Commercial EV charging stations are subject to ADA accessibility requirements, and many installations fail to meet these requirements because accessibility is treated as an afterthought rather than a design constraint. Installing chargers that are inaccessible to people with disabilities creates both legal exposure and the need to retrofit the installation later at greater cost. Our EV charging engineering team designs ADA-compliant charging stations for commercial clients in all 50 states.
Why ADA Applies to Commercial EV Charging
The Americans with Disabilities Act requires places of public accommodation and commercial facilities to provide accessible features so that people with disabilities can access goods, services, and amenities on an equal basis. EV charging is an amenity of the parking facility. When charging is available to the general public or to facility users, accessible charging must be provided for people with disabilities who use electric vehicles.
This obligation applies regardless of whether the ADA explicitly addresses EV charging stations in specific regulatory text. The DOJ has consistently interpreted ADA Title III to require accessibility at newly installed facilities, and the DOJ and DOE have both issued guidance indicating that EV charging stations at commercial facilities must be accessible. State accessibility codes in California, New York, and other states have added explicit requirements for accessible EV charging in their state building codes.
Accessible Parking Stall Requirements
Stall Dimensions
An accessible EV charging stall must meet the dimensional requirements for accessible parking. A standard accessible stall must be at least 96 inches (8 feet) wide with a 60-inch access aisle, or it can be a van-accessible stall at 132 inches (11 feet) wide with a 60-inch aisle, or 96 inches wide with a 96-inch aisle. The access aisle must be level (maximum 2 percent slope in all directions) and must connect to an accessible path of travel leading to the building entrance or facility.
The access aisle must be on the passenger side of the vehicle because most people who use wheelchairs exit from the passenger side. This affects the configuration of adjacent stalls and the placement of the charging equipment within the stall. Getting the access aisle placement right from the beginning is simpler than redesigning the stall layout after installation. Our engineering team incorporates these dimensional requirements into the site plan from the start.
Charging Equipment Placement
The charging equipment must be reachable from the vehicle without requiring the user to travel into the vehicle travel lane. Equipment that is mounted on a post within the stall must be placed so that the controls are within the reach range allowed by ADA: 48 inches maximum height for a forward reach and 54 inches maximum for a side reach when the reach is over an obstruction. Charging equipment that requires the user to reach across the vehicle is not accessible.
The charging connector and its cord must be long enough to reach from the equipment location to a vehicle parked in the accessible stall without the cord creating a trip hazard across the access aisle. Cord lengths and routing must be considered during equipment selection and placement design.
How Many Accessible Chargers Are Required
ADA does not specify an explicit ratio of accessible EV chargers to total chargers in its current regulations. The commonly applied interpretation uses the parking ratio: the same percentage of EV chargers should be accessible as the percentage of total parking spaces that are required to be accessible. For facilities with fewer than 25 charging stations, at least one accessible charger is typically required. State codes may specify higher minimums. Our commercial engineering services include accessibility ratio calculations for all EV projects.
Path of Travel and Signage
An accessible route must connect the accessible EV charging stall to the building entrance or facility entrance. This path must have a firm, stable, slip-resistant surface, comply with cross slope and running slope limits, and be free of protrusions that could be hazardous to users of mobility aids. If the path crosses a drive aisle, a marked and detectable crosswalk is required.
Accessible EV charging stalls must be identified with the International Symbol of Accessibility and, in most jurisdictions, with a sign indicating that the stall is reserved for electric vehicle charging by accessible permit holders. Signs must be at the appropriate height and located where they are visible to approaching drivers.
Common Design Mistakes
Placing chargers at the back of a parking lot without an accessible route to the building is the most common mistake. A second common error is providing an access aisle on the driver’s side rather than the passenger’s side. Mounting charging equipment at heights that exceed ADA reach ranges is another frequent issue, particularly with wall-mounted units designed for standard-height users. We review all of these factors during the site plan development phase to avoid costly retrofits.
Frequently Asked Questions
Does ADA apply to private employee parking facilities?
ADA Title I requires employers to provide reasonable accommodations to employees with disabilities, which may include accessible parking and EV charging if the employer provides charging as a benefit. ADA Title III applies to places of public accommodation. Employee-only parking may have different requirements than publicly accessible parking, but the employer’s obligations under Title I should be evaluated separately.
What happens if our existing EV installation is not accessible?
Existing installations that were not accessible when installed must be made accessible if the facility undergoes alterations that affect the area. If the existing installation is not being altered, the barrier removal standard under ADA Title III applies: barriers to accessibility must be removed when it is readily achievable to do so. Consult with legal counsel on the specific obligations for your facility.
Are state ADA requirements different from federal?
Some states have adopted building codes with accessibility requirements that are stricter than federal ADA. California’s Title 24 Part 2 (California Building Code) includes specific requirements for EV charging accessibility that go beyond federal ADA in some areas. Designing to the most stringent applicable standard, whether federal or state, provides the best protection against enforcement actions.
Get Your EV Charging Site Designed for Accessibility
We design ADA-compliant EV charging sites for commercial clients in all 50 states. Submit your project at rightangleeng.com/get-started.
References
U.S. Department of Justice and U.S. Department of Transportation. (2014). ADA Requirements for EV Charging Stations. ada.gov.
U.S. Access Board. (2017). Guide to ADA Accessibility Standards: Parking Spaces.
California Building Code, Title 24 Part 2. (2022). Chapter 11B: Accessibility to Public Buildings.