C A L I F O R N I A G OV E R N O R ’ S O F F I C E O F B U S I N E S S A N D E CO N O M I C D E V E LO PM E N T

Electric Vehicle
Charging Station Permitting
Guidebook
Second Edition

California Governor’s
Office of Business and Economic
Development (GO-Biz)

JANUARY 2023
C A L I F O R N I A G OV E R N O R ’ S O F F I C E O F B U S I N E S S A N D E CO N O M I C D E V E LO PM E N T

Electric Vehicle
Charging Station Permitting
Guidebook

Published January 2023 | Second Edition

Electronic Version Available: [Link]

Lead
Authors:
Heather Hickerson
Hannah Goldsmith

With Major Layout

Contributions From: and Production:
Gia Brazil Vacin California Department of
Tyson Eckerle General Services
Office of State Publishing
Acknowledgments
This Guidebook reflects the input and feedback
received from several federal, state, and local
agencies, along with a host of industry and non-
profit electric vehicle charging station experts.
The Governor’s Office of Business and Economic
Development would like to extend our deep
appreciation to the groups listed below, as well as
to those we inadvertently omitted.

Adopt a Charger; the Bay Area Air Quality

Management District; California Electric
Transportation Coalition; California state
agencies: Air Resources Board, Building Standards
Commission, Coastal Commission, Department
of Corrections and Rehabilitation, Department
of General Services, including the Division
of the State Architect, Energy Commission,
Environmental Protection Agency, Housing and
Community Development, State Transportation
Agency, Public Utilities Commission; Center for
Sustainable Energy; Chargepoint; Cities: Burbank,
Encinitas, Half Moon Bay, Menlo Park, Pasadena,
Sacramento, San Anselmo, San Bernardino, San
Diego, San Francisco, San Jose, Santa Monica;
Counties: Sacramento, San Francisco, Los Images courtesy of the
Angeles, Tuolumne; Contra Costa Transportation Bay Area Air Quality
Authority; Blink Charging; Electrify America; Management District,
EVgo and the California
EVgo; Electric Vehicle Charging Association; Energy Commission
Envision Solar; Energy Solutions; EV Alliance;
EV Charging Pros; Envoy; FLO; Frontier Energy;
Greenlots; Gladstein, Neandross & Associates;
the Governor’s Office of Planning and Research;
the Luskin Center for Innovation; Los Angeles
Department of Water and Power; Los Angeles
County; Nuvve; Paired Power; Pacific Gas &
Electric; Plug-in America; Powertree; Recolte
Energy; Sacramento Municipal Utility District;
San Diego Association of Governments; San
Diego Gas and Electric; Southern California Air
Quality Management District; Southern California
Association of Governments; Southern California
Edison; Tesla; Thor Trucks; Volta; US Environmental
Protection Agency; Veloz; WAVE; and Webasto.

Additionally, several publications formed the

foundation of this Guidebook. A list of select
resources can be found at the end of this
Guidebook.

Any errors in the Guidebook are the sole

responsibility of the Governor’s Office of Business
and Economic Development. With that in mind,
we are always looking for ways to improve the
resources we create. Please send suggestions to
zev@[Link].
 Table of Contents
Executive Summary . . . . . . . . . . . . . . . . . . . . . . . . . . . . vi Part 4: Permitting. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 33
Understanding the Permit Process . . . . . . . . . . . . . . . . 34
Part 1: Setting the Stage. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 State Permit Streamlining Laws
ZEVs in California Today . . . . . . . . . . . . . . . . . . . . . . . . . . 2 (AB 1236 and AB 970) . . . . . . . . . . . . . . . . . . . . . . . . . . . 36
Path to 100 Percent ZEVs . . . . . . . . . . . . . . . . . . . . . . . . . 2 AB 1236 Requirements . . . . . . . . . . . . . . . . . . . . . . . . 36
ZEV Strategy . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 AB 970 Requirements . . . . . . . . . . . . . . . . . . . . . . . . . 38
Scope and Purpose . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 AB 1236 and AB 970 Requirements and
Process Overview . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 40
Part 2: Planning and Site Selection. . . . . . . . . . . . . . . . . . . . . . 7 Complying with AB 1236 and AB 970 . . . . . . . . . . . . . . 41
How Station Developers Select Sites . . . . . . . . . . . . . . . 7 The Benefits of a Regional Approach . . . . . . . . . . . . . 42
Filtering Potential Locations . . . . . . . . . . . . . . . . . . . . 7 Resources to Help Communities
Securing a Specific Site . . . . . . . . . . . . . . . . . . . . . . . . 8 Enable a ZEV-only Future . . . . . . . . . . . . . . . . . . . . . . . . 42
Planning Charging Layout . . . . . . . . . . . . . . . . . . . . . 9 Additional Permitting Best Practices . . . . . . . . . . . . . . 43
Future-Proofing . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10 Preparing a Permit Application . . . . . . . . . . . . . . . . . . 45
How AHJs Plan and Support Station Development . . 11 What to Include in Your Application . . . . . . . . . . . . 45
Establishing Cooperation between Common Obstacles . . . . . . . . . . . . . . . . . . . . . . . . . . . . 46
Station Developers and AHJs . . . . . . . . . . . . . . . . . . 11
Planning for Charging Growth . . . . . . . . . . . . . . . . . 12 Part 5: Energization. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 49
Parking Requirements and Charger Installation . . 13 Understanding Energization . . . . . . . . . . . . . . . . . . . . . 50
Advancing Infrastructure through Timeline for Communicating with Your Utility. . . . . . . 51
Building Standards . . . . . . . . . . . . . . . . . . . . . . . . . . . 13 Major Utility Energization Processes . . . . . . . . . . . . . . . 52
Curbside Charging . . . . . . . . . . . . . . . . . . . . . . . . . . . 16 Pacific Gas & Electric. . . . . . . . . . . . . . . . . . . . . . . . . 54
Southern California Edison . . . . . . . . . . . . . . . . . . . . 54
Part 3: Accessibility . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19 San Diego Gas & Electric . . . . . . . . . . . . . . . . . . . . . 54
Background . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19 Los Angeles Department of Water and Power . . . 55
Federal Law . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19 Sacramento Municipal Utility District . . . . . . . . . . . 56
California’s Early Process and Need Opportunities to Streamline the
for Specific Requirements . . . . . . . . . . . . . . . . . . . . . 20 Energization Process . . . . . . . . . . . . . . . . . . . . . . . . . . . . 56
Regulation Development . . . . . . . . . . . . . . . . . . . . . 20
Regulatory Requirements (High-Level Summary) . . . 21 Part 6: Construction, Commissioning, and Operation . . . . . 61
Scoping Provisions. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21 Construction, Installation, and Review . . . . . . . . . . . . 61
Technical Requirements. . . . . . . . . . . . . . . . . . . . . . . . . 23 Commissioning and Operation . . . . . . . . . . . . . . . . . . 62
Van Accessible Spaces . . . . . . . . . . . . . . . . . . . . . . . 24 Increasing Access to Public Charging . . . . . . . . . . 62
Standard Accessible Spaces . . . . . . . . . . . . . . . . . . 24 Weights and Measures Certification . . . . . . . . . . . . 63
Ambulatory Spaces . . . . . . . . . . . . . . . . . . . . . . . . . . 24 Signs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 63
Drive-Up Spaces . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24
Sign Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24 Part 7: Looking Forward . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 65
Sample EVCS Layouts . . . . . . . . . . . . . . . . . . . . . . . . . . . 25
Path of Travel Improvements and
Part 8: Definitions and Additional Resources. . . . . . . . . . . . . 66
Accessible Route. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 27 Key Terms and Definitions . . . . . . . . . . . . . . . . . . . . . . . 66
Accessible Route . . . . . . . . . . . . . . . . . . . . . . . . . . . . 27 ZEV Readiness Scorecard . . . . . . . . . . . . . . . . . . . . . . . 68
Path of Travel Improvements . . . . . . . . . . . . . . . . . . 28 Electric Vehicle Charging Station
Streamlining All-Star Checklist . . . . . . . . . . . . . . . . . . . 70
Technical Infeasibility and
Unreasonable Hardship . . . . . . . . . . . . . . . . . . . . . . . . . 28 Planning for Zero-Emission Vehicles . . . . . . . . . . . . 70
Exceptions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 29 Permitting Best Practices. . . . . . . . . . . . . . . . . . . . . . 70
Private Multifamily Housing . . . . . . . . . . . . . . . . . . . . . . 30 Permit Application Best Practices . . . . . . . . . . . . . . 71
Working Together to Achieve Accessibility. . . . . . . . . 30 Energization Best Practices . . . . . . . . . . . . . . . . . . . . 71
Emerging Challenges . . . . . . . . . . . . . . . . . . . . . . . . 30 AB 1236 (Chiu, 2015) and AB 970
(McCarty, 2021) – Today’s Law As Amended . . . . . . . 72
Implementation Lessons &
Updating the Code . . . . . . . . . . . . . . . . . . . . . . . . . . 31 Select Station Development Resources . . . . . . . . . . . 76
Curbside Charging Best Practices . . . . . . . . . . . . . . . . 77
 Executive
Summary

California is in the midst of a massive transformation document. The best-case scenario includes a local
from internal combustion to 100 percent zero- government committed to strong building standards
emission vehicles (ZEVs). The question is not “if” and electric vehicle-related planning; a streamlined
we will complete the full transition; the question is and transparent permitting process that operates
“when.” “When” matters. Timing hinges in part on within the required timelines, inclusive of applying
our collective ability to streamline ZEV infrastructure an informed approach to ensuring accessibility;
development. a predictable energization process; and a well-
informed electric vehicle charging station developer 5
California’s transportation sector remains the single who has benefited from easily accessible resources.
largest contributor of emissions for both greenhouse
gases and health-impacting criteria pollutants. Over Planning: Local authorities having jurisdiction
3 million Californians suffer from asthma; climate (AHJs) can create a ZEV future by incorporating
change impacts in the state are already worse than ZEV infrastructure into city planning initiatives
expected.1,2 The solution is to reduce drive times and adopting voluntary building codes to ensure
and distances and eliminate emissions from the supporting infrastructure is installed at the least costly
transportation system. Each ZEV that replaces the point in time—during construction. Clear planning
function of an internal combustion vehicle brings us direction can help station developers with their
closer to the long-term goal of carbon neutrality and project proposals, just as understanding how station
a zero-emission transportation system. 3,4 developers choose sites can help inform permitting
processes.
To reach true market potential as quickly as possible,
California should be the most straightforward place Accessibility: As a market leader, California is also
in the country to install market enabling ZEV charging the first state in the nation to develop electric vehicle
and fueling infrastructure. The goal of this Guidebook charging station accessibility regulations to define
is to hasten the transition to ZEVs by simplifying the compliance with the broad responsibility under the
deployment of electric vehicle charging stations. federal Americans with Disabilities Act. The state
We aim to accomplish this by creating a shared developed these regulations to provide certainty
foundation of understanding for how cities, counties, for cities, charging station providers, and property
and developers can work together to streamline owners to help balance co-equal goals of deploying
the planning, permitting, installation, and ongoing infrastructure and ensuring broad access to services.
operation of electric vehicle charging stations and Implementation of these rules often comes down to
supporting equipment. local interpretation. This guide provides the context

The Guidebook is comprised of eight parts.

Throughout the Guidebook, we include three 1 State of the Air, 2022. American Lung Association.
layers of information: context, requirements, and 2 California’s Fourth Climate Change Assessment.
recommendations or best practices. We dive into 3 Executive Order B-55-18. Executive Order N-79-20.
the greatest depth in four key areas: planning, 4 AB-1279 The California Climate Crisis Act.
accessibility, permitting, and energization, and tie 5 A station developer is a public or private entity that develops charging
recommendations together with a ZEV Readiness stations, often a station development company, manufacturer of
electric vehicle supply equipment, investor-owned or publicly-owned
Scorecard and checklists at the end of the utility, automaker, nonprofit, or other interested party.

VI ELECTRIC VEHICLE CHARGING STATION PERMITTING GUIDEBOOK | SECOND EDITION

for the development of the accessibility regulations In addition to the above subject areas, the guide
and suggests resources to help local building officials addresses the construction, commissioning, and
and station developers deliver projects that benefit installation of stations and looks forward to a
all ZEV drivers. California with normalized electric vehicle charging
station development processes and ubiquitous ZEVs.
Permitting: California’s electric vehicle charging To get there, California has many advantages. We
station permit streamlining laws (AB 1236, Statutes have the most robust ZEV market in the country—the
of 2015, Chapter 598 and AB 970, Statutes of 2021, most charging and fueling stations, the most vehicles,
Chapter 710) were enacted to address mutual and the most experienced city and county planners,
frustration: electric vehicle charging station providers building officials, local workforce, and local leaders.
wanted to speed the permitting process; and cities
and counties often needed better information from While ultimate success is not inevitable, experience
applicants and/or a directive to create streamlined has shown that just one dedicated individual within a
processes. local government can catalyze efforts that turn their
city or county into a model ZEV-enabling community.
To help address these frustrations, AB 1236 establishes These leaders have come from local planning,
permitting process and communication requirements building, and sustainability departments. They have
for cities and counties—essentially putting best been elected officials and regional decision makers,
practices into statute. AB 970 codifies specific binding and all of them play a vital role in meeting our
timelines for project review and approval. However, collective vision.
to meet California’s ZEV goals, we need communities
to implement the laws and improve upon their Bold local and regional leadership, constructive
requirements by sharing on-the-ground learnings station developers, and a small amount of shared,
and best practices. The electric vehicle charging dedicated effort to streamline station development
industry continues to rapidly evolve and ultimate can help make local jurisdictions leaders in ZEV
success hinges on ongoing dialogue and process adoption and the future of transportation. California
improvements. is committed to working with these partners to create
the replicable systems necessary to create the future
Energization: Electric vehicle charging stations are our health and climate depends on.
one of many services vying for utility attention. This
guide explores the preferred processes for California’s
five largest utilities, all of which are committed to
electrifying transportation.

Image courtesy of Adopt a Charger

SECOND EDITION | ELECTRIC VEHICLE CHARGING STATION PERMITTING GUIDEBOOK VII

Image courtesy of Tesla
VIII ELECTRIC VEHICLE CHARGING STATION PERMITTING GUIDEBOOK | SECOND EDITION
 PART 01:

Setting the
Stage

The transportation sector remains the largest where they want to go. Widespread availability of
contributor of greenhouse gas and criteria pollutant infrastructure ensures that Californians will have
emissions in California. 6 We cannot meet our state that confidence.
climate and air quality objectives without a massive,
near-term shift from internal combustion engines to In addition to benefitting ZEV drivers directly, the
zero-emission drivetrains. construction and installation of ZEV infrastructure
benefits communities and supports local contractors
The State of California is a national and international and businesses. Each ZEV on the road means
leader in the deployment of zero-emission vehicles incrementally cleaner air, regardless of who owns
(ZEVs). These cars are any type of vehicle that has or drives the vehicle, and the presence of chargers
no tailpipe emissions. They run on electric motors attract drivers to local establishments—generating
and are powered by electricity stored in batteries or revenue for local businesses. Furthermore, ZEVs keep
created onboard using hydrogen and fuel cells. 7 fuel spending local and are often less expensive to
operate than conventional vehicles—saving residents
In contrast to conventional internal combustion and visitors money.10
vehicles, ZEVs produce zero tailpipe emissions,
preventing harmful greenhouse gas and criteria This Guidebook is comprised of eight parts and
pollutants from being released into the environment. is intended to help navigate station developers
They can also help integrate renewable energy into and local jurisdictions through the infrastructure
the transportation sector. Moreover, the communities development process from selecting sites for
most burdened by air pollution are often the ones electric vehicle charging through the permitting
along major transportation and shipping corridors and construction processes. This Guidebook goes
and a switch to ZEVs will help alleviate that burden. into greater depth in Part 3: Accessibility, Part 4:
Permitting, and Part 5: Energization, due to the
To support California’s ambitious ZEV deployment influence these stages can have on the overall
goals—5 million ZEVs in California by 2030, 8 100 project timeline and cost.11 We provide clarity
percent of new light-duty sales to be ZEV in
2035, and 100 percent of medium- and heavy-
duty vehicles to be ZEV by 2045 9 —the state is 6 California Greenhouse Gas Emissions for 2000 to 2020, Trends of
prioritizing the development of infrastructure to Emissions and Other Indicators

support these vehicles through policy, targeted 7 Plug-in electric and hydrogen fuel cell electric vehicles are
complimentary zero-emission technologies.
investment, and continued coordination. At the
8 Executive Order B-48-18.
most fundamental level, infrastructure in the form
9 Executive Order N-79-20.
of electric vehicle charging stations and hydrogen
10 Consumer Reports issued a study showing that battery electric vehicles
fueling stations enables the deployment of ZEVs. can save consumers thousands of dollars over the life of the vehicle
When consumers look to buy a new or used car, they compared to conventional cars – and save up to $4,700 in fuel costs in
just the first seven years.
need confirmation that it will be able to take them
11 Key definitions can be found in Part 8 of this document.

SECOND EDITION | ELECTRIC VEHICLE CHARGING STATION PERMITTING GUIDEBOOK 1

and tips on implementing the statewide permit
streamlining requirements (AB 1236, 2015, and AB
970, 2021), as compliance with and understanding
of these requirements are vital to ensuring ZEV
infrastructure deployment across the state.

Ultimately, a successful transition to zero emissions

hinges on success at the local level. Success up to
this point has been a necessarily iterative process
as the ZEV stakeholder community has learned how
to best deploy chargers in a variety of settings. This
Guidebook reflects the latest best practices collected
from station developers, local jurisdictions, and
utilities with experience in developing, approving,
and energizing electric vehicle charging stations. We
Image courtesy of Adopt a Charger
hope this experience can save time and minimize
iterations for station developers, local jurisdictions,
and utilities. The faster we deploy safe and reliable
infrastructure, the sooner we accumulate the
benefits ZEVs bring to our communities, the state, Level 2 (12–70 miles of range per hour, 71,499 total
and ultimately, the world. chargers),16 and Direct Current fast charging (3–20
miles of range per minute, 8,528 chargers). For the
purposes of this Guidebook, a charging station is
ZEVs in California Today defined as an electric vehicle charging space served
by an electric vehicle charger. A multiport electric
The California Energy Commission (CEC) tracks vehicle charger that can charge vehicles in multiple
and publishes quarterly Zero-Emission Vehicle and spaces simultaneously is counted based on the
Infrastructure Statistics in a series of data dashboards: number of vehicles that can charge at one time.
Light-Duty Vehicle Population, Medium- & Heavy-
Duty Vehicle Population, New ZEV Sales in California,
Electric Vehicle Chargers in California, and Hydrogen Path to 100 Percent ZEVs
Refueling Stations in California. CEC has also teamed
up with Veloz to deliver quarterly electric car sales California has established ambitious ZEV infrastructure
data to support Veloz’s sales dashboard that provides and vehicle targets for the state—250,000 shared
information on California electric car sales, national plug-in electric vehicle chargers, including 10,000
electric car sales, electric car chargers, hydrogen direct current fast chargers (DCFC) and 200 hydrogen
stations, and the current number of electric makes stations, by 2025. These targets were set to put
and models available in the state.

ZEVs as a percentage of new passenger car sales

continue to increase.12 In 2021, ZEV sales exceeded 12 ZEVs include Battery Electric Vehicles (BEVs), Plug-in Hybrid Electric
12 percent of all new passenger car sales in Vehicles (PHEVs), Fuel Cell Electric Vehicles (FCEVs). For the purpose
of this Guidebook, BEVs include both plug-in electric vehicles and
California, increasing to nearly 19 percent in 2022.13 In battery electric vehicles that charge wirelessly, using inductive
total, over 1.3 million ZEVs have been sold in California charging.

as of the publishing of this document, including 13 345,818 ZEVs were sold in 2022, more than all annual ZEV sales in any
previous year.
955,510 Battery Electric Vehicles (BEVs), 429,873 Plug-
14 California Energy Commission (2022). New ZEV Sales in California.
in Hybrid Electric Vehicles (PHEVs), and 14,530 Fuel Dashboard last updated January 18, 2023. Retrieved from
Cell Electric Vehicles (FCEVs).14 With the increasing [Link]

popularity of ZEVs, the need for charging and fueling 15 Shared private chargers are located at parking space(s) designated
by a property owner or lessee to be available to, and accessibly
infrastructure is increasingly important. by, employees, tenants, visitors, and residents. Examples include
workplaces and shared parking at a multifamily residence.
As of publishing, there are 36,499 public chargers 16 Note: not all public connectors serve all plug-in electric vehicles and
in California and 43,528 shared private chargers for not all connectors can be used simultaneously. Tesla, for example,
operates a network of chargers dedicated to Tesla vehicles. Single-
a total of 80,027 electric vehicle (EV) chargers.15 family home-charging, when available, is a key market enabler and is
This includes, also not accounted for in the connector count.

2 ELECTRIC VEHICLE CHARGING STATION PERMITTING GUIDEBOOK | SECOND EDITION

California on the path to host 5 million ZEVs by 2030.17 ZEV Strategy
California subsequently set targets to transition to 100
percent ZEVs: 100 percent of in-state sales of new To ensure coordination across state agencies,
passenger vehicles and trucks will be zero-emission local government, and the private sector, GO-Biz
by 2035; 100 percent of operating drayage trucks and developed the ZEV Market Development Strategy.
operating off-road vehicles and equipment will be The ZEV Strategy is meant to help California
zero-emission by 2035 everywhere feasible; and 100 collectively move forward and deliver zero-emission
percent of medium- and heavy-duty trucks and buses benefits to all Californians, outlining how state
will be zero-emission by 2045 everywhere feasible.18 agencies and stakeholder groups key to our transition
can move together with the scale and speed
More information on the plug-in electric charger required to reach the state’s ZEV targets.
targets is detailed in the California Energy
Commission’s Assembly Bill 2127 Electric Vehicle The ZEV Strategy is organized around four key pillars
Charging Infrastructure Assessment. For passenger of the ZEV market: vehicles, infrastructure, end users,
vehicle charging in 2030, the report projects over and workforce. To support and provide a fuller
700,000 public and shared private chargers are description of the infrastructure pillar, the California
needed to support the state’s 5 million ZEV goal. For Energy Commission, together with several state
the 8 million ZEVs anticipated by 2030 under the more agencies, developed the Zero-Emission Vehicle
ambitious 100 percent ZEV goals in Executive Order Infrastructure Plan (ZIP). The ZIP describes the state’s
N-79-20, nearly 1.2 million chargers will be needed for near- and long-term actions, in collaboration with the
light-duty vehicles. An additional 157,000 chargers are private market, to ensure that zero-emission vehicle
needed to support the 180,000 medium- and heavy- infrastructure will meet the needs of the growing zero-
duty vehicles anticipated for 2030. This projected emission vehicle market. 22
need for chargers is in addition to single-family
home chargers, which serve as the primary charging The ZEV Strategy and the ZEV Market Development
location for most plug-in electric vehicle drivers.19 Metrics that track the state’s progress toward the
targets set in the Strategy are living documents that
Charging needs vary across different areas of the will adapt over time based on feedback and
state, market segments, and communities. Suburban lessons learned.
communities primarily occupied by single-family
homeowners may not require as many public
chargers per vehicle since drivers will be able to Scope and Purpose
charge at home, while urban areas or those with
The intent of this Guidebook is to add value for
large numbers of renters and unassigned parking will
electric vehicle charging station developers and
require more shared access charging (in both public
local authorities having jurisdiction (AHJs) and help
and private locations). 20 Rural community needs are
both parties navigate emerging challenges that
likely to vary, depending on typical travel patterns
remain for the installation of plug-in electric
and vehicle types. Charging can and should be
vehicle charging.
considered in general planning, transit planning, and
other mapping and planning of regional, local, and The content reflects our efforts to prioritize new and
community travel patterns. emerging issues for electric vehicle charging, and
within that context, issues that can be addressed
A trained and skilled ZEV infrastructure workforce
is critical in preparing workers to meet state goals.
A suite of key occupations and local jobs in the
17 Executive Order B-48-18.
ZEV infrastructure sector are needed now as this
18 Executive Order N-79-20.
sector scales and prepares for increased public and
19 See “Quantifying the electric vehicle charging infrastructure gap
private investments. 21 Through the Electric Vehicle across U.S. states,” ICCT (2019), pg. ii.
Infrastructure Training Program (EVITP), local entities, 20 The majority of plug-in electric vehicle charging occurs at home
project and workforce partners, site developers, and importance of this segment cannot be overstated. However,
this document primarily focuses on charging at shared locations
and local electricians/electrical contractors should (public, workplace, multifamily), which have historically been the most
coordinate early in the development process to challenging to develop.

ensure that electrical work required for installations 21 See Workforce Projections to Support Battery Electric Vehicle
Charging Infrastructure Installation, Energy and Environmental
will be completed on time and within budget. Research Associates, LLC (2021).

22 Zero-Emission Vehicle Infrastructure Plan (ZIP)

SECOND EDITION | ELECTRIC VEHICLE CHARGING STATION PERMITTING GUIDEBOOK 3

at the statewide level to streamline the station This Guidebook does not cover how to seek and
permitting and development process. attain funding for station development. We begin
at the site selection phase under the assumption
Although station developers and AHJs are our two that funding has already been secured. If you are
main audiences, we elaborate on site host challenges looking to secure funding, we recommend consulting
when appropriate and recognize the complexity resources such as the GO-Biz ZEV Funding Resources
of the utilities’ role in station development (e.g., webpage.
sometimes utilities are a station developer, sometimes
they solely handle the energization process). This Guidebook and the 2020 Hydrogen Station
Permitting Guidebook serve as the companion
This Guidebook focuses primarily on the permitting documents to the 2013 ZEV Community Readiness
process, detailing obstacles and emerging Guidebook, a publication from the Governor’s Office
challenges and spotlighting best practices from of Planning and Research that provided an early
jurisdictions and station developers across the state. comprehensive guide to the steps communities can
We provide context on site selection and other issues take to support increasing adoption of ZEVs.
to help illuminate, for both station developers and
AHJs, the constraints that they operate under and the
decisions that inform permitting processes.

Part 2 of this Guidebook focuses on planning for

charging stations with a focus on actions cities
and counties can take such as incorporating ZEV
infrastructure into planning efforts and adopting
voluntary building codes. The section also explains
site selection considerations and work that station
developers complete before permitting stations with
the goal of informing AHJ approval processes.

Part 3 addresses the implementation of California’s

regulations for Americans with Disabilities Act
compliance.

Part 4 focuses on permitting including considerations

prior to submitting a construction or building permit
application for a charging installation, best practices
for charging station permitting, compliance with AB
1236 (Chiu, 2015) and AB 970 (McCarty, 2021) permit
streamlining requirements, and how to prepare a
permit application.

Part 5 focuses on energization, with sections on the

processes for California’s largest utilities.

Part 6 covers construction, commissioning, and

operation, including what to expect from a building
inspection and information on signage.

Part 7 takes a brief look forward, acknowledging the

fact that station development is a process that can
continually be improved.

Part 8 provides key definitions, the ZEV Readiness

Scorecard that GO-Biz uses to track station permit
streamlining, checklists for stakeholders to reference
as they work to improve the overall ZEV infrastructure
development system, the texts of AB 1236 and AB 970,
and curbside charging best practices.

4 ELECTRIC VEHICLE CHARGING STATION PERMITTING GUIDEBOOK | SECOND EDITION

Images courtesy of the Bay Area Air Quality Management District and Electrify America
SECOND EDITION | ELECTRIC VEHICLE CHARGING STATION PERMITTING GUIDEBOOK 5
Image courtesy of EVgo
6 ELECTRIC VEHICLE CHARGING STATION PERMITTING GUIDEBOOK | SECOND EDITION
 PART 02:

Planning and
Site Selection

In this section of the Guidebook, we explain the site to move forward. The site selection process can be
selection and approval process from both the station different for each station developer, but some general
developer and the AHJ perspective. Key questions principles apply.
include: Where is the best location to place stations to
ensure ample utilization and, if applicable, secure a At least five key factors play a role in determining
return on investment (however that return is defined)? site selection:
What type of stations should be installed? Where on 1. Location. Station developers typically use public
the property should chargers be located? Should the or proprietary data on surrounding real estate,
stations be grid connected or standalone? travel patterns, fleet use, nearby amenities,
throughput and availability to the public, and/or
How Station Developers local knowledge. Developers typically evaluate
a location based on several factors including
Select Sites but not limited to whether it will provide a safe
customer experience, be easily accessible for
Station developers look at a variety of factors in
drivers, contain sufficient space for charging stalls
selecting sites. Depending on their business model,
and supporting equipment, and whether it will
each station developer will consider and prioritize
be proximate to commute routes, amenities, and
factors differently. Some station developers select,
utility lines.
secure, own, and operate stations at sites. They may
sign a contract with the property owner for the right
to operate a station in a certain parking space and
hold responsibility for all operations of a station. Other
station developers may only select and secure sites,
leaving the property owner to own and operate the
station(s). Finally, some station developers do not
engage in site selection at all, and contract with site
hosts who are already interested in installing charging
stations. In this chapter, we look at the selection
process with intent to inform AHJs of all the work that
has already gone into site selection by the time a site
makes it to the permitting stage.

Filtering Potential Locations

Station developers may consider many sites, evaluate
different criteria at each one, and reach out to
Image courtesy of Penske Truck Leasing
several different site owners before selecting projects

SECOND EDITION | ELECTRIC VEHICLE CHARGING STATION PERMITTING GUIDEBOOK 7

2. Cost. Station developers are mindful of cost Negative grades for any of the above factors may
impacts when scouting new sites. Station significantly delay or cancel a project.
developers assess cost factors including whether
there is access to primary power, whether back- Securing a Specific Site
up generation could be necessary, and whether
By the time a potential station first appears on
the site could require extensive landscaping,
the radar of city or county planning and building
upgrades, modifications, or new lighting.
departments, a site host and station developer have
3. Permitting. A site that is difficult to permit can typically been involved in months of negotiation and
add months or more to a project, and cities contract development. In many cases, a site host and
with lengthy permitting processes may miss station developer will negotiate a property license
out on station developer investment. When agreement regarding a specific piece of land on
evaluating an area, developers often select which the parties have agreed to place the station.
cities with streamlined permitting, and cities These negotiations result in a site that addresses site
without streamlined processes often lose projects host concerns (accessibility, construction impacts,
to adjacent cities with streamlined processes. and site host customer experience) and station
AHJs can help attract charging stations and developer needs (cost, access to power, sufficient
investment by streamlining their permitting space, well-lit and visible, and acceptable
processes (see Part 4: Permitting). elevation grade).

4. Electrical capacity and location of service. Utility While there are many benefits to having charging
energization can add considerable cost when stations on-site, potential site hosts may be hesitant
major upgrades are required; sites with available to host charging stations if they have concerns
electrical capacity and/or well-located electrical about limiting non-electric vehicle parking capacity
service that does not cross the public right of way at the site, the amount of rent (if any) that will be
are attractive. More information on energization is paid to lease the parking spaces, and whether
provided in Part 5: Energization. individuals visiting the site to charge will patronize
their business. Additionally, site hosts do not always
5. Property ownership. Ultimate success depends have information on the electrical capacity of their
on a willing site host who understands the benefit building, which adds an additional complication to
of EV charging and the potential for stations to the site host solicitation process. If an EV charging
add value to their property. Depending on the station is installed using existing electrical capacity
property type, charging stations can increase and without the need for a new utility service
foot traffic, attract new and repeat business, through such options as load management, station
future-proof the property, support sustainability developers often must educate site hosts and
goals, and/or comply with EV charging codes. electricians about the technology and help alleviate

Electrical capacity and site viability

On a single property, such as a shopping center,

electrical capacity and location have a major impact
on where a station can be built economically. For
example, station developers have reported that two
sites in the same shopping center parking lot could
range in construction cost by substantially more than
$100,000 if one location requires utility/infrastructure
upgrades and the other does not.

Image courtesy of Electrify America

8 ELECTRIC VEHICLE CHARGING STATION PERMITTING GUIDEBOOK | SECOND EDITION

any initial concerns about impacts on the property
and utility bills.

Even after two parties have worked out a contract, Automated Load Management Systems
control and decision-making about the site may (ALMS)
still be delicate. If a building or construction permit
application has to go through multiple rounds ALMS for EV charging stations intelligently share power
of comments and if extensive unanticipated across multiple stations. The primary benefits are:
construction or site improvement is added as a
• Enabling existing site electrical infrastructure to meet
condition of approval, site hosts can become
the growing demand for EV charging at a site
frustrated with the process and withdraw from the
agreement. 23 The bottom line is that whenever a • Maximizing the number of EV
station developer is installing stations at a site they plugs at a site, while minimizing site electrical
infrastructure upgrade costs
do not own or where they do not have a pre-existing
relationship, taking the time to understand and work • Allowing a full charge to a vehicle when the parking
through potential site control challenges lot is empty, while maximizing the number of vehicles
is paramount. simultaneously charging when the parking lot is full

• Maximizing the number of charging ports in

Planning Charging Layout California while having a lesser impact on the
electrical grid
After selecting a site, station developers and site hosts
negotiate what level of charging to install, how many Power sharing is used every day across the state.
In order to protect people, property, vehicles,
chargers to install, and where the chargers should
and equipment, both software approaches and
be placed on the property. Common locations for traditional hardware approaches are used as failsafe
shared-use station development include shopping mechanisms. An ALMS is designed so that power is
centers, grocery stores, restaurants, gas stations, limited to circuit, branch, and panel capacities. In
convenience stores, parking garages, parking lots, addition, traditional overcurrent protection is hardwired
hotels, workplaces, apartment complexes and other to ensure circuits and panels will shut down in the
multi-family housing. Each location can present a event of software system failure. Load management is
discussed further in the Building Standards section.
different use case by attracting people, parking, and
charging at different times of the day and for different
lengths of time. This informs what charging layout
makes the most sense for the site.

For a workplace where some people leave their

cars parked all day, while others take their cars to
off-site locations throughout the day, a mix of Level where to locate the chargers, especially in locations
2 chargers and Level 1 charging for those with long with multiple potential sites (such as a large parking
dwell times may be appropriate. Similarly, a shopping garage). Some site hosts may wish to locate chargers
center may develop Level 2 and Level 1 chargers for in highly visible locations, such as close to the building
its employees who will stay on site for an extended entrance, to promote a sustainable image. Others
period, but DCFCs and Level 2 chargers for its may want to reserve prime parking spaces that can
customers who will be in and out. Similar logic applies be used by every car and prefer to locate charging
for a downtown parking garage that is partially used stations in the back of a parking lot. Safety and
by office workers who park all day and partially used convenience are factors as well. In addition, cellular,
by individuals running errands: slower charging for the Wi-Fi, or ethernet communication availability must be
office workers, and faster charging for individuals with
shorter dwell times. Drivers who rely on fast chargers
have tended to be drivers who do not have charging
23 Note: Per AB 1236, discussed later in this Guidebook, extraneous work
at home or at their workplace and/or need a fast not related to health and safety cannot be required as a condition of
charge to extend their trip or provide rideshares. 24 approval.

24 Planning charging layout also involves determining which model

Once the distribution of different charging or models of charger to procure and install. For more background,
readers can consult the Electric Vehicle Charger Selection Guide from
technologies and the specific charger models are the Redwood Coast Energy Authority, the Schatz Energy Research
decided, station developers and site hosts determine Center, the Local Government Commission/Civic Spark, and the
Siskiyou County Economic Development Council.

SECOND EDITION | ELECTRIC VEHICLE CHARGING STATION PERMITTING GUIDEBOOK 9

considered to enable any ‘smart’ features of electric of future charging installations; installing additional
vehicle charging stations, such as load management dedicated electrical circuits for anticipated charger
and station reporting. expansion; preparing a site for on-site energy
storage and power generation; installing charging
Station developers’ flexibility on the level and number equipment; and a host of other strategies to lower
of chargers can be heavily limited by available future expenditures on station development and
electrical capacity. The proximity to the electrical operation.
panel or transformer is a key factor that impacts site
design. Since there is usually minimal existing conduit Spaces can be prepared for future charger
and wiring throughout a parking lot, the most cost- installation to at least one of two levels, depending
effective option is often to place chargers closest on the level of desired up-front investment.
to the existing electrical panel or transformer. This
placement may not align with where the station • EV Capable: A vehicle space with electrical panel
developer and/or site host would prefer to locate the space and load capacity to support a branch
chargers, leaving station developers and site hosts to circuit and necessary “raceways” (the enclosed
face a trade-off between securing their ideal charger conduit that forms the physical pathway for
locations versus the increased costs to trench and lay electrical wiring to protect it from damage), both
additional conduit and wiring. This trade off will only underground and/or surface mounted, to support
be exacerbated as the needed power capacity and EV charging.
size of stations increases. During permit review, AHJs • EV Ready: A vehicle space which is provided
should be aware that station developers frequently with a branch circuit; any necessary raceways,
must place stations near power sources to allow for both underground and/or surface mounted; to
deployment of stations with the least disturbance to accommodate EV charging, terminating in a
site hosts in an economically viable manner. 25 receptacle or a charger.
Expected current and future throughput, the The most cost-effective time to create EV Capable
availability of electrical capacity, and the desired and EV Ready sites is during construction—either
level of charging inform how many chargers to when a building is being constructed or undergoing a
place on the site. At workplaces, employers will often major retrofit or when an initial electric vehicle charg-
survey staff to find out how many currently drive or ing station project is being installed. In the latter case,
are interested in driving a plug-in electric vehicle. At station developers plan for how many chargers they
other sites, publicly available data through sources intend to install in the future and prepare EV Capable
such as the Clean Vehicle Rebate Project can help or EV Ready spots accordingly. The approach helps
inform station developers on the prevalence of avoid expensive retrofitting costs and allows chargers
plug-in electric vehicles in their community and to be easily added to meet growing demand.
how many chargers would be reasonable to install.
Some incentive programs may require a minimum In addition to planning for the ability to add chargers
number of chargers to be installed to receive funding. and higher speed charging, future-proofing can
Accessibility regulations will also impact site design incorporate the addition of on-site energy storage
and location, as different numbers of chargers and and renewable power generation. Both can work
charging levels trigger required accessible spaces. together to minimize the cost of electricity by
We discuss accessibility regulations further in Part 3: reducing peak demand on the grid.
Accessibility. Finally, station developers may choose
to install chargers in anticipation of future growth. For their part, local jurisdictions can adopt more
ambitious voluntary codes via the ordinance process
Future-Proofing for new construction that places EV Capable and/
or EV Ready spaces in significant percentages of
Future-proofing involves creating opportunities parking spaces. 26 The Advancing Infrastructure
to enable future easy and low-cost expansion of
charging, upgrading of equipment, and improved
customer experience at a site. Future-proofing may
mean laying down additional cable and/or conduit 25 Note: depending on a station developer and property owner strategy,
load management and battery support systems can also be deployed
during new construction or renovations beyond what to minimize costs and avoid unnecessary grid upgrades.
is needed for the current project. It may also involve 26 CALGreen electric vehicle charging station voluntary codes for new
installing excess electrical capacity in anticipation construction can be found in sections A4.106.8 and A5.106.5.3 of the
residential and nonresidential voluntary measures respectively.

10 ELECTRIC VEHICLE CHARGING STATION PERMITTING GUIDEBOOK | SECOND EDITION

through Building Standards section discusses building city-owned locations including their own workplaces,
codes in more detail. public parks, and transportation corridors.

Station developers should also be aware of state Establishing Cooperation between Station
accessibility regulations when designing a site for Developers and AHJs
the addition of future chargers. For more details
on accessible design including requirements for A number of factors within an AHJ’s control can
accessible routes, path of travel, stall dimensions, attract charging to a jurisdiction (favorable parking
slope, and more, see Part 3: Accessibility. counts, progressive building standards, established
readiness plans and related resources). Perhaps most
importantly, AHJs can attract station developers by
How AHJs Plan and Support creating a straightforward, transparent, standardized,
Station Development and expedited permitting process. The more station
developers know about a jurisdiction’s approach to
AHJs engage in numerous planning and incentivizing permitting ahead of time, the more time and effort
efforts to influence and shape the private site all parties tend to save. Part 4: Permitting explores this
selection process and may also install stations at topic in detail.

Medium- and Heavy-Duty and site usage based on anticipated 3. These stations may require extra
vehicle profiles. clearance if the vehicles are larger
Vehicle Charging—Make-
in size and maneuverability may be
Ready Opportunities While similar to light-duty charging in
limited. Where possible, avoid low-
the site selection and development,
hanging canopies, tight turns, and
medium- and heavy-duty charging
compact spaces. Even panel vans
Plug-in electric medium- and heavy- differs in the following ways:
may be prevented from charging at
duty vehicles are increasingly
1. Depending on the fleet’s utilization, a compact-sized parking space.
common in commercial fleets and
will continue to grow over the next battery sizes, and dwell times,
Electrified parking improvements
decade to meet the state’s target of chargers may require more power
require conduit, trenching, and existing
100 percent zero-emission medium- to support the vehicle. However,
electrical infrastructure upgrades or
and heavy-duty vehicles by 2045. 24 there are fleets with low mileage
new electrical service that can be sized
The California Air Resources Board operations and shift patterns that
to support future charging. Contractors
(CARB) is adopting regulations that will would allow for L2 charging of
and facility managers should be
require fleets to transition to ZEVs, and trucks. A fleet/site specific analysis is
proactive when making decisions to
while initial ZEV fleet purchases may needed to determine the appropriate
construct new sites, or upgrade or
be small, the regulation will result in levels of charging.
modify their site’s existing infrastructure
100 percent ZEV fleets. Fleet operators 2. Fleet operators may have an added so that their improvements can double
and property owners may consider interest in deploying on-site storage as make-ready investments for future
preparing facilities for electrification and renewable power generation charging equipment. Being proactive in
in advance of vehicle deployments, to manage demand charges. The this decision can save tens of thousands
building infrastructure in the short payback for on-site storage and of dollars in construction cost for future
term with a plan to serve the whole energy generation technologies can charger installments.
fleet. In planning for future charging, be particularly attractive for projects
fleet operators and property owners serving medium- and heavy-duty
may consider power level, duty cycle, vehicles given the potential for
charging location, charging speed, increased consumption of electricity.

27 See CARB’s Advanced Clean Trucks regulation and draft Advanced

Clean Fleets regulation.

SECOND EDITION | ELECTRIC VEHICLE CHARGING STATION PERMITTING GUIDEBOOK 11

Furthermore, AHJs can experiment with innovative presenting to local government groups (e.g., Councils
ways to use zoning codes to further promote and of Governments, Associations of Governments,
streamline charger development. For example, ZEV Readiness Councils), and partnering with state
an AHJ could formally define an electric vehicle agency leadership and staff to communicate both
charging station (EVCS) as a permitted accessory general and specific plans. 28
and primary use, and further codify the permitting
process as part of the zoning code. The City of San Planning for Charging Growth
Diego code defines EVCS as its own use and outlines
Local planners and other leaders can incorporate
the types of permits needed in compliance with state
charging within their planning tools, both binding and
law, clarifies that review is limited to health and safety,
nonbinding. In addition to meeting and exceeding
and outlines the appeal process. The market is rapidly
state permit streamlining requirements (see the AB
evolving and open communication with and from
1236 and AB 970 section), ZEV charging and fueling
cities and counties is fundamental to success.
should be considered and included within general
Station developers can help AHJs by sharing their plans, capital improvement plans, climate action
development plans as soon as they can—ahead of plans, transportation plans, design guidelines,
permitting if possible. This sharing enables AHJs to and zoning codes as applicable. Incorporating a
proactively prepare for projects or classes of projects. jurisdiction’s plans for charging across all applicable
It can take place through a variety of avenues both documents helps communities plan and develop
within and external to the permitting process. In the charging. Advocates of zero-emission vehicles within
context of permitting, station developers can notify local governments should familiarize themselves with
AHJs as soon as they have a site in mind. Outside the timelines for updates of major documents and be
of permitting, developers can send public plans to prepared to advocate for charging and hydrogen
key jurisdictions, meet with pivotal cities or counties, fueling within those update cycles.

Regional EV Readiness ownership over a ZEV readiness regional EV readiness plan through
plan and ensures that it does not just Plug-in San Diego. Best practices,
Planning: An Example from
become another document languishing correction sheets, and checklists for
San Diego on a website. As a testament to its level charging station permitting, installation
of stakeholder engagement, the San and inspection were developed
Diego regional readiness plan is now and disseminated for plug-in station
The San Diego Regional Plug-in Electric
included in both the City and County developers and AHJs. SANDAG also
Vehicle Infrastructure Working Group,
Climate Action Plans. utilized the Center for Sustainable
led by the San Diego Association of
Energy as a regional “EV Expert” to
Governments (SANDAG) and the Center Councils of governments and other
provide no-cost technical assistance to
for Sustainable Energy, brought local regional planning bodies and transit
site hosts at any point in the process of
governments, Miramar College and commissions can play a useful role in
installing charging. 29 Interested parties
UC San Diego, the Port of San Diego, bringing together local governments
fill out a pre-screening questionnaire
San Diego International Airport, and to synchronize permit requirements
and then set up a free consulting
San Diego Gas & Electric to the table and plan across a region. In the
appointment to learn more about
as voting members during their EV San Diego region, SANDAG and the
options available to them.
readiness plan development and Center for Sustainable Energy were
deliberation process. This level of awarded additional California Energy
stakeholder engagement creates Commission funds to implement their

28 To help with this effort, GO-Biz has created a website to track

ZEV readiness, share best practices, and connect readers to ZEV
investment plans that can be used by AHJs to prepare for near term
ZEV investments – [Link]/ZEVReadiness.

29 Plug-In San Diego checklists/correction sheets/best practice reports:

[Link]

12 ELECTRIC VEHICLE CHARGING STATION PERMITTING GUIDEBOOK | SECOND EDITION

Through support from the California Energy required parking spaces by the amount necessary
Commission, many jurisdictions have developed and to accommodate the proposed EV charging station
adopted ZEV readiness plans. A ZEV readiness plan if the EVCS and associated equipment interferes
is a document at the neighborhood, city, county, with, reduces, eliminates, or in any way impacts the
or regional level that captures the current state of required parking spaces for existing uses. AB 1236 and
ZEVs and ZEV infrastructure deployment in the area, AB 970 are discussed in detail in Part 4: Permitting.
the local ZEV goals, and actions and strategies to
achieve those goals. An important component of Parking ordinances can be used to attract and
a ZEV readiness plan is stakeholder coordination encourage the installation of charging stations,
and buy-in. Involving stakeholders as deliberative especially in the context of new development.
committee members at every stage of readiness plan For example, Sacramento County development
development gives the plan the greatest chance of standards allow staff level planners to count charging
success and longevity. 30 spaces as up to two parking spaces depending on
other parking reduction measures; and the City of
When planning for public charging in their Stockton municipal code counts charging spaces
community, planners will likely evaluate similar as two parking spaces for up to 10 percent of total
qualitative and quantitative datasets as station required parking. Other cities, like Emeryville and
developers but will look at these factors through Alameda, have eliminated parking requirements
different lenses. Like station developers, AHJs altogether.
will look at data such as travel patterns, station
throughput, and available electrical capacity, but In addition, AHJs can take innovative approaches to
engage with these factors from a regional and parking challenges by promoting the deployment
local planning perspective. AHJs are more likely of ZEV car sharing. In this regard, AHJs can adopt
to plan public charging distribution through an ordinances that allow for parking space reductions
equity and environmental justice lens and consider when car sharing is utilized. For example, the City
charging’s relationship to multimodal transportation of Santa Monica reduces parking requirements by
projects and other community-wide planning two spaces (up to a maximum of 25 percent of the
considerations. AHJs may also develop charging in required parking spaces, not to exceed 10 spaces)
their parking lots and government buildings and for when a car-sharing parking space is provided. 31
their fleets. For example, in the City of Pasadena,
Advancing Infrastructure through
these two purposes go hand-in-hand as the City
is able to use its workplace charging to charge its
Building Standards
fleet vehicles overnight. Other AHJs may open their California Green Building Standards (CALGreen)
workplace charging to the public in the evening Code, the state’s green building code (California
and on weekends to create further public charging Code of Regulations, Title 24, Part 11), sets
opportunities. requirements for installing EV Capable infrastructure
and charging access in new residential and
Parking Requirements and nonresidential buildings. CALGreen Code contains
Charger Installation mandatory requirements that apply statewide, as well
Per Assembly Bill 1100 (Kamlager-Dove, 2019), codified as voluntary provisions that can be adopted by local
in Vehicle Code Section 22511.2, charging spaces governments. Local governments can also choose
count as at least one standard parking space for to develop and adopt their own local codes that go
complying with minimum parking requirements. beyond statewide mandatory minimum requirements.
Accessible charging spaces with an access aisle Starting January 1, 2023, the 2022 CALGreen Code
count as at least two standard parking spaces. In requires that newly constructed multifamily dwellings,
the context of permitting charging stations and
support equipment on existing sites, local zoning and
parking considerations should not factor into the
permit approval process unless the project would
pose a substantial health and safety risk. AB 1236
(Chiu, 2015) requires local jurisdictions to focus their
30 Example plans include the 2017 Sacramento Electric Vehicle
review of EVSE projects on non-discretionary health Readiness and Infrastructure Plan and the 2018 Final Butte PEV
and safety considerations. AB 970 (McCarty, 2021) Readiness Plan.
further clarifies that AHJs must reduce the number of 31 City of Santa Monica Municipal Code. See Section C-1.

SECOND EDITION | ELECTRIC VEHICLE CHARGING STATION PERMITTING GUIDEBOOK 13

 receptacles, and 15 percent of parking spaces to be
equipped with Level 2 EVSE for projects with 20
or more units.
Parking Enforcement
The EV Capable requirements do not require
installing EVSE at the parking space at the time of
Driver confidence and vehicle utility relate directly to original construction but reduce the costs and work
the ability to charge when needed. Jurisdictions can
required to install EVSE and simplify the process of
help ensure charging spaces are used for charging
installing a charger or receptacle later. This also
through signage and enforcement by installing tow-
away signs at charging spaces along with clearly eases nonfinancial barriers such as gaining site
striping and marking the associated pavement. For host or homeowners association (HOA) approval.
enforcement, local jurisdictions have authority under Furthermore, newly constructed single-family
AB 1314 (Havice, 2002) to designate off-street spaces dwellings, duplexes, and townhouses with private
for the exclusive use of plug-in electric vehicles and garages are already required to have raceway and
tow and fine violators, and authority to designate and
panel capacity to support future installation of Level
enforce similar restrictions on on-street parking as well
2 chargers or receptacles; under the CALGreen Code
under AB 1452 (Muratsuchi, 2017).
voluntary provisions a dedicated circuit including
208/240-volt wiring must be installed as well. These
residential EV infrastructure building codes align with
state policies, including AB 2565 (Muratsuchi, 2014)
and AB 1796 (Muratsuchi, 2018), which empower
renters to deploy EVSE on the properties where they
reside by reducing the practical barriers for them
hotels, and motels with less than 20 dwelling units or to do so.
guestrooms be EV Capable and include EV charging
infrastructure in at least 10 percent of parking
spaces, and 25 percent of total parking spaces be
equipped with low power Level 2 EV receptacles (“EV
Ready”). For newly constructed multifamily dwellings,
hotels, and motels with 20 or more dwelling units or
guestrooms, 10 percent of the parking spaces must
be EV Capable, 25 percent of parking spaces must
be EV Ready, and 5 percent of total parking spaces
must be equipped with Level 2 EVSE (Electric Vehicle
Supply Equipment). The 2022 CALGreen Code also
recognizes the use of automated load management
systems (ALMS) when receptacles or chargers are
installed beyond the mandatory minimum.

For some additions and permitted alterations of

parking facilities in existing multifamily dwellings, 10
percent of total parking spaces added or altered
must be equipped with EV Capable infrastructure.

The 2022 CALGreen Code repealed EV Capable

requirements in the Voluntary Tier 1 and Tier 2
measures. The Voluntary Tier 1 measure for new
multifamily, hotels, and motels requires that 35
percent of the total number of parking spaces
be equipped with low power Level 2 EV charging
receptacles, and 10 percent of parking spaces to
be equipped with Level 2 EVSE (for projects with
20 or more dwelling units). Tier 2 measures include
a requirement for 40 percent of parking spaces to
Image courtesy of the California Energy Commission
be equipped with low power Level 2 EV charging

14 ELECTRIC VEHICLE CHARGING STATION PERMITTING GUIDEBOOK | SECOND EDITION

In addition, CALGreen requires that in non-residential charging outputs from the electric vehicle charging
occupancies, 25 percent of the EV Capable spaces, station. How much power each vehicle receives in a
infrastructure only, be provided with Level 2 EVSE. reduced output scenario depends on the complexity
Two tiers of the voluntary CALGreen requirements of the charging management technology, the
increase these levels to 30 percent and 45 percent, charging patterns, and the desired charging
respectively. behaviors. In the simplest set-up, each car’s charging
rate would be reduced equally, but there are also
Local governments play a critically important role in more adaptive methods available, such as deploying
EV infrastructure building code development and batteries to augment power flow, allowing drivers
implementation. As of publication, over 20 California to indicate when they will need their vehicle fully
jurisdictions have exercised their authority to exceed charged, and/or modulating charging percentages
state minimum code requirements by adopting in real time to ensure that drivers with shorter dwell
higher EV infrastructure requirements to align with times will get proportionately higher charging rates
California’s ZEV adoption goals. Local codes range even in a reduced capacity scenario.
from adoption of CALGreen voluntary tiers to codes
that require EV charging electrical infrastructure
at one parking space per multifamily dwelling
unit (Menlo Park and Palo Alto) or require a mix of
dedicated circuits for some spaces and specified
levels of EV charging electrical infrastructure for
all remaining parking spaces (Oakland and San
Francisco). Local agencies can also ensure that Creative Strategies to Get Electricity to
local permitting and inspection staff are trained More Spaces
and prioritize implementing these codes, whether
it is the statewide minimum or more ambitious local
The City of Vancouver, British Columbia, is the
requirements.
international leader for combining charging
management with building code requirements.
In addition to increasing the number of parking
Vancouver has adopted a requirement for 100
spaces with EV infrastructure, local enforcement
percent of parking spaces in multi-unit dwellings to
agencies can harmonize with state accessibility be EV-ready but does not require the site to have
requirements, where applicable, so that EV electrical capacity to charge vehicles at 100 percent
Capable and EV Ready spaces can be built out of spaces at full power at any given time. Rather,
into EV charging spaces without conflicting with the Vancouver’s requirements allow for the use of charging
accessibility requirements in Title 24 Chapter 11B (see management software or hardware, achieving a high
level of plug-in electric vehicle readiness while not
for example Fremont, Oakland, and San Francisco
requiring exceedingly large electrical infrastructure
building codes) that are described later in this
upgrades.
Guidebook. Requirements such as accessible routes
and slopes can be designed into new construction The City of Oakland’s EV-readiness ordinance, which
requires panel capacity to charge 20 percent of spaces
but are much harder to change later.
at new multi-unit dwellings at 40 amps, also explicitly
One of the latest building code innovations is allows for the use of charging management to increase
the number of spaces served.32
the combination of voluntary tiers with charging
management software or hardware to get more
chargers out of a given amount of electrical
capacity—effectively reaching more spaces.
Automated Load Management Systems (ALMS), also
known as load sharing, allows vehicles at multiple
spaces to share a given amount of electrical panel
capacity, allowing more vehicles to charge with
less cost. Depending on the load management
level (panel or circuit breaker level), one or multiple
electric vehicles can receive full charging output
from the electric vehicle charging station, up to the
electrical capacity. Once the electrical capacity is
32 For further information, see the City of Oakland’s fact sheet on the
reached, the connected vehicles receive reduced ordinance.

SECOND EDITION | ELECTRIC VEHICLE CHARGING STATION PERMITTING GUIDEBOOK 15

Curbside Charging If a city does not have existing infrastructure to
leverage, or if cost issues are less of a constraint
Some local jurisdictions are implementing curbside compared to other priorities, installing curbside
charging programs (i.e., Level 2 or DCFC charging chargers on new infrastructure could help a city
stations on-street in the public right of way). While this achieve its goals to serve drivers in various areas of
is not currently a prominent strategy in California, it its territory.
may be a promising option, especially for providing
charging opportunities for residents of multi-family • Level 2 pole-mounted: the station is mounted
housing when off-street parking is limited, advancing on a newly constructed pole (also referred to as
rideshare vehicle electrification, and providing more a pedestal).
equitable distribution of infrastructure. While curbside
• Curbside DCFC: the DC fast charger is installed
chargers have many configurations and applications,
directly on top of the curb without necessarily
they can be generally categorized as follows:
leveraging any additional existing infrastructure.
(1) Level 2 stations or DC fast chargers that (2) are
either attached to existing infrastructure or installed Technically any charger can be installed on the curb,
on entirely new infrastructure. so it is important to deploy chargers that are truly
“fit for purpose” for parallel parking at the curb. A
Installing curbside chargers on existing infrastructure
charger that is “fit for purpose” for the curb takes into
could potentially save costs, because civil engineer-
consideration proper height and cable length, proper
ing work to do trenching and wiring, typically the
setback to avoid damage from snowplows and trash
costliest part of charger installations, can be avoided
trucks (if applicable), and unit display angles and
entirely. However, this is highly site specific and
specifications to make it more user friendly.
not all utilities in California currently offer all
curbside applications. Because the statewide accessibility regulations
promulgated by the Division of the State Architect
Existing infrastructure configurations include:
(DSA) in the California Building Codes do not apply
• Level 2 pole-mounted: the station is mounted to an to public rights of way, there are no statewide
existing pole, typically a utility-owned pole, using regulations on accessibility for curbside charging.
a mounting bracket. Pole-mounted chargers have However, accessibility must still be provided
the potential to save between 55 and 70 percent under state and federal law. It is up to each local
of installation costs. Example: National Grid, with government to determine what requirements
the City of Melrose in Massachusetts, mounted 16 charging on public rights of way must meet in order
chargers on its utility poles. 33 to be accessible. AHJs may refer to the existing
accessibility regulations as general guidance but
• Level 2 streetlight-mounted: the station is mounted may also develop their own criteria for equivalent
to an existing streetlight using a mounting bracket. facilitation for compliance with state and federal law.
Streetlights must typically have LED lighting to
also power the station. Mounting chargers on There are several different ownership models for
streetlights has the potential to save approximately curbside chargers, including:
the same amount on installation costs as pole-
• City-owned: the city owns the charger, with
mounted chargers, but this is dependent on
maintenance and operations work typically
whether the streetlight needs upgrades or not.
provided by the charging network. Example:
Example: The City of Los Angeles has deployed
The City of Montreal has deployed nearly 1,000
approximately 200 Level 2 stations mounted on its
FLO Level 2 pole-mounted chargers on new
streetlights. 34,35
infrastructure.
• Level 2 or DCFC connected to an underground
vault: the station is connected to utility equipment
installed in a subterranean room that is typically
accessible via the street or sidewalk.

• DCFC connected to a transformer: the station is 33 For further information, see the City of Melrose and National
connected to an adjacent transformer, ensuring Grid announcements.

sufficient electrical capacity. 34 For further information, see the City of Los Angeles Bureau of
Street Lighting.

35 Note: streetlight service in PG&E service territory is Level 1

16 ELECTRIC VEHICLE CHARGING STATION PERMITTING GUIDEBOOK

Image courtesy of FLO

• Utility-owned: the utility owns the charger, with process online that describes the process, makes all
maintenance and operations typically divided permit application forms available and details all
between the utility and the charging network. information needed for permits to be reviewed and
Example: Portland General Electric installed approved is critical to making it easier and simpler
and owns two pole-mounted chargers on its for charging vendors to engage local governments. 39
infrastructure. 36 Reducing parking rates can encourage drivers to
use curbside chargers more, creating consumer
• Third-party ownership (charging company): familiarity and buy-in with the technology. Feasibility
the charging company owns the charger and assessments will help a city determine which
also owns operations and maintenance; the applications are most appropriate given its goals and
deployment is typically funded in part by a city, constraints and which deliver the best results. Early
utility, or a public incentive program. Example: site selection work can provide clarity to charging
The City of Sacramento has deployed 12 chargers, companies regarding which curbside application a
owned and operated by EVgo, along the curb at city wants to prioritize, allowing a more streamlined
three sites. 37 and collaborative process to deploy stations quickly.
• Hybrid ownership: Some combination of the Early collaboration with a local utility can also help
harging company, utility, or city owns parts of the inform a city’s site selection process.
charger and its make-ready infrastructure and The best practices for curbside charging are far
carries out support and maintenance. This can ranging and highly dependent on the type of
help spread costs across multiple parties should charger being deployed. However, there are many
available funding be a limitation. Example: The universal best practices that can be applied to most
New York City Department of Transportation, its types. For established best practices for each phase
utility Con Edison, and the charging provider FLO of the deployment, reference Part 8: Definitions and
share ownership of 120 Level 2 pole-mounted Additional Resources.
curbside stations on new infrastructure. 38

Curbside charging could play a role in providing

access to charging for those who live in residences
without off-street parking. There are a number 36 For further information, see Portland General Electric Clean
Energy Choices.
of policy options local jurisdictions can adopt to
37 For further information, see the City of Sacramento’s EV Charging Pilot.
accelerate curbside charging deployment. Setting
38 For further information, see NYC DOT and Con Edison.
a curbside charging deployment goal can signal
39 For example, see Washington District Department of Transportation
interest to the private market and attract investment and Pepco’s established right of way charging permitting process:
in new infrastructure. Establishing a permitting Electric Vehicle Charging Station Program | ddot ([Link])

ELECTRIC VEHICLE CHARGING STATION PERMITTING GUIDEBOOK 17

Images courtesy of EVgo and Electrify America
18 ELECTRIC VEHICLE CHARGING STATION PERMITTING GUIDEBOOK | SECOND EDITION
 PART 03:

Accessibility

Providing accessibility to plug-in electric vehicle Background

charging stations requires advancing two of California’s
key values: accessibility to goods and services for all and Federal Law
the growth of an equitable clean mobility market. With
the largest zero-emission vehicle market in the United Providing accessibility at public plug-in electric
States and a long history of firsts in providing accessibility, charging stations has always been required under the
California is leading the nation in both contexts, and federal Americans with Disabilities Act. The Americans
most importantly, at their intersection. with Disabilities Act includes construction standards
for accessible design that apply to all types of public
Accessibility has always been required at plug-in electric accommodations including privately-owned facilities
vehicle charging stations (as with all goods or services that are open to the public and publicly-owned
available to the public) under the federal Americans facilities. The scope of the Americans with Disabilities
with Disabilities Act. As of January 1, 2017, California Act provides broad coverage intended to prohibit
became the first state in the nation to have specific discrimination against individuals with disabilities
accessibility standards for electric vehicle charging in all areas of public life, including jobs, schools,
stations in its building code. As a result, AHJs and station transportation, and all publicly-owned and privately-
developers are on the front lines of implementation owned places that are open to the general public.40
of these specific requirements. After years of careful
development, the challenge and responsibility rests with The Americans with Disabilities Act is the overarching
all parties involved in plug-in electric vehicle charging applicable law. When a benefit or service is provided,
station development to successfully implement the it must be provided in an accessible manner. For the
specific requirements, collect lessons learned along the application and scope of construction standards in
way, and work with the local jurisdictions to problem the Americans with Disabilities Act, it is the Division
solve and provide accessibility for this technology. of the State Architect’s (DSA) role to incorporate
these requirements for accessibility into the California
This section of the Guidebook is not intended to Building Code (CBC), Part 2, Title 24, California Code
be consulted in lieu of the specific requirements in of Regulations.
regulation, which can be found in the California Building
Code. Rather, the purpose of this section is to provide
context, summarize the code requirements, and
highlight examples of implementation success thus far
across California. It is critical for all parties involved to
read and adhere to the applicable code requirements 40 Title II of the Americans with Disabilities Act requires all state and
local governments to give individuals equal opportunity to engage
as the primary and final resource when designing with services and opportunities provided. Title III of the Americans
for accessibility. with Disabilities Act requires access to all public accommodations.
California’s electric vehicle charging station accessibility regulations
in the California Building Code cover public accommodations, public
buildings, commercial buildings, and public housing.

SECOND EDITION | ELECTRIC VEHICLE CHARGING STATION PERMITTING GUIDEBOOK 19

The 2010 Americans with Disabilities Standards • Stakeholder Engagement: The formal regulatory
for Accessible Design do not include scoping process provides a venue for all stakeholders
requirements related to electric vehicle charging. to participate in the development of building
Beginning with the 2016 CBC, DSA has incorporated standards.
specific scoping and technical requirements for
Electric Vehicle Charging Stations in California to Regulation Development
assure that programs and benefits provided by state
With the need for specific regulations identified, DSA
and local government entities, as well as goods
initiated a transparent, multi-year public process
and services provided by public accommodations
to develop building standards for accessibility at
and commercial facilities meet the requirements
charging stations. In September 2014, DSA convened
and intent of the Americans with Disabilities Act,
a working group to discuss accessibility needs
California’s Unruh Civil Rights Act, Disabled Persons
for charging stations and inform the regulatory
Act, and other state law. In July 2022, the U.S.
process. The working group included an array of
Access Board published Design Recommendations
stakeholders including individuals with disabilities,
for Accessible Electric Vehicle Charging Stations.
disability advocates, access professionals, building
However, these recommendations have not
officials, architects, electric vehicle charging station
been adopted by the Department of Justice as
manufacturers, electric utility companies, building
requirements and are not currently enforceable
industry representatives, electric vehicle advocates,
in California.
and state agency representatives. The working group
California’s Early Process and Need for convened for a series of meetings (eight in total) over
the course of approximately six months to discuss
Specific Requirements
accessibility options specific to electric vehicle
During the development of the ZEV Community charging stations.
Readiness Guidebook in 2013, accessibility for plug-in
Taking the feedback from the working group, DSA
electric vehicle charging stations emerged as a key
drafted the accessibility building standards which
issue requiring additional focus and discussion. As
were initially submitted to the California Building
a result, in parallel to the ZEV Community Readiness
Standards Commission (CBSC) for rulemaking in June
Guidebook process, DSA and the Office of Planning
2015. In August 2015, the regulations entered a formal
and Research jointly worked with stakeholders to
public comment process. DSA then analyzed the
develop best practice guidance for accessibility
comments, amending the regulatory rulemaking,
at charging stations as an interim guidance
as appropriate, and submitted the final building
document. This Guidebook expanded upon the
standards for approval to CBSC at the end of 2015.
very first California guidance document on this topic
published by DSA in 1997. In January 2016, the building standards were
approved by CBSC commissioners. In July 2016, the
Although the initial guidance document was helpful
building standards were published by the CBSC and
and provided detailed assistance for charging
became effective on January 1, 2017.
stations being developed at the time, it soon became
clear that a full regulatory process should be The electric vehicle charging station accessibility
undertaken to develop specific building standards in provisions for public facilities, public
California for the following reasons: accommodations, and commercial facilities are
located in Part 2 of the CBC, Chapter 11B and are
• Projected Growth: California’s zero-emission
promulgated by DSA. California’s accessibility
vehicle market is expected to increase rapidly in
building standards for electric vehicle charging for
coming years and with such significant growth
privately-owned covered multifamily dwellings are
expected, developing specific standards for
promulgated by the Department of Housing and
accessibility will ensure that infrastructure built for
Community Development.
the transportation system of the future is accessible
to all and accessible in a consistent manner, to the Part 2 of the CBC is updated during two code cycles,
extent possible. the model code adoption cycle (Triennial cycle) and
an intervening code cycle eighteen (18) months after
• Clarity: With specific building standards formalized
the triennial adoption cycle. The current applicable
in code, station developers and AHJs can ensure
code is the 2019 CBC which includes amendments
that projects in their jurisdiction comply with
requirements to provide accessibility.

20 ELECTRIC VEHICLE CHARGING STATION PERMITTING GUIDEBOOK | SECOND EDITION

from the intervening code cycle. On January 1, 2023 States Access Board:
the adopted 2022 CBC will become effective.
1. Electric vehicle charging is a service provided by
The regulations included in the CBC are minimum the facility owner or public entity, and therefore
standards which cannot be reduced by any local must be accessible to individuals with disabilities.
amendments. It is possible for local jurisdictions to
adopt more stringent standards. 2. An electric vehicle may not need to charge
every time it is parked, so public and common
use charging stations are charging spaces, not
Regulatory Requirements parking spaces.

(High-Level Summary) 3. While an electric vehicle needs to be parked to

charge, charging (not parking) is the primary
California’s requirements for electric vehicle
purpose of a charging station.
charging station accessibility at public housing,
public accommodations, commercial facilities, and Because parking and charging are separate and the
public buildings are found in the current edition of two functions have separate scoping requirements,
the California Building Code (California Code of they are also located in different sections of the
Regulations, Title 24, Part 2). The CBC is typically used building code. Scoping provisions for accessible
in three parts: 1) definitions, 2) scoping provisions ( parking are located in the California Building Code
what type of spaces and how many are required) Chapter 11B, Section 11B-208. Scoping provisions for
and 3) technical requirements (where exactly the accessible charging are located in the California
spaces are and how to make them accessible). For Building Code Chapter 11B, Section 11B-228.3.
electric vehicle charging, the three main parts are in
the California Building Code as follows:41

1. Definitions: Chapter 2, Section 202

2. Scoping: Chapter 11B, Division 2, Section 11B-228.3

Electric Vehicle Charging Stations Charging vs. Parking
3. Technical: Chapter 11B, Division 8, Section 11B-812
Electric Vehicle Charging Stations It is easy to confuse “charging” and “parking” when
applying local zoning requirements for the number
The remainder of this section will outline the major of parking spaces. Within the context of zoning
requirements of the accessibility standards for electric requirements, cities or counties should help enable
vehicle charging in California. This is not a copy of charging projects by clarifying that charging stations
the actual code and any station developers or local count as one or more parking spaces, as required by
law (Vehicle Code Section 22511.2 and Government
AHJs that are planning, designing, or approving
Code Section 65850.71). This approach ensures that
actual sites must comply with the regulations in
charger installation does not take a site out of zoning
the California Building Code. This is intended to compliance. In contrast, the California Building Code
aid understanding of the core requirements of the and the California Green Building Standards Code have
regulations for a general audience. specific requirements that address charging stations as
charging stations, because accessible parking stalls
(i.e., the accessible parking stalls that are required
Scoping Provisions at any public parking location) have their own set of
separate regulatory provisions.
Scoping provisions broadly determine how many
charging spaces must be accessible. The required
number of accessible charging spaces is based
on the total number of charging spaces provided,
for each combination of charging level and EV
connector type integral to the EV charger and
the type of accessible spaces required (standard
accessible, van accessible, ambulatory, or drive
through). California’s scoping provisions are consistent
with three key determinations made by the United 41 The California Building Code can be accessed at:
[Link]

SECOND EDITION | ELECTRIC VEHICLE CHARGING STATION PERMITTING GUIDEBOOK 21

For scoping provisions related to charging spaces, To demonstrate how the table is used, let’s consider
the number and type of accessible charging spaces two different examples:
required at a site are determined by the total number
of charging spaces at a facility. CBC amendments • Facility with three electric vehicle charging
that took effect July 1, 2021, clarify that each spaces. A facility with three charging spaces falls in
combination of charging level and EV connector the range of “1-4” within the first column on the left
type shall be considered a facility, and each facility (“Total Number of EVCS at a Facility”). Follow the
is considered separately for purposes of determining 1 to 4 range across the row to determine what is
the number and type of accessible charging spaces required. For a facility with three charging spaces,
that must be provided. Table 1 provides a guide that one van accessible space is required and no
enables station developers to determine the required standard accessible and ambulatory accessible
number and type of accessible EVCS. Accessible spaces need to be provided. In this example,
EVCS types include van accessible, standard because the total number of EVCS at a facility is
accessible, and ambulatory. four or fewer, the regulations do not require the
van accessible space to be marked with an ISA.
A sign with an International Symbol of Accessibility
(ISA) is not required at any EVCS for facilities with four • Facility with 22 electric vehicle charging spaces.
or fewer total charging spaces. A sign with an ISA is A facility with 22 charging spaces falls in the
required at each van accessible EVCS when there range of “5-25” within the first column on the left
are five or more total EVCS at a facility. Additionally, (“Total Number of EVCS at a Facility”). Follow the
a sign with an ISA is required at each standard 5 to 25 range across the row to determine what is
accessible EVCS when there are 26 or more total required. For this facility with 22 charging spaces,
EVCS at a facility. A sign with an ISA is not required one van accessible space and one standard
and should not be provided at ambulatory EVCS. accessible space are required and no ambulatory
accessible spaces need to be provided. In
this example, the regulations require the van
accessible space to be identified with ISA signage,
but the standard accessible stall is not required to
be identified with an ISA.

Table 1: Required number and type of accessible spaces

(Table 11B-[Link] from the 2019 California Building Code, Chapter 11B, Section 11B-228.3)

Total Number of EVCS Minimum Number

at a Facility1 (by type of EVCS Required to Comply with Section 11B-812)1

Van Accessible Standard Accessible Ambulatory

1 to 4 1 0 0

5 to 25 1 1 0

26 to 50 1 1 1

51 to 75 1 2 2

76 to 100 1 3 3

101 and over 1, plus 1 each 300 or fraction 3, plus 1 each 60, or fraction 3, plus 1 each 50, or fraction
thereof, over 100 thereof, over 100 thereof, over 100

1 Where an EV charger can simultaneously charge more than one vehicle, the number of EVCS provided shall be considered equivalent to the number
of electric vehicles that can be simultaneously charged.

22 ELECTRIC VEHICLE CHARGING STATION PERMITTING GUIDEBOOK | SECOND EDITION

An electric vehicle charger that has two ports
and can simultaneously charge two vehicles (and
therefore there is a charging space available for
each), is counted as two charging spaces. 42 If Best Practices to Promote
the charger has multiple connectors (like a DCFC
Accessibility Use
with both a CHAdeMO and a CCS connector, for
example), but can only charge one car at a time, it is
counted as one charging space despite technically Signage plays a key role in the success of a location by
making parking requirements and recommendations
having more than one charging port. The count is
clear to users, especially since each site may be
not based on the number of chargers but rather
different. Federal and state laws require accessible
the total number of vehicles that the chargers can parking spaces with an ISA to be reserved for disabled
simultaneously serve. persons with the appropriate parking placard or license
plate. However, for accessible EV charging spaces,
When new charging stations are added to a site local jurisdictions may have their own local ordinances
with existing EVCS, the requirements of Section 11B- that allow for variation with sign requirements and
812 shall apply only to the new EVCS. Alterations to regarding whether the spaces are reserved.43
existing EVCS shall comply with the requirements of Depending on a jurisdiction’s local laws and
Section 11B-228.3 scoping. enforcement, “use last” signs may indicate that
accessible charging spaces may be used by any driver
but should be used last by non-disabled drivers. The U.S.
Technical Requirements Access Board has designed the examples below, which
would not require the accessible charging spaces to
With the number and types of accessible spaces be reserved exclusively for disabled persons with a
required identified, we turn to the technical parking placard or license plate. While these examples
requirements to determine how the accessible do not contain the ISA, similar signs could be used in
sites should be constructed to provide accessibility. combination with the ISA if authorized by the local
jurisdiction and if all other related state requirements
The following text highlights the differences in
are met, when the ISA is required for accessible EV
requirements between the spaces. Please note
charging spaces.
that the language and code citations below are
for reference only and not a replacement for the
regulations in the California Building Code. Please
refer to the California Building Code for all applicable
requirements.44

There are four types of accessible spaces (defined

below), three of which were introduced above in the
Scoping Provisions section, and each has different
requirements set by the California Building Code,
Chapter 11B, Section 11B-812.6. All four types of
accessible EV spaces must be 18 feet (216 inches/5486
mm) minimum in length and marked with letters that
are at least 12 inches (305 mm) high that read, “EV
CHARGING ONLY.” Vertical clearance of at least 98
inches (8 feet 2 inches/2489 mm) must be provided
and overhead cable management systems cannot
obstruct required vertical clearance. Please note
there are two exceptions under Section 11B-812.6:

1. Where the long dimension of vehicle spaces

is parallel to the traffic flow in the adjacent
vehicular way, the length of vehicle spaces shall
be 240 inches (6096 mm) minimum. 42 It is worth noting that a dual port charger can be positioned to service
both an accessible and a standard charging station.

2. Vehicle spaces at drive-up EVCS shall be 240 43 Existing and new facilities have differing access requirements, which
may also allow for sign variation.
inches (6096 mm) long minimum and shall not be
44 The California Building Code can be accessed at:
required to be marked to define their width. [Link] Refer to Chapter 11B.

SECOND EDITION | ELECTRIC VEHICLE CHARGING STATION PERMITTING GUIDEBOOK 23

The below text is included to increase general are required to be 9 feet (108 inches/2743 mm)
understanding of basic accessibility requirements for minimum in width, and 18 feet (216 inches/5486 mm)
each type of charging space. Again, please refer minimum in length. The access aisle is required to be
to the California Building Code for all applicable 5 feet (60 inches/1524 mm) minimum width, located
requirements. on either side of the vehicle.

Van Accessible Spaces Ambulatory Spaces

Van accessible spaces are three feet wider than An ambulatory space is a slightly wider charging
standard accessible spaces to accommodate a space that gives a little additional room to maneuver.
van equipped with a ramp or lift. Van accessible Ambulatory spaces are required to be 10 feet (120
spaces are required to be 12 feet (144 inches/3658 inches/3048 mm) minimum in width and 18 feet (216
mm) minimum in width and 18 feet (216 inches/5486 inches/5486 mm) minimum in length. An adjacent
mm) minimum in length. The access aisle, which access aisle is not required.
is a no-parking zone wide enough for the use of a
wheelchair, is required to be 5 feet (60 inches/1524 Drive-Up Spaces
mm) minimum width and be located on the
A drive-up space is a space for an electric vehicle
passenger side except where four or fewer total
where charging is limited to 30 minutes maximum.
EVCS are provided in which case the access aisle for
The site is designed so that the driver approaches the
non-angled van accessible spaces may be located
station moving forward, stops to charge, and then
on either the driver or passenger side of the vehicle
continues moving forward to leave the space. The
space. Two vehicle spaces or one parking and one
design is similar to a traditional gas station. Drive-up
electric vehicle charging space are permitted to
spaces are required to be 17 feet (204 inches/5182
share a common access aisle. The access aisle
mm) minimum in width and 20 feet (240 inches/5182
shall have the words “NO PARKING” painted on the
mm) minimum in length.
surface at a minimum of 12 inches (305 mm) in height.
Where one parking space and one electric vehicle
charging space share an access aisle, the access Sign Requirements
aisle shall comply with Section 11B-502.33.
• Where four or fewer total charging spaces are
Standard Accessible Spaces provided at a site, none of the spaces are required
to be identified with an ISA.
Standard accessible spaces are provided with an
adjacent access aisle. Standard accessible spaces • Where five to 25 charging stations are provided at
a site, one van accessible space is required to be
identified with an ISA.

• When 26 or more charging stations are located at

a site, all van accessible spaces are required to be
identified with an ISA. While this may seem like a
large requirement, it is important to remember that
only a site with 101 or more charging stations will
be required to have more than one van accessible
charging space.

• When 26 or more charging stations are located

at a site, all standard accessible spaces must be
identified with an ISA. For perspective, a site with
100 charging stations would require three standard
accessible spaces.

• Ambulatory spaces are not required to be

identified with an ISA.

• Drive-up spaces are not required to be identified

Image courtesy of EVgo with an ISA.

24 ELECTRIC VEHICLE CHARGING STATION PERMITTING GUIDEBOOK | SECOND EDITION

Table 2: Requirements for accessible parking spaces by type

use is limited to
Van Accessible Standard Ambulatory 30 minutes
Drive-up
Accessible
maximum.
Width
Purpose 12Wider
feetcharging
(144 space 9 Charging
feet (108space with 10 feetwider
Slightly (120charging 17 feet
Similar to (204
a gas station
inches)
with adjacent access
aisle to accommodate
inches)
adjacent access aisle
inches)
space
inches)
– drive in and drive
out, moving forward.
Access aisle Yes,
van on
withpassenger
ramp or lift Yes, on either No No
Per definition in CBC

side (can be on side, marking Chapter 2, use is

limited to 30 minutes
either side of non- required maximum.

Width
angled spaces
12 feet (144 inches) 9 feet (108 inches) 10 feet (120 inches) 17 feet (204 inches)
when four or
Access aisle fewer
Yes, ontotal
passenger side Yes, on either side, No No
charging station
(can be on either side
of non-angled spaces
marking required

facilities
when fourare or fewer
provided),
total charging station
facilities are provided),
marking required
marking required

Identify with an When 5-25 When 26+ No No

Identify with an ISA sign? When 5-25 charging When 26+ charging No No
ISA sign? charging stations,
stations, identify one; charging stations,
stations, identify all
identify one;
when 26+, identify all
van accessible spaces
identify all
standard accessible
spaces
when 26+, standard
identify all van accessible spaces
accessible spaces
Sample EVCS Layouts
Sample
Figure EVCS
1: Two EVCSLayouts
= one van accessible EV space required

Figure 1: Two EVCS = one van accessible EV space required

Figure 2: Five EVCS = two accessible EV spaces required

SECOND EDITION | ELECTRIC VEHICLE CHARGING STATION PERMITTING GUIDEBOOK 25

Figure 2: Five EVCS = two accessible EV spaces required

Figure 3: 26 EVCS = three accessible EV Spaces required

Figure 3: 26 EVCS = three accessible EV Spaces required

Figure 3: 26 EVCS = three accessible EV Spaces required

Figure 4: Curb Cut Design

Figure 4: Curb Cut Design

26 ELECTRIC VEHICLE CHARGING STATION PERMITTING GUIDEBOOK | SECOND EDITION

Figure 4: Curb Cut Design

Some companies have developed designs which If the electric vehicle charging station is located in a
are intended to comply with California Building parking lot that serves a particular building or facility
Code requirements for electric vehicle charging such as a business, shopping center, or school, all
station accessibility with the practical requirements accessible charging spaces must be located on
of CCS charging equipment. 45 Many sites do not an accessible route to an accessible entrance of
support head-of-stall charging station locations (as that building or facility. If the charging station does
shown in Figures 1-3) and instead must be installed not serve a particular facility, e.g., if it is a general-
adjacent to a stall in an end island. Volta’s “curb cut” purpose parking garage that is not connected to any
design (Figure 4) positions the CCS charger near the particular establishment, an accessible route must be
driver side front while still allowing for an accessible provided to the public way, such as to the sidewalk.
route and access to the equipment outlined in CBC There must be an accessible route between the
Chapter 11B-812. The “curb cut” design is intended to vehicle space and the charger. Charging cables may
allow for easier and more convenient use of a CCS not obstruct the accessible route. 46
charger by placing the charger closest to the most
common CCS charging port location. It allows the Unlike accessible parking spaces, accessible electric
charging cables to be kept shorter, creating an easier vehicle charging spaces are not required to be
to use and safer to operate station that is less prone to on the shortest accessible route to the accessible
cable damage. entrance of the facility. While an accessible route
is required to connect accessible electric vehicle
charging stations to an accessible facility entrance,
Path of Travel Improvements the length of the accessible route is not specified;
therefore, station developers and facility owners have
and Accessible Route flexibility to locate charging stations throughout a
Path of travel improvements and accessible route are parking facility.
two separate concepts.

Accessible Route
Per CBC Chapter 2, an accessible route is defined
as a continuous unobstructed path connecting 45 Note: alternative designs must be approved by the local jurisdiction
accessible elements and spaces of an accessible in which they are deployed. DSA does not provide certification of
compliance for any products.
site, building or facility that can be negotiated by
46 Note: Site specific issues and opportunities should be addressed by
a person with a disability using a wheelchair. An working with the local building official. DSA is available for consultation
accessible route must meet the requirements of at the request of the local building official. Contact information is listed
at the end of this section.
Division 4 of Chapter 11B of the CBC.

SECOND EDITION | ELECTRIC VEHICLE CHARGING STATION PERMITTING GUIDEBOOK 27

 When alterations or additions are made to existing
buildings or facilities, path of travel improvement
requirements apply. However, in the case of electric
vehicle charging stations, the full path of travel
improvements, including restrooms, drinking fountains
signs etc., are required only at those facilities where
vehicle fueling, recharging, parking, or storage is a
primary function, such as parking garages or fueling
stations. At such facilities, if the building entrance,
bathrooms, telephones, and drinking fountains are
not in compliance with applicable accessibility
Image courtesy of Electrify America regulations, these elements will need to be upgraded
to comply pursuant to CBC Chapter 11B-202.

At facilities where vehicle fueling, recharging, parking

or storage is not the primary function, the parts of
Locating Accessible Chargers on an “path of travel” located within the building served by
Accessible Route the parking area, are not required to be improved as
part of the addition of electric vehicle charging. Per
In a best-case scenario, accessible charging locations CBC 202.4 Exception #10, path of travel requirements
can be located adjacent to accessible parking spaces are required to the primary entrance to the building,
– which may make the accessible route as short as not to exceed 20 percent of the cost associated to the
possible. This arrangement potentially enables a installation of the electric vehicle charging spaces.
connection to the existing accessible route provided
from existing accessible parking.

For a variety of reasons (space, power supply, rights of Technical Infeasibility and
way, landowner preferences, etc.), accessible charging
will not always be able to be placed next to accessible
Unreasonable Hardship
parking. In these cases, the station developer or facility
“Technical infeasibility” and “unreasonable hardship”
owner should work with a design professional and the
are regulatory terms defined in the California Building
local building official to determine the best location of
electric vehicle charging stations for the project, taking Code. If legal or structural constraints make it
site constraints into account. When locating accessible impossible to comply with accessibility regulations, a
electric vehicle charging spaces, it is important to station developer may request a finding of technical
remember that they must be on an accessible route but infeasibility from the local building official. Examples
are not required to be on the shortest accessible route. of technical infeasibility include scenarios where the
installation of electric vehicle charging space would
require the removal of a load-bearing column, would
require construction beyond the legal boundary of
the site, or if it is not possible to meet the minimum
height clearance in a parking garage. 47 If a technical
infeasibility is declared, station developers must
Path of Travel Improvements
provide equivalent accessibility or comply with
Per CBC Chapter 2, an accessible route is defined as requirements to the maximum extent feasible.
an identifiable accessible route within an existing site,
A finding of unreasonable hardship is when the costs
building or facility by means of which a particular
of compliance with path of travel improvements
area may be approached, entered and exited, and
would be so high as to make the project infeasible.
which connects a particular area with an exterior
In general, when a finding of unreasonable hardship
approach (including sidewalks, streets and parking
has been demonstrated to the enforcement entity,
areas), an entrance to the facility, and other parts
the cost of path of travel improvements can be no
of the facility. When alterations, structural repairs or
additions are made to existing buildings or facilities,
the term “path of travel” also includes the toilet and
47 Note: Site specific issues and opportunities should be addressed
bathing facilities, telephones, drinking fountains and by working with the local building official. DSA is available for
signs serving the area of work. consultation at the request of the local building official. Contact
information is listed at the end of this section.

28 ELECTRIC VEHICLE CHARGING STATION PERMITTING GUIDEBOOK | SECOND EDITION

lower than 20 percent of the construction cost. Given
the fact that path of travel improvements for the
installation of electric vehicle charging stations are
Understanding Accessible Route and Path
capped at 20 percent of the construction cost in the
of Travel in Simple Terms
California Building Code, unreasonable hardship
does not apply to electric vehicle charging station
projects. This aligns with the federal Americans with In all cases, new charger installation projects must
Disabilities requirement. provide an accessible route to an accessible building
entrance from the accessible charging spaces. Where
EVCS do not serve a particular building, an accessible
Exceptions route is required to an accessible entrance of the EV
charging facility. In either instance, this route is not
Within the types of properties that California Building required to be the shortest accessible route to the
entrance.
Code Chapter 11B regulations cover (public housing,
public accommodations, commercial facilities, Path of travel improvements (e.g., altering drinking
and public facilities), there are two cases where fountains, bathrooms, telephones, building entrances)
accessible charging is not required: are only required in specific circumstances if facilities
are not compliant and are limited to 20 percent of the
1. If the charging station is not available to the cost of the work directly associated with the installation
of the charging stations if the scope of the project is
general public and intended for use by a
limited to the installation of EVCS.
designated driver or vehicle (for example, public
or private fleet vehicles or an EVCS assigned
to a designated parking spot for a particular
employee).

2. In public housing, if the charging station is

intended for use by an electric vehicle owner or
driver that has an assigned parking space.

Required to do Full Path of Travel Improvements?

Chargers added to: Yes (only if elements are not No

compliant to current code)

Shopping Centers X

Restaurant Parking X

Event Parking X

Standalone DC Fast Charger Depot X

Gasoline Station X

Standalone Parking Garage X

Business Park Parking Lot X

SECOND EDITION | ELECTRIC VEHICLE CHARGING STATION PERMITTING GUIDEBOOK 29

Private Multifamily Housing also reference the federal Access Board’s Design
Recommendations for EVCS. 48
CBC Part 2, Chapter 11B does not include accessibility
building standards for specified private multifamily If you are a station developer, please review the
housing. Technical requirements for EV charging code in detail and if you have general questions
spaces or stations serving private multifamily housing about the regulations, please reach out to the local
can be found in CALGreen. The 2019 CALGreen Code jurisdiction. For site-specific questions about a project
(effective January 1, 2020) establishes an exception in development, the most helpful way to resolve
allowing private multifamily projects, constructed outstanding questions is to request that the local
for first occupancy after March 13, 1991, to meet enforcement authority contact the DSA directly.
accessibility requirements by designing the project
Emerging Challenges
in compliance with Chapter 11B. EV Ready spaces
with receptacles for EV charging or EV chargers in The electric mobility market is rapidly evolving:
privately funded multifamily development projects available charging speeds are increasing, wireless
shall comply with California Building Code, Chapter charging is poised to expand, car-sharing and
11A, Section 1109A, as applicable. EV station ridesharing are gaining popularity, more types of
developers should check with the local jurisdiction vehicles are being electrified, and autonomous
to determine whether housing is public or private, as vehicles could revolutionize the way people move.
only private housing is exempted. Public housing and These exciting developments can be constrained by
accommodations, including hotels and motels, must the reality that much of California’s building stock was
comply with Chapter 11B. constructed without anticipating the need to install
charging infrastructure or accommodate current
accessibility standards. The following issues highlight
Working Together to Achieve some of this inherent tension between an ideal
Accessibility accessible site configuration and on-site feasibility, as
well as the challenge of introducing new technology
Achieving accessibility at plug-in electric vehicle without the benefit of clear regulatory parameters.
charging stations is an ongoing process and
stakeholders are still refining best practices to provide In all cases below, the applicant should consult
accessibility for this quickly changing technology. with the local building official as early as possible to
To achieve both our accessibility and rapid station collaborate and find a workable solution.
development goals, feedback is critical.
As always, the DSA is available for consultation at the
First, all stakeholders should consult the current local building official’s request, but the decision rests
edition of the California Building Code and the suite with the local building official. Looking forward, DSA
of support materials available at the DSA website and the State of California are eager to receive input
(search “Electric Vehicle Charging Station” on the about on-the-ground solutions that can help other
DSA website). sites and inform regulation development as charging
infrastructure continues to expand.
The DSA website hosts a video titled “California
EVCS Accessibility” which expands on the material • Parking Garages. Many old parking garages in
provided in this Guidebook and can serve as training California were constructed before the Americans
material. All AHJ plan reviewers who review EVCS with Disabilities Act was passed and implemented,
projects, including Certified Access Specialists and and it may be technically infeasible to meet one
Building Officials, are encouraged to watch the video or more accessibility standards for a variety of
and refer to the associated slide decks. reasons. For example, in some garages, all spaces
meeting the technical requirements for surface
If you are a local jurisdiction/enforcement authority slope are already designated as accessible
and have questions about how to provide parking spaces or it might not be possible to
accessibility at plug-in electric vehicle charging create an accessible route that does not go
stations in California, please contact DSA’s Access behind cars.
Technical Assistance Help Line at (916) 445-5827. DSA
can provide resources to assist with your site-specific
interpretation in your jurisdiction as well as discussing
48 Note: these recommendations have not been adopted by the
general questions about the requirements. You may Department of Justice and thus are not enforceable.

30 ELECTRIC VEHICLE CHARGING STATION PERMITTING GUIDEBOOK | SECOND EDITION

• Multiple Charger Types. One site may host multiple
charger types, from Level 1 to Level 2 to various DC
fast chargers. The minimum number of required
accessible EVCS must be calculated based on A Note on Addressing Liability Concerns
the total number of chargers for each type of
charging facility (equipment). Each combination
Legal liability, as it relates to accessibility, remains
of charging level (such as: AC Level 1, AC Level 2, a legitimate concern for AHJs and property owners
DC Fast Charge) and EV connector type shall be alike. When liability concerns arise, it is important to
considered as a separate facility. remember that a building official can approve projects
by identifying and clearly articulating a code path to
• Providing Access to Curbside Charging. California justify and substantiate their decisions.
Building Code accessibility regulations do not
In other words, if it is technically infeasible to install
apply to the roadway, including on-street charging
charging that meets accessibility standards on a site,
in the public right of way. Local jurisdictions may charging stations can often still be installed. The key
have alternative enforcement procedures for is providing the maximum feasible accessibility with
projects in the public right of way. a clear code path that supports the building official’s
decision and recording the determination in the files of
• Car Sharing. Electric car sharing is either the enforcing agency.
being piloted or starting to take hold in a
variety of locations, improving mobility for
these communities. Charging for car-sharing
applications does not receive unique treatment
and still requires accessibility, but may necessitate
specific regulations in the future.
requirements are being implemented on the ground,
• Innovative Designs. The EV charging industry is collect lessons learned, and adapt through time.
rapidly evolving with new power levels, dispenser The end goal is to ensure that this technology, which
designs, and station layouts. Situations may arise will make up a growing percentage of California’s
where a new design provides for accessibility but vehicle fleet, is both accessible to all Californians and
is not consistent with specific code requirements. also rapidly installed to meet the growing demand.
If this occurs, a local building official may interpret
the accessibility regulations using equivalent If you are an enforcement official or charging station
facilitation (11B-103). However, such alternatives developer and you are witnessing recurring issues
must result in substantially equivalent or greater that are consistently creating challenges on the
accessibility and usability. ground for providing accessibility and/or meeting
station installation goals, please share your stories
• Angled Parking. Converting existing angled and insights with DSA. It is only with quality feedback
parking stalls to accessible charging stalls can and input that regulations can be properly adapted
present unique space challenges. In some with advancements in technology.
scenarios, as many as four angled parking stalls
would need to be used to meet the width and The process to amend the California Building Code
depth requirements for one accessible charger. requires a rigorous public process and extended
In these cases, the designer may propose an timeline, so it is important to share your feedback with
alternative under equivalent facilitation (11B-103, DSA as early as possible. The process to address code
provided the solution provides for substantially changes begins two years before the effective date
equivalent or greater accessibility and usability) for of the new regulations. DSA accepts code change
review and approval by the building official. proposals on an ongoing basis and all proposed
amendments to the regulations must have the input
Implementation Lessons & of all stakeholders.
Updating the Code
Because the electric vehicle industry is rapidly
changing and California was the first jurisdiction to
create accessibility requirements for electric vehicle
charging stations, it is important to document how the

SECOND EDITION | ELECTRIC VEHICLE CHARGING STATION PERMITTING GUIDEBOOK 31

Images courtesy of the Bay Area Air Quality Management District and the City of Sacramento
32 ELECTRIC VEHICLE CHARGING STATION PERMITTING GUIDEBOOK | SECOND EDITION
 PART 04:

Permitting

In this section, we share requirements and best Charging Station Permit Streamlining Requirements
practices for station permitting to help AHJs & Best Practices) and is followed by a narrative
streamline their processes and station developers designed to communicate context and insights
submit effective applications. The section begins with collected from leading practitioners.
a summary table for AHJs (Table 3: Electric Vehicle

Table 3: Electric Vehicle Charging Station Permit Streamlining Requirements & Best Practices

AB 1236 and AB 970 Compliant Not AB 1236 and AB 970 Compliant

(EVCS Friendly) (Challenging to Deploy Charging)

Required Permit Streamlining Ordinance: Ordinance creating an expedited, No permit streamlining ordinance; and/or ordinances
streamlined permitting process for electric vehicle charging or practices that create unreasonable barriers to EVCS
by AB 1236 installation
stations (EVCS) including Level 2, direct current fast chargers
(DCFC), and wireless inductive charging has been adopted

Permit Checklist Online: Checklist of all requirements needed for No checklist for EVCS permitting requirements
expedited review posted on Authority Having Jurisdiction (usually a
city or county) website

Administrative, non-discretionary approval: EVCS projects that Permitting process centered around getting a
meet expedited checklist are administratively approved through discretionary use permit first
building or similar non-discretionary permit

Review limited to health and safety: EVCS projects reviewed with EVCS projects reviewed for aesthetic considerations
the focus on health and safety (including landscaping and screening) in addition to
building and electrical review

Electronic Application: AHJ accepts electronic signatures on Wet signatures required on one or more application forms
permit applications 49

No Permit Authority for Associations: EVCS permit approval not EVCS approval can be conditioned on the approval of a
subject to approval of an association (as defined in Section 4080 of common interest association
the Civil Code)

49 Note: if a city or county determines it is unable to accept electronic

signatures on all forms, the permit streamlining ordinance shall state
the reasons

SECOND EDITION | ELECTRIC VEHICLE CHARGING STATION PERMITTING GUIDEBOOK 33

 AB 1236 and AB 970 Compliant Not AB 1236 and AB 970 Compliant
(EVCS Friendly) (Challenging to Deploy Charging)

Required Single Corrective Action Notice: AHJ commits to issuing one New issue areas introduced by AHJ after initial comments
complete written correction notice detailing all deficiencies in an are sent to the station developer
by AB 1236
incomplete application and any additional information needed to
(continued) be eligible for expedited permit issuance

Required Permit Review Timelines: EVCS application reviewed for completeness AHJ does not have expedited permitting process for
within 5 or 10 business days (based on the size of the project), and EV applications – resulting in EV charging station permit
by AB 970 applications being deemed complete and deemed
approved or denied within 20 or 40 business days (based on the size of
the project)50 approved in each case where the jurisdiction has not
abided by the statutory deadlines

Parking Count Requirements: AHJ reduces the number of required EVCS installation projects trigger a parking count review of
parking spaces at the existing building hosting the station by the the station site host property
amount necessary to accommodate the EVCS (including chargers
and associated equipment) if the EVCS interferes with, reduces,
eliminates, or in any way impacts the required parking spaces for
existing uses

Best Permitting Process Online: Clear EVCS permitting process detailed on Permitting process not explained or available on AHJ
AHJ website website
Practice

Permit Ombudsman: ZEV Infrastructure permitting ombudsperson AHJ does not offer access to an expert who can support
appointed to help applicants through the entire permitting process station developers through the entire permitting process

Permitting & Inspection Guidance: Guidance documents for permitting Limited or no information online
and inspecting charging stations at single-family home, multifamily
home, workplace, public (L2 and DCFC), and commercial medium
and heavy duty posted on AHJ website

Pre-application Meetings: Pre-application meetings with Full permit package needs to be submitted to gain
knowledgeable AHJ staff are offered feedback from AHJ staff

Concurrent Reviews: Permit applications routed through one Permits sequentially routed through multiple Departments
Department. If multiple Departments are necessary, concurrent
reviews are made available for building, electrical (and planning, if
deemed necessary)

Integrated ZEV Planning: Planning for ZEVs and supporting infrastructure EV charging guidelines are not incorporated into planning
is incorporated and prioritized within documents such as the general documents
plan, capital improvement plan, climate action plan, and design
guidelines

Primary Use and Accessory Use Classification: EVCS are classified as an AHJ considers charging stations as fueling stations, leading to
accessory use to a site, not a traditional fueling station additional zoning review

Conditional Approvals: AHJ’s expedited EV permit review process AHJ does not encourage conditional approval of permits
encourages permit reviewers to conditionally approve permits (aka
“approved as noted”)

Understanding the Permit based on the processes and organizational structure

of the AHJ. If possible, these reviews are done
Process concurrently and AHJs and station developers should
continue to look for ways to save time and share
In California, EVCS permit applications are required
successes that can be emulated by others.
to be approved through a truncated and streamlined
permitting process. EVCS permit applications will
usually be administratively reviewed for compliance
with building, electrical, accessibility, and fire safety 50 Note: an application will be deemed complete and approved if the
regulations. The permit applications may also receive AHJ does not review the project in the specified timeframe or has not
made a finding, based on substantial evidence, that the EVCS could
public safety, structural, and engineering review have a specific adverse impact upon the public health or safety.

34 ELECTRIC VEHICLE CHARGING STATION PERMITTING GUIDEBOOK | SECOND EDITION

AHJs must evaluate the permit application within the submitter with one complete set of instructions for
required timelines (see Table 4) to determine whether revision. This is called a cycle, or round of comments,
all required documentation is attached, whether the and requires the submitter to revise and resubmit until
load calculations are correct, whether new electrical approval can be granted.
service will be required, whether all diagrams are
accurate, whether the proposed design will comply Once approval to build is granted, construction can
with the electrical code, whether the proposed begin. Depending on the type of installation, the site
charging layout is in accordance with the California may be visited by a building inspector one or more
Building Code accessibility regulations, and other times during the construction process, including
evaluation factors as deemed necessary to ensure after construction is finished for final approval. After
public health and safety. final approval from the AHJ and utility, the station is
eligible for commissioning and operation.
If the application package is deemed complete
and accurate and all materials are in compliance The following sections explore the requirements
with applicable codes and regulations, the permit and best practices related to electric vehicle
must be approved within the required timelines. If charging stations. The concepts apply to all levels of
the AHJ determines that revisions to the application charging, but it is important to consider the unique
are required in order to address a health or safety circumstances of some installations.
matter, they must return the permit application to the

Single-Family Residential Charging

As a first priority, many AHJs have streamlined single-

family charging station permits with electronic
applications, no need for a plan review, and the option
of same-day approval.

Residential charging is easily streamlined because

typically only one or two Level 2 chargers will be
installed at a given house. The electrical work needed
for a Level 2 charging installation is similar to the
installation of a dryer or other household appliance, in
essence only requiring a field inspection.

Image courtesy of Tesla

SECOND EDITION | ELECTRIC VEHICLE CHARGING STATION PERMITTING GUIDEBOOK 35

Direct Current Fast Charging the station. If necessary, this commonly similar to what some jurisdictions have
requires a right of way permit, in developed for the telecommunications-
Considerations and Right of
addition to the AHJ’s standard EV related applications.
Way Permits charging permitting process.
A station developer may need to get
AHJs can help identify and provide special encroachment permits—from
DC fast charging (DCFC) installations clear direction on the right of way Caltrans for example—to trench under
are more complex than Level 1 and permit process during an early an existing right of way. In general,
Level 2 installations since these consultation and help incorporate the encroachment permits can add
installations often require delivering right of way permit in the application considerable time and cost to a project
more power to a site. Some EV charging package. High-volume AHJ’s should and should be accounted for during
stations require a new utility electrical consider developing a dedicated project planning.
service to provide sufficient power to EVCS right of way permitting process,

Multifamily Housing Best Practices Best Practices

Encourage charging in rental properties to be

Multifamily Housing (also referred to as Multi-Unit Dwellings shared use
[MUD]) represents a key market segment in need of charging
options. They constitute between 38 percent and 67 percent Encourage the highest rate of charging to maximize
of California’s housing stock (depending on the region) throughput capacity, while balancing cost
but fewer than 9 percent of ZEVs in California have been
registered to MUD residents.51 To achieve 100 percent ZEV Avoid treating EV charging at MUDs as a commercial
adoption, this market segment likely needs to be served by a parking service
combination of access to Level 2 charging, DC fast charging,
and hydrogen fueling. Allow/encourage load management and battery
supported chargers if the electrical capacity at a site
A variety of factors—ranging from ownership structure to is insufficient
available power and parking—have worked against adding
charging to existing MUDs at the necessary scale. The For new buildings – adopt CALGreen voluntary
following best practices can help address the challenge: measures or better (see Advancing Infrastructure
through Building Standards section)

State Permit Streamlining Laws stations that are installed as the accessory or primary
use of a site. This law was developed based on the
(AB 1236 and AB 970) reality that the availability of charging infrastructure
drives the adoption of zero-emission vehicles—the
AB 1236 Requirements faster charging stations are deployed, the sooner
AB 1236 requires all cities and counties to develop
an expedited, streamlined permitting process for
all charging station installations including: Level
1, Level 2, DC Fast, and wireless charging; public
and private charging stations; light-, medium-, and
51 See “Quantifying the electric vehicle charging infrastructure gap
heavy-duty electric vehicle charging stations; and
across U.S. markets,” ICCT (2019).

36 ELECTRIC VEHICLE CHARGING STATION PERMITTING GUIDEBOOK | SECOND EDITION

California’s air quality improves, greenhouse gas 3. Laying the foundation for streamlined reviews:
emissions are reduced, and local economic benefits Under AB 1236, cities and counties shall approve
are captured. 52 permit applications through a building permit
or similar non-discretionary permit with review
When AB 1236 was being developed, permitting limited to public health and safety issues. The
processes and actual timelines varied widely—in station permitting checklist plays a key role. Any
many cases adding considerable delay to EV project that meets all the requirements in the
charging station permitting processes and station checklist, as determined by the AHJ, shall qualify
development. AB 970 builds on AB 1236 by adding for expedited review. In the vast majority of cases,
specific binding timelines to the permit review period. this means that no discretionary use permit will be
AB 1236 and AB 970 aim to address the core issues required, which can be the most time-consuming
that tend to undermine station permitting by focusing aspect of permit approvals. 55
on the following solutions for all levels of charging
stations: 65850.7(b) “A city, county, or city and county
shall administratively approve an application
1. Aligning AHJs and applicants: Process and to install electric vehicle charging stations
communication matters. Much of the frustration through the issuance of a building permit or
on both sides of the permitting process arise from similar nondiscretionary permit. Review of
a breakdown in communication. To address this, the application to install an electric vehicle
AB 1236 requires cities and counties to adopt charging station shall be limited to the building
an electric vehicle charging station permitting official’s review of whether it meets all health
checklist (or checklists) detailing the requirements and safety requirements of local, state, and
for a project to be eligible for an expedited federal law. The requirements of local law shall
review. The idea is to create process transparency be limited to those standards and regulations
that simplifies communication for both AHJs and necessary to ensure that the electric vehicle
station developers. More and more communities charging station will not have a specific,
are establishing these required checklists, but adverse impact upon the public health or
much work remains to be done to spread this safety. However, if the building official of the
solution across the state (checklists were required city, county, or city and county makes a
to be posted by September 30, 2017). 53 finding, based on substantial evidence, that the
65850.7(g)(1)“…In developing an expedited electric vehicle charging station could have
permitting process, the city, county, or city a specific, adverse impact upon the public
and county shall adopt a checklist of all health or safety, the city, county, or city and
requirements with which electric vehicle county may require the applicant to apply for
charging stations shall comply to be eligible for a use permit.”
expedited review…” AB 1236 requires cities to adopt an ordinance (or
2. Making it easy to apply for a permit: AHJs are ordinances) to ensure the above solutions are
required to allow for electronic submission of enabled through a transparent, streamlined EVCS
application packets for vehicle charging stations permitting process. Additionally, the law establishes
through email, internet, and/or fax and allow that local ordinances cannot create unreasonable
for electronic signatures on all forms. This simple barriers to station installation, including subjecting
change can save considerable time and money. 54

65850.7 (2) “The checklist and required

permitting documentation shall be published 52 Streamlined permitting of electric vehicle charging and hydrogen
on a publicly accessible Internet Web site, if fueling stations is a key climate strategy that cities and counties can
add to their Climate Action Plans—the faster infrastructure is added
the city, county, or city and county has an the sooner cities can reduce transportation related emissions.
Internet Web site, and the city, county, or city 53 See the Town of Woodside’s EV permitting checklist for an example.
and county shall allow for electronic submittal 54 To be clear, electronic application submittals do not replace the
of a permit application and associated value of in-person communication, especially for large projects. The
approach simply saves applicants from having to make a separate
documentation, and shall authorize the trip to submit their application.
electronic signature on all forms, applications, 55 A discretionary permit can only be required if the building official
and other documentation in lieu of a wet makes a finding, based on substantial evidence, that the electric
vehicle charging station could have a specific, adverse impact upon
signature by an applicant…” the public health or safety.

SECOND EDITION | ELECTRIC VEHICLE CHARGING STATION PERMITTING GUIDEBOOK 37

 counter, as opposed to going through the planning
or zoning department for planning approval.

Per AB 1236, the city building and/or electrical

CEQA: Ministerial vs.
department’s review of an EV charging station permit
Discretionary Decisions
application “shall be limited to the building official’s
review of whether it meets all health and safety
AB 1236 requires California cities and counties to requirements.” AB 1236 allows building officials to
approve the installation of EV charging stations using assess if a “specific, adverse impact upon the public
non-discretionary permits, unless the local officials
health or safety” may result due to the installation
make a finding that the EVCS could have a specific,
of EVCS or EVSE equipment. For example, health
adverse impact on public health or safety. Accordingly,
under certain circumstances, an EVCS approval can be and safety concerns can lead to the need for
ministerial and therefore would not trigger an analysis project revisions when the building official believes
under the California Environmental Quality Act (CEQA). that added EV charging loads may affect existing
electrical infrastructure or when the project might
CEQA only applies to discretionary decisions by public
agencies. (Public Resources Code, § 21080(a).) A create a visual hazard. It should be noted that a
decision is discretionary when it requires the exercise visual hazard is different than a visual impairment.
of judgment or deliberation. (CEQA Guidelines, § A visual hazard may compromise fire safety, while a
15357.) In contrast, CEQA does not apply to ministerial visual impairment can be mitigated to not adversely
decisions, or decisions requiring little or no personal impact safety. However, the fact that the EV charging
judgment by public official as to the wisdom or manner
station or its equipment is visible from the street or
of carrying out the project. (CEQA Guidelines, § 15369.)
other right of way is not a visual impairment and no
For example, a building permit would be ministerial
if the ordinance requiring the permit limits the official mitigation (i.e., screening) should be required.
to determining whether applicable zoning laws allow
the structure to be built in the requested location, the AB 970 Requirements
structure meets the strength requirements in the Uniform
Building Code, and the applicant has paid the fee. AB 970 adds specific binding timelines for AHJ review
(CEQA Guidelines, § 15369.) of EVCS project applications based on the size of the
proposed project. For projects with 1 to 25 stations
Please note that even if an EVCS permit is considered
at a single site, AHJs must review applications for
discretionary, an EVCS project may still be exempt from
CEQA consideration, such as if the project is otherwise completeness within 5 business days and approve
excluded from CEQA or falls within a categorical or deny the application within 20 business days. For
exemption. projects with 26 or more stations at a single site, AHJs
must review applications for completeness within 10
business days and approve or deny the application
within 40 business days.

An EVCS application will be deemed complete if

after 5 or 10 business days (based on the number of
applications to aesthetic review or other processes chargers at the site) the AHJ has not either:
that require unnecessarily long timelines. On the
1. Found the application to be complete; or
contrary, AB 1236 explicitly calls out the legislative
intent “to encourage the installation of electric 2. Issued a one-time written deficiency notice that:
vehicle charging stations,” and a growing number of
cities and counties are responding with constructive a. Details all changes needed to make the
policies and procedures. application consistent with the city or county
EVCS permitting checklist (where a checklist
Taken together, a station developer will know, exists); or
up front, everything they need to do to have a
streamlined permit process. Similarly, AHJs will be b. Identifies specific information necessary for
able to use the complete information supplied by the building official to conduct a limited
project applicants to approve charging stations review of whether the project meets all health
through a ministerial process. In practice, this means and safety requirements.
that permit review will typically be conducted by the
If the city or county has not yet created its checklist,
building and/or electrical department, often over the
the deficiency notice will be limited to the building

38 ELECTRIC VEHICLE CHARGING STATION PERMITTING GUIDEBOOK | SECOND EDITION

official’s review of whether the project meets all Table 4: AB 970 EVCS Permit Timelines
health and safety requirements of local, state, and
federal law per AB 1236.
Application Submittal >> Review for
If not already approved or denied pursuant to
Completeness
the requirements of AB 1236 (Section 65850.7(b) or
(c), respectively), the application will be deemed Project Size Business Days
approved 20 or 40 business days (based on the
number of chargers at the site) after it was deemed 1-25 stations at a single site 5 days
complete if:
26 or more stations at a 10 days
1. The AHJ has not made a finding, based on single site
substantial evidence, that the EVCS could have a
specific adverse impact upon the public health
or safety; Complete Package >> Approval to Build

2. The AHJ has not required the applicant to apply

Project Size Business Days
for a use permit as specified in Section 65850.7(b);
and
1-25 stations at a single site 20 days
3. An appeal has not been made to the planning
commission pursuant to Section 65850.7(d). 26 or more stations at a 40 days
single site
Table 4 below summarizes the EVCS permit
application review and approval timelines required
by AB 970.

When interpreting the table and timelines, please Although not included in the AB 970 required
consider the following points: timelines, it is a best practice for an AHJ inspection
to occur within 5 business days of receiving a
1. The optimal scenario is a day-of response, online construction complete notice.
or over the counter. Online transactions can
save considerable travel time and expense. Cities and counties eager to attract charging can
Depending on staff resources and project publish their expedited timelines for EVCS application
complexity, day-of approval or responses are not review. To help meet and exceed these timelines,
always feasible—but the objective is to get as simple time saving measures, such as encouraging
close to optimal as possible. plan checkers to conditionally approve permits
(also known as “approved as noted”), can have a
2. Expedited review hinges on the station developer considerable impact. In many cases, this time savings
submitting a well-organized, complete translates into monetary savings—savings that can
application with all necessary materials. The be invested in more charging stations in the state.
application should match the AHJ’s permitting Furthermore, cities or counties that contract with
checklist. third-party reviewers should ensure AB 1236 and AB
970 requirements are met – including using a checklist
3. Communication matters—station developers
and building in expedited turn-around times – so that
can help AHJs by giving them a heads up
third-party review does not add time to the process.
about an upcoming application submittal and
advance notice about when construction will be
complete.

4. Under AB 970, the EVCS application shall be

deemed complete and approved if the AHJ has
not reviewed the project within the specified
timeframe (see Table 4) or has not made a
finding, based on substantial evidence, that the
EVCS could have a specific adverse impact upon
public health or safety.

SECOND EDITION | ELECTRIC VEHICLE CHARGING STATION PERMITTING GUIDEBOOK 39

AB 1236 and AB 970 Requirements and Process Overview

Ordinance

Checklist Online Application

20–40 Days

Plan Review
Approval to
Permit Submittal (Health and
Build
Safety)

Resubmittal Deficiency Notice*

* The deficiency notice should include one complete set of comments.

5–10 Days

Parking Requirements

Local zoning and parking considerations must not factor

into the permit approval process. AB 970 requires AHJs
to reduce the number of required parking spaces by
the amount necessary to accommodate the EVCS if
the EVCS and associated equipment interferes with,
reduces, eliminates, or in any way impacts the number
of parking spaces available for existing uses.

40 ELECTRIC VEHICLE CHARGING STATION PERMITTING GUIDEBOOK | SECOND EDITION

Complying with AB 1236
and AB 970
Taking Steps to Simplify the Process
AB 1236 gave communities until September 30,
2017 to develop and adopt streamlined processes,
including passing an ordinance to codify the Permit streamlining need not be complex or expensive.
approach. 56 Unfortunately, due to lack of awareness, Tuolumne County used to require paper submittals,
enforcement, and inconsistent application across expensive studies, and station developers reported
waiting at least 30 days for approval of typical Level 2
the state, a wide variance in permitting processes
projects. This was problematic for several reasons, not
persists. AB 970 became operative on January 1, the least of which is that the County is large, and travel
2022 for every city, county, or city and county with to the permit office can be time consuming.
a population of more than 200,000 residents, and
To improve the process, the County decided to go
January 1, 2023 for every city, county, or city and
to a paperless permitting system, with electronic
county with fewer than 200,000 residents. plan check, auto-approval of permits, and printable
permits. Software tools exist to handle an all-electronic
AB 1236 and AB 970 establish streamlined charging
permitting system, but the County did not have the
station permitting as a statewide imperative, but budget to purchase the software. Instead, they used
success depends on local implementation and common software (AdobePro) they already owned
AHJs retain flexibility in how they implement the to create and share downloadable, fillable PDF
law and intake and process applications. From a applications. Station developers simply download and
station developer perspective, the ideal process of fill out the forms, include an electronic signature, and
submit the document to the County via email. In many
permitting charging stations would be uniform across
cases, the only in-person interaction occurs during the
all jurisdictions, modeled after the fastest processes in
final site inspection.
the state. In reality, processes vary. In one city, it may
make sense to create a unique process specifically The County permit process for EVCS is now paperless,
with approvals granted in five days or less.
for charging stations. In another, putting charging
station reviews through a standard electrical permit
process may yield the best results.

The best approach to comply with the binding

statutory requirements and deadlines may depend
on the volume of applications, the structure of
planning and building departments, whether the not provide a second round of unrelated comments
AHJ has full-time staff for permit review or whether it unless related to a health and safety issue which can
contracts with external reviewers, and other factors. add preventable expenses and time to a project.
The most important factor is to ensure that whatever
process is adopted, it streamlines the process for both We encourage AHJs to invite industry and
the AHJ and station developer rather than adding stakeholders to the table to discuss existing processes,
additional complications and permitting delays. identify restrictions in the process, and develop
strategies for streamlining and improvement. Local
In all cases, permit application documents must jurisdictions can also use this as an opportunity
be available to be downloaded and submitted to train local contractors and station developers
digitally with the ability to provide electronic on proper permit submittals to save time spent on
signatures (in fillable PDF or similar format). If reviewing incomplete applications. A streamlined
comments are necessary, AHJs should send one process designed to be responsive to stakeholders
complete set of comments that can be addressed in saves staff time for both the station developer and the
a streamlined manner through modifications to the AHJ involved.
existing application. Giving station developers one
complete set of comments as early in the process as
possible saves time and money by enabling them to
streamline resources when developing their response.
While it may take more than one iteration to
completely address an AHJ’s comments, AHJs should
56 For example, the City of Burbank, and the County of Sonoma

SECOND EDITION | ELECTRIC VEHICLE CHARGING STATION PERMITTING GUIDEBOOK 41

 The Benefits of a Regional
Approach
Best Practice: Identify a ZEV Permitting
Ombudsperson AB 1236 allows flexibility for local jurisdictions in
terms of allowances for unique climatic, geological,
seismological, or topographical conditions,
An ombudsperson who understands the entire
how they design their permitting checklist and
permitting process and serves as a single point of
contact for ZEV infrastructure projects can save time expedited review process, and other components
and frustration for both the applicant and AHJ staff. In of implementation. However, it is also beneficial to
many cities, individual staff members may only know coordinate with other AHJs in the region to share
their specific piece of the process. Having a single point best practices and, ideally, develop substantially
of contact who understands the process in its entirety similar standardized intake and review processes.
can help expedite the application and review.
Relatively similar permitting processes across a
region allow for station developers to clearly plan
and install stations across a geographic area without
having to spend additional labor time familiarizing
themselves with significantly different processes.
Ideally, these conversations could be coordinated
through the local council of governments or other
Primary Use vs. Accessory Use
regional planning body, saving time and expense for
all involved.
Local jurisdictions often have different permitting and
planning procedures based on project use types.
Permitting of accessory use projects for existing building Resources to Help Communities
sites may be more streamlined than permitting of
primary use, new construction projects. AB 1236 requires Enable a ZEV-only Future
permit streamlining for all charger installation projects,
regardless of whether projects are primary or accessory There are several resources available to help
use. However, because primary use projects may have local jurisdictions comply with AB 1236 and AB
different or expanded impacts on matters of health 970. California Building Officials (CALBO) offer AB
and safety, it is reasonable to implement a different, but 1236 compliance toolkits for both small and large
still streamlined permitting process for these types of
jurisdictions. These toolkits include model ordinance
installations. For example, the streamlined permitting
templates, adoption timelines, and supporting
process for a primary use charger installation project
may require more consideration of health and safety staff reports, as well as a sample permitting
components than a charging station that is accessory checklist. Local governments should also study their
use (e.g., due to increased vehicle usage of the site). implementation of AB 2188 (Statutes of 2014, Chapter
Importantly, a charging station that is the primary use of 521), which mandated streamlined rooftop solar
a site should not be required to complete a conditional permitting, or AB 57 (Statutes of 2015, Chapter 685),
use permit process. To meet the requirements of AB 1236
which mandated deemed approved requirements
and AB 970, a local jurisdiction should aim to align its
for telecommunications facilities, for areas of overlap
streamlined permitting process for a charging station
that is accessory use as close as possible for a charging and lessons learned.
station that is primary use.

Additional Permitting
Best Practices
Station developers who do not own the land being
developed often have limited flexibility on any given
site. For a variety of reasons, a site host may limit
installation of charging to a specific location on the
property. Providing accessibility and the existing
electrical infrastructure and capacity can also
constrain options.

42 ELECTRIC VEHICLE CHARGING STATION PERMITTING GUIDEBOOK | SECOND EDITION

Implemented by the AHJ, the following strategies can
help prevent permitting from being an additional
constraint:

1. Collaborate with the EV charging industry

to minimize the constraints and maximize
opportunities for charging projects to qualify for
expedited permitting, as required by AB 1236 and
AB 970.

2. Define upfront the materials needed for a permit

package to be complete, the associated fees,
and what building inspectors will be looking for.

3. Offer pre-application meetings with

knowledgeable AHJ staff for projects that may
require additional review and help the applicant
understand the advantages or disadvantages of
each project approval approach.

4. Acknowledge AB 970 timelines on the AHJ’s

website and position AHJ staff to meet or exceed
the timelines, targeting day-of approvals
whenever possible.
Image courtesy of Tesla
Station developers with a clear understanding of
what AHJs will be looking for are better positioned to
work with site hosts to identify favorable solutions that
work for all parties. 57

Installing Charging Stations in respective jurisdictions, but some § 30610(a), (b); 14 Cal. Code Regs §§
local CDP decisions can be appealed 13250, 13253) or may be approvable
the Coastal Zone
to the Coastal Commission. In areas through an expedited review process,
where there is no certified LCP, the such as through a de minimis permit
A Coastal Development Permit (CDP) Coastal Commission is responsible for waiver. Ensuring that proposals for
may be required to install charging determining whether a CDP is required new or expanded EV charging stations
stations located in the coastal zone. for proposed development. avoid adverse impacts to coastal
Local governments in the coastal resources, particularly habitats, public
Construction of new, or expansion
zone with certified Local Coastal coastal views and coastal access
of existing, EV charging stations
Programs (LCPs) are responsible parking will help expedite the CDP
constitutes development that is subject
for determining whether a Coastal determination and review process.
to the Coastal Act; however, such
Development Permit (CDP) is required
development may be exempt from
for proposed development within their
CDP requirements (see Pub. Res. Code

57 In defining which types of projects might trigger a longer review, it is

important to note that for typical charging installations at an existing
facility, electric vehicle charging should be considered an accessory
use and should not be considered a fueling station or otherwise trigger
additional zoning review. This approach is consistent with AB 1236.

SECOND EDITION | ELECTRIC VEHICLE CHARGING STATION PERMITTING GUIDEBOOK 43

What does a streamlined In the City of Sacramento, for example, effectively eliminating an uncertainty
the City tells applicants up front to for a station developer.
process look like?
design projects to avoid impacts to
On the station developer side,
heritage trees and bio-swales to avoid
successful streamlining requires
At the most basic level, a streamlined complicating the review process. This
understanding any unique constraints
permitting process does two things: type of direction to applicants can be
of a particular site, designing projects
given on a city or county permitting
1. Creates clear pathways for non- to avoid triggering special review,
website, using permitting checklists
discretionary permit approval. and providing transparent details in
and fact sheets, and re-iterated at pre-
permitting submittals.
2. Makes the non-discretionary permit application meetings, which are often
application process simple and recommended for larger projects. If an application requires amendments
straightforward. after review, AHJs provide one round
Sacramento also clearly communicates
of complete comments for applicants
On the AHJ side, successful that putting charging stations
to respond to—and for applicants to
implementation requires clear into existing parking lots will not
answer AHJ questions in full.
communication about how project trigger bringing the parking lot into
applicants can design their project to compliance for new landscaping,
avoid triggering a lengthier special or other onerous requirements that
review. could make the project infeasible—

In addition to minimizing the chances of incomplete

application packages (which creates extra work for
both the AHJ and station developer), providing clear
information on a city or county’s website can also be
a great way to attract charging station development,
as a transparent and informational website will allow
station developers to more easily plan for and deploy
charging within a jurisdiction. Reasonable fees, or
even subsidized fees, can also attract development.
For instance, the City of Anaheim waives what would
be a $147.67 fee.
Image courtesy of FLO
It is important to delineate between the requirements
for each kind of installation site, be specific about any
differences in requirements between different levels
of charging and provide comprehensive and clearly the driver and could ultimately influence consumer
labeled information. Fact sheets for these scenarios decision making. An installed bank of chargers at
help save time—especially if the fact sheets define the right location and time can make the difference
parameters within which permitting and inspection between converting a driver to a ZEV or committing
can be streamlined. 58 While the requirements and them to internal combustion for an additional
fees are sometimes the same across various levels of purchase cycle.
charging, this is not always the case, hence the need
for clear communication and information.

Finally, timing matters. Long permitting processes add

expense and uncertainty to any project and may
risk cancelling the project entirely. Losing projects
due to lengthy permitting processes will negatively 58 For example, a DCFC fact sheet could communicate that an
application placed in a parking lot that does not impact existing drive
impact the station developer, the AHJ, the state, and aisles would go straight to building/electrical review.

44 ELECTRIC VEHICLE CHARGING STATION PERMITTING GUIDEBOOK | SECOND EDITION

Preparing a Permit Application
When developing a permit application, station
developers should carefully review the application Increasing Awareness
requirements for the specific jurisdiction they are
working in, especially in cities and counties that
Awareness about charging installations, the different
have not yet complied with the state’s permitting levels of charging, and the requirements for each
streamlining requirements (AB 1236 and AB 970). is still growing in local jurisdictions across the state,
Requirements can differ significantly from other even in jurisdictions with high numbers of electric
jurisdictions in the region. Even if a developer has vehicles. Station developers should be ready to address
worked with the AHJ before, processes may have questions or misconceptions with building department
staff, fire officials, and other permit reviewers, and share
changed since the last project. If the AHJ has
this Guidebook or other resources specific to the kind
a checklist for expedited permit review, station
of project.
developers should review those requirements and
ensure the project meets the standards for expedited
review. If the AHJ offers pre-application meetings,
station developers should take advantage of the
opportunity to learn about any special considerations
for the process, what kind of reviews to expect, and
any steps they can take to make the process easier.
Pre-Application Meetings
If the city or county has developed an EV-ready
ordinance, regional readiness plan, or other planning
or policy document, station developers should Pre-application meetings are strongly encouraged for
large projects being pursued in communities that have
familiarize themselves with the contents and look to
not yet established a streamlined permitting process
engage with the local department or departments and/or for projects that might trigger additional review.
involved in creating it. Whether plug-in electric These meetings should occur as early in the process as
vehicle readiness has been led by planning, public possible, include decision makers from both the AHJ
works, environment and sustainability, or other and applicant, and be used to ensure the project is set
city or county departments, engaging the lead up for a streamlined process following the meeting and
departments in the project can help resolve any ultimately permitting success.

issues that come up and can develop valuable allies Clear fact sheets and checklists can minimize the
to help get a project through the process. need for pre-application meetings by communicating
how projects can be designed to avoid triggering
Station developers should begin engaging the local additional review, and conversely which types of
utility at the pre-application stage of the process as projects or project features are likely to trigger special
well. The state’s utilities differ in how they expect the review. Station developers can use this information to
design projects to meet the pre-defined criteria for a
timelines of the parallel permitting and energization
streamlined process.
approval processes to interact. Some are comfortable
with a simultaneous review process, while some may
want to wait until the permit is approved to begin
the service connection review process. At this stage,
station developers should develop an understanding
of the extent of electrical work that will be required
and the timeline for its completion. We discuss service load calculations and whether a panel upgrade
connection in further detail later in this Guidebook will be required; a separate mechanical permit
(Part 5: Energization). application if ventilation will be required for the
station; and charger installation instructions from the
What to Include in Your Application manufacturer. Public station applications will need
to pay special attention to accessibility, with clear
A number of documents may be required for an
diagrams and text showing how the project will meet
application to install a public charger, and the
state accessibility regulations.
information requested can vary by jurisdiction
and project type. Common pieces of information Given the requirements of AB 1236, it is important
include site plans; a single line electrical diagram; for project applicants to focus their submittal on

SECOND EDITION | ELECTRIC VEHICLE CHARGING STATION PERMITTING GUIDEBOOK 45

alleviating any potential health and safety concerns permitting process, but another team of contractors
up front. For example, a DCFC project that draws install the charging station. While this can work if
energy from the existing electrical service could executed carefully, it raises the risk of mistakes in the
require additional safety review compared to a construction process and inconsistencies with the
project that will rely on its own service drop. In either approved permit, raising costs for both parties and
case, the review will benefit from documentation causing frustration for inspectors and building officials.
that demonstrates how the electrical load will be This is especially likely to happen if the construction
managed. From a visual perspective, building and and installation contractors have not seen the site
fire officials will look for visual hazards – for example, before the start of construction.
structures that block fire lane visibility.

If not all the components on a jurisdiction’s AB 1236 Common Obstacles

expedited review checklist are present, a project
may be deemed ineligible for expedited review Aesthetics: Some jurisdictions have subjected projects
without revision or resubmission and may be routed to design review and asked the permit applicant to
through a standard review process. Additionally, if make aesthetic changes to the permit application.
the AHJ determines that the project poses a specific, While design guidelines that implicate health and
adverse impact upon health and safety, the AHJ safety, such as safety related lighting, clearance, and
may remove the project from expedited review and signage are permissible under AB 1236, aesthetic
may also require a conditional or special use permit changes without a specific impact on health and
application. safety—such as landscaping and other screening
requirements—are not in accordance with state
Station developers must pay permit application permitting requirements under AB 1236. In areas with
fees when they submit a project. Permit fees are sensitive design standards, station developers and
usually based on a combination of the percentage AHJs are encouraged to collaborate on practical
of anticipated cost of materials and construction, design elements that can be implemented with
staff time, the size and scope of the project, any minimal expense, minimal complication, and without
additional permits required, and fees for inspection. impacting the project timelines set by AB 970. AHJs
Fees are not standardized statewide and can vary may also provide alternative compliance pathways
dramatically, even in neighboring cities. To support or ministerial flexibility for EVCS to meet design
ZEV deployment, AHJs should structure fees to both standards in their zoning code wherever possible.
meet their needs while also minimizing the costs to Staff should have flexibility when reviewing EVCS sites
developers of installing charging stations. in areas with sensitive design standards to ensure
creative, practical solutions can be developed and
Just as AHJs can implement steps and procedures
approved easily.
to make the permitting process easier for station
developers, so too can station developers take Zoning Conflicts: Some AHJs have deemed larger
actionable steps to streamline the permitting process charging installations to be fueling stations, as
for cities and counties. Common errors from station opposed to site accessories, and expressed concern
developers include inaccurate load calculations, over their compliance with zoning codes. Similarly,
inconsistent diagrams, and failure to comply with some cities and counties have communicated
accessibility regulations, such as inclusion of grades that a DCFC charging depot application could be
that are too steep, inaccessible placement of the streamlined in a location zoned for fueling but not if
charging station itself, and lack of accessible route the DCFC depot is to be constructed in a commercial
and path of travel. Errors in submission lengthen the zone or retail setting. This approach runs contrary
process and can also jeopardize site control if a site to AB 1236 and AHJs are encouraged to develop
host grows concerned over a process being delayed strategies to enable streamlined permitting for all
by many rounds of comments and revision. charging installations, including DCFC depots, in
as many site types as possible. AHJs may consider
Consistent and clear lines of communication
making EVCS its own permitted, primary use to the
between staff and contractors working on the
widest extent feasible.
permit application and station installation are
also important. Some station developers who Inconsistency: Accessibility regulations (see Part 3:
work with many contractors will have one team of Accessibility for an in-depth overview) are ultimately
contractors develop the plans and go through the applied on a site-specific basis by local building

46 ELECTRIC VEHICLE CHARGING STATION PERMITTING GUIDEBOOK | SECOND EDITION

officials. That means that one AHJ’s interpretation of overcome misconceptions to achieve the state’s
the code may differ from another AHJ’s interpretation goals of 10,000 DCFCs in the state by 2025. Station
of the code, especially if an installation presents a developers should be ready to share manufacturer
site-specific challenge. installation instructions and other resources, as
necessary, to help clear up misconceptions and
Lack of Familiarity: The amount of power required for address concerns.
DCFC installations may be unfamiliar and concerning
for AHJs, especially to fire inspectors given the reality
that some DCFC installations can pull as much power
as a city block. However, it is important to understand
that DC fast charging is a normal and tested
technology found across the state in thousands of
installations. DCFCs are carefully constructed and
equipped with numerous safety features. DCFCs are
designed and manufactured to meet national safety
regulations, and building officials ensure that all
codes and standards are safely met. We encourage
station developers and AHJs to work together to

Image courtesy of Paired Power

47
Image courtesy of Sacramento Municipal Utility District
48 ELECTRIC VEHICLE CHARGING STATION PERMITTING GUIDEBOOK
 PART 05:

Energization

Energization describes the process through which

electric vehicle charging stations are connected
to the electrical grid through the local utility. This
process may involve connecting electric vehicle Off-grid and mobile solutions
supply equipment to pre-installed make-ready
wiring, upgraded or new electrical services, installing
Most charging stations are hardwired to the electrical
subsurface or surface mounted conduit/wiring, grid. Depending on the setup, grid-connected stations
trenching to facilitate that conduit and wiring, and can source their power from any mix of grid power,
more. While not all stations require connection to the local power generation, or on-site energy storage.
electric grid—some, for example, may have sufficient However, not all chargers need to be grid connected,
solar generation and on-site battery storage to cover and solutions exist to add increased flexibility to the
the anticipated load—most stations are energized by charging ecosystem.

utilities. Thus, it is important to understand this process For example, stand-alone or off-grid EV charging
early in station planning to reduce potential for infrastructure solutions, which do not require electric
development delays in permitting and utility grid connection generally receive their power
construction phases. from locally-generated renewable energy. These
systems can be permanent or mobile. Mobile off-grid
solutions have the advantages of rapid deployment,
no trenching, and minimal permitting. A permanent
off-grid solution might be dedicated to charging or feed
into a micro-grid. In both cases, one clear advantage is
the ability to continue to charge vehicles during power
outages and offset peak demand charges.

Mobile chargers, which are essentially batteries on

wheels, can bring the charger to the car. These systems
Image can be charged when electricity rates are low and
courtesy
of Envision
deployed whenever needed, effectively decoupling
Solar the time of power consumption from the time of power
generation.

Bottom line: stakeholders should be aware that non-

grid-connected solutions complement traditional grid
connected resources and provide flexible solutions
that can help ensure charging can be made available
everywhere vehicles travel.

SECOND EDITION | ELECTRIC VEHICLE CHARGING STATION PERMITTING GUIDEBOOK 49

Energization can be complex and can significantly Utilities Commission (CPUC) and the state’s major
lengthen a project timeline, especially with larger utilities are currently taking steps to streamline the
charging installations and at sites with limited existing energization process. 59
electrical capacity. By engaging with the local utility
early in the process, station providers can gain a
clearer understanding of the development timeline, Understanding Energization
costs, and requirements. Utility approval to begin
Usually, similar to any other commercial customer,
the energization process is a separate and distinct
the station developer will be responsible for some
approval process from an AHJ permitting process,
of the work of energization. The delineation of
although the processes may be more closely linked
responsibilities between a developer and the utility
in areas with a municipal utility. The California Public
varies by territory. Most utilities provide a breakdown

Bidirectional Charging power can flow both from the grid to Bidirectional DCFC must be approved
charge an EV’s batteries and back to for interconnection. California’s
a building or the grid. This is referred to interconnection procedure known as
Bidirectional charging allows electric as vehicle to building (V2B) or vehicle Rule 21 accommodates bidirectional
vehicles to export stored battery to grid (V2G). The California Public DCFC for interconnection that meets
energy, enable emergency backup Utilities Commission (CPUC) and the the UL 1741 safety standard. Eventually,
services in the event of grid shutoffs California Energy Commission (CEC) V2G with alternating current (AC) will
or general power failures, manage have been promoting VGI including be approved for interconnection where
onsite load, and potentially receive V2B and V2G.62,63 Utilities have been the inverter that converts the DC energy
compensation for reducing system experimenting with V2G technology from a vehicle’s battery to AC is located
peaks. In December 2020, CPUC and CEC offers incentives to encourage on the vehicle. CPUC is currently
adopted a decision on Vehicle-Grid V2B and V2G technology deployment. pursuing the development of V2G
Integration (VGI), which created AC standards. At the time of writing,
metrics and strategies for advancing V2G may contribute to the reliability
commercially available bidirectional
VGI and authorized almost $45 of California’s electric system. For
chargers are limited.
million for investor-owned utilities to example, electric school buses located
spend piloting VGI technologies and at Cajon Valley Union School District
programs.60 have six V2G capable buses and six
bidirectional DCFC that participated
In November 2021, CPUC adopted in San Diego Gas & Electric’s demand
a resolution creating a pathway response program called the
for alternating current (AC) Emergency Load Reduction Program.
interconnection for VGI and allowing The school district earns revenue
some plug-in EVs to easily enable from using its electric school buses to
bidirectional mode.61 Today, some support the grid and help avoid power
DCFC are bidirectional, meaning outages.

59 Resolution E-5247

60 Decision (D.) 20-12-029 authorized the investor-owned utilities to

spend up to $35 million for VGI pilots, and $10 million for pilots,
demonstrations, emerging technologies, and studies.

61 CPUC Resolution E-5165.

62 For more information on California’s V2G activities visit the California

Public Utilities Commission Vehicle-Grid Integration Activities:
[Link]
infrastructure/transportation-electrification/vehicle-grid-integration-
activities

63 PG&E’s VGI pilots were approved via Resolution E-5192, CPUC is still
reviewing SCE’s proposed VGI pilots

50 ELECTRIC VEHICLE CHARGING STATION PERMITTING GUIDEBOOK | SECOND EDITION

of rules and responsibilities for all involved. It is information including hosting capacity and line
important to clearly understand the specific steps capacity. While intended for wholesale generation
that must be followed and potential pitfalls for a customers looking for potential distributed energy
project and site as these can affect the budget resource projects, these maps can also be used
and timeline. For example, if underground lines are to help station developers identify preliminary
being installed, easements must be attained by the sites to discuss with the utility. These maps do not
developer. This can create a barrier if the site host is show service impacts, such as whether you can
unwilling to provide an easement or lacks the legal connect to an existing transformer or whether an
authority to do so. Understanding these details up upgrade will be needed, which could be useful in
front can reduce project delays. streamlining the EVSE deployment process. Further
utility improvements to these maps with transformer
The scope and scale of energization differs based locations, load, etc. may enable more economical
on the size of the project and the levels of charging site selection, more efficient use of grid infrastructure,
involved. If a site already has excess electrical and enhance energization timelines overall.
capacity, energization via a new service connection
may not be required. However, this is not always the
case. For example, even when a property appears to Timeline for Communicating
have adequate capacity, the utility may be required
to update the drop lines to match the existing active
with Your Utility
service panel rating. If only Level 1 charging is As a rule of thumb, station developers should engage
planned and there are existing power outlets on-site utilities as early in the process as feasible. Given
that can be easily designated as Level 1 charging the large amount of electrical load and extensive
spaces, little to no electrical work will be required. construction that can be involved, early engagement
However, an electrician may still be hired to examine can shave weeks or months off a project timeline.
and test the outlets prior to operation as charger
outlets. To expedite the process, station developers should
get in contact with their utility to ensure they
For DCFC projects, energization will be a more understand what components a utility will require
involved process and could include new conduit and for an application to be deemed complete. The
wiring, a panel upgrade, and a transformer upgrade IOUs state that many applications commonly sit in
via a new service connection. Older buildings the construction phase for several months before
and parking lots may not have significant amounts they are deemed “construction-ready” because of
of excess electrical capacity. At these locations, an outstanding dependency such as an AHJ-issued
electrical upgrades are likely necessary. On the other permit. 66
hand, newer buildings are often built with excess
capacity. A load study done by the local utility will Each utility has different expectations and bandwidth
reveal how much capacity is available. to help walk station developers through the process.
Some utilities are available to help with the site
In the best-case scenario, sufficient capacity will exist selection process, while others cannot provide
in both the electrical panel and the transformer to timeline and cost estimates until a site is selected
accommodate the addition of charging stations. and secured. In the following sections of this part,
There may be enough capacity in one but not we provide more information on how the process
another, necessitating a panel upgrade without a varies at different major utilities in the state, including
transformer upgrade or the other way around. A Pacific Gas & Electric (PG&E), Southern California
transformer upgrade could involve adding a new Edison (SCE), San Diego Gas & Electric (SDG&E), Los
transformer or upgrading the existing transformer. Angeles Department of Water and Power (LADWP),
This can be an expensive task, underscoring the and Sacramento Municipal Utility District (SMUD).
importance of understanding a project’s unique These five utilities (three investor-owned and two
demands and needs—and communicating them to
the utility—early in the process. 64
64 If the customer is taking service through the EV Infrastructure Rules
29/45, the individual customer will not have to pay for transformer
California’s three major investor-owned utilities (IOUs) installation costs as they will be covered by ratepayers.
each make capacity maps65 publicly available on 65 PG&E; SDG&E; SCE.
their websites. These maps show transmission and 66 For more information, see the Joint Utility Advice Letter in Compliance
with Ordering Paragraph 8 of Resolution E-5167 and Ordering
distribution lines as well as substations and give
Paragraph 8 of Resolution E-5168.

SECOND EDITION | ELECTRIC VEHICLE CHARGING STATION PERMITTING GUIDEBOOK 51

publicly-owned) are the most prominent in the state 6. Utility finalizes design and delivers contract to
and represent the majority of California’s population, station developer
although there are over 80 utilities that cover the
whole of California’s needs. 67 7. Utility creates and submits easement documents
and AHJ permit requests

Major Utility Energization 8. Station developer and utility complete pre-

construction field meeting
Processes
9. Station developer delivers easement signatures
Each utility has a different energization process and and signed contracts to utilities and AHJ issues
will follow different intake, review, estimation, and requested permit
construction processes. However, there are also
many commonalities between them. Installing install 10. Station developer completes all onsite work and
stations in multiple service territories, it is important to applicable inspections
become familiar with the similarities and differences
11. Utility schedules and completes civil construction
across the utilities. Steps in the energization process
work
may include:
12. Utility schedules and completes electric
1. Station developer submits site inquiry
construction work
2. Utility performs preassessment/engineering study
The figure below provides a visual journey map of
3. Station developer reviews site feasibility study and the energization process for California’s IOUs and
submits all required information illustrates how the responsibility for completing
tasks shifts from the project applicant to the utility
4. Utility executes preliminary design throughout the process.

5. Station developer approves or declines The basic processes within a utility for installation of
preliminary design Level 2 and DCFCs are similar, with some additional

EV Infrastructure Rules The establishment of the EV and the IOUs will begin reporting data
Infrastructure Rules signals a from implementation in their EV Cost
(AB 841)
major policy shift in transportation and Load report submitted in 2023.
electrification (TE), as the new
• PG&E’s Electric Rule 29
The EV Infrastructure Rules serve as approach incorporates utility-side
alternatives to Rule 16 for any customer TE investment into the IOUs’ general • SCE’s Electric Rule 29
installing separately metered EV rate case proceedings rather than
individual program applications. • SDG&E’s Electric Rule 45
charging, excluding single-family
homes, which receive similar treatment Additionally, for separately metered • BVES Electric Rule 24
based on exception to Rule 16. The IOUs EV charging installed outside of
will recover in rates most of the utility- IOU TE programs, these Rules will • Liberty Electric Rule 24
side costs associated with upgrades allow customers to cover less of the
• PacifiCorp Rule 24
for EV charging installations, covering associated utility-side costs.
the costs of service line extensions and
The IOUs began offering service under
electrical distribution infrastructure.
the EV Infrastructure Rules in mid-2022,

67 This includes investor-owned utilities, electric load serving entities

(including publicly-owned utilities), rural electric cooperatives, and
community choice aggregators. See CEC’s Electric Load Servicing
Entities (LSEs) in California.

52 ELECTRIC VEHICLE CHARGING STATION PERMITTING GUIDEBOOK | SECOND EDITION

 General EV Customer/IOU Journey Map
* Process varies by IOU
APPLICATION READINESS KEYS TO SUCCESS
Do I have specific location identified? Understand applicable Utility Standards and Processes
CUSTOMER TASK
Do I have the information and documents Open communication with jurisdictional authorities
UTILITY TASK
required, such as Project support from site host or landlord
BOTH • Forecasted load/charge cut sheets
• Site plans with all utilities identified
(gas/water/sewer/phone, etc);
• Single line diagrams
• Existing easements
• Landscaping/drainage

CUSTOMER SITE
START READINESS
APPLICATION
13 ELECTRIC
Customer constructs CONSTRUCTION
Customer submits their portion of
service infrastructure ELECTRIC Utility
application for utility 1 8 12 CONSTRUCTION infrastructure,
PAYMENT AND
SCHEDULE installs meter and
SIGNED CONTRACT

SECOND EDITION | ELECTRIC VEHICLE CHARGING STATION PERMITTING GUIDEBOOK

7 make necessary
ENGINEERING ADVANCE/ Customer sends DEPENDENCIES Electrical
construction is system upgrades
UTILITY AGREEMENT 2 payment and signed 9
contract Utility and Customer scheduled
Some utilities may to complete all 10
require and EA payment, required applicable ENERGIZATION
or an additional agreement dependencies such 14 PROJECT
before proceeding work as land rights, and/ COMPLETE
into the Construction or construction
Design and Estimating PRE-CON MEETING permits**
phases (dollar amounts 6
vary by scope) Pre-con meeting 10
is set up with
inspector and INSPECTIONS CIVIL
customer 10 11 CONSTRUCTION
Complete all applicable SCHEDULED
inspections which may AND COMPLETED
include the following:
Standard Utility
5 • Trench Cross Bore practice to
•• Mandrel
complete civil
APPLICATION REVIEW 3 • Final City/County scope prior to
COMPLETED Green Tag electric
•
Customer/Utility to 4
confirm if project will
proceed to final utility
design
UTILITY ESTIMATE DRAWING AND
CONTRACT
Estimator designs
electric distribution Final drawing
infrastructure* completed and
contract is issued 10
* There may be instances where a proposed site location requires additional utility work to serve the forecasted load. In those instances, if utility work is required at the
substation or distribution circuit level to serve the proposed bad, projects with these scopes usually require multi-year timelines before construction is completed.
** All dependencies need to be met before scheduling for construction as this is a common utility business requirement.

53
requirements and longer timelines for DCFC projects scope. Engineering technical review can be the most
since they tend to be more complex, including time-intensive part of the process.
demanding more power. In the following sections,
process differences between Level 2 and DCFCs are The SCE process for developers, fleets, and other
delineated where possible. multi-site EV projects is described on their New
Development Project Management page. This page
Pacific Gas & Electric has a wealth of information, many FAQs, and all of
the forms needed to apply for service or upgrades
Pacific Gas and Electric Company (PG&E) has to existing service extensions. Station developers are
established dedicated resources to support project encouraged to refer to them when pursuing projects
coordination and construction for new, non- in SCE service territory.
residential EV charging infrastructure projects across
its service territory. Customers apply for service In addition to streamlining EV service requests, SCE
online using the “Your Projects” portal and specify offers multiple “Charge Ready” programs to support
that the project is for EV charging to ensure that the EV charging, as well as Transportation Electrification
application(s) are routed efficiently to the EV team for Advisory Services to support eligible business and
further coordination support. property owners in preparing for the potential
deployment of electric vehicle charging equipment
PG&E has also developed an “EV Customer Road at their commercial business locations or multifamily
Map” that is available online to help customers properties. SCE’s Transportation Electrification
understand end-to-end process and general Advisory Services include educational webinars, EV
timelines. This resource includes links to important readiness studies, grant assistance, and other tools
supporting documents to facilitate overall project and resources.
success for customers such as:
SCE also offers different rate options based on EV
• Commercial EV Site Requirements List charging demands. Access to these rates depends
on how stations are metered and is something
• Construction Best Practices
station developers and site hosts should take into
• Frequently Asked Questions consideration when designing a project:

In addition, once a customer applies for service, the • For stations metered together with the existing
EV team is prepared to provide additional phone facility load, SCE offers their full range of Time-Of-
consultation support where necessary to ensure that Use (TOU) rates depending on maximum facility
customers understand existing utility processes and demand.
procedures.
• For separately metered stations, SCE offers TOU-
PG&E currently offers two EV rate plans for residential EV rates for business customers charging electric
customers and two EV rate plans for business vehicles.
customers with on-site EV charging:
SCE offers a Business Rate Analysis Tool to help some
• Residential EV rates business owners estimate their annual rates under
different TOU plans. The tool currently only supports
• Non-residential EV rates Level 1 and Level 2 charging installations at multi-unit
dwellings or workplaces.
Southern California Edison
San Diego Gas & Electric
Southern California Edison (SCE) has a dedicated
electric vehicle connection team, the Transportation San Diego Gas & Electric (SDG&E) assigns grid
Electrification Project Management team, that connection projects to a geographically close
manages customers submitting requests throughout planner who already has familiarity with the area.
the service territory. This team acts as the single point The planner will gather information on the size of the
of contact for multi-site EV developers including job and look at their service maps to see whether
government entities, fleets, and third-party EV enough power will be available for the project.
developers. SCE estimates an average 4–6 months for
engineering review and planning once the customer If a station developer is planning to develop a
has delivered a complete submittal to SCE. Customer network of sites, or multiple similar sites, they can
construction timelines will vary based on project work with one of the design firms with whom SDG&E

54 ELECTRIC VEHICLE CHARGING STATION PERMITTING GUIDEBOOK | SECOND EDITION

contracts to ensure more consistency and efficiency the assigned planner to discuss the particularities of
than if each site were assigned a different regional the site and identify ways to reduce costs.
staff planner. This list is dynamic and updated
frequently. Station developers can access the latest SDG&E anticipates about 14 weeks to deliver a
version of the list from the SDG&E Project Resources service order with all information on the work that will
webpage, under Design Resources. be necessary.

After this stage, planners are available to perform More information is available on the SDG&E Builder
a site walk with the customer. SDG&E highly Services webpage.
recommends the site walk, which often leads to
Los Angeles Department of Water and Power
fruitful conversations and highlights opportunities
to slightly modify the plans to save money on grid Los Angeles Department of Water and Power (LADWP)
connection costs. After the site walk, the planner will is the largest municipal water and power utility in
perform additional technical work, as required, such the nation, providing service to 1.4 million electric
as conducting a fusing study, verifying connections in customers in the region. The territory is broken into
electrical vaults, and studying the electrical mapping three service areas: Valley Service Planning, Metro
system. This goes into designing the utility portion of West Service Planning, and Metro East Service
the job which concludes in issuing a service order to Planning.
the station developer with details and instructions for
the contractor. LADWP has a dedicated EV Service Design Group
that handles all EV charger project installation
The service order will include a fee for the utility’s requests. Typically, the developer/installer completes
work. An allowance based on anticipated ratepayer the Commercial EV Charging Plan Review Form
recovery over the first year of station operation will be and provides complete plot plans and/or site plans,
applied to the fee to reduce it. 68 This may result in no building profile and/or elevation plans, one line
fee being charged due to the station developer and electrical diagram, load schedule and Service
the utility bearing the full construction cost. In larger Planning Information Sheet. The developer/installer
jobs, the station owner will pay the balance of the fee. must submit a complete submittal package to LADWP
to proceed with engineering review and design work.
The customer is responsible for laying all conduit
LADWP will then review the submittal and analyze the
from the transformer to the meter pedestal, as well
distribution system capacity available to serve the
as connecting the pedestal to the station or stations.
new load and provides an adequate facilities letter or
SDG&E is responsible for placing wire in the empty
if upgrades are required a service planning engineer
conduit between the meter pedestal and the
will provide a cost estimate and duration for the
transformer and for placing the meter into the socket.
required upgrades to be completed. When new EV
SDG&E may require that their trench inspectors review
loads are associated with larger scale projects such
any trenching before the trenching can be refilled
as new residential or commercial buildings, these
and paved. 69
projects will be handled by LADWP’s standard Service
After construction is complete, an SDG&E crew Planning groups. Developers can use “Find The Right
will visit the site, make transformer upgrades as Person” to find the appropriate service planner and
needed, put wire through the conduit, connect the office to submit these jobs.
transformer to the meter pedestal, and set the meter,
The design process for Level 2 and DC fast chargers
energizing the new service. After this point, the station
is the same, with timelines typically longer for DC
developer can turn on the equipment and begin the
fast charger projects. DC fast charger projects also
commissioning process.
include a customer commitment/requirement plan
To minimize costs, SDG&E recommends several (the plan delineates work to be completed by the
proactive steps. Early engagement is key, although a developer and LADWP). The typical design timeline
customer will likely not be referred to a planner for a
more detailed estimate until a project is reasonably
planned out. Trenching, which can easily account for
two-thirds of costs, should be minimized. Trenching 68 For Rules 15/16; not applicable to Rule 45.

through concrete is typically the most expensive, then 69 Only applicable to Rule 16. Under Rule 45, IOUs will be responsible for
poles, vaults, service drops, transformers, mounting pads, trenching,
trenching through asphalt, then through landscaping. conduit, wire, cable, meters, associated engineering and civil
Finally, SDG&E recommends taking a site walk with construction work, and other equipment.

SECOND EDITION | ELECTRIC VEHICLE CHARGING STATION PERMITTING GUIDEBOOK 55

for this portion of the project is approximately 18 request a basic evaluation by SMUD of one or more
weeks or more depending on the size and complexity sites under consideration to identify potential issues or
of the project. Construction timelines will vary once pitfalls and help the project developer make a more
the customer and utility scope are determined. A informed site selection decision.
Service Planning Engineer can provide the latest
Once the site is selected, the developer submits an
trending timelines. For new or existing services
application with a site diagram, estimated power
requiring conduit work, transformer work, or street
draw, and a $5,000 deposit (this is later applied
resurfacing on public property, charges may be
to project construction costs). A Line Designer is
incurred. The Service Planning Engineer will calculate
assigned to the project and begins to create a
projected charges based on the submitted plans.
“commitment drawing.” This portion of the project
LADWP also offers a feasibility study for the potential usually takes approximately 60 days. The applicant
project site that provides cost estimates of new or is then responsible for adding their portion of the
upgraded installations, without having to submit infrastructure to the drawing – conduits, boxes,
detailed engineering drawings and plans. There is a subsurface infrastructure – and ensuring entitlements
non-refundable $1,500 fee that is credited toward the and other permit requirements are received. Once
final cost of the project. the developer-installed infrastructure is complete,
the applicant and SMUD execute the final contract
The developer is responsible for scheduling a pre- and the applicant pays the grid connection project
construction meeting to review the service design, costs in full. SMUD typically has a 4-to-6-week
discuss inspection requirements, confirm the next steps minimum lead time once the project is ready to move
to complete the installation, and sign any necessary forward with construction. The entire process, from
documents. The developer is also responsible for applying to having the grid connection complete,
obtaining required permits and final electrical is approximately 4-6 months, assuming there are no
approval from the Los Angeles Department of Building hold-ups on the project developer side.
and Safety (LADBS) and installing electric service
infrastructure as detailed in the service design. To minimize costs and project delays, the SMUD
team recommends engaging with them early in the
Once the installation of the electrical service process and utilizing the site “due diligence” service.
infrastructure is completed, the developer arranges The SMUD Interconnection Information page outlines
final inspections by LADBS and LADWP and completes the interconnection process, and provides guidelines,
payment of service installations costs. LADWP then applications forms, and other helpful information.
schedules crews to install the remaining electrical
equipment and cables and energize the projects
(typically 6–8 weeks lead time). Opportunities to Streamline the
To save time and money, LADWP recommends Energization Process
beginning this process early, prior to selecting the
California’s major utilities have been trailblazers in
final site and signing agreements with the site host.
bringing charging infrastructure to the state. As the
Developers should be aware that LADWP has a
market for charging continues to grow, utilities can
one-site, one-service policy that can affect project
continue to take leadership by addressing barriers
designs and costs. Exceptions may be made and are
to station development and providing transparent
considered by LADWP on a case-by-case basis.
information about their processes and timelines.
More information on EV charger installation is Utilities should also strive to connect customers with
available on LADWP’s general EV programs website. the best rate options for each situation. Below are
specific recommendations to streamline the process
Sacramento Municipal Utility District and provide greater transparency for all parties:

Sacramento Municipal Utility District (SMUD) is one of Timeline Transparency: A lack of understanding of
the ten largest publicly-owned utilities in the United the timeline to add new electrical service can doom
States, providing electricity to Sacramento County a project and frustrate the station developer and AHJ
and a small portion of adjacent Placer County. involved. By providing timely and realistic estimates
of the timeline and cost estimates to develop a site
SMUD has a dedicated team for grid connection and complete construction, utilities can help station
projects in its territory. EV charging customers can developers plan and develop projects as planned.

56 ELECTRIC VEHICLE CHARGING STATION PERMITTING GUIDEBOOK | SECOND EDITION

Equally important is meeting those timelines in a be problematic for property owners as they limit
realistic manner. In December 2022, the CPUC potential future development of the site for other
established a 125-business days service energization purposes and may hinder a sale if the buyer has
average timeline that the utilities must meet, starting concerns.
from when a customer submits an application for
service through the EV Infrastructure Rules to the Proximity to Power Supply: Minimizing the distance
energization of the EVSE. The timeline includes from the utility system tie-in can reduce the cost of
25-business days for the AHJ permit process.70 both material and construction. Contractors working
on behalf of developers generally make suggestions
Dedicated Team for Plug-In Electric Vehicles: Utilities on where to place transformers to achieve this goal
can benefit from establishing a dedicated design and also minimize the easement impacts of utility
and project management team for EV projects. These connections. Working closely with developers and
teams should be equipped with technical expertise, utilities ahead of time can help achieve this goal.
familiar with the nuances of EV infrastructure
deployment, and can serve as a single point of Thorough Pre-Application Discovery: Establishing
contact for EV infrastructure requests. Incorporating the readily available power at a site or nearby
expert review into the process can help speed up transformer is essential to understand what type and
the process for everyone. Moreover, a dedicated size of project can be built without major upgrades.
team can ensure coordination is happening Utilities should provide this information early in
between utility departments and with external utility the process (e.g., before detailed site plans are
contractors, vendors or AHJs. Utilities should assess completed) to enable station developers to explore
whether they need additional staff resources to help possible sites and, when appropriate, adapt site sizing
support increased EV charging project applications and layout to minimize utility costs.
in the near term and future. Staffing should also be Collaborate to Plan and Prepare to Meet Installation
evaluated in the context of construction crews and Demand: AHJs can share information about the
whether additional resources are needed. number of installations under review and when they
Clear Understanding of Roles and Responsibilities: It is are likely to be approved given AB 970 timelines.
not always clear to station developers the delineation This can help utilities start their processes before AHJ
of energization responsibilities between the utility and approval so they can get the right resources in place
the station developer. Providing clear and up-front to minimize the time between permit approval and
guidance is helpful and allows station developers energization. Fleets can also communicate plans
to better plan and reduce the potential back-and- for infrastructure and electrification geographically
forth between the utility and developer. During the to help utilities plan power capacity and upgrades
process, utilizing online portals or tools can help needed to meet demand before receiving project
with project transparency and facilitate the handoff applications.
of responsibilities between the station developer Utility Equipment and Resource Availability: In
and utility.71 addition to all the customer-side design and
Property Ownership: In situations where the station equipment that must be procured, utilities may or
developer is not the landowner, it is important for may not need to procure utility-side equipment.
the station developer to complete their planning Fulfillment and delivery of equipment orders is a part
and negotiating with the property owner up front. of project timelines, hence early communication
The station developer should have the authority to
execute real property contracts so that they can
make any needed design adjustments.

Minimize Easement Footprints: IOUs have the 70 The average timeline excludes projects with a capacity exceeding
responsibility to site utility-side infrastructure along two-megawatts (MW), projects that need distribution line upgrades
via Electric Rule 15, and projects requiring substation upgrades. For
the shortest, cheapest, most practical route. The more information see Resolution E-5247.
utilities should—to the degree they are able— 71 PowerClerk for example helped to streamline interconnection of
incorporate into their processes ways to minimize rooftop solar.

the real estate required for easements. For example, 72 PG&E provides pre-approved easement language to customers to
avoid any potential delays in securing land rights, which is recognized
PG&E has implemented a lease in lieu of easement as a model easement process.
to help streamline the process.72 Easements can

SECOND EDITION | ELECTRIC VEHICLE CHARGING STATION PERMITTING GUIDEBOOK 57

with the utility is key to minimizing lead time. Other
influences outside the utility’s control can impact
equipment availability, such as the supply chain
disruptions witnessed during the COVID-19 pandemic.

Application Checklist: Providing a checklist with

information about what is required to apply for
energization, which is available to station developers
online, can help ensure submittal of complete
applications. To further streamline the process, the
utilities could work to create a standardized checklist
utilized across California’s major utilities.

Standardized Review Within Utility: Station developers

have reported inconsistency in feedback from
different project managers within the same utility,
which can prolong the approval process, adding
significant time and confusion. Utilities can help
to standardize the review process, guidance, and
feedback among their project managers.

Assigning Consistent Premise Addresses: Addressing

requirements differ by jurisdiction, which is a
significant challenge for EV charging projects. The
utilities may work to encourage standard addressing
templates.

58 ELECTRIC VEHICLE CHARGING STATION PERMITTING GUIDEBOOK | SECOND EDITION

Image courtesy of FLO
ELECTRIC VEHICLE CHARGING STATION PERMITTING GUIDEBOOK 59
Images courtesy of Electrify America
60 ELECTRIC VEHICLE CHARGING STATION PERMITTING GUIDEBOOK | SECOND EDITION
 PART 06:

Construction,
Commissioning, and
Operation
In this section, we explore the typical review junctures • Clearly communicate what documents should
for a charging station permit and how these junctures be brought to the inspection and who needs to
vary based on jurisdiction or charging station size and be present
discuss key steps station developers should be aware
of in the commissioning and operating process. • Employ, or contract with, certified electrical plan
reviewers and inspectors 74

Construction, Installation, • Allow for the option of inspections to be done

without the project electrician present, saving
and Review significant labor costs for the station developer
by not having to pay the electrician for idle time
After permits are issued and installation of the
during the entire inspection window
charger is complete, an inspection is required to
receive approval to operate the station. Typically,
building inspectors can be scheduled within 48
hours of the end of construction and installation.
The building inspector will ensure proper charger
installation, code compliant electrical work, and that
construction is in line with the permit granted by the
building department. If the charger is not constructed
and installed in accordance with the granted
permit, the building inspector will request changes
to the installation before final approval is given. Any
changes at this point should be limited to essential
health and safety alterations.

The building inspector evaluates the site to determine

whether the station passes key tests such as secure Image courtesy of Electrify America

mounting and fastening, the presence and function

of disconnect switches if applicable, adequate space
and protection from collision, proper identification
73 Another recommendation is for AHJ plan checkers to approve
and rating of all equipment, and other factors.
developer-specific “templates” or “master plans.” They no longer
would need to comb through details of a site, but simply check
To ease the review process, AHJs should: to make sure the template matches the template their manager
approved.
• Develop and share a concise review checklist 74 Within the renewable energy space (photovoltaics, energy storage
systems, and EVCS), underqualified inspectors can create avoidable
that gives permit applicants a clear view into
confusion and delays. AHJs should ensure they send qualified
what aspects of the charging installation will be inspectors that are familiar with these types of projects to ensure
timely inspections.
inspected before final approval 73

SECOND EDITION | ELECTRIC VEHICLE CHARGING STATION PERMITTING GUIDEBOOK 61

Some station developers report working with Station developers should plan for long-term
building inspectors who have a substantially different operations and maintenance as well as public safety
interpretation of the state building code accessibility considerations. For public or shared charging, station
regulations than the building official who approved developers should have a plan for dealing with
the permit. These discrepancies in review may potential vandalism or collision.
delay the project significantly and lead to costly
work to reach compliance. AHJs should harmonize Increasing Access to Public Charging
interpretations across staff and divisions as much
Station operators should be aware of the EVSE
as possible and provide clear mechanisms for
Standards Regulation requirements adopted by the
reconciling disparate interpretations. Any concern or
California Air Resources Board in 2019 to implement
disagreement about accessibility regulations should
the Electric Vehicle Charging Stations Open Access
be resolved prior to permit issuance and the start of
Act (Statutes of 2013, Chapter 418). The regulation
construction.
is for open payment and price notifications,
Before a charging station can be commissioned and so membership to an Electric Vehicle Service
opened to the public, the station developer also Provider (EVSP) is not a requirement for drivers. Key
needs to coordinate a final inspection with the utility. requirements include:
An inspector from the utility will evaluate the site
• On-site pricing disclosure before a driver uses
and ensure the conduit is complete, the structures
the charger 75
are set and backfilled, the bollards are secure, the
switchgear is installed properly, among other factors. • Public EVSE or kiosk on site must accept payment
Ideally, there will be close coordination between the using chip-enabled credit cards and contactless
utility and building department regarding on-site payment for mobile payment methods
inspections, with inspections from both happening
simultaneously or in close parallel. The station • The display of federal standardized power
cannot be turned on until approved by both parties. information
Especially in AHJs with municipal utilities where the
• Interoperable billing standard on networked
opportunity for collaboration is greater, AHJs should
stations
maintain open lines of communication with the local
utility and work to align their inspections whenever • Station location information reporting to the
possible. federal Alternative Fuel Data Center

Compliance requirements for payment hardware,

Commissioning and Operation roaming standards, display of fees, labeling, and
reporting will phase in over a multi-year timeline
After construction and review and before activating starting in 2021 for new charging stations.76 This is not
the station for operation, stations go through a required for electric vehicle charging equipment
brief commissioning process that typically takes provided at a private residence, reserved for the
a few hours (two days at most). For 120-volt or exclusive use of an individual driver, vehicle, or group
240-volt outlets, commissioning should merely
involve a quick confirmation that electricity flows
through the outlet. With higher levels of charging,
commissioning includes confirming all electrical
components and connectors are working and 75 Neither the Open Access Act nor CARB’s implementing regulations
require a screen on the EVSE, but pricing information must be
securely connected, verifying cellular connectivity if disclosed to the consumer prior to the transaction start which could
applicable, conducting torque checks, ensuring all include a placard or sticker in the absence of a screen. This differs
from the requirements of the Division of Measurements and Standards
covers are attached, and other steps as applicable. (DMS) Electric Vehicle Supply Equipment Regulation (see section
For sites requiring new electrical service that is not on Weights and Measures Certification). Per DMS’ EVSE Regulation,
devices are required to display for 15 second intervals the continuous
completed at the time of station installation, some aggregation of energy being dispensed. Many devices, if not all, do
or all of this review may wait until all electrical work display a current rate of energy transfer, but this is not a requirement.
The device must be labeled to identify its optimal energy transfer (e.g.,
is finished. Depending on the electric vehicle supply 12.5kW AC, 75kW DC, etc.), but the rate of energy transfer during any
equipment manufacturer involved, this review particular time of a transaction is not a requirement. The transaction
receipt is also required to provide the maximum rate of energy transfer
and commissioning may be performed either and type of current (AC or DC).
by a contractor from the manufacturer or by the 76 See CARB’s EVSE Standards Regulation Background and FAQs, for
contractor hired by the site host. more details on the regulation timeline, requirements, and penalties.

62 ELECTRIC VEHICLE CHARGING STATION PERMITTING GUIDEBOOK | SECOND EDITION

of drivers or vehicles, such as employees, or as a Zero-Emission Vehicle Station Sign Installation Guide
service by the producer of electric vehicles. for more information. Additional details on signage
requirements can be found in Chapter 21 of the
Weights and Measures Certification California Manual on Uniform Traffic Control Devices
(CA MUTCD).
The California Department of Food and Agriculture
(CDFA), Division of Measurement Standards (DMS), Encroachment permits and installation costs for
is responsible for the enforcement of California trailblazer signs are the responsibility of the station
weights and measures laws and regulations. In the developer. However, the purchase and installation of
context of electric vehicle charging, DMS’ programs highway signage will be covered by Caltrans at no
are organized to ensure that a kilowatt hour (kWh) cost to the station developer.
dispensed in a commercial retail environment
equals a kilowatt hour received. This helps ensure
fair competition for industry and accurate value
comparison for consumers.

In April 2020, CDFA adopted the Electric Vehicle

Supply Equipment Regulation, making EVSE device
standards and requirements from the National
Institute of Standards and Technology Handbook
44 enforceable in California.77 All new commercial
alternating current (AC) EVSE installed on or after
January 1, 2021 are fully subject to the regulation and
new commercial direct current fast charger EVSE
installed on or after January 1, 2023 are fully subject
to the regulation.78,79 DMS has posted Frequently
Asked Questions about the 2020 Electric Vehicle
Supply Equipment Regulation on its Zero-Emission
Vehicle Projects webpage.

In April 2021, DMS adopted regulations establishing

the first-ever inspection frequencies for the oversight
of EVSE (i.e., biennially), allowing state and local
officials to determine whether the device is labeled
and dispensing fuel correctly and whether the
business is adhering to the officially adopted method
of sale and unit prices. State and county officials have
already begun inspecting and testing EVSE used for
Image courtesy of Adopt a Charger
commercial purposes. Since the EVSE regulations
became effective in January 2021, county officials are
quickly ramping up their efforts to inspect the ever-
increasing number of charging stations.

Readers are encouraged to track DMS’s website for

77 The EVSE regulation comprises requirements in NIST Handbook 44,
updates on the regulation and its implementation. Section 3.40. with adopted exceptions and additions. For more
information, see Final Regulation Endorsed and Filed with the
Signs Secretary of State and Final Statement of Reasons.

78 All commercial AC EVSE installed prior to January 1, 2021 may

continue in operation, as is, but must comply with the regulation by
When advertising the presence of a station, chargers January 1, 2031. All commercial DCFC EVSE installed prior to January
that are accessible to the public 16 or more hours per 1, 2023 may continue in operation, as is, but must comply with the
regulation by January 1, 2033.
day and located within three miles driving distance
79 The following EVSE are not subject to the regulation: 1) EVSE
of a state highway interchange are eligible for free wholly owned and operated by public utilities, public entities, and
highway signage, providing the local jurisdiction municipalities; 2) EVSE which are not used for commercial purposes;
e.g., EVSE used for residential or workplace charging exclusively used
places directional signage, if necessary, from the by employees; 3) EVSE that dispense electricity as motor vehicle
freeway to the site (also known as trailblazer signs) fuel at no cost to the consumer; and 4) EVSE that deliver wholesale
electricity.
on the local streets and roadways. Refer to the

SECOND EDITION | ELECTRIC VEHICLE CHARGING STATION PERMITTING GUIDEBOOK 63

Image courtesy of EVgo

64 ELECTRIC VEHICLE CHARGING STATION PERMITTING GUIDEBOOK | SECOND EDITION

 PART 07:

Looking
Forward

The State of California is firmly committed to the state momentum, and leads to national momentum,
success of zero-emission vehicles. Too much is at stake all of which benefits our shared resources–natural
to fail. Regions of California suffer from the worst air and man-made.
quality in the nation and the transportation sector
continues to be the largest source of our greenhouse GO-Biz intends for this Guidebook to serve as the
gas emissions. While the state can write laws, set continuation of an intentional effort for ongoing ZEV
targets, and dedicate staff to the cause, the mission infrastructure development improvement, not the
to replace internal combustion vehicles with zero- end of a process. With the help of local leaders and
emission vehicles will only be achieved with focus station developers, we will be collecting and sharing
at the local level–deploying groups of stations and lessons learned, instructive case studies, and actively
vehicles community by community. reaching out to communities that are on their way
to creating a robust electric vehicle charging station
Ultimately, it takes local leadership to scale zero- permit approval process.
emission vehicles across the state. Ideally, ZEV
initiatives will have strong support from city or county If you have insights or ideas that can help improve
leadership–but to get started, they do not have to. station deployment processes, please share them with
Station developers report that some of the best cities the GO-Biz ZEV team (zev@[Link]) and anyone
and counties to work with are those with dedicated who has a role to play in the station development
front-line staff pushing from the bottom up. To date, process. The keys to success are in our hands.
one of the best predictors of an easy permitting
process is whether city staff drive zero-emission
vehicles. If they do, projects tend to be extremely
welcome, and the city is more likely to have engaged
in planning to help enable ZEV deployment. These
drivers understand—firsthand—the importance of
infrastructure.

This local leadership is crucial for a host of reasons.

Nobody knows a city or county’s permitting
processes, constraints, and opportunities like city and
county staff. They know how to avoid red flags and
streamline processes. Cities and counties willing to
work with station developers to streamline processes
create opportunities for statewide improvement. A
process breakthrough in one city can open the door
for improvement in another. This local momentum
often turns into regional momentum, which feeds

SECOND EDITION | ELECTRIC VEHICLE CHARGING STATION PERMITTING GUIDEBOOK 65

 PART 08:

Definitions
and Additional
Resources
Key Terms and Definitions on the charger speed and state of charge of the
battery. Most PHEVs, and some lower-range BEVs are
Accessibility: Under the federal Americans with not equipped with DCFC ports.
Disabilities Act (ADA), most public accommodations
are required to meet federal regulations ensuring Demand charge: The charge from a utility that
equitable use of services by people with disabilities. corresponds to the peak energy transfer rate over a
Requirements cover the layout and design of given period of time.
physical space and components, design elements Electric vehicle charging station (EVCS): One or
and signage, visual and auditory cues, and more. more electric vehicle charging spaces served by an
In California, the California Building Code (CBC) electric vehicle charger or other charging equipment.
and the California Green Building Code (CALGreen) Where a multiport electric vehicle charger can
regulate accessibility for most public charging simultaneously charge more than one vehicle, the
stations. number of electric vehicle charging stations shall
Authority having jurisdiction (AHJ): The local entity, be considered equivalent to the number of electric
usually the city or county, that has planning and vehicles that can be simultaneously charged.
building authority over a specific site. Electric vehicle supply equipment (EVSE): The
Charging management: Also known as load hardware, including connectors, fixtures, devices,
balancing. Charging management describes and other components required to charge an
a set of hardware and software tools that can electric vehicle.
intelligently throttle the amount of electricity going Level 1 charging: The slowest charging speed,
to charging stations to charge more vehicles with less adding 3-5 miles of range per hour of charging.
electrical capacity. If many vehicles are plugged Level 1 charging is the equivalent of plugging into an
in at once, charging management can be used to everyday outlet and is typically used where a car will
proportionately decrease the charging speed of be parked for a long period of time, such as overnight
one or more of the vehicles in real time, so that more while the driver is sleeping or at the workplace.
cars can be charged without having to significantly
expand electrical capacity. On-site battery storage Level 2 charging: A medium charging speed 14-35
can also be used to minimize grid impacts and avoid miles of range per hour of charging. Level 2 charging
having to upgrade utility electric supply. is the equivalent of plugging into a dryer or other
large appliance outlet.
DC fast charging (DCFC): Direct current fast charging,
the fastest charging currently available. DCFCs Light, medium, and heavy-duty: These are vehicle
currently range from 50 kilowatt (kW) up to 350kW, classifications based on the weight and engine of a
adding about 3 to 20 miles per minute, depending vehicle. Light-duty vehicles include most passenger

66 ELECTRIC VEHICLE CHARGING STATION PERMITTING GUIDEBOOK | SECOND EDITION

vehicles. Medium-duty vehicles include buses and Zero-emission vehicle (ZEV): A zero-emission vehicle
forklifts. Heavy-duty include the heaviest trucks is any type of vehicle that has no tailpipe emissions.
and trailers. These cars run on electric motors and are powered
by electricity delivered from batteries or hydrogen
Station developer: A public or private entity and fuel cells. In contrast to conventional internal
that develops charging stations, often a station combustion vehicles, ZEVs prevent air pollution,
development company, manufacturer of electric lower greenhouse gas emissions, and help integrate
vehicle supply equipment, investor-owned or renewable energy into the transportation sector.
publicly-owned utility, automaker, nonprofit, or other
interested party. Station developers have a variety of
business models, with some engaging in every step of
the development process and owning and operating
their stations, while others only engage in parts of
the process.

SECOND EDITION | ELECTRIC VEHICLE CHARGING STATION PERMITTING GUIDEBOOK 67

ZEV Readiness Scorecard Permitting

The Governor’s Office of Business and Economic The below “Permitting Electric Vehicle Charging
Development has established a Plug-in Electric Stations Scorecard” serves as the foundation for
Vehicle Charging Station Readiness landing page assessing statewide compliance with California’s
([Link] electric vehicle charging station permit streamlining
vehicles/plug-in-readiness/) that will be used to law (AB 1236 and AB 970). Communities do not
track station development streamlining, resulting in a need to create ordinances and checklists from
shared resource of best practices, ordinances, and scratch. California Building Officials (CALBO) offer
checklists. GO-Biz anticipates that the ZEV Readiness AB 1236 compliance toolkits for both small and large
page will evolve and improve through time with jurisdictions. These toolkits include model ordinance
stakeholder participation and feedback. 80 templates, adoption timelines, and supporting staff
reports, as well as a sample permitting checklist. 81

Permitting Electric Vehicle Charging Stations Scorecard: All cities and counties, including charter
cities, in California are required to comply with AB 1236 (Chiu, 2015) and AB 970 (McCarty, 2021).

Scoring Criteria: Complete If:

1. Streamlining Ordinance Streamlining ordinance has been adopted

Ordinance creating an expedited, streamlined permitting process
for electric vehicle charging stations (EVCS) including Level 2 and
direct current fast chargers (DCFC) has been adopted.

2. Permitting checklists covering L2 and DCFC Permitting checklist is available and easily found on city
Checklist of all requirements needed for expedited review posted or county website
on city or county website.

3. Administrative approval of EVCS The streamlining ordinance states that permit

EVCS projects that meet expedited checklist are administratively applications that meet checklist requirements will be
approved through building or similar non-discretionary permit. approved through non-discretionary permit (or similar)

4. Approval limited to health and safety review The streamlining ordinance states that no discretionary
EVCS project review limited to health and safety requirements use permit is required and permit approval will be
found under local, state, and federal law. limited to health and safety review

5. Electronic signatures accepted Electronic signatures accepted on City or County

AHJ accepts electronic signatures on permit applications.* website (usually specified in the ordinance)

6. EVCS not subject to association approval The streamlining ordinance states that EVCS permits do
EVCS permit approval not subject to approval of an association (as not require association approval
defined in Section 4080 of the Civil Code).

7. One complete deficiency notice The streamlining ordinance dictates that a written
AHJ commits to issuing one complete written correction notice correction notices must detail all deficiencies
detailing all deficiencies in an incomplete application and any
additional information needed to be eligible for expedited permit
issuance.

* If a city or county determines it is unable

to accept electronic signatures on all
forms, the permit streamlining ordinance 80 Please send information and feedback to zev@[Link].
shall state the reasons. 81 Note: at the time of publication of this document, CALBO’s sample
permitting checklist resides only in the small jurisdiction toolkit.

68 ELECTRIC VEHICLE CHARGING STATION PERMITTING GUIDEBOOK | SECOND EDITION

Furthermore, the GO-Biz Permit Streamlining Map Grading is based on relevant ordinances, checklists,
acts as a repository of streamlining ordinances and and stakeholder feedback. It is important to note that
checklists of jurisdictions throughout California. The the intent of this tool is to assess permit streamlining
included information and links can assist cities and from a holistic perspective. While AB 1236 and AB 970
counties in crafting ordinance and checklists to guides the assessment, this effort is not intended to
become EVCS Permit Ready (and compliant with determine compliance with both laws.
AB 1236 and AB 970).

AB 970 timelines:
EVCS Permit Ready Score:
AHJs are required to meet the EVSE permit review and
approval timelines established by AB 970: Green: City or County is EVCS Permit Ready, charging
infrastructure permitting is streamlined
• Projects with 1-25 stations—5 business days to
deem an application complete or incomplete. 20
business days to approve/deny the project after Yellow: City or County EVCS permit streamlining is in
progress, or partially complete
administrative review limited to health and safety.
The project will be deemed approved if no action
is taken within these timelines. Red: City or County is not streamlined for EVCS
permitting
• Projects with 26 or more stations—10 business days
to deem an application complete or incomplete.
40 business days to approve/deny the project after
administrative review that is limited to health and
safety. The project will be deemed approved if no
action is taken within these timelines.

AB 970 implementation dates:

• January 1, 2022 for cities/counties above
200,000 residents.

• January 1, 2023 for cities/counties below

200,000 residents.

How scoring works:

Cities and counties that meet at least 6 of the first 7
checklist criteria will be highlighted as streamlined
“EVCS Permit Ready” if the missing criteria does not
have a negative impact in practice. Jurisdictions
must have a checklist posted online (criteria 2)
covering both residential and commercial projects
in order to be considered streamlined “EVCS
Permit Ready.” The checklist (criteria 2) cannot
be considered the one missing criteria. All criteria
must be verifiable in ordinances, checklists or EVCS
permitting webpages.

Prior to AB 970 (2021), local jurisdictions received a

bonus point for committing to expedited timelines.
All cities and counties are now required to meet the
mandatory timelines established by AB 970 and will
no longer receive a bonus point. However, GO-Biz
will look to develop a way to highlight jurisdictions
that move faster than the required timelines
described above.

SECOND EDITION | ELECTRIC VEHICLE CHARGING STATION PERMITTING GUIDEBOOK 69

Electric Vehicle Charging Station Are EVCS projects that meet expedited checklist
parameters administratively approved through
Streamlining All-Star Checklist building or similar non-discretionary permit?
(State Permit Streamlining Requirements)
The following checklists provide a series of questions
that various stakeholders can ask to help ensure Are EVCS projects reviewed with the focus on
streamlining of the electric vehicle charging health and safety, without triggering planning/
station deployment system. Each of the questions zoning review? (State Permit Streamlining
is anchored in the Guidebook text with sections Requirements), (Common Obstacles)
included for reference.
Has the AHJ committed to responding to
Planning for Zero-Emission Vehicles incomplete permit applications with one
complete written correction notice that details
A Checklist for Authorities Having Jurisdiction all deficiencies and any additional information
(AHJs – usually a city or county) needed to be eligible for expedited permit
issuance? (Complying with AB 1236)
Are ZEVs, and charging and fueling needs,
incorporated within documents such as the Does the AHJ accept electronic submittals and
general plan, capital improvement plan, signatures on permit applications? (State Permit
climate action plan, and design guidelines? Streamlining Requirements), (Complying with AB
(Planning for Charging Growth) 1236 and AB 970)

Has the AHJ participated in the development Has the AHJ established that EVCS permit
and implementation of a regional ZEV readiness approval is not subject to approval of an
plan? (Planning for Charging Growth) association (as defined in Section 4080 of the
Civil Code)? (Table 3: Electric Vehicle Charging
Has the AHJ established by ordinance, zoning Station Permit Streamlining Requirements & Best
code or bulletin that electric vehicle charging Practices)
spaces count as one or more parking spaces
for zoning purposes? (Parking Stall Requirements Does the permit approval process meet
and Charger Installation) required AB 970 turnaround timelines? (AB 970
Requirements)
Has the AHJ adopted voluntary reach
building codes for EV charging? (Advancing Permitting Best Practices:
Infrastructure through Building Standards)
Is the EVCS permitting process, including fees,
Does the AHJ have an enforcement policy timelines, and required application materials,
and plan for electric vehicle charging spots? detailed on the AHJ’s website? (Additional
(Parking Enforcement) Permitting Best Practices)

Permitting Electric Vehicle Charging Stations Has a ZEV Infrastructure permitting

Requirements (per AB 1236, 2015 and ombudsperson been appointed or identified to
AB 970, 2021): help applicants through the entire permitting
process? (Best Practice – Identify a ZEV
Does the AHJ have an ordinance or ordinances
Permitting Ombudsperson)
creating an expedited, streamlined permitting
process for electric vehicle charging stations Has the AHJ posted fact sheets or guidance
(EVCS) including Level 2, direct current fast documents for permitting and inspecting
chargers (DCFC), and wireless inductive charging stations at single-family home,
charging? (State Permit Streamlining multifamily home, workplace, public (L2 and
Requirements), (Complying with AB 1236) DCFC), and commercial medium and heavy-
duty locations? (Additional Permitting Best
Does the AHJ have a checklist of all
Practices)
requirements needed for expedited review
posted on the AHJ website? (State Permit Are pre-application meetings with
Streamlining Requirements) knowledgeable AHJ staff offered? (Additional
Permitting Best Practices)

70 ELECTRIC VEHICLE CHARGING STATION PERMITTING GUIDEBOOK | SECOND EDITION

 Has the AHJ has published an ordinance or Has the station developer engaged the local
bulletin clarifying that a plug-in electric vehicle utility prior to submitting a permit application?
charging space counts as one or more parking (Preparing a Permit Application), (Timeline for
spaces for zoning purposes? (Parking Stall Communicating with Your Utility)
Requirements and Charger Installation)
Energization Best Practices
Are concurrent reviews made available
for building and electrical plan checks A checklist for station developers and utilities
(and planning, if deemed necessary)?
Has the station developer carefully reviewed the
(Understanding the Permit Process)
energization process and engaged the utility
Are EVCS classified as an accessory use to a site, early in the development process? (Major Utility
not as a traditional fueling station? (Additional Energization Processes, major utility processes
Permitting Best Practices) are shared on subsequent pages)

Does the expedited permit review process If available, has the station developer used
encourage permit reviewers to conditionally maps to conduct a preliminary assessment of
approve permits (aka “approved as noted”)? the hosting and line capacity at the project
(Additional Permitting Best Practices) site(s)? (Understanding Energization)

Does the AHJ have a concise review checklist Have clear roles and responsibilities been
for building inspections, showing what will established between the station developer and
be inspected and what documents will be utility? (Opportunities to Streamline Energization)
required? (Construction, Installation, and
Has the utility provided timely and realistic
Review)
energization timelines to the project applicant?
Does the AHJ allow inspections to proceed (Opportunities to Streamline Energization)
without an electrician present whenever
Has the utility provided a complete application
possible? (Construction, Installation, and Review)
checklist? (Opportunities to Streamline
Permit Application Best Practices Energization)

A checklist for EVCS station developers Does the utility have a dedicated team to help
shepherd EVSE projects through the energization
Has the station developer carefully reviewed the process? (Opportunities to Streamline
AHJ’s permitting requirements (checklists, forms, Energization)
etc.)? (Preparing a Permit Application)
Does the utility provide information on available
Does the application provide all the information power on a connection or nearby transformer
required by the AHJ? without requiring detailed site plans?
(Opportunities to Streamline Energization)
Are the permit application diagrams
consistent? Has the review process been standardized
within each utility project management team?
Are permit application load calculations (Opportunities to Streamline Energization)
complete? Have they been double
checked? (What to Include in Your Does the station developer have authority from
Application) the property owner to make any necessary
design adjustments? (Opportunities to
Has the station developer designed the project Streamline Energization)
to comply with accessibility regulations?
(Part 3: Accessibility, What to Include in Your Has the utility made an effort to minimize
Application) easement footprints? (Opportunities to
Streamline Energization)
For complicated projects or project types that
have not been approved by the AHJ, has the Have the utility and station developer discussed
station developer requested a pre-application utility-side equipment and timelines for orders,
meeting? (Pre-Application Meetings) if needed? (Opportunities to Streamline
Energization)

SECOND EDITION | ELECTRIC VEHICLE CHARGING STATION PERMITTING GUIDEBOOK 71

AB 1236 (Chiu, 2015) and AB 970 standards and regulations necessary to ensure
that the electric vehicle charging station will not
(McCarty, 2021) – Today’s Law have a specific, adverse impact upon the public
As Amended health or safety. However, if the building official
of the city, county, or city and county makes a
SECTION 1. finding, based on substantial evidence, that the
electric vehicle charging station could have a
Section 65850.7 of the Government Code is amended specific, adverse impact upon the public health
to read: or safety, the city, county, or city and county may
require the applicant to apply for a use permit.
(a) The Legislature finds and declares all of the
following: (c) A city, county, or city and county may not deny
an application for a use permit to install an
(1) The implementation of consistent statewide
electric vehicle charging station unless it makes
standards to achieve the timely and cost-
written findings based upon substantial evidence
effective installation of electric vehicle
in the record that the proposed installation
charging stations is not a municipal affair, as
would have a specific, adverse impact upon the
that term is used in Section 5 of Article XI of the
public health or safety, and there is no feasible
California Constitution, but is instead a matter
method to satisfactorily mitigate or avoid the
of statewide concern. Therefore, this section
specific, adverse impact. The findings shall include
applies to all cities, including charter cities.
the basis for the rejection of potential feasible
(2) It is the intent of the Legislature that local alternatives of preventing the adverse impact.
agencies not adopt ordinances that create
(d) The decision of the building official pursuant to
unreasonable barriers to the installation of
subdivisions (b) and (c) may be appealed to the
electric vehicle charging stations and not
planning commission of the city, county, or city
unreasonably restrict the ability of homeowners
and county.
and agricultural and business concerns to
install electric vehicle charging stations. (e) Any conditions imposed on an application to
install an electric vehicle charging station shall be
(3) It is the policy of the state to promote and
designed to mitigate the specific, adverse impact
encourage the use of electric vehicle
upon the public health or safety at the lowest
charging stations and to limit obstacles to
cost possible.
their use.
(f) (1) An electric vehicle charging station shall meet
(4) It is the intent of the Legislature that local
applicable health and safety standards and
agencies comply not only with the language
requirements imposed by state and local
of this section, but also the legislative intent to
permitting authorities.
encourage the installation of electric vehicle
charging stations by removing obstacles (2) An electric vehicle charging station
to, and minimizing costs of, permitting for shall meet all applicable safety and
charging stations so long as the action does performance standards established by the
not supersede the building official’s authority California Electrical Code, the Society of
to identify and address higher priority life- Automotive Engineers, the National Electrical
safety situations. Manufacturers Association, and accredited
testing laboratories such as Underwriters
(b) A city, county, or city and county shall
Laboratories and, where applicable, rules of
administratively approve an application
the Public Utilities Commission regarding safety
to install electric vehicle charging stations
and reliability.
through the issuance of a building permit or
similar nondiscretionary permit. Review of the (g) (1) On or before September 30, 2016, every city,
application to install an electric vehicle charging county, or city and county with a population
station shall be limited to the building official’s of 200,000 or more residents, and, on or
review of whether it meets all health and safety before September 30, 2017, every city, county,
requirements of local, state, and federal law. The or city and county with a population of less
requirements of local law shall be limited to those than 200,000 residents, shall, in consultation

72 ELECTRIC VEHICLE CHARGING STATION PERMITTING GUIDEBOOK | SECOND EDITION

 with the local fire department or district Guidebook” published by the Office of
and the utility director, if the city, county, or Planning and Research. A city, county, or city
city and county operates a utility, adopt an and county may adopt an ordinance that
ordinance, consistent with the goals and intent modifies the checklists and standards found
of this section, that creates an expedited, in the Guidebook due to unique climactic,
streamlined permitting process for electric geological, seismological, or topographical
vehicle charging stations. In developing an conditions. If a city, county, or city and county
expedited permitting process, the city, county, determines that it is unable to authorize the
or city and county shall adopt a checklist of acceptance of an electronic signature on all
all requirements with which electric vehicle forms, applications, and other documents in
charging stations shall comply to be eligible lieu of a wet signature by an applicant, the
for expedited review. An application that city, county, or city and county shall state, in
satisfies the information requirements in the the ordinance required under this subdivision,
checklist, as determined by the city, county, or the reasons for its inability to accept electronic
city and county, shall be deemed complete. signatures and acceptance of an electronic
Upon confirmation by the city, county, or city signature shall not be required.
and county of the application and supporting
documents being complete and meeting the (h) A city, county, or city and county shall not
requirements of the checklist, and consistent condition approval for any electric vehicle
with the ordinance, a city, county, or city and charging station permit on the approval of
county shall, consistent with subdivision (b), an electric vehicle charging station by an
approve the application and issue all required association, as that term is defined in Section 4080
permits or authorizations. However, the city, of the Civil Code.
county, or city and county may establish a (i) The following definitions shall apply to this section:
process to prioritize competing applications
for expedited permits. Upon receipt of an (1) “A feasible method to satisfactorily mitigate or
incomplete application, a city, county, or city avoid the specific, adverse impact” includes,
and county shall issue a written correction but is not limited to, any cost-effective method,
notice detailing all deficiencies in the condition, or mitigation imposed by a city,
application and any additional information county, or city and county on another similarly
required to be eligible for expedited permit situated application in a prior successful
issuance. An application submitted to a city, application for a permit.
county, or city and county that owns and
operates an electric utility shall demonstrate (2) “Electronic submittal” means the utilization of
compliance with the utility’s interconnection one or more of the following:
policies prior to approval. (A) Email.
(2) The checklist and required permitting (B) The internet.
documentation shall be published on a
(C) Facsimile.
publicly accessible internet website, if the city,
county, or city and county has an internet (3) “Electric vehicle charging station” or
website, and the city, county, or city and “charging station” means any level of electric
county shall allow for electronic submittal vehicle supply equipment station that is
of a permit application and associated designed and built in compliance with Article
documentation, and shall authorize the 625 of the California Electrical Code, as it
electronic signature on all forms, applications, reads on the effective date of this section, and
and other documentation in lieu of a wet delivers electricity from a source outside an
signature by an applicant. In developing electric vehicle into a plug-in electric vehicle.
the ordinance, the city, county, or city and
county may refer to the recommendations (4) “Specific, adverse impact” means a significant,
contained in the most current version of quantifiable, direct, and unavoidable impact,
the “Plug-In Electric Vehicle Infrastructure based on objective, identified, and written
Permitting Checklist” of the “Zero-Emission public health or safety standards, policies,
Vehicles in California: Community Readiness or conditions as they existed on the date the
application was deemed complete.

SECOND EDITION | ELECTRIC VEHICLE CHARGING STATION PERMITTING GUIDEBOOK 73

SEC. 2. (A) Five business days after submission of the
application to the city, county, or city and
Section 65850.71 is added to the Government Code, county, if the application is for at least
to read: 1, but not more than 25 electric vehicle
charging stations at a single site.
65850.71.
(B) Ten business days after submission of the
(a) The Legislature finds and declares both of the
application to the city, county, or city and
following:
county, if the application is for more than
(1) An electric vehicle charging station has a 25 electric vehicle charging stations at a
significant economic impact in California single site.
and is not a municipal affair, as the term is
(c) (1) An application to install an electric vehicle
used in Section 5 of Article XI of the California
charging station shall be deemed approved
Constitution, but is instead a matter of
if the applicable time period described in
statewide concern. Therefore, this section
paragraph (2) has elapsed and all of the
applies to all cities, including charter cities.
following are true:
(2) Table 3 of the Governor’s Office of Business
(A) The building official of the city, county, or
and Economic Development (GO-Biz)
city and county has not administratively
Electric Vehicle Charging Station Permitting
approved the application pursuant to
Guidebook, published July 2019, recommends
subdivision (b) of Section 65850.7.
best practices for electric vehicle supply
equipment permitting that would establish (B) The building official of the city, county,
a 15-day timeline and satisfy the intent of or city and county has not made a finding,
Assembly Bill 1236 (Chapter 598 of the Statutes based on substantial evidence, that the
of 2015). electric vehicle charging station could
have a specific adverse impact upon
(b) (1) An application to install an electric vehicle
the public health or safety or required
charging station submitted to the building
the applicant to apply for a use permit
official of a city, county, or city and county
pursuant to subdivision (b) of
shall be deemed complete if, after the
Section 65850.7.
applicable time period described in
paragraph (2) has elapsed, both of the (C) The building official of the city, county,
following are true: or city and county has not denied the
permit pursuant to subdivision (c) of
(A) The building official of the city, county,
Section 65850.7.
or city and county has not deemed the
application complete, consistent with the (D) An appeal has not been made to the
checklist created by the city, county, or planning commission of the city, county, or
city and county pursuant to subdivision (g) city and county, pursuant to subdivision (d)
of Section 65850.7. of Section 65850.7.
(B) The building official of the city, county, or (2) For purposes of paragraph (1), “applicable
city and county has not issued a written time period means” either of the following:
correction notice detailing all deficiencies
in the application and identifying any (A) Twenty business days after the application
additional information explicitly necessary was deemed complete, if the application
for the building official to complete a is for at least 1, but not more than 25
review limited to whether the electric electric vehicle charging stations at a
vehicle charging station meets all single site.
health and safety requirements of local,
(B) Forty business days after the application
state, and federal law, consistent with
was deemed complete, if the application
subdivisions (b) and (g) of Section 65850.7.
is for more than 25 electric vehicle
(2) For purposes of paragraph (1), “applicable charging stations at a single site.
time period means” either of the following:

74 ELECTRIC VEHICLE CHARGING STATION PERMITTING GUIDEBOOK | SECOND EDITION

(d) If an electric vehicle charging station and any
associated equipment interfere with, reduce,
eliminate, or in any way impact the required
parking spaces for existing uses, the city, county,
or city and county shall reduce the number of
required parking spaces for the existing uses
by the amount necessary to accommodate
the electric vehicle charging station and any
associated equipment.

(e) If the electric vehicle charging station is being

installed in an area that receives electrical
service from a local publicly owned electric
utility, this section does not expand or restrict the
local publicly owned electric utility’s role and
responsibility in providing new electric service to
the electric vehicle charging station in a manner
consistent with safety, reliability, and engineering
requirements.

(f) This section shall become operative on

January 1, 2022, but for every city, county, or city
and county with a population of less than 200,000
residents, this section shall apply beginning on
January 1, 2023.

SECOND EDITION | ELECTRIC VEHICLE CHARGING STATION PERMITTING GUIDEBOOK 75

Select Station Development
Resources
Bay Area and Monterey Bay Regions PEV Local Best
Practices Document. Prepared for the Bay Area Air
Quality Management District by ICF International
(August 2012).

Electric Vehicle Charger Selection Guide. Redwood

Coast Energy Authority, the Schatz Energy Research
Center, the Local Government Commission/
Civic Spark, and the Siskiyou County Economic
Development Council (Updated January 2018).

Electric Vehicle Charging Station Permitting and

Inspection Best Practices: A Guide for San Diego
Region Local Governments, Center for Sustainable
Energy, Plug-In SD (June 2016).

Creating EV-Ready Towns and Cities: A Guide to

Planning and Policy Tools Electric Vehicle Supply
Equipment Support Study. Prepared for New York
State Energy Research and Development Authority
and Transportation and Climate Initiative by
WXY Architecture + Urban Design and Energetics
Incorporated for New York (November 2012).

Lessons from Early Deployments of Electric Vehicle

Charging Stations: Case Studies from the Northeast
and Mid-Atlantic Regions. Prepared for the
Transportation Climate Initiative by Logios (May 2013).

Plug-In Electric Vehicle Handbook for Workplace

Charging Hosts. U.S. Department of Energy Clean
Cities (August 2013).

Plugging In: Speeding the Adoption of Electric

Vehicles in California with Smart Local Policies.
Environment California Research & Policy Center and
Frontier Group (February 2018).

South Bay Cities Plug-in Electric Vehicle Deployment

Plan. Prepared for the Southern California Association
of Governments by the UCLA Luskin Center for
Innovation (June 2013).

Streamlining the Permitting and Inspection Process for

Plug-In Electric Vehicle Home Charger Installations
Report and Recommendations. California Plug-In
Electric Vehicle Collaborative (July 2012).

76 ELECTRIC VEHICLE CHARGING STATION PERMITTING GUIDEBOOK | SECOND EDITION

Curbside Charging Best • Consider the proximity of other charging
stations and volume of EV adoption and use
Practices in an area to ensure stations are distributed
equitably across the community and to avoid
Below are established best practices for each
duplication of deployments.
phase of curbside charging deployment –– (1) goal
setting, (2) site selection, (3) technology and vendor • Review streetlights or poles for mechanical
selection, (4) utility coordination, (5) community integrity (e.g. wall thickness, weld strength) to
education and engagement, (6) installation, see if it can tolerate the EV charging station’s
operations & maintenance, and (7) measuring additional load). Also review electrical cable
success. integrity (e.g. cable brittleness).
1. Goal Setting 3. Technology and Vendor Selection
• Define the overall objective of the deployment • Conduct an initial review of utility poles
first. Some goals or metrics to consider could to determine suitability of selection and
include: placement, if utility pole mounted chargers
are an option to be considered.
» Even distribution of infrastructure across a
geography or territory • Mount chargers on streetlights only if the
streetlights currently use LED lighting or the
» Providing an amenity to drivers to increase
infrastructure owner intends to upgrade them
traffic at downtown businesses
to LEDs.
» Providing home charging for multi-family
• Use master and auxiliary units to facilitate later
housing residents
scalability –– by deploying master units initially,
» Providing public charging options for it can extend the deployment to auxiliary units
ridesharing drivers to reduce civil engineering and electrical work
later on.
» Deploying chargers in low-income
communities or generally harder to serve • Use rugged hardware — this helps the station
areas endure the elements, abuse, and vandalism.
Use aluminum enclosures that are resistant to
» Reducing costs, operating at cost neutral, or weather and vandalism, lockable charging
perhaps creating revenue connector to avoid unwanted use and
tampering, powder coated enclosure that is
» High utilization or high turnover
resistant to graffiti, and a retractable cable
2. Site Selection management system to avoid cables
being left on the ground and acting as a
• To maximize utilization of any project, deploy tripping hazard.
chargers in close proximity to businesses,
workplaces, and residential or recreational • Consider using custom designs if necessary
areas. City planning departments are key to better fit the charger on available
to identifying these locations. Co-location infrastructure.
near amenities and convenience to access
4. Utility Coordination
increases use of the station.
• Review utility metering requirements and how
• To minimize costs and streamline permitting,
it impacts proposed charging stations.
coordinate with utilities to identify areas with
convenient access to power. • Consider participating early-on in site
selection evaluations with data on load and
• Deploy stations in areas that (1) are easily
capacity, right of way access, and permitting
walkable for ease of pedestrian access, (2)
for the locations.
have a high concentration of businesses
to increase utilization, and (3) allow drivers • Encourage varying utility rates for EV charging
to park for a long time to ensure usability purposes to help stimulate EV adoption
(minimum of 2 hours). initiatives.

SECOND EDITION | ELECTRIC VEHICLE CHARGING STATION PERMITTING GUIDEBOOK 77

 • Coordinate with the Department of » Once connected, the charging cable
Transportation and parking authorities to remains (1) off the ground and is not an
coordinate access to construction areas, obstacle to pedestrians and (2) off the
and once deployed, to implement parking vehicle surface so that it does not damage
restrictions to ticket internal combustion it; and
engine vehicles who park in EV spots.
» Provides optimal conditions for
5. Community Education and Engagement maintenance, including enough overhead
clearance and access to the charger
• Engaging with the local community is critical head and panel (if applicable) without
to identifying their needs, addressing their redirecting pedestrian traffic.
questions and concerns, and soliciting their
input on where chargers should optimally • Deploy stations 1 to 3 blocks away from a main
be placed. street. Installing on main streets can be more
expensive or difficult because it has to be shut
• Engage the following stakeholders: local down or is not friendly for driver access.
businesses, community-based organizations,
faith-based organizations, residents, property • The cable reach must be able to service all
owners and management companies, school sides of a parked vehicle.
boards, park and recreational staff, parking
• The width of the sidewalk should be wide
enforcement, street cleaning services, and the
enough to socialize acceptance by
local utility.
pedestrians.
• Use local community groups to help notify
• Install the charger as close as possible to the
businesses and residents about the incoming
curbside to reduce the distance between
stations and provide materials on the benefits
the charger and vehicle to optimize cable
of EVs.
management.
• Hold multiple community listening sessions to
• For pole-mounted chargers, consider whether
give the public an opportunity for input and to
to elevate it higher up on the utility pole –
ask questions.
this has the benefit of reducing vandalism,
• Notify any merchants that charging resiliency in flood prone areas, and keeping
infrastructure is being considered in proximity cords away from snowplows.
to their storefront to encourage their
• Consider integrating a distribution panel to
cooperation.
host a utility meter and incoming supply if
• Pilot deployment with a smaller number of needed, with capacity to feed additional
stations across 5 to 10 locations. Once the curbside chargers from this supply point.
community has become more aware of their
• Use “hot swappable” equipment. This allows
presence, then expand deployment if desired.
quick and cost-effective change-out of
• Measure benefits and outcomes of the project hardware components that does not require
and outreach overall. There is no “one size coordination with the utility and can enable
fits all” approach to curbside deployments hardware replacement in as little as 15 minutes.
and including the community in the process.
• Conduct ongoing station support with
Tracking metrics for involving the community is
extended warranty program, proactive
critical to assessing how to improve processes
monitoring, routine maintenance, access to
for future deployments.
spare parts and replacements etc.
6. Installation, Operations, and Maintenance
• Use smart chargers that are connected to
• Upon installation, position the charger to a reliable EV charging network operator.
satisfy three requirements: Support chargers with 24/7 customer service,
mobile app for drivers, secure payments, and
» It is convenient and safe for drivers to more to ensure reliability and a consumer-
access, connect to a vehicle, and operate; friendly experience.

78 ELECTRIC VEHICLE CHARGING STATION PERMITTING GUIDEBOOK | SECOND EDITION

 • For cold weather climates, consider installing
the charger on a pedestal with tall masts so
that it is noticeable for snowplows and is high
enough off the ground to remain accessible
when there is snow.

• Make sure there is proper signage to help

drivers identify the charger.

• Make sure the City’s parking division is

proactive about enforcing internal combustion
engine vehicle parking violations – they often
block EVs from accessing charging spots.

7. Measuring Success

• Quantifying the population of multi-family

dwellings in the approximate area that could
be served by the chargers.

• Identifying the income demographics of the

neighborhood the chargers are deployed in.

• Evaluating the outreach opportunity to

educate residents about the value of EVs.

• Measuring charger utilization through

customers served and GHG emissions
reduced, especially if this helps justify
expanding curbside deployment.

• Evaluating cost-effectiveness of the

deployment compared to other charger
deployment scenarios.

• Interviewing local businesses to determine

whether EV drivers have frequented their
businesses.

SECOND EDITION | ELECTRIC VEHICLE CHARGING STATION PERMITTING GUIDEBOOK 79

California Governor’s
Office of Business and Economic
Development (GO-Biz)

JANUARY 2023