National Electrical Code -- requires hardwiring?

[phidauex]

The "authority having jurisdiction" is the standard phrase used, as to who makes the final call. That means the local government inspector/permit office, regardless of what documents they use for reference, has the final say. How they interpret the NEC may be different than another jurisdiction, and in fact it is not necessary for them to even reference NEC, since they determine the local requirement.

Not to get too far into the weeds on code topics, but AHJs have "limited discretion" as opposed to "unbounded discretion", meaning that while they can set additional requirements, and make certain interpretations of the code, they can only do so in a relatively small box set out by the local statutes. There isn't anywhere in the US that I'm aware of that can choose not to follow the NEC (or the locally adopted version) - that would be "unbounded discretion".

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[phidauex]

The true "fuzzy distinction" is in thinking that there is a distinction with a difference. See my example above pointing out that the outlet requirements for both types ARE EXACTLY THE SAME. With an exception for three phase power, not relevant here, any "portable" EVSE can plug into the same outlet as a similar "fastened-on" EVSE. If you don't think this is the case, explain yourself.

Rather than focusing on whether the EVSE is portable or fastened-on, which doesn't matter, focus on the GFCI breaker requirement, which does.

I agree with you that the requirements for fastened and portable are the same - I'm not focusing on that difference, I'm focusing on the difference between fastened and fixed, which are not the same. I'm not sure what you are objecting to here.

If you want to know whether the 2020 NEC allows a 32A EVSE to be plugged into a receptacle, or must be hardwired, then you need to know whether it requires a tool to be removed or not. If it needs a tool to be removed, then it must be hardwired, regardless of what the GFCI requirement is.

The reason I'm a little less worried about the GFCI requirement, though that is germane, is that you'd be more likely to get a part 90 exemption to the GFCI requirement by showing that the installation manual tells you not to install one. That is an area for AHJ interpretation (since other equipment could also use that receptacle), but guidance from the instruction manual of a UL listed product can and does allow for overriding some provisions of the NEC.

I'm willing to bet that the Grizzl-E's use of a cotter pin is a careful dance around the fastened/fixed distinction, allowing it to clearly fall into the "fastened" category and giving the homeowner more options, which is nice.

 

[phidauex]

Does anyone have a copy of the latest NEC part 625? Oregon's (or Portland's) corresponding electrical code?

Here is the 2020 Article 625. I omitted the ventilation tables since they won't format right and aren't relevant to these installs, and I left out the wireless power transfer section, too.

ARTICLE 625 Electric Vehicle Power Transfer System

Part I. General

625.1 Scope.
This article covers the electrical conductors and equipment connecting an electric vehicle to premises wiring for the purposes of charging, power export, or bidirectional current flow.

Informational Note No. 1: For industrial trucks, see NFPA 505-2018, Fire Safety Standard for Powered Industrial Trucks Including Type Designations, Areas of Use, Conversions, Maintenance, and Operations.

Informational Note No. 2: UL 2594-2013, Standard for Electric Vehicle Supply Equipment, is a safety standard for conductive electric vehicle supply equipment. UL 2202-2009, Standard for Electric Vehicle Charging System Equipment, is a safety standard for conductive electric vehicle charging equipment.

625.2 Definitions.
The following definitions shall apply only within this article.

Cable Management System.
An apparatus designed to control and organize the output cable to the electric vehicle or to the primary pad.

Charger Power Converter.
The device used to convert energy from the power grid to a high-frequency output for wireless power transfer.

Electric Vehicle Connector.
A device that, when electrically coupled (conductive or inductive) to an electric vehicle inlet, establishes an electrical connection to the electric vehicle for the purpose of power transfer and information exchange. Informational Note: For further information, see 625.48 for interactive systems.

Electric Vehicle Power Export Equipment (EVPE).
The equipment, including the outlet on the vehicle, that is used to provide electrical power at voltages greater than or equal to 30 Vac or 60 Vdc to loads external to the vehicle, using the vehicle as the source of supply.

Informational Note: Electric vehicle power export equipment and electric vehicle supply equipment are sometimes contained in one piece of equipment, sometimes referred to as a bidirectional EVSE.

Electric Vehicle Supply Equipment (EVSE).
The conductors, including the ungrounded, grounded, and equipment grounding conductors, and the electric vehicle connectors, attachment plugs, personnel protection system, and all other fittings, devices, power outlets, or apparatus installed specifically for the purpose of transferring energy between the premises wiring and the electric vehicle.

Informational Note: Electric vehicle power export equipment and electric vehicle supply equipment are sometimes contained in one piece of equipment, sometimes referred to as a bidirectional EVSE.

Fastened in Place.
Mounting means of equipment in which the fastening means are specifically designed to permit periodic removal, without the use of a tool, for relocation, interchangeability, maintenance, or repair.

Fixed in Place.
Mounting means of an EVSE attached to a wall or surface with fasteners that require a tool to be removed.

Output Cable to the Electric Vehicle.
An assembly consisting of a length of flexible EV cable and an electric vehicle connector (supplying power to the electric vehicle).

Output Cable to the Primary Pad.
A multi-conductor, shielded cable assembly consisting of conductors to carry the high-frequency energy and any status signals between the charger power converter and the primary pad.

Personnel Protection System.
A system of personnel protection devices and constructional features that when used together provide protection against electric shock of personnel.

Portable (as applied to EVSE).
A device intended for indoor or outdoor use that can be carried from charging location to charging location and is designed to be transported in the vehicle when not in use.

Power-Supply Cord.
An assembly consisting of an attachment plug and length of flexible cord that connects equipment to a receptacle.

Primary Pad.
A device external to the EV that transfers power via the contactless coupling as part of a wireless power transfer system.

Wireless Power Transfer (WPT).
The transfer of electrical energy from a power source to an electrical load via electric and magnetic fields or waves by a contactless inductive means between a primary and a secondary device.

Wireless Power Transfer Equipment (WPTE).
Equipment consisting of a charger power converter and a primary pad. The two devices are either separate units or contained within one enclosure.

625.4 Voltages.
Unless other voltages are specified, the nominal ac system voltages of 120, 120/240, 208Y/120, 240, 480Y/277, 480, 600Y/347, 600, and 1000 volts and dc system voltages of up to 1000 volts shall be used to supply equipment covered by this article.

625.5 Listed.
All equipment covered by the scope of this article shall be listed.

Part II. Equipment Construction

625.17 Cords and Cables.

625.17(A) Power-Supply Cord.
The cable for cord-connected equipment shall comply with all of the following:

1. Be any of the types specified in 625.17(B)(1) or hard service cord, junior hard service cord, or portable power cable types in accordance with Table 400.4. Hard service cord, junior hard service cord, or portable power cable types shall be listed, as applicable, for exposure to oil and damp and wet locations.
2. Have an ampacity as specified in Table 400.5(A)(1) or, for 8 AWG and larger, in the 60°C columns of Table 400.5(A)⁠(2).
3. Have an overall length as specified in either of the following:
   1. a.
      When the interrupting device of the personnel protection system specified in 625.22 is located within the enclosure of the supply equipment or charging system, the power-supply cord shall be not more than the length indicated in (i) or (ii):
      1. (i)
         For portable equipment in accordance with 625.44(A), the power supply cord shall be not more than 300 mm (12 in.) long.
      2. (ii)
         For stationary equipment in accordance with 625.44(B), the power supply cord shall be not more than 1.8 m (6 ft) long and the equipment shall be installed at a height that prevents the power supply cord from contacting the floor when it is connected to the proper receptacle.
   2. b.
      When the interrupting device of the personnel protection system specified in 625.22 is located at the attachment plug, or within the first 300 mm (12 in.) of the power-supply cord, the overall cord length shall be not greater than 4.6 m (15 ft)

625.17(B) Output Cable to Electric Vehicle.
The output cable to the electric vehicle shall be one of the following:

1. Listed Type EV, EVJ, EVE, EVJE, EVT, or EVJT flexible cable as specified in Table 400.4
2. An integral part of listed electric vehicle supply equipment

Informational Note: For information and listing requirements for electric vehicle supply equipment, see UL 2594-2016, Standard for Electric Vehicle Supply Equipment, and UL 2202-2009, Standard for Electric Vehicle (EV) Charging System Equipment.

625.17(C) Overall Cord and Cable Length.
The overall usable length shall not exceed 7.5 m (25 ft) unless equipped with a cable management system that is part of the listed electric vehicle supply equipment.

625.17(C)(1) Portable Equipment.
For portable EVSE, the cord-exposed usable length shall be measured from the face of the attachment plug to the face of the electric vehicle connector.

625.17(C)(2) Fastened in Place.
Where the electric vehicle supply equipment is fastened in place, the usable length of the output cable shall be measured from the cable exit of the electric vehicle supply equipment to the face of the electric vehicle connector.

625.17(D) Interconnecting Cabling Systems.
Other cabling systems that are integral parts of listed EVSE and are intended to interconnect pieces of equipment within an EVSE system using approved installation methods shall be permitted.

625.22 Personnel Protection System.
The equipment shall have a listed system of protection against electric shock of personnel. Where cord-and-plug-connected equipment is used, the interrupting device of a listed personnel protection system shall be provided according to 625.17(A). A personnel protection system shall not be required for supplies less than 60 volts dc.

Part III. Installation

625.40 Electric Vehicle Branch Circuit.
Each outlet installed for the purpose of charging electric vehicles shall be supplied by an individual branch circuit. Each circuit shall have no other outlets.

625.41 Overcurrent Protection.
Overcurrent protection for feeders and branch circuits supplying EVSE, including bidirectional EVSE, and WPTE shall be sized for continuous duty and shall have a rating of not less than 125 percent of the maximum load of the equipment. Where noncontinuous loads are supplied from the same feeder, the overcurrent device shall have a rating of not less than the sum of the noncontinuous loads plus 125 percent of the continuous loads.

625.42 Rating.
The power transfer equipment shall have sufficient rating to supply the load served. Electric vehicle charging loads shall be considered to be continuous loads for the purposes of this article. Service and feeder shall be sized in accordance with the product ratings. Where an automatic load management system is used, the maximum equipment load on a service and feeder shall be the maximum load permitted by the automatic load management system.

Adjustable settings shall be permitted on fixed-in-place equipment only. If adjustments have an impact on the rating label, those changes shall be in accordance with manufacturer’s instructions, and the adjusted rating shall appear with sufficient durability to withstand the environment involved on the rating label. Electric vehicle supply equipment with restricted access to an ampere adjusting means shall be permitted to have ampere ratings that are equal to the adjusted current setting. Sizing the service and feeder to match the adjusting means shall be permitted. Restricted access shall prevent the user from gaining access to the adjusting means. Restricted access shall be accomplished by at least one of the following:

1. A cover or door that requires the use of a tool to open
2. Locked doors accessible only to qualified personnel
3. Password protected commissioning software accessible only to qualified personnel

625.43 Disconnecting Means.
For equipment rated more than 60 amperes or more than 150 volts to ground, the disconnecting means shall be provided and installed in a readily accessible location. The disconnecting means shall be lockable open in accordance with 110.25.

625.44 Equipment Connection.
EVSE and WPTE shall be connected to the premises wiring system in accordance with one of the methods in 625.44(A) through (C).

625.44(A) Portable Equipment.
Portable equipment shall be connected to the premises wiring system by one or more of the following methods:

1. A nonlocking, 2-pole, 3-wire grounding-type receptacle outlet rated at 125 volts, single phase, 15 or 20 amperes
2. A nonlocking, 2-pole, 3-wire grounding-type receptacle outlet rated at 250 volts, single phase, 15 or 20 amperes
3. A nonlocking, 2-pole, 3-wire or 3-pole, 4-wire grounding-type receptacle outlet rated at 250 volts, single phase, 30 or 50 amperes
4. A nonlocking, 2-pole, 3-wire grounding-type receptacle outlet rated at 60 volts dc maximum, 15 or 20 amperes

625.44(B) Fastened-in-Place Equipment.
Equipment that is fastened in place shall be connected to the premises wiring system by one of the following methods:

1. A nonlocking, 2-pole, 3-wire grounding-type receptacle outlet rated 125 volts or 250 volts, single phase, up to 50 amperes
2. A nonlocking, 3-pole, 4-wire grounding-type receptacle outlet rated 250 volts, three phase, up to 50 amperes
3. A nonlocking, 3-pole, 4-wire grounding-type receptacle outlet rated 250 volts, single phase, 30 or 50 amperes
4. A nonlocking, 2-pole, 3-wire grounding-type receptacle outlet rated 60 volts dc maximum, 15 or 20 amperes

625.44(C) Fixed Equipment.
All other EVSE and WPTE shall be permanently wired and fixed in place to the supporting surface.

625.46 Loss of Primary Source.
Means shall be provided such that, upon loss of voltage from the utility or other electrical system(s), energy cannot be back fed through the electric vehicle and the supply equipment to the premises wiring system unless permitted by 625.48.

625.47 Multiple Feeder or Branch Circuits.
Where equipment is identified for the application, more than one feeder or branch circuit shall be permitted to supply equipment.

625.48 Interactive Systems.
EVSE that incorporates a power export function and that is part of an interactive system that serves as an optional standby system, an electric power production source, or a bidirectional power feed shall be listed and marked as suitable for that purpose. When used as an optional standby system, the requirements of Article 702 shall apply; when used as an electric power production source, the requirements of Article 705 shall apply. EVPE that consists of a receptacle outlet only shall be in accordance with 625.60.

Informational Note: For further information on supply equipment, see ANSI/UL 1741, Standard for Inverters, Converters, Controllers and Interconnection System Equipment for Use with Distributed Energy Resources, and ANSI/UL 9741, Bidirectional Electric Vehicle (EV) Charging System Equipment; for vehicle interactive systems, see SAE J3072, Standard for Interconnection Requirements for Onboard, Utility-Interactive Inverter Systems.

625.50 Location.
The EVSE shall be located for direct electrical coupling of the EV connector (conductive or inductive) to the electric vehicle. Unless specifically listed and marked for the location, the coupling means of the EVSE shall be stored or located at a height of not less than 450 mm (18 in.) above the floor level for indoor locations or 600 mm (24 in.) above the grade level for outdoor locations. This requirement does not apply to portable EVSE constructed in accordance with 625.44(A).

625.52 Ventilation.
The ventilation requirement for charging an electric vehicle in an indoor enclosed space shall be determined by 625.52(A) or (B).

625.52(A) Ventilation Not Required.
Where electric vehicle storage batteries are used or where the equipment is listed for charging electric vehicles indoors without ventilation, mechanical ventilation shall not be required.

625.52(B) Ventilation Required.
Where the equipment is listed for charging electric vehicles that require ventilation for indoor charging, mechanical ventilation, such as a fan, shall be provided. The ventilation shall include both supply and exhaust equipment and shall be permanently installed and located to intake from, and vent directly to, the outdoors. Positive-pressure ventilation systems shall be permitted only in vehicle charging buildings or areas that have been specifically designed and approved for that application. Mechanical ventilation requirements shall be determined by one of the methods specified in 625.52(B)(1) through (B)(4).

625.52(B)(1) Table Values.
Omitted

625.52(B)(3) Engineered Systems.
For an equipment ventilation system designed by a person qualified to perform such calculations as an integral part of a building’s total ventilation system, the minimum ventilation requirements shall be permitted to be determined in accordance with calculations specified in the engineering study.

625.52(B)(4) Supply Circuits.
The supply circuit to the mechanical ventilation equipment shall be electrically interlocked with the equipment and shall remain energized during the entire electric vehicle charging cycle. Equipment receptacles rated at 125 volts, single phase, 15 and 20 amperes shall be switched and the mechanical ventilation system shall be electrically interlocked through the switch supply power to the receptacle. Equipment supplied from less than 50 volts dc shall be switched and the mechanical ventilation system shall be electrically interlocked through the switch supply power to the equipment.

625.54 Ground-Fault Circuit-Interrupter Protection for Personnel.
In addition to the requirements in 210.8, all receptacles installed for the connection of electric vehicle charging shall have ground-fault circuit-interrupter protection for personnel.

625.56 Receptacle Enclosures.
All receptacles installed in a wet location for electric vehicle charging shall have an enclosure that is weatherproof with the attachment plug cap inserted or removed. An outlet box hood installed for this purpose shall be listed and shall be identified as extra duty. Other listed products, enclosures, or assemblies providing weatherproof protection that do not utilize an outlet box hood shall not be required to be marked extra duty.

625.60 AC Receptacle Outlets Used for EVPE.
AC receptacles installed in electric vehicles and intended to allow for connection of off-board utilization equipment shall comply with 625.60(A) through (D).

625.60(A) Type.
The receptacle outlet shall be listed.

625.60(B) Rating.
The receptacle outlet shall be rated 250 volts maximum, single phase 50 amperes maximum.

625.60(C) Overcurrent Protection.
Electric vehicles provided with receptacle outlets for power export shall be provided with overcurrent protection integral to the power export system. The overcurrent protection shall have a nominal rating sufficient for the receptacle it protects. The overcurrent protection shall also be sufficiently rated for the maximum available fault current at the receptacle and shall be included in the interactive equipment evaluation. See 625.48.

625.60(D) GFCI Protection for Personnel.
Ground-fault circuit-interrupter protection for personnel shall be provided for all receptacles. The ground-fault circuit-interrupter indication and reset shall be installed in a readily accessible location.

Informational Note: There are various methods available to achieve ground-fault circuit-interrupter protection.

 

[louibluey]

Okay that makes sense. I wrote to PGE and asked for more information. Let's see what Oregon PGE says. I sent them this link too.

PGE answered today. There are two reasons @DBC is correct as to reason 1, probably the most important one.

The second reason is interesting, PGE believes that according to 2020 NEC, a settable EVSE (EVSE with adjustable circuit amperage), must be hardwired. Presumably they are going for a fail safe approach, where if someone sets the amperage incorrectly, it will still be safe (although that notion of "fail safe" assumes the hardwire installation is for the maximum available EVSE setting).

PGE can set rules as they desire, but with respect, and for possible future rule making, both rules defeat important considerations. First those with a 240V outlet for the EVSE can have a spare EVSE to plug in, possibly including the Ford OEM EVSE with the correct receptacle, and also can unplug and travel with the same EVSE. Second the new flexibility of settable EVSE is defeated if they need to be hardwired, because the whole point as I understood it, was that you could buy one model (e.g. chargepoint flex) and set it for the circuit you have available, with some upgrade/future proofing kind of built in, especially for those initially running at one of the lower settings.

As far as I saw, PGE did not expressly say that the hardwire installation has to be rated for the highest possible settable EVSE amperage, so that could be a minor inconsistency in the policy, or maybe they just did not mention it in the email reply.

Ah well, many thanks to PGE for replying.

 

[phidauex]

PGE answered today. There are two reasons @DBC is correct as to reason 1, probably the most important one.

The second reason is interesting, PGE believes that according to 2020 NEC, a settable EVSE (EVSE with adjustable circuit amperage), must be hardwired. Presumably they are going for a fail safe approach, where if someone sets the amperage incorrectly, it will still be safe (although that notion of "fail safe" assumes the hardwire installation is for the maximum available EVSE setting).

PGE can set rules as they desire, but with respect, and for possible future rule making, both rules defeat important considerations. First those with a 240V outlet for the EVSE can have a spare EVSE to plug in, possibly including the Ford OEM EVSE with the correct receptacle, and also can unplug and travel with the same EVSE. Second the new flexibility of settable EVSE is defeated if they need to be hardwired, because the whole point as I understood it, was that you could buy one model (e.g. chargepoint flex) and set if for the circuit you have available, with some upgrade/future proofing kind of built in, especially for those initially running at one of the lower settings.

As far as I saw, PGE did not expressly say that the hardwire installation has to be rated for the highest possible settable EVSE amperage, so that could be a minor inconsistency in the policy, or maybe they just did not mention it in the email reply.

Ah well, many thanks to PGE for replying.

Thanks for getting their view on it. It does look like the 2020 NEC is stacked against plug-in EVSEs on a few fronts. Regarding the adjustable current, they are probably referring to 625.42, which says that you can use an adjustable setting to get a lower current rating on the circuit, but only if the unit is fixed-in-place (and hence hardwired), and if the adjustment requires tools or a password. It is annoying, but matches how the NEC treats adjustable breakers.

That does somewhat defeat the purpose of adjustable settings for portable EVSEs since yeah, it would be nice to have a charger that you could use on anything from 15A to 50A outlets in one product... I wonder if this will start to impact product design, or more flexible UL listings for EVSEs. This is like the early days of PV where every code cycle saw massive changes that upheaved system designs. Finally starting to slow down after 15 years...

 

[janitorjim]

get information from licensed electricians in your area.

 

[mikewillnot]

I think you could make an argument for some EVSE based on how they're mounted then. For example, the Grizzl-e has a mounting plate that is affixed to the wall with screws, but then the actual EVSE slides into place and is only retained with a cotter pin, so you could easily remove it without tools. Maybe this design choice was intentional for this reason?

Grizzl-E and Enel-X (Juicebox) have a similar mounting mechanism. It fits the definition of "fastened in place" and not "fixed in place." (ChargePoint & Tesla have "fixed in place mechanisms, with bolts/screws holding the unit directly to the wall.) Code seems pretty clearly to say that "fastened" requires outlets, while "fixed" requires (or can be?) hard-wired.
Grizzl-E has information in their system indicating that the unit can be hard-wired, by opening it up and removing the line cord. I've installed maybe a dozen units in this way, due to the GFCI problem. We're on the 2017 now, but it seems that in the 2020, this kind of mounting mechanism will *require* the outlet (1450 or 650) approach. I'm thinking, drop this brand until they come up with a "fixed" mounting mechanism.

 

[dtbaker61]

The typical 32A to 40A EVSE on the market uses fasteners, at least one of which is usually intended to go in a through hole (and so "needs" a tool for removal) and currently offer one or more plug options. Either the NEC will need to be revised, ignored, or manufactures need to catch up (e.g. slide on or snap on mounting to the wall, so no tool is needed).

The one specific case not mentioned is the 48A EVSE option, where all EVSE, in most if not all jurisdictions, presently need to be hardwired according to the manufacturer guidelines (because the typical 50A wall receptacles/wiring do not have the 80%/20% overhead for 60A supply/48A use).

in the case of a Ford mobile charger.... only the (optional) holder bracket is screwed into the wall. The charger is 100% 'portable'.

The other thing is that I don't think many Inspectors would hold you to 'upgrading' an outlet to GFCI if it were installed prior to adoption of 2020 NEC

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