Jill Stern
Chair, Construction Codes Coordinating Board
Department of Consumer and Regulatory Affairs
Dear Ms. Stern,
The Sierra Club wrote to you on August 14 with comments about the inclusion of biogas in the updated District of Columbia Construction Codes. Today we write with additional comments about the need for DC to take advantage of our greening electricity sector to encourage the use of electric vehicles (EVs) in DC. Replacing fossil- fuel-based transportation with electricity-power transportation, and the required EV charging infrastructure, is necessary if DC is to meet our commitment of reducing greenhouse gas emissions 50 percent by 2032 and achieving carbon neutrality by 2050.
DC’s current Building Codes are inadequate to facilitate the adoption of electric vehicles that will be necessary to meet our climate goals. Other U.S. cities have far more advanced building codes that can be used as a model.
Most critically, under the current Building Codes proposals, making buildings EV-ready would be elective, and only for buildings requiring compliance with the Green Construction Code (i.e. large buildings). Instead, DC should follow the most advanced regulations for all new construction and significant building updates. Doing so during initial or major construction will limit the impact of costly upgrades in the future.
The Sierra Club has several recommendations for the updated Building Codes to advance EV adoption in DC.
Single-family dwellings and townhouses: All new garages and carports that are accessories to one- and two-family dwellings and townhouses should be outfitted with the outlet for Level 2 electric vehicle charger or the adequate electrical wiring to accommodate such an outlet in the future. An example can be found in Boulder’s Building Code. Accordingly, the Sierra Club proposes adding the following language to “12-B DCMR Residential Code Supplement of 2017” as a new section, either under Section R309 of the 2015 IRC (added as R309.6) or appended as a new section to the Chapter 3 amendments (R328.1):
R328.1 Electric vehicle charging with pre-wire option. In addition to the one 125-volt receptacle outlet required for each car space by NEC Section 210.52(G)(1.), every new garage or carport that is accessory to a one- or two-family dwelling or townhouse shall include at least one of the following, installed in accordance with the requirements of Article 625 of the Electrical Code:
1. A Level 2 (240-volt) electric vehicle charging receptacle outlet, or
2. Upgraded wiring to accommodate the future installation of a Level 2 (240-volt) electric vehicle charging receptacle outlet, or
3. Electrical conduit to allow ease of future installation of a Level 2 (240-volt) electric vehicle charging receptacle outlet.
Multi-family dwellings: For new or significantly updated multi-family buildings complying with the Building Codes, all parking spaces required under current zoning requirements should be EV-ready, outfitted with the outlet for Level 2 electric vehicle charger or the adequate electrical wiring to accommodate such an outlet in the future. Palo Alto’s building code requires an EV-ready parking spot for each residential dwelling, but the Sierra Club’s proposal recognizes that DC zoning currently requires less than one parking spot per dwelling unit.
Non-residential constructions: For new or significantly updated non-residential constructions, 25 percent of parking spaces should have the necessary infrastructure to support electrical vehicle charging outlets in the future and 5 percent of parking spaces should provide Level 2 EV charging infrastructure. For new or significantly updated hotels, 30 percent of parking spaces should have the necessary infrastructure to support electrical vehicle charging outlets in the future and 10 percent of parking spaces should provide Level 2 EV charging infrastructure. Palo Alto’s building code offers an example. Accordingly, the Sierra Club proposes adding the following language to “12-A DCMR Building Code Supplement of 2017”:
APPENDIX K ADMINISTRATIVE PROVISIONS
Appendix K of the International Building Code is adopted in the District of Columbia and incorporated by reference as part of the Building Code with the following amendments:
K111 ELECTRICAL PROVISIONS
Insert a new section in Appendix K, Section 111 in the Building Code to read as follows:
K111.8.1 Definitions. For the purposes of this section, the following definitions shall apply:
(a) Level 2 EVSE. “Level 2 EVSE” shall mean an EVSE capable of charging at 30 amperes or higher at 208 or 240 VAC. An EVSE capable of simultaneously charging at 30 amperes for each of two vehicles shall be counted as two Level 2 EVSE.
(b) Conduit Only. “Conduit Only” shall mean, at minimum:
A panel capable to accommodate dedicated branch circuit and service capacity to install at least 208/240V, 50 amperes grounded AC outlet; and
raceway or wiring with capacity to accommodate a 100-ampere circuit; terminating in
a listed cabinet, box, enclosure, or NEMA receptacle.
The raceway shall be installed so that minimal removal of materials is necessary to complete the final installation.
(c) EVSE-Ready Outlet. “EVSE-Ready Outlet” shall mean, at minimum:
(1) a panel capable to accommodate a dedicated branch circuit and service capacity to install at least a 208/240V, 50 amperes grounded AC outlet;
(2) a two-pole circuit breaker;
(3) raceway with capacity to accommodate a 100-ampere circuit;
(4) 50 ampere wiring; terminating in
(5) a 50 ampere NEMA receptacle in covered outlet box.
(d) EVSE Installed. “EVSE Installed” shall mean an installed Level 2 EVSE.
K111.8.2 Non-Residential Structures Other than Hotels. The following standards apply to newly constructed non-residential structures other than hotels.
(a) In General. The property owner shall provide Conduit Only, EVSE-Ready Outlet, or EVSE Installed for at least 25 percent of parking spaces, among which at least 5 percent (and no fewer than one) shall be EVSE Installed.
(b) Accessible Spaces. Projects shall comply with the 2016 California Building Code requirements for accessible electric vehicle parking.
(c) Minimum Total Circuit Capacity. The property owners shall ensure sufficient circuit capacity, as determined by the Chief Building Official, to support a Level 2 EVSE in every location where Circuit Only, EVSE-Ready Outlet or EVSE Installed is required.
(d) Location. The EVSE, receptacles, and/or raceway required by this section shall be placed in locations allowing convenient installation of and access to EVSE. Location of EVSE or receptacles shall be consistent with District guidelines, rules, and regulations.
K111.8.3 Hotels. The following standards apply to newly constructed hotels.
(a) In general. The property owners shall provide Conduit Only, EVSE-Ready Outlet, or EVSE Installed for at least 30 percent of parking spaces, among which at least 10 percent (and no fewer than one) shall be EVSE Installed.
(b) Accessible spaces. Projects shall comply with the 2016 California Building Code requirements for accessible electric vehicle parking.
(c) Minimum total circuit capacity. The property owners shall ensure sufficient circuit capacity, as determined by the Chief Building Official, to support a Level 2 EVSE in every location where Circuit Only, EVSE-Ready Outlet or EVSE Installed is required.
(d) Location. The EVSE, receptacles, and/or raceway required by this section shall be placed in locations allowing convenient installation and access to EVSE. Location of EVSE or receptacles shall be consistent with all District guidelines, rules, and regulations.
Thank you for allowing the Sierra Club to comment on this very important Building Codes update. We look forward to working with you to ensure DC’s updated Building Codes are consistent with DC’s climate commitments and address the existential threat climate change poses to the District and the planet.
Sincerely,
Mark Rodeffer
Chair, Sierra Club DC Chapter
Aykut Yilmaz
Smart Growth Committee, Sierra Club DC Chapter
CC:
Ernest Chrappah, Director, Department of Consumer and Regulatory Affairs
Tommy Wells, Director, Department of Energy and Environment
Mary Cheh, Chair, DC Council Committee on Transportation and Environment
Sierra Club Calls for Electric Vehicle Requirements in Building Code
August 26, 2019