Webinar: Designing for Accessible EV Charging Stations (Text Version)

This is a text version of Webinar: Designing for Accessible EV Charging Stations, presented on May 18, 2023.

Bridget Gilmore, Joint Office of Energy and Transportation: —directly, so please do put those questions into the Q&A box. As a disclaimer, this webinar is being recorded and may be posted on the Joint Office website or be used internally. And if you speak during the webinar or use your video, you are presumed to consent to recording and use of your voice or image.

By way of agenda, we will have a brief introduction from the Joint Office. For folks who have been to these before, it's similar but a little bit different today. So hopefully keep you on your toes.

And then we'll hear from our presenter, Juliet, on best practices and recommendations for accessible EV charging stations, and then we'll have plenty of time for questions and answers. We saw that there were great ones that came in through registration. But like we said, if there are questions that come to mind during the presentation, please do put them in that Q&A function.

Just a bit about the Joint Office, really briefly. The Joint Office is a joint collaboration between the Department of Energy and the Department of Transportation to accelerate an electrified transportation system that is affordable, convenient, equitable, reliable, and safe. And we hope to see a future where everyone can ride and drive electric come into fruition.

We're supporting four programs at the Joint Office that are Bipartisan Infrastructure Law programs. The first one is the NEVI program. This is the National Electric Vehicle Infrastructure Formula Program—so $5 billion over five years to build out a national EV charging network along major highway corridors. And then the Charging and Fueling Infrastructure Discretionary Grant Program. This is a $2.5 billion program over five years. Hope folks saw that the deadline has been extended to June 13, so a two-week extension for that application, as this one is now currently open for applicants.

We're also supporting the Low-No Emission Grants Program for transit buses, the U.S. Department of Transportation. So this is $5.6 billion in support of low and no emission transit bus deployment. And we also provide technical assistance for the Clean School Bus Program, which is $5 million to support clean school bus deployment.

In terms of specialized technical assistance, we are working with states, communities, tribal nations, transit agencies, and school districts. We also have one-on-one meetings with states to address questions and concerns that are related to the NEVI Formula Program. We have a great concierge service. So this is really open to anyone. Please feel free to reach out. You can reach out via phone, email, or web form to efficiently route your technical assistance requests.

These can be small requests—small questions—to really particular things. We welcome anything through that service. And our technical assistance support team has over 50 staff members across 10 organizations ready to help you. Our website is driveelectric.gov. There's a lot of great information there, including infrastructure, planning, and implementation guidance; data and tools that are free for you to use; great news and events; and our technical assistance request form.

Wanted to also highlight some really exciting news that came out today, two announcements. The Joint Office has announced the National Charging Experience Consortium. So this is an effort that is going to be led by department of energy national laboratories to work to rapidly develop solutions to ensure a reliable and frictionless charging experience for all Americans.

And then the Joint Office funding opportunity was also released today. So this is called the Ride and Drive Electric funding opportunity that looks to advance the Joint Office mission by enhancing EV charging resilience, providing equitable access and opportunity and electrification through community-driven models for EV charging deployment and workforce development, and improving EV charging performance and reliability. So I believe some folks will drop the link to that news—those news items in the chat so you can look more in depth on these really exciting announcements.

And finally, throughout our website, this is where you can find ways to keep in touch with news and updates as they do come out. So feel free to subscribe to those news alerts. And also in the top right of our website, you can find our contact form. So this is where you can reach out with any technical assistance requests that you may have. So great. That's our spiel. And now we'll go into our polling questions. So, Sam, if you wouldn't mind pulling up our first poll, that'd be great.

Thank you so much. So the first polling question today is, what sector are you coming from? Just want to know who our audience is that we're speaking with today. So if you wouldn't mind just taking a quick moment to fill out this first poll question. And then once we looked at a critical mass—looks like there are hundreds folks on the call—we can close that and see the results.

Awesome. So it looks like we have a lot of folks from across local, state, federal government, a lot of folks from the non-government public sector, and then folks also from the EV charging side of things. That's great. Thanks so much. We can go to our second poll.

Okay, this one is what region of the country are you coming from today? Want to make sure we're reaching across the country. Awesome. Thanks so much for taking some time to respond. We've got a great, great breadth across the country, folks from all over. Thank you so much for being here with us today.

All righty, so I will now take the time to introduce our wonderful speaker. So today we are joined by Juliet Shoultz, who joined the Access Board's Office of Technical and Information Services in 2017 as a transportation systems engineer. She has 15 years of experience in transportation planning and engineering for state government.

Prior to working at the Access Board, Juliet worked as the Americans with Disabilities Act, ADA, policy engineer at the Illinois Department of Transportation, where she led the development and implementation of the department's ADA transition plan and served as the department's accessibility expert, providing technical assistance and reviewing plans for state projects.

She previously served as a member of the Illinois Accessibility Code revision committee, which was tasked with revising the Illinois Accessibility Code. Juliet has been an active participant as a member of the National Cooperative Highway Research Program panel and the Transportation Research Board standing committees. So thank you so much for being with us, Juliet. I'll now stop sharing my screen and allow you to jump on and share your presentation with us today.

Juliet Shoultz, U.S. Access Board: Thank you, Bridget. Let me start sharing. Okay. So first, I'll tell you a little bit about the U.S. Access Board where I currently work. We are a small, independent federal agency with a staff of about 30. We are governed by a board that consists of 13 public members that are appointed by the president, and the majority of them must have a disability. That board also includes 12 representatives from federal departments. Our mission is to promote equality for people with disabilities.

Some of the things we do is we establish accessible design guidelines and standards. We provide technical assistance and training. We also enforce accessible design standards, but that's only on the federal sector. So the Architectural Barriers Act is what we get involved in, in terms of enforcement.

What I'll be covering today are the contents of the design recommendations for accessible electric vehicle charging stations. The Access Board published these design recommendations last year, July 21, 2022. And in the absence of any rulemaking, we decided to put out this guidance to assist covered entities in making sure that EV charging stations are accessible.

Both the ADA and the ABA standards do not explicitly address electric vehicle charging stations, but regulated entities still have an obligation to make sure that EV charging stations are accessible to and usable by people with disabilities. And that's where the design recommendations come in. We provide them as a technical assistance tool. And we are in the process of rulemaking, which I'll discuss toward the end of my presentation. And I'll also let you know what you can do as stakeholders to be involved in our rulemaking process once we release a public draft hopefully this July.

One of the questions we frequently get is why the requirements in our design recommendations for charging spaces are different for accessible parking spaces and why accessible parking spaces can't just be used, in other words, just place a charger there, and there you go. You have an accessible EV charging space. One of the key things to consider is the difference in how charging spaces are used versus parking spaces.

The charging space requires a driver with a disability to exit their vehicle, traverse to the charger, carry the connector back to their EV charging inlet, which may be on the opposite side of where they enter their electric vehicle. So these vehicle charging inlets are located on different sides of the vehicle depending on the maker of that vehicle. And I'll talk more about that and the implications and why that EV charging space needs to be big.

So there's a lot going on when you're using an EV charging space unlike an accessible parking space that gives you an access aisle. And so based on whether you use a walker, or a cane, a wheelchair, you can orient yourself in that parking space so that you can easily use it with the adjacent access aisle. So there's a lot more going on with the charging space than the parking space. And so that's why the charging space has requirements that are unique and slightly different from an accessible parking space.

In developing the design recommendations, what we looked at is what's currently in the ADA and ABA standards. And so to that end, they're entities that are covered either by the ADA or the ABA. And when they provide EV charging stations, those EV charging stations may be covered as well in terms of needing to make them accessible.

So if you're providing EV charging stations, and you are a state or local government, there might be obligations for accessibility. If you're providing them at a public park municipal building, if you have on-street parking and on-street charging spaces, any public EV charging stations provided by a private entity, whether it's at a shopping center or just a standalone EV charging station, any fleet charging stations that are used by the federal government, if you have commercial fleet charging stations, and also if you are providing EV charging stations along the interstate highway, for example, or rest stops, there are obligations that those EV charging stations be accessible to and usable by people with disabilities.

In developing the EV charging station recommendations, what we looked at are basically two buckets, the accessible mobility features. So those are for people who use mobility devices and what their needs are in an accessible EV charging space. And then we also looked at accessible communication features, so, for example, for people who are deaf or hard of hearing and they're needing to interact with the charger interface. So we looked at those requirements as well in developing our design recommendations.

First we'll look at the accessible mobility features. In the recommendations, what we're suggesting is a vehicle charging space that's at least 11 feet wide and 20 feet long. If you're familiar with our ADA or ABA standards, you'll know that we do not specify a length in those standards, but it was critical for the EV charging spaces that we specify a length. And I'll talk more to that in follow up slides, which discuss vehicle charging inlets and how they're located on different parts of the car.

The EV charging space needs to have an adjoining access aisle that's at least five feet wide. There must be a clear floor or ground space at the same level as the vehicle charging space, and it needs to be positioned for an unobstructed side reach. And, again, this is just an outline of the accessible mobility features. And I'll dig a little deeper in slides that are coming.

The last thing on accessible mobility features is operable parts. And that includes the charger, the connector. And if you have a charger that includes an interface, there might be requirements in there for the mobility features depending on the design of that EV charger user interface itself.

Then on the communications side, what we looked at is the EV charger user interface. We looked at speech output, if there's any sort of interaction between the user with the EV charging interface, if these charging status indicators, and also in terms of 508, if especially if you're dealing with an EV charging station at a federal space. We also looked at websites and also considered mobile applications in terms of how to make those accessible for people with disabilities.

We drew a lot of the requirements from the ADA Accessibility Standards, the ABA Architectural Barriers Act Accessibility Standards, as well as section 508 standards. And section 508, if you're not familiar with it, deals with information and communication technologies. So that's where we drew from in terms of what's currently required. So even though the ADA standards and the ABA standards and section 508 standards do not explicitly mention EV charging stations, there are components within those standards that are applicable today.

On this slide, we have a listing of some of those provisions that are required. So in the ADA and the ABA standards where you have an operable part—so your EV charger itself, that's an operable part—there are requirements of any operable parts to have a clear floor and ground space. And I've listed the provision numbers. So that would be 302 for floor and ground space, 305 as well.

Reach ranges—if your EV charger has an interactive component, there might be some reach range requirements, reach range requirement for how high you place that connector so that someone could use it and actually take it to their car—operable parts in terms of, again, the connector and maybe the user interface, accessible routes from the access aisle to the EV charger, and then to the accessible entrance.

So let's say you have an EV charger that's located—an EV charging station that's located at a grocery store. In terms of accessible routes, we're looking at an accessible route from the accessible EV charging space and the adjoining access aisle to the grocery store entrance.

Other provisions where applicable are provisions for parking. And we'll talk a little bit about that when it comes to scoping and how you need to make sure when you're considering your scoping, you consider scoping for parking separate from scoping for EV charging spaces.

Signage is also addressed in the ADA standards. So we already require signage for an accessible parking space. There'll also be signage required for an accessible EV charging space. And then 707 fare machines, this may be applicable depending on the interface of the EV charger.

So let's look at the EV charging station on a site and what that means in terms of accessibility. We understand that a lot of your utility infrastructure will be located on the perimeter of existing sites. And so what we're recommending is wherever you place your EV charging stations—so in this picture you have a bank of EV charging stations—the accessible EV charging space should be the closest one within the grouping to the accessible entrance. That's what the requirement is.

And you need to make sure you have an accessible route from the accessible EV charging space to the accessible entrance for the facility that it serves. In this scenario specifically, this bank of EV charging spaces serves this building. And so you want to make sure that that accessible EV charging space is connected to the accessible entrance of that building that it serves.

You'll notice there are also accessible parking spaces. And there's a distinction because of the ADA and ABA standards. We require that the accessible parking spaces be the closest ones to the accessible entrance. So the slight difference is in that and in recognizing that with EV charging spaces, your utilities might dictate where you place the EV charging stations.

The EV charging spaces are not always going to be closest to the building. But out of the bank of EV charging spaces you provide, the accessible one should be the one that's closest to the accessible entrance. And you might have sites where EV charging is the primary purpose. And so you'll want to look at what amenities are you providing.

So let's say you have a rest area off the highway. The primary purpose there is—maybe these restrooms. So you definitely want to make sure any amenities, whether it's a restroom or maybe there's some picnic tables at the rest area, you want to make sure that you're providing an accessible route from the accessible EV charging station to the different amenities that you're providing on that site.

Where you have EV charging stations in the public right of way, so on-street, there are definitely going to be limitations in existing infrastructure because of however much right of way you have available, how wide your sidewalk is, how close your buildings are to the roadway. So there are definitely restrictions in the right of way where adjacent facilities are already developed. But there's definitely a way to make EV charging spaces on street more accessible.

So if you do not have enough right of way, for example, in this picture, what we recommend, which is similar to accessible on-street parking—what you want to do with your accessible EV charging space if you don't have enough room to have an access aisle that's depressed adjacent to the car, you want to make sure you locate the accessible EV charging space either at the end of the block face or at mid-block crossing. That way someone can get out of their car and not be in traffic too much so they can easily access that curb ramp and get on to the sidewalk and hopefully be able to access the EV charge of the connector and get it to their car.

It's not going to work for every user depending on their mobility limitations and also depending on where on their electric vehicle their vehicle charging inlet is located. But this type of design where you have limited right of way provides for more opportunity for people with disabilities to use electric vehicle charging stations that are located in the public right of way.

What we recommend is you orient the EV charger, so basically the operable parts, whereby you can provide a clear floor space. So in this image, you would not want this EV charger facing the roadway because then that limits the accessibility to the—if you have an interface or the connectors. So you want to orient it where you have a clear floor space for someone in a wheelchair, for example, to pull up and be able to interface with the EV charger.

You do not want to place the EV charger within the middle 50% of the sidewalk adjacent to on-street charging space. So what does that mean? The space from the front of the car to the back of the car, you want to make sure you don't put the EV charger in the middle of that space. Reason being that there are some people who deploy, whether it be a ramp or whatever their mechanism of getting out of their car, if you locate this EV charger in this middle section, you obstruct how they can get in and out of their car if that's the route that they use. So you want to make sure that the EV charger is on one end or the other of that space.

To give greater opportunity for people with disabilities to use EV chargers that are within the public right of way, you want to make sure you're providing charges on both sides of a one-way street. So in this case, if this is one-way, if someone has—someone's vehicle—maybe their vehicle charging inlet is located on the back passenger side, then they can at least have the choice of parking on this side of the street versus if you have all the accessible EV chargers on the other side, which would put their charging inlet within the vehicle travel way.

If you do have enough right of way, this is an optimal design. In this image here to the left, you have the accessible EV charging space on-street. You have an access aisle adjacent. And you have a clear floor space. So this gives plenty of room for someone to exit their vehicle. They have this clear—this access aisle so that they're able to maneuver from the charger to their car.

What you don't want to do is locate the EV charger up on a curb and not provide any way to get to it. So the image on the right, first of all, the charger is up on a curb, so that's not accessible. And it's actually quite far back from the curb. So it's not even on the edge. And even if it were in the edge, you'd need to look at reach ranges because now that you've added, let's say, a 6-inch curb, operable parts are a little higher. So you want to avoid that type of design.

So let's talk about the space itself, an accessible space with mobility features. I mentioned earlier that in the design recommendations, we are looking at a space to be at least 11 feet wide with a 5-foot axis aisle, and it needs to be at least 20 feet long. And we do need to have signage the same way you'd have signage for an accessible parking space. And we'll talk a little bit more about those options when we talk about scoping.

And then also in terms of installing a ground level, that comes into play when we're talking about your reach range. I know some EV charging providers are concerned about impact to the EV chargers, so they would prefer to place the charger on a curb. And what we recommend is to look at different options, maybe bollards that aren't blocking the accessible route. So look at different options to protect the EV charger but still making it accessible.

This is another illustration of the accessible EV charging space with that 11-foot minimum, 5-foot access aisle. And two EV charging spaces can share an access aisle. One thing that you want to look at and we'll touch on in a little bit here in the next few slides is the cable slack. In the design recommendations, what we're stating is to look at some sort of cable management depending on the length of your cable. And that accomplishes two things.

The cable management system helps keep the cable slack out of the access aisle. So once someone gets the cable, plugs it into the vehicle charging inlet, they still need to use this access aisle to get to their destination. So we want to make sure we're keeping this access aisle clear.

And so with that, the cable management systems would assist in keeping more of the charger elevated and not in the accessible route, but it would also help with the weight management of the cable itself if there is a cable management system. So it accomplishes two things, keeping the cable slack out of the access aisle and out of the accessible right of way but also helping reduce that weight.

Here's an example of how you might orient your EV charger at an accessible EV charging space. In this case, it's oriented facing perpendicular to the space itself. You have your clear floor space, so you have plenty of room to park your car, get into the axis aisle. And this clear floor space is not in the way of the sidewalk. You're still able to protect the chargers with bollards instead of locating them on a curb for protection from impact. So you're able to do that while still making sure that it's accessible.

Here's another illustration. And this illustration, the EV charger is facing the vehicle charging space. And, again, you have enough room where you're providing a clear floor space. And you have the bollards that are protecting the EV charger but not obstructing the usability of the charger.

Now we're going to talk over the next, I think, about four or five slides about why the EV charging space, the accessible EV charging space needs to be wider than your standard accessible parking space. I mentioned that depending on the manufacturer of the vehicle, your vehicle charging inlet can be located anywhere. In this specific illustration, the vehicle charging inlet is on the back driver's side.

So what this driver did is to give them the best chance of getting their vehicle charged easily. What they did is they backed in, which puts the vehicle charging inlet closest to the EV charger. And it also gives them plenty of room to exit their vehicle onto the access aisle, get to the cable, get it back to their car, and go on about their way.

In this image, this car has the vehicle charging inlet either on back center or back passenger side. So the driver gets out of the vehicle from the driver's side, gets in the access aisle. Because the charging space is longer—so it's 20 feet—they have plenty of room to maneuver in the back and get to the EV charger, grab the cable, and bring it to the vehicle charging inlet.

If this wasn't 20 feet, there are only two—really, their only option is to park their car such that it's sticking out of the parking space in order to get room to give themselves room to get back here to the vehicle charging inlets. But a longer space, a wider space gives them the option to still be parked within the space but be able to use it and get around to the location of the vehicle charging inlet.

In this scenario, the vehicle charging inlet is on the passenger front side. So what the driver did in this case they pulled in forward, putting the vehicle charging inlet closest to the charger exit out of the driver's side. This wide 11-foot, 5-foot access aisle gives them plenty of space to locate their car or to park their car in a way that meets their needs. So they're able—they have all the space to get out of the car, get to the access aisle to the charger, and plug their vehicle in.

In this example, you have your charging inlet either at front center or front driver's side. Again, this wider space, longer space is giving them that option of not pulling all the way to the bollards. They're pulling in and leaving themselves enough room to be able to navigate and get to the charger. So that hopefully explains why in the design recommendations we call for 11-foot wide, 5-foot aisle, 20-feet deep. And we understand that will pose some challenges in existing sites.

But there's different ways of getting things done and making them more accessible when you're dealing with new construction especially. So those are some things to think about in terms of these mobility features where on a site is optimal to locate your EV charging stations. So that was the charging space itself. We're going to talk more about the charger and making sure the charger meets mobility requirements.

We did touch on the clear floor space. This is already a requirement in the ADA and ABA standards, a clear floor space add an operable part. And these are considered operable parts. And so there's different ways you can orient this clear floor space.

In the picture to the left where you have the 60-inch wide, you're orienting it for a parallel approach. And so someone would approach it and orient their wheelchair parallel to the EV charger. On the right-hand side where you see a 48-inches wide, this is oriented for a forward approach. Either option is acceptable. You just need to really consider the space you're working with and what works best to provide accessibility.

So we also talked about—there is a concern to protect the EV chargers from impact. And that's where the bollards come in. But it's important to make sure that the bollards are not obstructing the required clear floor space.

In the ADA and ABA standards, the clear floor space must be firm, stable, and slip-resistant. So these requirements—and I mentioned this earlier. When you're looking at our design recommendations for accessible EV charging stations, you'll want to make note in some places we use language such as shall. And where we do that, we're really referring to things that are already required even though there isn't language in the standards that speaks to EV charging spaces. So in this case, the clear floor space, that's a "shall" because this is an operable part.

So we're still talking about operable parts. Both the ADA and ABA standards talk about reach ranges for operable parts. And at an EV charger, there's some components that you might be reaching. Whether it be the cable, whether it be an interface, or payment system, these different things that you might be interacting with at the EV charger.

Any operable parts on the EV charger, first of all, they cannot be obstructed. So they must be reachable with an unobstructed side reach. So you want to make sure there is nothing in front of the EV charger, such as bollards.

And so also the other piece to that is there are reach range requirements. In order for an operable part to meet reach range requirement for an unobstructed side reach, it needs to be located between 15 inches off the ground up to 48 inches off the ground. This is within the space you have to work with in terms of operable parts.

If you have display screens, for example, at some gas stations they have display screens that are just running commercials, nothing pertinent to the usage of the EV charger, those can be located outside of the speech range because the user is not interacting with them. But anything on the EV charger that requires physical interaction, it needs to be located within this range of 15 inches minimum off the ground to 48 inches maximum off the ground.

We're talking about operable parts. And keep in mind the cable. And the connector, that is an operable part. And the ADA and ABA requirements have requirement specifications for operable parts. And those are it needs to be operable with one hand. It shouldn't require tight grasping, pinching, or twisting of the wrist. And it shouldn't require more than 5 pounds force to operate. Those are the requirements in the ADA/ABA standards.

Keep in mind EV charges, again, are not covered in the ADA/ABA standards. So in the ADA/ABA standards, gas pumps specifically get an exception to the 5 pounds force to operate. And we will be doing rulemaking—and I'll talk about that on my last slide—where operators, vendors, manufacturers will have an opportunity to opine on what we will be proposing as regulation.

And so we absolutely welcome any input to any of the requirements that will be proposing in our notice of proposed rulemaking. Any component of that draft, please send in your feedback. We really take that into consideration.

So your EV charger, maybe it has a status indicator, for example, if you're providing them in a public space. If you're providing for a fleet, maybe it's not so much as an issue or employee parking may not be so much an issue. But the big thing really to point out here is how the charger, the EV charger, communicates information to the user.

On this slide we're specifically talking about the status of charging. So if you have an EV charger that indicates status by lighting up—maybe when you plug it in, it lights up red, and then when it's complete—the charger is complete, it lights up green, or blue, what have you—you're providing a visual indication of the charging status.

And what ADA and ABA would require is that information that you're providing that's visible, it should also be audible. So it needs to be accessible because obviously someone with—whether it be color blindness or someone who's blind—they cannot see if all you're providing in terms of the status of charging is visual indication. So it's important to consider that.

And there's probably different ways depending on the technology you have set up with your product on how you can convey the status of charging in ways that are accessible. Do you have an app that notifies the user via phone? So whatever method you're looking at for interface with the customer, it needs to be accessible.

If you have an EV charger with a display screen, I talked about reach ranges. So in this case, this display screen actually requires the user to interact with the screen. So what you're looking at in terms of accessibility is communication features. In the design recommendations, we point to our section 508 requirement, the information and communication technology requirements. So those are the things to keep in mind when you're procuring EV chargers. You want to look at what does the interface look like. Is it going to be accessible to all users?

One thing we looked at and we talk about in the design recommendations in terms of scoping, which I'll discuss in a little bit here, is we're looking at if you have—let's say you have at your bank of EV charging stations you have 10 of them. And maybe only one of them needs to be accessible. Ideally in terms of communication features, all of them are accessible. In terms of mobility features, maybe you might have just that one.

And the reason for that is if you have somebody who is deaf or hard of hearing, it's better that they be able to use any of the EV charger charging spaces to free up the one that has mobility features or that has access aisle that's bigger and whatnot because they may only need the communication features. They may not be mobility device users. So if you make all EV chargers accessible in terms of communication features, then that narrows down the number of people who have to line up just for the one with mobility features as well.

In the design recommendation, we also talk about payment systems. Again, this is still dealing with how one interfaces and interacts with the EV charger and the payment system. If you have registration and payment card readers, they should be compatible with contactless payment systems. They need to be tactically discernible. They need to provide visual and audible feedback.

In the design recommendations, we talk about different scoping options. And, again, these are design recommendations intended to provide technical assistance. Once rulemaking comes out, just like with any other rulemaking and scoping, you see more specific requirements in terms of scoping unlike the options that I'm showing on this slide, the options that we discuss in the design recommendations.

So there's different approaches that we discuss in the design recommendations. The first is to base the minimum number of accessible EV charging spaces in the same way that you would for accessible parking spaces. So if you have 25 accessible parking spaces, the ADA and ABA standards require that at least one of those accessible parking spaces be accessible.

So you could take the same scoping concept. And if you have 25 EV charging spaces, if you're following what ADA/ABA says to parallel the parking space scoping, you would have one accessible EV charging space. That's one option.

The key to remember, though, is you cannot double dip essentially. So if you have 25 parking spaces, and you decide you're going to add another five spaces, and those will—so now you have a total of 30. So you have 25 parking spaces and five charging spaces. You can't go to the ADA/ABA standards and look at the scoping for parking and determine, okay, I need two, and I'm going to make the charging space also be used as the parking space for the accessible spaces. You have to scope them different—separately.

So if you have 25 spaces total, you need to—if you're looking to mirror the parking, that would give you at least one accessible parking space and at least one accessible charging space. But the accessible parking space and accessible EV charging space cannot be one and the same. They have to be scoped separately. Another option we discuss is aligning with the International Building Code, which calls for 5% of your provided EV charging spaces be accessible.

Now, when it comes to signage and restricting the use of accessible parking spaces, there's different approaches. You could take an approach similar to accessible parking spaces. So with accessible parking spaces, no one is allowed to park in an accessible parking space, unless you have the disabled parking placard or license plates. It's 100% restricted. So you could take that approach as well with EV charging spaces where the accessible ones are 100% restricted to those who have the disabled parking placards or license plates.

There's also the option of use last. So, let's say, on your site you have four EV charging spaces and maybe one of them is accessible. So instead of the restricted signage on that accessible EV charging space, maybe you have a "use last" signage, meaning if anyone comes to this bank of EV charging spaces, if the other for non-accessible are already in use, then you can use the accessible one.

But if the non-accessible spaces are not in use, then if you do not need an accessible EV charging space, you should use the non-accessible charging spaces. And understandably, there are some challenges to that concept. Again, this will all get flushed out through our rulemaking process.

Then the last approach for scoping is to have a hybrid, so a hybrid of use last. So some of those accessible EV charging spaces are use last, and some of them are reserved, so strictly reserved for people with disabled parking placards or license plates, so different approaches there.

Throughout the presentation, I've been talking about our rulemaking. And so, again, these are design recommendations, not final rules, not enforceable under the ADA or ABA. So we're moving into rulemaking. And right now what we're indicating is July of this year, we will publish a notice of proposed rulemaking.

What that is it will be a draft of what the requirements would be once they're finalized and adopted into the ADA, into the ABA. And what you'll be looking at is scoping technical requirements. Those are the kind of things you're going to be looking at and the technical specs in terms of what that space should look like. That's what we'll be publishing in July of this year.

In the meantime, if you need technical assistance, you're dealing with an existing site or a new site on how to make sure your EV charging spaces are accessible, feel free to reach out to us. We have a technical assistance email address. We also have a technical assistance hotline, which runs five days a week. But in the meantime, do look out for a notice of proposed rulemaking.

And on our website, we have an option where you can sign up for a newsletter, so you'll get notification if you don't already keep up with federal rulemaking. But you would get notification that we've published that notice of proposed rulemaking. And once we publish that, it gives the opportunity for the public to review and comment on whatever we put out there in June—sorry, July. And we welcome any feedback.

Again, it helps inform what we do with rulemaking moving forward because some of you guys have more expert or on-the-ground experience with a lot of implementing these things. So we absolutely welcome your feedback. That concludes my presentation. I'll take any questions.

Bridget Gilmore: Thank you so much, Juliet. That was a lot of really wonderful information. I think being able to see the visualizations is really helpful, too. We had a couple of questions come in—and thanks for folks who submitted them—thinking about how charger designs might look thinking of emulating the gas pump model we see today. So Michael and Peter had both asked, if you have standard specification or detail for pull-through designs, like those at gas stations or thinking about an island of chargers similar to how we see gas pumps.

Juliet Shoultz: Yeah, we actually in our design recommendations—and I think they'll probably be a link to the design recommendations put in the chat there for you guys—we do address pull-through EV charging stations similar to a gas station-type design. So that's definitely a design—I'm sorry, that's definitely something we discuss in the design recommendations. And we have illustrations in there talking about how much space you should really allocate—maybe put them on the outside of your bank of EV chargers. So we definitely do discuss that in the design recommendations.

Bridget Gilmore: Great. Thank you so much. This next one is a quick question. The 5 pounds of force that you had mentioned, does it include the weight of the charger connector?

Juliet Shoultz: Yeah, it includes everything. So really what the 5 pounds of force is—it's how much force it requires the user to operate this operable part, whatever it might be. So however much pound force it requires, so that would include the cable. It would include the connector itself, if you have to push a button or twist something. Yes, absolutely that—the force required to operate it.

Bridget Gilmore: Great, thank you. One question that had come in was if the Access Board had considered a requirement for vehicles to have a uniform charging port location as opposed to requiring larger spaces.

Juliet Shoultz: Well, I guess the key thing here, two things. When we develop our—any standard for any technology, especially these emerging technologies—we try to write our standards in a way that we don't inhibit innovation and really restrict technology. So in terms of vehicle charging inlet location, for one—and while the vehicles came before we even came up with standards, unfortunately that's how it worked out. But, again, there's also something to be said about not restricting technology and letting technology lead but with accessibility in mind. So I guess the short answer is, no, we did not do that.

Bridget Gilmore: One question that came in from Steven, are EV chargers allowed to be placed in accessible parking spaces assuming the intent is not to turn it into an accessible EV charging space? If not, why not? Does the answer change if it's at a commercial facility not serving the general public?

Juliet Shoultz: Nope, not allowed. We really want the accessible parking space to be distinct and separate from accessible EV charging space. And they shouldn't—your required accessible parking space should not also serve as your required EV charging space. If you have a facility where all you have is EV charging spaces, then all that's required is accessible EV charging spaces. But if you have a combination of both, they cannot—you can't double one requirement for another.

Bridget Gilmore: Thank you for clarifying. This question is, how do your requirements related to accessibility for visual impairment apply?

Juliet Shoultz: So for visual impairment and really for a lot of the communication requirements, what we did is we pointed to our 508 requirements, which at this point they primarily apply to federal government—to federal entities essentially. And we discuss in depth.

And I have to mention, my presentation on these design recommendations covered the broad, the big picture. And the design recommendation itself, it digs a little bit deeper and points to specific sections of whether it be the ADA standards or 508 standards, which are the communication features basically that you're talking about. And so that digs a little bit deeper into the specific requirements in terms of speech, output, or visual and audible requirements.

Bridget Gilmore: Gotcha. One question that had come in is trying to think about where some regulations do apply, where they may apply, and then which ones are not necessarily enforceable. Could you provide a little bit of clarity there on how these recommendations align with federal guidance that's already out there, and then what might be coming with the notice of proposed rulemaking?

Juliet Shoultz: Right. So the design recommendation technical assistance document is not enforceable. It's strictly a technical assistance document. But what I want to point out is within that, we point out things that are required right now in spite of the fact that neither the ADA standards or the ABA standards address electric vehicle charging stations. The clear floor spaces, the operable parts, the reach ranges, those are already required right now on anything.

If you come up with some new soda vending unit that's placed on sidewalks and neighborhoods, it has operable parts, you're required to meet the operable parts requirements, that clear floor space reach ranges. So in the design recommendation technical assistance document, we took great lengths to make sure we point out what's required by law now and what is a recommendation.

Now, the size of the EV charging space, that's not required in the ADA standards or the ABA standards because they don't speak to that, but they do indeed speak to operable parts.

Bridget Gilmore: Thank you for clarifying. Let's see. So we have a question on how state agencies might be thinking about this. So does the state agency—will a state agency need to install ADA accessible EV charging stations for their fleet even though they don't have employees with disabilities in order to apply for federal/state incentives for EV charging infrastructure?

Juliet Shoultz: Okay, so I can't speak to the funding piece—whether you're getting money from the federal, what have you. But one thing I can speak to is—and this is a question that we get often just with parking even in terms of “none of my employees have a disability, does my fleet parking require an accessible parking space in that case?”

What we point people to—your obligations under Title 2, those might drive you to have to provide an accessible space. But then also if you have an employee who either becomes disabled on the job, but they can still do their job—it's just a parking space needs to be accessible. So these different regulations—these regulation, and these obligations under the ADA that as a Title 2 entity you might be required to meet. So it's not a blanket: this is a fleet parking space, so I don't have any obligations there.

Bridget Gilmore: This is a question that goes back to the visual impairment accessibility. To what extent should the accessibility of stations be enabled for the visually impaired who may not be able to drive?

Juliet Shoultz: So there isn't a—I guess, a degree of it needs to be visually accessible to this level. So there isn't a clear measure of that sort. But one thing I can speak to is, for example, one may have a visual impairment, but they can still drive. So, for example, their issue might be contrast, color contrast, light on dark or darker light. And so that's a visual component that you would provide.

So there's different—it's hard to say. I mean, obviously someone who's completely blind and does not drive, that's one end of the spectrum. And then there's the other range of different variations of visual impairments where you still have the capability to drive.

Bridget Gilmore: Yeah. We're already coming close to the end of the hour. And I'm going to close this out with just a couple of minutes left, so I'm just going to ask one more question. One question that had come in through registration was, what are some of the key things to require for all EV charging stations and the right of way that will make them accessible? At what density of EV charging stations in the right of way should a parking spot include the signage for ADA accessible or use last, like you were mentioning?

Juliet Shoultz: So in the right of way, for parking right now, signage is required for accessible parking spaces no matter how many of them you're required to provide. The public right of way accessibility guidelines gives you scoping based on how many parking spaces you provide on a block perimeter. And those accessible parking spaces must have the signage. So same thing if you're providing accessible EV charging spaces, there isn't a limit to how many of those accessible EV charging spaces need to have the signage.

Bridget Gilmore: Great. Thank you so much. This was—I know we have a lot of questions that are still rolling in. But if you don't mind, I'll share my screen again, Juliet, just to make sure folks know what the resource looks like. You can find it on driveelectric.gov as well. But this is the recommendations that are also mentioned in the final rule for the minimum standards. So this is what the guidance looks like.

And then in terms of what's coming next from the Joint Office, next week we are planning to have a webinar on ensuring a reliable charging experience, and then also a workforce development webinar on June 13. We also wanted to make sure that if you didn't get your questions answered, you know that you can still feel free to reach out. Like we mentioned, we have lots of folks on our technical assistance team that are here to help support those questions that you did receive. And Juliet also mentioned that they have a specific technical assistance contact that you can reach out to as well.

So thank you all so much for being here. Thank you so much, Juliet. This was a lot of really wonderful information and a really important topic. And we hope to see you all at the next Joint Office webinar. Have a great rest of your day. Thank you.