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Electrical Safety Authority is Crazy

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Doug_G

Lead Moderator
Global Moderator
Apr 2, 2010
17,888
3,421
Ottawa, Canada
They are nuts. This is not a huge big deal, but my electrician called ESA to verify that separate disconnecting means are not necessary, since the NEMA 14-50 provides that function.

Unfortunately, they told him that the switch is necessary. The stated reason: in case the user doesn't unplug the car first.

Something tells me that if some idiot doesn't think to unplug the car first, they're not going to think to pull the switch first either. DUH!!!

IMG_1550.JPG


What we need now is disconnecting means for the disconnecting means. No wait, what if someone is working on the new disconnecting means. Better add another one! Switches all the way back to the panel!
 
What we need now is disconnecting means for the disconnecting means. No wait, what if someone is working on the new disconnecting means. Better add another one! Switches all the way back to the panel!

I design systems with process piping. EVERY time a system gets installed I get a question "Why aren't there valves here and here?" Where 'here' and 'here' are the exact perfect spots for their first problem/maintenance issue. The conversation always gets back to just putting valves back to back in lieu of piping.

You can't win.

I always find it amazing/frustrating when the first maintenance issue is a isolation valve. Because I get asked why can't you isolate that valve. This happens so often I just expect it now.
 
I design systems with process piping. EVERY time a system gets installed I get a question "Why aren't there valves here and here?" Where 'here' and 'here' are the exact perfect spots for their first problem/maintenance issue. The conversation always gets back to just putting valves back to back in lieu of piping.

You can't win.

I always find it amazing/frustrating when the first maintenance issue is a isolation valve. Because I get asked why can't you isolate that valve. This happens so often I just expect it now.

Lets talk about valves and redundancy...heh.
 
They are nuts. This is not a huge big deal, but my electrician called ESA to verify that separate disconnecting means are not necessary, since the NEMA 14-50 provides that function.

Unfortunately, they told him that the switch is necessary. The stated reason: in case the user doesn't unplug the car first.

Something tells me that if some idiot doesn't think to unplug the car first, they're not going to think to pull the switch first either. DUH!!!

View attachment 17837

What we need now is disconnecting means for the disconnecting means. No wait, what if someone is working on the new disconnecting means. Better add another one! Switches all the way back to the panel!
Technically, they are correct; the plug can by pulled out under load BUT it is meant for that! You can unplug your drier or range while it is running also. There is nothing in the canadian electrical code that requires this switch to be there.

Interesting that the J1772 'chargers' are only really glorified contactors so that chances of pulling the plug from the car with 40-70 amps current flowing is minimized, with current shut down ( and contactor opened ) when the button on the connector is pushed.
 
Doug,

I believe the inspector was wrong. Here is the Code Rule governing EV disconnecting means:

86-304 Disconnecting means
(1) A separate disconnecting means shall be provided for each installation of electric vehicle charging
equipment rated at 60 A or more, or more than 150 volts-to-ground.
(2) The disconnecting means required in Subrule (1) shall be
(a) on the supply side of the point of connection of the electric vehicle charging equipment;
(b) located within sight of and accessible to the electric vehicle charging equipment; and
(c) capable of being locked in the open position.

Your equipment is rated below the threshold for where a switch is required (50 amps and 120 volts to ground)

Oddly, the inspector missed this Rule:

86-200 Warning sign
Permanent, legible signs shall be installed at the point of connection of the electric vehicle charging equipment
to the branch circuit wiring, warning against operation of the equipment without sufficient ventilation as
recommended by the manufacturer’s installation instructions.
 
I believe the inspector was wrong. Here is the Code Rule governing EV disconnecting means:

Like I said, nuts. I think whoever the electrician talked to didn't know what they were talking about and reverted to CYA mode.

86-200 Warning sign
Permanent, legible signs shall be installed at the point of connection of the electric vehicle charging equipment
to the branch circuit wiring, warning against operation of the equipment without sufficient ventilation as
recommended by the manufacturer’s installation instructions.

The operative word here is, "as recommended by the manufacturer's installation instructions." This is not required for Tesla, or any other OEM electric vehicle. That rule was designed specifically for lead-acid battery charging, which vents hydrogen. The J1772 standard includes a signal state from the vehicle to indicate when ventilation is required. Most EVSEs including Clipper Creek will not allow charging at all if that signal state is present.
 
Oops... meant to quote this section on labeling...

86-306 Receptacles for electric vehicle charging equipment (see Appendix B)
(1) Each receptacle for the purpose of electric vehicle charging shall be labelled in a conspicuous, legible, and
permanent manner identifying it as an electric vehicle charging receptacle and shall be
(a) a single receptacle of CSA configuration 5-20R supplied from a 125 V branch circuit rated not less
than 20 A; or
(b) of the appropriate CSA configuration in accordance with Diagram 1 or 2 when supplied from a
branch circuit rated at more than 125 V or more than 20 A.
(2) The receptacle in Subrule (1)(a) shall be protected with a ground fault circuit interrupter of the Class A type,
when the receptacle is installed outdoors and within 2.5 m of finished grade.
 
Oddly, the inspector missed this Rule:

86-200 Warning sign
Permanent, legible signs shall be installed at the point of connection of the electric vehicle charging equipment
to the branch circuit wiring, warning against operation of the equipment without sufficient ventilation as
recommended by the manufacturer’s installation instructions.

Actually, he just came and did the inspection, and insisted the following words be added to the switch: "CAR CHARGER ONLY".

Obviously the world will come to an end should someone plug a welder into the circuit...
 
Actually, he just came and did the inspection, and insisted the following words be added to the switch: "CAR CHARGER ONLY".

Obviously the world will come to an end should someone plug a welder into the circuit...

It is kinda hilarious. I met with some of the people involved in making these rules (after the fact) and remember saying that I could just tell the inspector that I'm making a "summer kitchen" in the garage and will plug a stove into the 14-50, thereby negating the labeling requirements. The answer was "well, uh, yeah I guess you could do that". Your welder example would have been better, but I didn't think of that!

One of the issues that they're trying to address (and I do get this) is to figure out how to notify electric utilities of these installations. That is partly why there are all these new rules, and it is why recipients of the EV Charger grants will have their postal codes provided to the utility. Most electrical loads have some diversity to them (cycle on and off), but EV charging is a continuous draw, often for many hours. The weak link in the distribution chain is at the transformer on the street, which is historically sized taking load diversity into account. Primary feeder capacity is not generally an issue, and the service conductors coming into the home are also not an issue as they are (or should be) sized to the maximum capacity of the home's main disconnect. Utilities are really thrilled to have these new loads (they do represent revenue, after all) and would like to proactively make sure that the capacity exists to supply them. Nobody wins if distribution transformers fail. It's inconvenient for the affected customers, and costs the utility money in damaged equipment. I can utilize my smart meter network to create virtual meter points at transformers to watch for overloads, but by that time, it may be too late. Ideally, I can change that transformer in anticipation of the load and avoid failures and service interruptions.

One of my personal goals at the utility I work for is to be an advocate of EV adoption. EV's are a "behind the meter" activity which utilities are generally prohibited from getting involved in. Our demarcation point is at the meter. Entities like the ESA (responsible for behind the meter safety) are new at this too, and we need to figure much of this stuff out. I'll probably try to start with some education materials on our web site to help people understand the challenges and solutions that are available to them.
 
Sounds like a lot of hoops to jump through when a simple e-mail to the local utility would suffice. I sent an e-mail to Horizon Utilities 6 weeks ago and told them that I had an EV coming. I asked if a 40A load be ok? Would 80A charging be ok down the road?? As it turns out, 40A is fine but they'd need to do some upgrades if I wanted to charge at 80A...



It is kinda hilarious. I met with some of the people involved in making these rules (after the fact) and remember saying that I could just tell the inspector that I'm making a "summer kitchen" in the garage and will plug a stove into the 14-50, thereby negating the labeling requirements. The answer was "well, uh, yeah I guess you could do that". Your welder example would have been better, but I didn't think of that!

One of the issues that they're trying to address (and I do get this) is to figure out how to notify electric utilities of these installations. That is partly why there are all these new rules, and it is why recipients of the EV Charger grants will have their postal codes provided to the utility. Most electrical loads have some diversity to them (cycle on and off), but EV charging is a continuous draw, often for many hours. The weak link in the distribution chain is at the transformer on the street, which is historically sized taking load diversity into account. Primary feeder capacity is not generally an issue, and the service conductors coming into the home are also not an issue as they are (or should be) sized to the maximum capacity of the home's main disconnect. Utilities are really thrilled to have these new loads (they do represent revenue, after all) and would like to proactively make sure that the capacity exists to supply them. Nobody wins if distribution transformers fail. It's inconvenient for the affected customers, and costs the utility money in damaged equipment. I can utilize my smart meter network to create virtual meter points at transformers to watch for overloads, but by that time, it may be too late. Ideally, I can change that transformer in anticipation of the load and avoid failures and service interruptions.

One of my personal goals at the utility I work for is to be an advocate of EV adoption. EV's are a "behind the meter" activity which utilities are generally prohibited from getting involved in. Our demarcation point is at the meter. Entities like the ESA (responsible for behind the meter safety) are new at this too, and we need to figure much of this stuff out. I'll probably try to start with some education materials on our web site to help people understand the challenges and solutions that are available to them.
 
Sounds like a lot of hoops to jump through when a simple e-mail to the local utility would suffice. I sent an e-mail to Horizon Utilities 6 weeks ago and told them that I had an EV coming. I asked if a 40A load be ok? Would 80A charging be ok down the road?? As it turns out, 40A is fine but they'd need to do some upgrades if I wanted to charge at 80A...

As a utility guy, I thank you for doing this. The fact is that there is no real requirement for people to do this, and most won't. You can hire an electrician to add outlets, do wiring and so forth, but unless the main service is being upgraded (i.e. 100 amp to 200 amp) your local utility won't know anything about it. Even with a service upgrade, often the "reasons" for the upgrade are never passed along to the utility. One EV on a distribution transformer may cause a problem, but two or three definitely will.

One change the ESA recently made is to have all EV wiring additions inspected on-site by an inspector. There is the concept of "pre-authorized" electricians who can do certain type of wiring and be exempt from inspection, but now that will not apply to EV work. One reason for the compulsory EV inspection is so that the utility can be informed.

It's a work in progress and will certainly need to be streamlined. If everyone were like you and called their utility ahead of time, all of this wouldn't be needed!