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Electric Vehicle Charging Stations (EVCS) & Access

 

Janis Kent, Architect, FAIA, CASp © January, 2016

As Electric Vehicles become more prevalent, the question comes up of what to do to make them accessible and even whether or not they are required to be accessible. Although not specifically mentioned in the ADA Standards, the prevailing requirement in the implementing regulations requires a measure of access for all. So if an element is available to the able-bodied population, then it should also be available for those with a disability. Since there are no scoping and technical requirements what do you do?

Suggested Requirements per the US Access Board

The US Access Board does provide us some direction in their Technical Guide —“Parking Spaces – Electric Vehicle Charging Stations & Common Questions.” One thing to keep in mind is that charging stations are NOT considered parking spaces and hence are not considered in the overall parking counts. They are considered separately and scoped separately.

The Technical Guide suggests providing the number of electric vehicle charging stations in the same proportion that Table 208.2 provides for accessible parking spaces, based on the total number of charging stations per parking facility. The suggested technical requirements are a 10’ to 13’ width accessible vehicle charging space, with an additional 3’ minimum on each long side leading to an accessible route at the head of the charging station. So the suggested, not required, charging station measures 16’ to 19’ in width by the length designated by local authorities for accessible parking.

EVCS in California

California has developed further actual requirements which go into effect on January 1, 2017. These requirements differ from the suggested Technical Guide, but are in agreement that charging stations are not parking spaces and are not part of the overall parking count. When EVCS are provided, there are requirements for van and standard accessible and when over 25 stations are provided, then there is a provision of ambulatory charging stations. When calculating the number of charging stations, use the number of stalls a multi-port charger can serve at one time.

Although a van accessible station is to be provided whenever EVCS are provided, it is not reserved with an ISA until there are 5 or more charging stations. When there are more than 25 EVCS then all van and standard accessible charging stations are to be reserved with an ISA. There is also provision for drive-up charging stations similar to a gas filling station. There is no requirement for proportional spending when installing new EVCS in an existing facility, nor is there a requirement to retrofit older charging stations when altered, although the existing stations are included in the count when determining the required number of van, standard, or ambulatory stations to provide.

There are more specific technical requirements for size, signage, and surface markings in the access aisle, as well as a chart for the required number of charging stations per quantity and type. There are also scoping exceptions for assigned employee spaces, vehicle fleets not available to the general public, and to public multi-family housing for tenant use at their residence.

Do realize that if EVCS are already provided and currently not accessible, they require readily achievable barrier removal or program access, depending on whether it is private or public, in order to provide for Access. General requirements applicable are for reach range for the controls, operating force, point-of-sale, and clear height requirements would also be applicable where provided. The other item to keep in mind, is provision of accessible parking spaces for designated recreational vehicle parking, motor homes, and camping and boating trailers which would also be applicable. RV spaces should be scoped separately from parking and have an access aisle for the full length of the designated space, using Table 208.2 to determine quantity.

 

Be aware that your local City or County may have additional requirements that are more restrictive and providing greater access than the State or Federal requirements. Also, this article is an interpretation and opinion of the writer. It is meant as a summary – current original regulations should always be reviewed when making any decisions.

© Janis Kent, Architect, FAIA, CASp 2016