National Electrical Code -- requires hardwiring?

[Roger tobin]

My local utility (Portland General Electric) is offering a rebate to EV owners if a qualified charger is installed that they can then control for peak usage stuff. They are currently pushing the ChargPoint Flex as well as the FLO Home, and are working on qualifying the Enel X Juicebox.

They also have a note on their site saying that as of 5/1/21, all home EV chargers need to be hardwired. They say that this is because Oregon has updated their electrical codes "to align with the 2020 National Electric Code (NEC) in April 2021. The updates to the code require devices like EV chargers to be hardwired for safety purposes. Please work with your electrician to properly hardwire your EV charger according to the manufacturer’s instructions."

I am a little suspicious that this may be a misunderstanding on the part of PGE, but I'd like to defer to those who know more, as I'm not sure all electricians would be up on this, and I don't want to have an inspector say "no" after the fact.

(I'd also like to have a NEMA 14-50 plug installed anyway so that I could use the Ford Mobile charger.)

Thanks,
Roger

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[DBC]

I am a little suspicious that this may be a misunderstanding on the part of PGE, but I'd like to defer to those who know more, as I'm not sure all electricians would be up on this, and I don't want to have an inspector say "no" after the fact.

I don't know what the Oregon code requires. AFAIK the national code doesn't require an EVSE to be hardwired, but it requires a GFCI circuit breaker on a circuit with a 14-50 outlet. Since many EVSE won't work with a GFCI breaker (because they already have a less sensitive GFCI), using one of these has the practical effect of requiring hardwiring. (The ChargePoint Flex would I believe be problematic. The Ford Mobile charger would not be). One benefit of hardwiring is that you don't need the GFCI breaker, which will save some money.

Depending on the amount of the incentive it might or might not be cheaper to use the mobile charger. If you hardwire the Flex but later want to use the mobile charger you would need to add a 14-50 outlet and swap out the breakers. Neither is a big deal but not as simple as if the Flex was using a 14-50 outlet.

 

[phidauex]

To the question of whether an EVSE has to be hardwired or not in the 2020 NEC, it depends on whether you are calling your charger "Portable", "Fastened In Place" or "Fixed". This is new language in the 2020 NEC - in the 2017, for instance, it is "Portable", "Stationary" or "Fixed".

In both cases, "Fastened in Place" and "Stationary" have a similar definition, which is that you leave it in place, but you can easily move it for "interchange, maintenance or repair, or repositioning". In both cases this is supposed to be done without tools, though the 2020 is more specific (the 2017 has a definition mismatch with 625.44(B), which isn't uncommon).

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.

So the conservative view here is that under both 2017 and 2020 NEC, if you are using screws to attach the charger to the wall, then it is "Fixed" and has to be hardwired. People have probably been arguing so far that their Chargepoint with a short cable on it is Stationary or Fastened-in-Place, because they can lift it off the wall and take it to grandma's house.

As always with the NEC, your ability to know the code definitions and make this argument to your local building official will vary - some would be convinced by that, some wouldn't.

Regarding GFCI, the 2017 NEC doesn't appear to mention it in section 625 at all, though the usual GFCI requirements for outdoor/garage outlets would still apply, and the usual requirement that you "follow all manufacturer instructions" would still apply.

In the 2020, it is more explicit:

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.

So outlets do need the GFCI. For Fixed equipment (hardwired) it doesn't state either way, which to me would indicate that the manufacturer's instructions would govern - if they tell you not to install a GFCI breaker (because the unit provides GFCI protection itself) then that would be allowed.

In the Fastened In Place case you might have a conflict - the code says you need the GFCI, the manufacturer may tell you not to install it. Your building official would have to make the call whether the code provision or the manufacturer instructions would govern, but the conservative view would be that the code governs and you need the 50A GFCI breaker (or hardwire).

 

[DBC]

To the question of whether an EVSE has to be hardwired or not in the 2020 NEC, it depends on whether you are calling your charger "Portable", "Fastened In Place" or "Fixed".

Don't overthink this. By definition, when an EVSE is plugged into a specified outlet it's either "Portable" or "Fastened in Place". If it's hardwired it's "Fixed".

So outlets do need the GFCI. For Fixed equipment (hardwired) it doesn't state either way, which to me would indicate that the manufacturer's instructions would govern - if they tell you not to install a GFCI breaker (because the unit provides GFCI protection itself) then that would be allowed.

Since the reason for the GFCI requirement is the outlet, if you don't have an outlet you don't need a GFCI breaker. FWIW ChargePoint says not to have a GFCI on the circuit but that's neither here nor there since the recommendation holds for both the plug-in and wired versions.

 

[phidauex]

Don't overthink this. By definition, when an EVSE is plugged into a specified outlet it's either "Portable" or "Fastened in Place". If it's hardwired it's "Fixed".

The whole business of the NEC is overthinking things.

Here are the 2020 definitions - to me this reads that the method of mounting determines the type of EVSE, and the type of EVSE determines how you can connect it, so an EVSE bolted to the wall (Fixed) with a plug connection would not be compliant. Not saying all AHJs would interpret that way, but if I was a building official and I didn't like you, then that is how I'd call it...

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.

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.

It is clear that the industry making these chargers isn't following the same criteria, but they don't necessarily have to, there are frequently mismatches between installation instructions and the code that need to be worked out, sometimes case by case.

 

[DBC]

Here are the 2020 definitions - to me this reads that the method of mounting determines the type of EVSE, and the type of EVSE determines how you can connect it, so an EVSE bolted to the wall (Fixed) with a plug connection would not be compliant. Not saying all AHJs would interpret that way, but if I was a building official and I didn't like you, then that is how I'd call it...

Several problems with insisting that these definitions are meaningful. One is that unless the EVSE is hardwired all you're looking at is an outlet. How the EVSE might be attached is unknown. Two is that since it's a choice how the EVSE is attached, any EVSE can be fastened in place or portable. I have two EVSE. One is attached to the wall and one hangs on an Elfa hook from The Container Store. I could switch them! Third and finally, other than when using 3 phase power -- which isn't an issue -- the requirements are exactly the same. It simply doesn't make any difference if the EVSE is fastened in place or portable. Why do you think it matters?

The reality is that the only distinction is between hardwired and not hardwired.

 

[phidauex]

Several problems with insisting that these definitions are meaningful. One is that unless the EVSE is hardwired all you're looking at is an outlet. How the EVSE might be attached is unknown. Two is that since it's a choice how the EVSE is attached, any EVSE can be fastened in place or portable. I have two EVSE. One is attached to the wall and one hangs on an Elfa hook from The Container Store. I could switch them! Third and finally, other than when using 3 phase power -- which isn't an issue -- the requirements are exactly the same. It simply doesn't make any difference if the EVSE is fastened in place or portable. Why do you think it matters?

The reality is that the only distinction is between hardwired and not hardwired.

Don't mistake my position here - I'm not saying the code makes sense (particularly on the fuzzy distinction between Fastened and Fixed). However, the OP's question was specifically about the 2020 NEC, so I wanted to point out exactly what the 2020 NEC says, and what its definitions are. Whether they match common sense or not is a totally different question, and what an individual homeowner should do with their own EVSE is a third question.

I've spent enough hours in testimony on NEC and UL topics with building officials and boards to know that whether the definition makes sense or not, if there is a dispute with the utility or the building department, those definitions will govern. If there is no dispute, then there is nothing to worry about.

 

[louibluey]

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).

 

[CHeil402]

So the conservative view here is that under both 2017 and 2020 NEC, if you are using screws to attach the charger to the wall, then it is "Fixed" and has to be hardwired. People have probably been arguing so far that their Chargepoint with a short cable on it is Stationary or Fastened-in-Place, because they can lift it off the wall and take it to grandma's house.

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?

I have a NEMA 14-50 plug and don't have a GFCI breaker as the Grizzl-e manual says not to install it; however, PA is still using the 2014 NEC.

 

[DBC]

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).

It doesn't make any difference. The standards are EXACTLY the same. My objection to the post about the difference in EVSE attachments was that introducing the meaningless concepts of "portable" or "fastened on" would just confuse people and send them down bunny trails. You've made the point by running down one of those trails.

Let's take an example of a 32A EVSE. If it's "portable" then it has to be connected to:

(3) A nonlocking, ... 3-pole, 4-wire grounding-type receptacle outlet rated at 250 volts, single phase, 30 or 50 amperes

If it's "fastened on" then it has to be connected to:

(3) A nonlocking, 3-pole, 4-wire grounding-type receptacle outlet rated 250 volts, single phase, 30 or 50 amperes

What is the difference? Obviously there isn't any -- the same outlet will be code compliant regardless of which is plugged in. Again, for the fourth or fifth time, the only thing that matters is whether the EVSE is hardwired or not. If not then the outlet needs to be on a circuit protected by a GFCI breaker. If it's hardwired you can use regular breakers.

I think you could make an argument for some EVSE based on how they're mounted then.
....

I have a NEMA 14-50 plug and don't have a GFCI breaker as the Grizzl-e manual says not to install it; however, PA is still using the 2014 NEC.

Code is not retrospective, meaning that you don't have to change things when the code changes. Code requires dryer outlets to be four wire but there are millions and millions of three wire dryer outlets out there.

 

[DBC]

Don't mistake my position here - I'm not saying the code makes sense (particularly on the fuzzy distinction between Fastened and Fixed).

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.

 

[louibluey]

My local utility (Portland General Electric) is offering a rebate to EV owners if a qualified charger is installed that they can then control for peak usage stuff. They are currently pushing the ChargPoint Flex as well as the FLO Home, and are working on qualifying the Enel X Juicebox.

They also have a note on their site saying that as of 5/1/21, all home EV chargers need to be hardwired. They say that this is because Oregon has updated their electrical codes "to align with the 2020 National Electric Code (NEC) in April 2021. The updates to the code require devices like EV chargers to be hardwired for safety purposes. Please work with your electrician to properly hardwire your EV charger according to the manufacturer’s instructions."
...

okay, slow down. Let's go back to the original question. I got as far as reviewing the Portland requirement. PGE Home EV Charging Rebates

Here’s how to get your rebate: ... Purchase and install a new qualifying EV charger (starting May 1, 2021, all new installations must be hardwired) ... Wait, Roger can you have it installed today or tomorrow

So, Roger's post is seemingly unrelated to receptacles and GFCI.

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

 

[DBC]

okay, slow down. Let's go back to the original question. I got as far as reviewing the Portland requirement. PGE Home EV Charging Rebates

Here’s how to get your rebate: ... Purchase and install a a new qualifying EV charger (starting May 1, 2021, all new installations must be hardwired) ... Wait, Roger can you have it installed today or tomorrow

So, Roger's post is seemingly unrelated to receptacles and GFCI.

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

Actually Roger's post was very much related to receptacles and GFCI. The question was whether, as PGE claimed, code required hardwiring an EVSE. The answer was: Technically "no" but as a practical matter "yes" if the EVSE in question is the authorized ChargePoint.

The reason has everything to do with the requirement for GFCI breakers and nothing whatsoever to do with whether or how the EVSE is attached. The EVSE has a GFCI. If there is a second GFCI on the same circuit which is more sensitive, then you'll get unintended tripping. Since code now requires a GFCI breaker on a 240v outlet, as a practical matter you can't plug in an EVSE which isn't designed to accommodate a second GFCI into a code compliant outlet. However, if you hardwire the EVSE you don't have an outlet, and if you don't have an outlet you don't need a GFCI breaker. Problem of unintended tripping solved. And you'll save some money on the breaker.

The point here is that the requirement for hardwiring flows from the code provisions requiring GFCI breakers and the fact that the authorized ChargePoint EVSE won't work with a GFCI breaker.

 

[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.

 

[ab13]

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.

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