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

[wwhitney]

So... If this is definitive then I have to agree that we can use a cordset.

Well, we can't NEC-compliantly use a cordset on an EVSE designed to be hard-wired, but a manufacturer can list and sell a 240V EVSE that uses a cordset. Why noone has, I don't know. Hopefully someone will.

Or could it be that the PREVIOUS NEC - the one in effect when all this stuff was in 'gestation mode' - was the limiting factor?

I don't know when this J1772 was being written. But I checked the 2005 and 2002 NECs, they have the same version of 625.13 as in the 2008 NEC. And the 2002 NEC shows in the margin where sections have been changed; since this is not shown for 625.13, presumably the 1999 NEC was the same.

http://www.bchydro.com/etc/medialib/int ... -Aug09.pdf
Page 63 references applicable NEC articles. This version of 625.14 clearly prohibits L2 w/plugs. The current NEC doesn't include this text, but the entire EVSE industry and standards bodies are acting as if it's still in place.

I'm not convinced that was ever really in the NEC, that document could be wrong. If it was, it was prior to 1999.

Cheers, Wayne

[wwhitney]

DEFINITIONS
3.1 AC Level 1 Charging
A method that allows an EV/PHEV to be connected to the most common grounded electrical receptacles (NEMA 5-15R and NEMA 5-20R. THe vehicle shall be fitted with an on-board charger capable of accepting energy from the existing single phase alternating current (AC) supply network. The maximum power supplied for AC Level 1 charging shall conform to the values in Table 1. A cord and plug EVSE with a NEMA 5-15P plug may be used with a NEMA 5-1=20R receptacle. A cord and plug EVSE with a NEMA 5-20P plug is not compatible with a NEMA 5-15R receptacle.

3.2 AC Level 2 Charging
A methos that uses dedicated AC EV/PHEV supply equipment in either private or public locations. The vehicle shall be fitted with an on-board charger capable of accepting energy from a single phase alternating current (AC) electric vehicle supply equipment. The maximum power supplied for AC level 2 charging shall conform to the values in Table 1.

Notice that the definition of L1 DID include 1. that fact that it COULD be connected with a plug, and 2. the exact combination of plugs that can be used. Now notice what is NOT included in the L2 definition - no mention of plug what so ever.

It seems clear to me that if the standard is silent on the issue (of cord and plug connected Level 2 EVSEs), then it is agnostic and is not taking a position. The standard does require a cord and plug for a Level 1 EVSE; for a Level 2 EVSE, manufacturers can do go either way.

All the diagrams for a L1 EVSE show a plug and define that plug like this: NEMA 5-15 or 5-20 Plug -- while the diagrams for L2 devices say 'electric supply'.

Right, because for an L1 EVSE they know that a plug and cord will be used, while for the L2 devices they don't know what choice will be made, so they use generic terminology.

They don't specify a plug for L2 devices because they have already stated in the beginning of the document that OTHER standards also apply - and one of those standards is the NEC - and the NEC in place when the standard was being worked SPECIFICALLY REQUIRED hard-wiring the EVSE to the mains supply.

I don't agree with that last inference, it is possible that the document with the weird version of 625.14 is just wrong.

Cheers, Wayne

[wwhitney]

I'm not convinced that was ever really in the NEC, that document could be wrong. If it was, it was prior to 1999.

Well, I found the 1999 NEC at resource.org, and it has the same version of 625.14 as currently, with no indication that it changed in 1999. So if that weird version of 625.14 was ever in the NEC, it was 1993 or earlier.

Interestingly, the 1999 NEC shows that 625.13 was revised that year. I couldn't find the 1996 NEC, so I don't know what the previous version said. It is possible that the 1996 version of 625.13 did not allow 240V cord-and-plug-connected EVSEs. If that is true, and that turns out to be the basis for some belief at recent J1772 meetings that 240V cord-and-plug-connected EVSEs are prohibited, then the J1772 committee is at least 15 years behind the times. [The NEC is published the year before the title date, so the 2011 NEC will come out later this year.]

Cheers, Wayne

[AndyH]

I don't agree with that last inference, it is possible that the document with the weird version of 625.14 is just wrong.

Cheers, Wayne

That's fine - you don't have to.

It's always possible that a contractor hired by the Department of Energy (and someone that not only works on EVSE studies but is a L2 and L3 EVSE manufacturer) could get it wrong...but the odds are very, very, very low that they mis-quoted the NEC. Actually very low - they would have had to not only mis-quote the NEC, but then not look at the code for what - 12 years? And none of their contributors - including power companies and government planning bodies called them on their error? Not likely.

Excerpt from an interview with the CEO of eTEC
http://gm-volt.com/2009/09/28/interview ... structure/

Is your company a hardware producing company or are you coordinating the hardware of others? I’m wondering how your company fits into this.
We build both the level 2 and level 3 hardware. And we were very involved in the late 90s and early 2000s in deployment of EVs in response to the zero emission mandate in California. So we installed all of Chrysler’s infrastructure nationwide for the Epic minivan. We installed a lot of infrastructure for Ford, but not so much for GM. They typically worked through utilities to make that happen. We were buying others EVSEs in those days. We did make the 90 kw fast charger for the Chrysler minivan. Then when the auto EVs went away we had already been working with airport ground support equipment and material handling lift trucks on fast charging and we continued to do that over those 8 or 9 years. So we are in a number of airports through North America supporting both the airports and the airlines with material handling chargers across the country. We’ve got like 5000 chargers deployed throughout North America in industrial applications. We also have a line of chargers for neighborhood vehicles and things like that.

I'm personally very confident in the progression. Between:
- The briefing docs from the various programs (Project Get Ready, Nissan, eTEC, ChargePoint America, EV Project, etc.) that say specifically that the EVSE must be hard wired
- The docs from various EVSE manufacturers that show their products must be hard-wired (including those designed specifically to the Jan 2010 J1772)
- The fact that the NEC is adapted and/or adopted by states/counties/cities and all that mention L2 EVSE state that it MUST be hard-wired...
- Back and forth comments between participants of the June J1772 working group meeting
- Conversations with folks from EVSE manufacturers
- Experience from being part of rules groups and committees in government settings

There's absolutely no doubt in my mind that the units were planned in an environment that required them to be hard-wired.

I'm glad the environment has changed, but don't care much because the NEC wasn't going to stop me from putting a cord on my EVSE anyway.

[wwhitney]

http://www.bchydro.com/etc/medialib/int ... -Aug09.pdf
Page 63 references applicable NEC articles. This version of 625.14 clearly prohibits L2 w/plugs. The current NEC doesn't include this text, but the entire EVSE industry and standards bodies are acting as if it's still in place.

Section 625.14 Rating:
Level 1. 125vac. This method, which allows broad access to charge an EV, permits plugging into a common, grounded 125-volt electrical receptacle (NEMA 5-15R or 5-20R) when cord-and-plug is approved. Level 2. 240 VAC, 40 amp. electric vehicle supply equipment shall be permanently connected and fastened in place.

I took a look at this document. It is dated July 2009 and includes the language you quoted above. As such, it is just wrong. Since at least 1996, NEC 625.14 has included no such language. If you don't believe me, then look for yourself, try resource.org. Maybe they are quoting a version amended by some state, or some non-enforceable commentary in the NEC Handbook. In any event it is just incorrect. And the document is prefaced by a lengthy disclaimer in which they take no responsibility for accuracy, see below.

Likewise, I verified that since 1999, NEC 625.13 contains the language that allows 240V cord-and-plug-connected EVSEs. So if anyone in the industry thinks the NEC prohibits them, they are over 10 years out of date. [I don't know what the 1996 NEC 625.13 says, just that it is different, and so it may have prohibited 240V cord-and-plug-connected EVSEs.]

Cheers, Wayne

Disclaimer
This document was prepared for Natural Resources Canada and British Columbia Hydro and Power Authority by Electric Transportation Engineering Corporation. Neither Natural Resources Canada, British Columbia Hydro and Power Authority, Electric Transportation Engineering Corporation, nor any of the named organizations comprising the Review Committee:
(a) represents, guarantees or warrants to any third party, either expressly or by implication: (i) the accuracy, completeness or usefulness of; (ii) the intellectual or other property rights of any person or party in; or (iii) the merchantability, safety or fitness for purpose of; any information, product or process disclosed, described or recommended in this document,
(b) assumes any liability of any kind arising in any way out of the use by a third party of any information, product or process disclosed, described or recommended in this
document, or any liability arising out of reliance by a third party upon any information, statements or recommendations contained in this document. Should third parties use or rely on any information, product or process disclosed, described or recommended in this document, they do so entirely at their own risk.

[garygid]

Good work, Wayne!

[evnow]

http://www.nfpa.org/aboutthecodes/About ... ?DocNum=70

You can register here for free and see the code online. I'm quite sure they carry the approved versions.

bchydro version is wrong (or a canada specific version ?). 625.14 doesn't say anything about levels (in both 2005 & 2008 versions). It makes sense - why would something irrelevent to rating be adding in 625.14 - in the code it correctly states that the load should be considered continuous. Thats it.

BTW, this is the ROP of the request we were discussiing using ROC.

http://www.nfpa.org/assets/files/AboutT ... 10-ROP.pdf

12-55 Log #3969 NEC-P12 Final Action: Reject
(625.13)

Submitter: Frank C. Lambert, Georgia Tech/NEETRAC / Rep. Chairman,
Plug-in Hybrid & Electric Vehicle Working Group, EPRI National Electric
Transportation Infrastructure Working Council
Recommendation: Revise text to read as follows:
Electric vehicle supply equipment rated at 125 volts, single phase, 15 or 20
amperes shall be permitted to be cord-and-plug-connected. EVSE rated greater
than 20 amperes and not more than 250 volts and ora 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.
Substantiation: None given.
Panel Meeting Action: Reject
Panel Statement: The proposal does not comply with 4.3.3(d) of the NFPA
Regulations Governing Committee Projects. The submitter has not
substantiated the proposal.
Number Eligible to Vote: 12
Ballot Results: Affirmative: 12

BTW, note the typos here ... their proposal isn't even coherent. ANyway they rejected it out of hand as no substantiation was given.

[AndyH]

...But it's not up to the NEC.

It appears that the NEC is not law but a recommendation. According to the Nov 2008 "Plug-in Hybrid Electric Vehicle
Charging Infrastructure Review" published by a Department of Energy National Lab:

Standards for installation and functionality requirements of electric vehicle infrastructure are provided
in the NEC Article 625, published by the National Fire Protection Association. The NEC is provided as
purely advisory to regulatory bodies in the interest of life and property protection. The National Fire
Protection Association revises and publishes a new NEC handbook every 3 years. Adoption of the NEC
into law is carried out by local jurisdictions and adoption of new NEC versions that may follow several
years from the most recent National Fire Protection Association publication.

Page 26 from: http://avt.inel.gov/pdf/phev/phevInfras ... port08.pdf

To view the 'rules of installation' from one of the 'local jurisdictions' that adopted the guidance into law, enjoy this "ELECTRIC VEHICLE
INFRASTRUCTURE INSTALLATION GUIDE" from Pacific Gas and Electric:
http://www.pge.com/includes/docs/pdfs/a ... ehicle.pdf

EV Charging Essentials beginning on page 10 is worth a look if one is interested in the interplay between the NEC, the California code, and local rulings. Code requirements for installing EVSE begins on page 19.

[AndyH]

And the document is prefaced by a lengthy disclaimer in which they take no responsibility for accuracy, see below.

That's a standard disclaimer required for any government-sponsored report - it's not an indicator of accuracy (or lack thereof).

This might provide some insight into why the NEC might not be calling the shots with regard to EV charging:
This from an April 2010 paper "Electric Vehicle Charging Infrastructure Deployment Guidelines for the Oregon I-5 Metro Areas of Portland, Salem, Corvallis and Eugene April 2010 Final Version 3.1" http://projectgetready.com/docs/Oregon% ... %203-1.pdf

In 1991, the Infrastructure Working Council (IWC) was formed by the Electric Power Research Institute (EPRI) to establish consensus on several aspects of EV charging. Charging levels were defined by the IWC, along with the corresponding functionality requirements and safety systems. EPRI published a document in 1994 that describes the consensus items of the IWC.

(footnote): “Electric Vehicle Charging Systems: Volume 2.” Report of the Connector and Connecting Station Committee, EPRI, December 1994.

It's beginning to appear that organizations and studies such as this are driving the NEC and not the other way around.

[wwhitney]

It appears that the NEC is not law but a recommendation.

That's right, when the NFPA releases a new version of the NEC, it does not automatically become law. It is up to each jurisdiction to adopt it, and they may make changes when they do. Some jurisdictions are slower than others. For example the 2007 California Electrical Code (CEC) is still current in California and is based on the 2005 NEC. The next version (maybe taking effect at the end of the year?) will be based on the 2008 NEC.

I checked the 2007 CEC, it does not have any changes to article 625.

BTW, my theory on the language in the bchydro/etec report we've been discussing: I bet it is from the NEC Handbook. The handbook includes the NEC and adds commentary on each article. The commentary is not enacted into law by any jurisdiction and is not enforceable. I expect that the language on Level 2 charging that the report quoted is from the Handbook commentary and is misidentified in the report.

To view the 'rules of installation' from one of the 'local jurisdictions' that adopted the guidance into law, enjoy this "ELECTRIC VEHICLE
INFRASTRUCTURE INSTALLATION GUIDE" from Pacific Gas and Electric:
http://www.pge.com/includes/docs/pdfs/a ... ehicle.pdf

That document is from 1999, so it is pretty out of date. However it is interesting to note what it says on PDF page 20 about Level 2 EVSE:

Receptacle and Wall Plug: Where the EVSE calls for an in-wall receptacle, a 50 amp, 240 volt, 3- or 4-wire wall plug configuration is required. However, most charging equipment will be directly wired, eliminating the need for an in-wall receptacle.

Cheers, Wayne