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DSA advisory: accessibility rules in California Building Code generally do not apply to strictly medium‑ and heavy‑duty charging depots unless open to passenger
Summary
The Division of the State Architect issued guidance clarifying that California Building Code (Chapter 11B) accessibility requirements were written for light‑duty passenger EV charging and generally do not apply to medium‑ and heavy‑duty depots unless those sites are open to passenger vehicles or include accessible buildings or services.
The Division of the State Architect (DSA) has published an advisory clarifying when California Building Code (CBC) accessibility requirements apply to medium‑ and heavy‑duty electric vehicle charging depots.
Michelle Davis of DSA told a Governor’s Office of Business and Economic Development (GO‑Biz) webinar that CBC Chapter 11B governs accessibility for public buildings, public accommodations, commercial facilities and public housing, and that the EV charging rules were written with light‑duty passenger vehicles in mind. "The building code when those regulations were developed had not anticipated medium density and high density charging," Davis said, noting DSA has posted an access compliance advisory available on its website.
Why it matters: developers building truck or fleet charging depots face different obligations depending on whether light‑duty vehicles will use the same stalls or whether the site includes accessory facilities such as restrooms or concessions. Davis summarized the advisory's practical tests: accessibility provisions apply when (1) charging spaces are available to operators of regular passenger vehicles, or (2) the facility includes buildings or services (restrooms, concessions) that trigger accessible parking and accessible routes under the CBC. "If you're developing a project that is strictly charging spaces for medium/heavy duty use cases and those charging spaces are not open to light duty vehicles and you do not have some sort of accessory building on site... then the ADA requirements will not apply to your site," GO‑Biz lead advisor Jesse Denver said during the webinar.
Technical takeaways: the panel highlighted these specifics drawn from the CBC and DSA guidance: when CBC applies, accessible EV charging counts follow the CBC table (for example, one van‑accessible stall when one‑to‑four charging spaces are provided), operable parts on publicly available EV chargers must meet 5 pounds of force and not require grasping/pinching/twisting, and drive‑up charging islands (common for medium/heavy vehicles) are sized differently (panelists used 17 ft by 20 ft as a practical example for drive‑up minimum dimensions).
Limitations and exemptions: DSA and GO‑Biz stated that fleet charging strictly behind fences and handled by a designated employee is treated under employment law (ADA Title I) rather than CBC accessibility rules; sites that require contractual access by specific fleets and do not allow public charging were described as falling under the exemption. However, the panel cautioned that common‑use employee charging elements (for example, where employees routinely charge personal vehicles at the site) can trigger CBC requirements.
Advice for developers: the DSA advisory is downloadable from DSA’s website and the office offers a technical assistance line (916‑445‑55827) for project‑specific questions. GO‑Biz recommended that developers consult DSA early, flag accessory buildings that might trigger CBC obligations, and plan site layouts to avoid unexpectedly large accessibility footprint requirements if the site is to be open to passenger vehicles.
Next steps: developers with unresolved questions or disputes over how an AHJ is applying CBC rules were encouraged to contact GO‑Biz for facilitation; GO‑Biz emphasized it provides guidance and assistance but does not have enforcement authority to compel local action.
