With the increased popularity of electric vehicles (EVs), more and more charging stations are popping up across the US. The problem is, because it’s a rather new development, these charging stations aren’t specifically addressed in the Americans with Disabilities Act Access Guidelines (ADAAG). In fact they aren’t even covered under any general design standards. But that’s all set to change as the US Access Board recently released their proposed Electric Vehicle Charging Station Regulations; and they are seeking public comments, from end-users, designers and builders on these preliminary regulations. So it’s time to let your voice be heard.

Proposed Electric Vehicle Charging Station Regulations

Even if you don’t use a EV, you still might want to have a look at the proposed regulations, and have your say, because once the regulations are finalized it will be too late. The public comment period is open until November 4, 2024.

And you can be darn sure that the folks that build and design these EV charging stations will certainly have their say; in fact a few of the major players have already voiced their concerns to the US Access Board. One of their concerns is about the “accessible route” to the charging stations. Their claim is that since they lease the space from parking lots and shopping centers, they don’t feel they should have to provide an accessible path of travel to them.

Another issue is size. Space is at a premium, as it’s usually leased and they of course would prefer to have a smaller space The proposed guidelines call for a minimum width of 132 inches and a minimum length of 240 inches with an access aisle. These are larger than standard parking spaces, to allow for access to the charging equipment. Of course the designers want them to be smaller. There would also be no distinction between van accessible spaces and car accessible spaces. Additionally the proposed number of accessible charging spaces will depend on the total number of charging stations.

“Use Last” Model for Accessible Spaces

The US Access Board is also seeking comments about an alternative designation of the accessible charging spaces, in their proposed Electric Vehicle Charging Station Regulations. Specifically they are asking if the “use last model” for accessible charging stations is acceptable. In this model they would require more accessible charging stations, but they would allow everyone to use the accessible spaces if all the other spaces are occupied. The accessible spaces would be labeled with the blue wheelchair pictogram, but it would also include the words “use last”. Under this model, the number of accessible charging spaces would also be increased.

So it would be like accessible bathrooms. They have all the required modifications, and usually have a blue wheelchair on the door, but they can be used by anyone if someone isn’t using it.

That model could lead to a lot of problems. First, there would have to be some sort of education to the public to help them understand the whole “use last” concept; and even then some folks would probably just use the accessible spaces because they were convenient. And to be honest, there’s no real way to enforce it.

Personally, I think it’s a bad idea, as it’s a slippery slope. Look at accessible parking for example. Even with fines, and threatened tows, there’s still an enormous problem with accessible parking abuse. Can you imagine how much worse that would be if you labeled the accessible parking spaces as “use last”?

In any case, I urge you to send your comments in to the access board, to let your voice be heard.

How to Comment

It’s pretty easy to make a public comment on the proposed Electric Vehicle Charging Station Regulations

First off, I encourage you to read a copy of the proposed Electric Vehicle Charging Station Regulations here.

You can make a public comment online at https://www.regulations.gov/document/ATBCB-2024-0001-0001. Click on “comment” to make your comment or “all comments on docket” to read comments that have already been submitted. Sometimes reading other comments can give you an idea of what to say.

Alternatively, you can submit a comment by e-mail at docket@access-board.gov. If you go this route, be sure and include include the docket number –ATBCB-2024-0001– in the subject line of the message.

And finally, you can also submit a comment by postal mail: Office of General Counsel, U.S. Access Board, 1331 F Street NW, Suite 1000, Washington, DC 20004-1111. And again, be sure and include Include the docket number — ATBCB-2024-0001– in your correspondence.

But don’t tarry, as the public comment period closes on November 4, 2024. After that they will review the comments and make decisions on the final regulations.