking lots, is there any variance on being able to share EV charging with the existing accessible parking spaces?

RESPONSE: The accessibility provisions in CBC Chapter 11B do not permit a required accessible EVCS to be installed in a required accessible parking space. Section 11B-208.1 notes, “For the purposes of this section, electric vehicle charging stations are not parking spaces…”

Can you put an EV charger in an existing accessible parking space instead of doing costly upgrades?

RESPONSE: The accessibility provisions in CBC Chapter 11B do not permit a required accessible EVCS to be installed in a required accessible parking space. Section 11B-208.1 notes, “For the purposes of this section, electric vehicle charging stations are not parking spaces…”

Currently, the DCFC time limit is 30 minutes maximum. New larger battery capacity will take longer to get 80% charge – i.e. Chevy Bolt EV, Tesla Model 3, 2018 Nissan LEAF, etc. Can we reconsider the time limit?

RESPONSE: The 30 minute time limit applies to drive-up EVCS of any type. This design option allows brief charging and queuing for charging service, and does not consider that batteries will be charged to full capacity. Where DCFC or any other type of charging is intended for use longer than 30 minutes, EVCS may be provided in regular parking-style vehicle spaces.

CAL Green requires x number of EVSE per xxx number of spaces - each on its own 40 amp circuit. Some dual EVSE are on a single 40 amp circuit and split the 40 amp. Does this mean that half of those plugs don't comply with the required number?

RESPONSE: The California Green Code appears to require service panels, sub-panels, and raceway of sufficient capacity to accommodate 40 amp circuits rather than mandating one 40 amp circuit for each EVCS in residential and nonresidential locations. For additional information you may contact the Department of Housing and Community Development for infrastructure requirements at residential locations or the Building Standards Commission for infrastructure requirements at nonresidential locations.

Can you provide recommended signage for ADA accessible spaces?

RESPONSE: Required identification signs for accessible EVCS vehicle spaces are indicated in CBC Chapter 11B Section 11B-812.8 and required vehicle space surface markings are indicated in Section 11B-812.9. Other courtesy messages may be provided but are not required by CBC Chapter 11B.

For projects within the public rights-of-way, the California Department of Transportation (Caltrans) has several signs for EV charging in its California Manual on Uniform Traffic Control Devices. For the appropriate use of these signs you may contact Caltrans.

What are the auditory/braille requirements for EVCS units with a touch screen?

RESPONSE: Accessibility requirements for all point-of-sale devices have been a part of the CBC for many years and allow people with vision impairments to conduct automated transactions in a secure manner. These requirements apply to point-of-sale devices in public buildings, public accommodations commercial buildings and public housing, including restaurants, stores, banks, theaters and DVD rental kiosks – just about anywhere the public conducts automated transactions.

The new CBC accessibility requirements for EVCS specifically identify that each EVCS, whether or not accessible, provided with a point-of-sale device must provide a tactilely discernable numerical keypad, like a push-button telephone keypad or some other technology such as RFID, biometric fingerprint or other mechanism that allows access and privacy (see CBC Section 11B-707.9.1).

Where EVCS are provided with a touch screen but without point-of-sale devices, neither the CBC nor the ADA Standards for Accessible Design provide explicit requirements for the touch screen accessibility. However, Title III of the ADA prohibits discrimination against individuals “…on the basis of disability in the full and equal enjoyment of the goods, services, facilities, privileges, advantages or accommodations of any place of public accommodation…” (see 42 U.S.C. § 12182(a)) Past court cases have indicated that accessibility must be provided at places of public accommodation and governmental programs and services, even in the absence of explicit requirements. Accordingly, DSA advises that designers incorporate touch screen accessibility into their projects.