wwhitney
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NEC definitely allows cord-and-plug connected 240V EVSEs

Sat Jul 17, 2010 10:49 am

I've noticed some debate recently on whether the 2008 (and 2011) NEC allows EVSEs (other than 15A-20A/120V models) to be cord-and-plug-connected. I don't think the debate quite reached my last point below; if it has, I apologize for missing it.

As previously reported, 2008 NEC 624.13 says the following (parentheses by me):

625.13 Electric Vehicle Supply Equipment. Electric vehicle supply equipment (rated at 125 volts, single phase, 15 or 20 amperes ) or (part of a system identified and listed as suitable for the purpose and meeting the requirements of 625.18, 625.19, and 625.29) shall be permitted to be cord-and-plug-connected. All other electric vehicle supply equipment shall be permanently connected and fastened in place. This equipment shall have no exposed live parts.

The second "or" in the first sentence should be parsed as shown. So the permission given in the first sentence includes that given by deleting the first phrase enclosed in parentheses, yielding "Electric vehicle supply equipment part of a system identified and listed as suitable for the purpose and meeting the requirements of 625.18, 625.19, and 625.29 shall be permitted to be cord-and-plug-connected."

I've checked the current (2007) California Electrical code (based on the 2005 NEC), and it has no changes to this section. Other states could vary, they do sometimes amend the NEC before adopting it.

For those conversant in building code language, this should be sufficient. However, in case there is any doubt remaining, it is worth looking to the statements made by the code-making panel in charge of section 625 during the process of preparing the changes for the 2011 NEC. In this document from the NFPA, see the bottom left corner of page 454, the panel statement on proposal 12-28 Log #2121 NEC-P12. It reads "The panel reaffirms its action on this proposal. An EVSE meeting the requirements of 625.18, 625.19, and 625.29 can be cord-and-plug connected even when the voltage is greater than 120 VAC." That is definitive, I think.

Now all we need is for someone to sell one commercially for us. :) I still believe it is true that the various NEMA plugs and receptacles were not designed for daily insertion and removal, so such a unit should not be moved between two locations on a daily basis (e.g. used at both home and work). But on a weekly or less frequent basis it could be very convenient.

Cheers, Wayne

AndyH
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Re: NEC definitely allows cord-and-plug connected 240V EVSEs

Sat Jul 17, 2010 10:56 am

Welcome to the forum Wayne.

Please search.
http://www.mynissanleaf.com/viewtopic.p ... 915#p10915

So - we agree that the current NEC might now allow portable and/or plug-in EVSE.

But since the overall EVSE process from the AC connection to the car connector is governed by J1772, and J1772 states quite clearly that level 2 EVSE is hard-wired to the supply, what'll you think it'll take to modify the spec before EVSE manufacturers can comply?

wwhitney
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Re: NEC definitely allows cord-and-plug connected 240V EVSEs

Sat Jul 17, 2010 11:29 am

In that post you quote a "substantiation" from the ROC document. A "substantiation" is just a comment made by the public at large, a reason given for a proposed change. The next proposal down gives the "panel statement" I quoted, which is what the code making panel itself has to say.
AndyH wrote: So - we agree that the current NEC might now allow portable and/or plug-in EVSE.
There's no "might" about it, both the 2008 NEC and the 2011 NEC as currently drafted allow cord-and-plug-connected EVSE meeting the given requirements.
AndyH wrote: But since the overall EVSE process from the AC connection to the car connector is governed by J1772, and J1772 states quite clearly that level 2 EVSE is hard-wired to the supply, what'll you think it'll take to modify the spec before EVSE manufacturers can comply?
I didn't see that information in the thread you quoted, can you provide a pointer to the relevant section of J1772? I agree that requirement should be deleted. In any event, the requirement doesn't yet have the force of law. Now if UL incorporates it into its listing requirements, that would effectively kill the possibility, as the cord-and-plug-connection allowance provided by NEC 625.13 requires the EVSE be listed for the purpose.

Thanks,
Wayne

AndyH
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Re: NEC definitely allows cord-and-plug connected 240V EVSEs

Sat Jul 17, 2010 11:34 am

Have you read the latest J1772? It's very clear which devices can have a plug and which cannot. There's a link to a soft copy of the J1772 here as well.

Again - welcome!

wwhitney
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Re: NEC definitely allows cord-and-plug connected 240V EVSEs

Sat Jul 17, 2010 11:45 am

AndyH wrote:Have you read the latest J1772? It's very clear which devices can have a plug and which cannot.
OK, I found the J1772 pdf file and looked through it quickly it and searched for a few relevant terms. Nothing jumped out at me. Can you provide a page number or other reference for me?

Thanks,
Wayne

AndyH
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Re: NEC definitely allows cord-and-plug connected 240V EVSEs

Sat Jul 17, 2010 12:06 pm

wwhitney wrote: For those conversant in building code language, this should be sufficient. However, in case there is any doubt remaining, it is worth looking to the statements made by the code-making panel in charge of section 625 during the process of preparing the changes for the 2011 NEC. In this document from the NFPA, see the bottom left corner of page 454, the panel statement on proposal 12-28 Log #2121 NEC-P12. It reads "The panel reaffirms its action on this proposal. An EVSE meeting the requirements of 625.18, 625.19, and 625.29 can be cord-and-plug connected even when the voltage is greater than 120 VAC." That is definitive, I think.
We have two possible page 454s. The first is page 454 of the PDF doc. The second is 70-454 (PDF page 467).

Page 70-454, lower left, is not the 12-28/NEC-P12 you suggest.

Page 454 of the PDF (hard-copy page 70-441), lower left, is about 625-29(b) - EVSE wall mounting and considerations for hazardous environments. This has absolutely nothing to do with confirming/denying the ability to connect a Level 2 EVSE with a plug/socket.
12-34 Log #2405 NEC-P12 Final Action: Accept
(625.29(B))
_______________________________________________________________
Submitter: Brian E. Rock, Hubbell Inc.
Comment on Proposal No: 12-64
Recommendation: I support the panel action.
Substantiation: This Comment is provided to aid Panel 12 with regard to the
accuracy of the Panel Statement for P12-84. As one of the co-authors (along
with Tim Croushore, Greg Nieminski, Charlie Claar, Craig Toepfer, etc.) under
EPRI IWC Task Force Chair Dave Brown of the original Article 625, I can
provide insight as to the technical basis for the 18-inch lower height limit that
the Submitter sought to change.
The primary purpose of the National Electrical Code® is to insure
installations safe from the risk of fire and shock. To the extent that other
mandates unrelated to this primary purpose (such as ADA), those were taken
into account, as reflected by 4-foot upper height limit from ADA. Where
those mandates for other purposes leava a “gap” in terms of electrically safe
installations, the primary purpose must predominate.
For the lower limit, however, the use of electric vehicle charging equipment
is highly likely in a mixed environment of electric-powered and gasolinepowered
vehicles. This mixed usage environment includes refueling/recharing
of gasoline- and electric-powered vehicles.
Section 625.28 requires that EVSE installed in Hazardous (Classified)
Locations must comply with Articles 500 through 516, specifically Article 514
for Motor Fuel Dispensing Facilities. Table 514.3(B)(1) establishes an upper
gasoline fume height limit of 18 inches, this was taken by the Task Force to
establish the lower limit for nonhazardous (unclassified) ordinary locations
so that there would be no “gray areas” with regard to this boundary between
potential gasoline fume accumulation and where EVSE could be safely located
in ordinary locations.
Panel Meeting Action: Accept
Number Eligible to Vote: 14
Ballot Results: Affirmative: 14

This is the item that was presented and approved - from which I pulled the 'substantiation' text (I suggested in my post to look for the article mid-page, left column, page 453:
12-27 Log #1405 NEC-P12 Final Action: Accept
(625.13)
_______________________________________________________________
Submitter: Frank C. Lambert, Georgia Tech/NEETRAC / Rep. Plug-In Hybrid
& Electric Vehicle Working Group
Comment on Proposal No: 12-54
Recommendation: We support the committee’s action on this proposal.
Substantiation: EVSE meeting the requirements of 625.18, 625.19, and
625.29 can be cord-and-plug connected even when it is greater than 120 VAC.
Panel Meeting Action: Accept
Number Eligible to Vote: 14
Ballot Results: Affirmative: 14
_______________________________________________________________
This change was apparently compiled for a June 2010 meeting.

The current J1772 spec was ratified in Jan 2010 - well before this change was accepted. In addition, the roll-out plan, DOE-funded studies and presentations, and current EVSE products that are either on the streets or are undergoing UL approval, were prepared before this NEC change was accepted.

What it comes down to now is the UL approval and/or warranty support an EVSE manufacturer will provide if an end-user purchases a device designed for permanent wall mounting and installs a flexible cord with the required strain relief. (I wonder if the plastic case for the AV EVSE was designed to support a strain relief for the entry cord?)

Can we use a plug legally? Maybe. Illegally? Doesn't matter how the NEC has changed.

wwhitney
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Re: NEC definitely allows cord-and-plug connected 240V EVSEs

Sat Jul 17, 2010 12:47 pm

wwhitney wrote: For those conversant in building code language, this should be sufficient. However, in case there is any doubt remaining, it is worth looking to the statements made by the code-making panel in charge of section 625 during the process of preparing the changes for the 2011 NEC. In this document from the NFPA, see the bottom left corner of page 454, the panel statement on proposal 12-28 Log #2121 NEC-P12. It reads "The panel reaffirms its action on this proposal. An EVSE meeting the requirements of 625.18, 625.19, and 625.29 can be cord-and-plug connected even when the voltage is greater than 120 VAC." That is definitive, I think.
My apologies, the statement on comment 12-28 Log #2121 NEC-P12 is on page 453 of the PDF file, not 454. This page is also marked 70-440 on the bottom.
AndyH wrote: This is the item that was presented and approved - from which I pulled the 'substantiation' text (I suggested in my post to look for the article mid-page, left column, page 453:
Right, the comment I am referencing is the one just below that.
AndyH wrote: This change was apparently compiled for a June 2010 meeting.
I'm not sure of the timing. The NEC revision process is quite involved:

For each code cycle there is a deadline for submitting proposed changes; anyone can do that. Then the code-making committees consider each proposal and take an action on it, often a vote. If the vote is negative, then they usually make a statement why. This content becomes the Report on Proposals, the ROP, which is made public. Then people get an opportunity to comment on each committee action on each proposal. The code making committees then consider all the comments and again vote on any actions recommended by the commenters. This becomes the Report on Comments, the ROC. At this point I believe that a Draft NEC gets published, and there may be one more round of comments and voting (not sure).

Anyway the ROC file we both referenced does not contain the original proposals or the comittee actions on those proposals, it only contains the comments on the committee actions and the committee responses to the comments. For example, in the entry you referenced, we have the submitter of the comment, the proposal number for which the submitter is commenting on the committee's action, the submitter's recommendation, his reasons for the recommendation (the substantiation), and the panel's action in response to that comment.

The upshot is that a "substantiation" is just anybody's stated reason for the code making committee to do something. In contrast, a panel statement, usually made after a vote, is a reflection of what the pane itself has to say on something. So the "panel statement" I originally quoted shows how the panel that wrote 625.13 interprets it. Sorry I wasn't clear about the difference in my original post.
AndyH wrote: What it comes down to now is the UL approval and/or warranty support an EVSE manufacturer will provide if an end-user purchases a device designed for permanent wall mounting and installs a flexible cord with the required strain relief.
Oh, I'm not proposing that at all. I'm just saying that there is no legal impediment I am aware of to a manufacturer designing, listing, and selling a cord-and-plug-connected EVSE operating at 240V compliant with NEC 625.13. Unless there is some part of J1772 you can point me to, and UL incorporates that part of J1772 into its listing requirement.

Cheers, Wayne

AndyH
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Re: NEC definitely allows cord-and-plug connected 240V EVSEs

Sat Jul 17, 2010 2:16 pm

12-27 Log #1405 NEC-P12 Final Action: Accept
(625.13)
_______________________________________________________________
Submitter: Frank C. Lambert, Georgia Tech/NEETRAC / Rep. Plug-In Hybrid
& Electric Vehicle Working Group
Comment on Proposal No: 12-54
Recommendation: We support the committee’s action on this proposal.
Substantiation: EVSE meeting the requirements of 625.18, 625.19, and
625.29 can be cord-and-plug connected even when it is greater than 120 VAC.
Panel Meeting Action: Accept
Number Eligible to Vote: 14
Ballot Results: Affirmative: 14
_______________________________________________________________
So...this specific item is essentially a statement of support from Mr. Lambert?

What does the "final action: Accept" and "panel meeting action: accept" mean?

I hoped that the pair of 'accept' items meant that the substantiation text would appear in the next revision.

edit... I did jump ahead when I read this - because this gent couldn't support the decision to allow plug-in connections if there wasn't something posted somewhere that allowed plug-in connections. I hadn't found the 'source' item however.
Last edited by AndyH on Sat Jul 17, 2010 7:19 pm, edited 1 time in total.

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Re: NEC definitely allows cord-and-plug connected 240V EVSEs

Sat Jul 17, 2010 2:42 pm

Nice - this is what I was planning to spend some time on. Liiks like Wayne has already done that.

BTW, Wayne welcome to the forum. Are you involved with NEC or industry in some way ?
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wwhitney
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Re: NEC definitely allows cord-and-plug connected 240V EVSEs

Sat Jul 17, 2010 2:47 pm

AndyH wrote:
12-27 Log #1405 NEC-P12 Final Action: Accept
(625.13)
_______________________________________________________________
Submitter: Frank C. Lambert, Georgia Tech/NEETRAC / Rep. Plug-In Hybrid
& Electric Vehicle Working Group
Comment on Proposal No: 12-54
Recommendation: We support the committee’s action on this proposal.
Substantiation: EVSE meeting the requirements of 625.18, 625.19, and
625.29 can be cord-and-plug connected even when it is greater than 120 VAC.
Panel Meeting Action: Accept
Number Eligible to Vote: 14
Ballot Results: Affirmative: 14
_______________________________________________________________
So...this specific item is essentially a statement of support from Mr. Lambert?
Yes, that's right. To even find out what is being discussed, we need to find the ROP and look for proposal 12-54. The ROP is available from the NFPA's website. Proposal 12-54 occurs on PDF page 809 and consists of changing 625.13 to read "Electric vehicle supply equipment rated at 125 volts, single phase, 15 or 20 amperes shall be permitted to be cord-and-plug-connected. All other electric vehicle supply equipment shall be permanently connected and fastened in place. This equipment shall have no exposed live parts." That is, the proposal would have specifically deleted the language that currently allows cord-and-plug-connected EVSE operating at greater than 120VAC.

The panel's action on proposal 12-54 was to reject the proposal unanimously and issue the statement "Panel Statement: Cord and plug connected electric vehicles are already permitted. CMP-12 does not accept eliminating equipment that meets the requirements of 625.18, 625.19, and 625.29. This is outside the scope of the NEC as it deals with the hazards of fire and shock, and the NEC does not regulate product development"

After this all occurred and was published in the ROP, then Mr. Lambert wrote in to say "good job".
AndyH wrote: What does the "final action: Accept" and "panel meeting action: accept" mean?
It means that the panel voted to agree with Mr. Lambert that it had done a good job. :)
AndyH wrote: I hoped that the pair of 'accept' items meant that the substantiation text would appear in the next revision.
No, but what I mentioned in my original post is that there was another comment on the committee action on proposal 12-54, comment 12-28, just after the one discussed above. There someone wrote in to suggest that instead of rejecting Proposal 12-54, they should rewrite it to change 625.13 to allow any EVSE that is rated at 240V/20A or less to be cord-and-plug-connected (without being explicitly referred to 625.18, 625.19, and 625.29). Sort of the opposite effect of the original proposal. The committee rejected this proposed action in comment 12-28. In doing so they issued the panel statement I originally quoted which says, to paraphrase, "in case it wasn't clear, 625.13 already allows EVSE operating at 240V to be cord-plug-connected, subject to compliance with 625.18, 625.19, and 625.29."

Hence the title of this thread.

Cheers, Wayne
Last edited by wwhitney on Sat Jul 17, 2010 2:56 pm, edited 1 time in total.

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