Standards Council Meeting August 18th -- Appeal on GFCI reach

B

brycenesbitt

Senior Member
Location
United States
Monday August 18 2025 10am EST is the 2025 Standards Council Meeting. Agenda is at
http://www.nfpa.org/sc2025
You have to appear in 15 minutes in advance virtually or in person to register.



There's an item there that started with Public Input No. 1440 by a member of this very forum. That PI was later releveled to have had a different purpose as a challenge to another rule (and variously as a "joke"). Yet:

Even the original submitter of this public input later submitted Public Comment No. 275 asking the committee to reverse their action based on the lack of substantiation. Other public comments correctly identified a lack of technical substantiation.
Click to expand...

This change has a similar impact to 210.8(F) in creating significant angst among those working in the space. The risk data is just not there to justify an action that will create secondary risks. It's a solution worse than the (theoretical) problem. Diligent searches by various parties including SAE and UL have shown there is no problem to solve: the existing system is working fine. And my view is adding SPGFCI is another bad solution that still misses the safety point.



Anyway here's the core appeal document, as supported by Honda, Rivian, Chargepoint, Electric Drive Transport Association and more:
National Fire Protection Association
1 Batterymarch Park
Quincy, Massachusetts U.S. 02169-7471

July 11, 2025

Attention: Mr. Dwayne E. Sloan
Secretary, NFPA Standards Council

Regarding: 2026 National Electrical Code Making Process
National Electrical Code Making Panel 12
Matters of 2025 Certified Amendment Motions affecting NEC 625.54
CAM 70-58/70-77/70-147/70-151/70-178
CAM 70-134/70-182
CAM 70-135/70-142/70-145/70-179

Dear Mr. Sloan:

We, as members of the auto industry, appreciate NFPA's dedication to improving Article 625 of National Electrical Code, "Electric Vehicle Power Transfer System." As of 2024, about 4 million electric vehicles are on road in the United States according to an Experian Automotive report. It is important for us to offer safe and reliable electric vehicle charging environment to users of those vehicles in a code-compliant and affordable manner.

As we approach the end of the revision cycle of 2026 Edition of National Electrical Code, we are concerned that elements of the current Drafts text are incompatible with ANSI/UL EVSE standards resulting in customers being unable to charge their vehicles. We see key issues that were not addressed in the Drafts and were not solved in the 2025 Technical Meeting of the NFPA Conference and Expo held in Las Vegas, NV on June 19-20, 2025.

The grounds for this Appeal are structured under three categories:
  • Non-compliance with Regulations Governing the Development of NFPA Standards
  • Inconsistencies under NEC Style Manual: Clarity and Usability
  • Nonadherence to NFPA’s Guide for the Participants in the NFPA Standards Development Process

1. NAME, AFFILIATION, AND ADDRESS OF THE APPELLANT​

Dr. Rodney McGee PE

SAE International Standards Chair for
Electric Vehicle Conductive Power Transfer for the Motor Vehicle Council
and the Truck and Bus Council

139 The Green
Newark, Delaware 19716 USA

2. STATEMENT IDENTIFYING THE PARTICULAR ACTION TO WHICH THE APPEAL RELATES​

This appeal relates to the failed Certified Amending Motion CAMs, 70-58/70-77/70-147/70-151/70-178, concerning NFPA 70 Article 625.54, which were rejected at the 2025 NFPA Annual Technical Meeting held in Las Vegas, NV on June 19-20, 2025.

3. ARGUMENT SETTING FORTH THE GROUNDS FOR THE APPEAL​

The development and approval of the proposed 2026 NEC Section 625.54 text violated multiple provisions of NFPA's governing documents, resulting in technically unsound and unusable requirements that will harm public safety and the electric vehicle infrastructure.

A. Compliance to Regulations Governing the Development of NFPA Standards​

1. Section 4.3.4.1(d) and (e) - Lack of Technical Substantiation for Public Input​

Public Input No. 1440 expanded the requirements of 625.54 to add GFCI or SPGFCI for outlets without providing any technical substantiation or data to justify this expansion.

The lack of technical substantiation was evident from the First Draft stage, and the requirements were significantly expanded yet again in the Second Draft without providing experts the opportunity to provide input. Even the original submitter of this public input later submitted Public Comment No. 275 asking the committee to reverse their action based on the lack of substantiation. Other public comments correctly identified a lack of technical substantiation.

2. Section 4.3.9.2.2 - Inadequate Committee Statement​

The Committee Statement on Public Comment No. 1440 failed to provide any technical substantiation or data justifying the expansion of requirements of 625.54.

3. Section 4.4.8.2 - Insufficient Technical Rationale in Second Draft​

Section 4.4.8.2 provides that committee statements "shall preferably be technical in nature and shall be sufficiently detailed so as to convey the committee's rationale," but the committee statement associated with Second Draft Revision No. 7875:
  • Provided insufficient technical substantiation or data explaining why the committee ignored technical incompatibilities identified in the ballot.
  • Created contradictions with the published text, including conflation of GFCI and SPGFCI requirements.
  • Did not clarify the applicability of effective dates as they pertain to GFCI versus SPGFCI and related voltage levels.
B. Conformance to 2023 National Electrical Code Style Manual

Section 1, Purpose - Included Language does not Achieve Clarity and Usability​

The Style Manual requires technical committees to produce documents "as clear, useable, and unambiguous as possible." The current text conflicts with this fundamental purpose in multiple ways:

1. Unclear and Ambiguous Effective Dates:
  • 625.54(B)(2) states the effective date of January 1, 2029
  • The committee statement in the Second Revision, 7875, regarding the exception claims this date applies to all of 625.54(B).
  • However, 625.54(B)(1) contains no such effective date language.
  • The resulting language introduces confusion about implementation requirements.
2. Demonstrably Unusable Requirements:

Documented empirical evaluations have proven that the proposed requirements are not merely impractical, but they conflict with prevailing standards and are impossible to implement:
  • Verified Heavy-Duty Vehicle Failures: Empirical evidence was included in the documentation for the NITMAM CAM 70-54. This data was collected during field testing where it verified failed operation of commercially available electric bus models used by First Student (the largest school bus operator in the US). These vehicles utilize single-phase 208VAC for AC EVSE, and none were able to charge at all from Class A GFCI as required by the 2026 625.54(B)(1).
  • Broader Impact: Identical school bus charging components are utilized in other heavy-duty vehicles, this failure pattern extends across not only the heavy-duty vehicle but also all automotive sectors.
  • Passenger Vehicle Incompatibility: Multiple OEMs have produced test data which shows significant performance variability for passenger cars and pickup trucks. These data support findings that many cannot operate at all, while others trip unpredictably.
  • Bidirectional Charging: Systems falling under 625.54(B)(1) would require GFCI protection, yet no GFCI or SPGFCI products exist that are compatible with bidirectional charging.
3. Ambiguous Application of Exception No. 2:
  • Exception 2 lacks GFCI-specific language for a bidirectional use case and applies only to SPGFCI under 625.54(B)(2).
  • The proposed language is unusable for residential or commercial 120/240V and 120/208V installations because EVSE under Section 625.54(B)(1) are required to use GFCI, not SPGFCI.
  • Importantly, this contradicts CMP-12's stated intent regarding the January 2029 implementation timeline for all EVSE under 625.54(B). The committee statement is as follows: "625.54(B): The January 1, 2029 date allows the industry time to develop the technology for power export and GFCI protection."
 

C. Following the Guide for the Conduct of Participants in the NFPA Standards Development Process​

1. Section 1 - Contrary to Statement of Purpose​

The Guide's purpose is to "reduce the worldwide burden of fire and other hazards on the quality of life." The proposed language achieves the opposite effect and will result in increased hazards:
  • No Hazard Justification: No reported cases of hazards justify these requirements
  • Life Safety Risks from Stranding: The expansion of 625.54 will result in nuisance tripping of GFCI/SPGFCI devices, very likely stranding EV users. This is especially true in outdoor charging sites, leading to potential loss of life in transportation-essential situations such as emergency evacuations
  • Mission Critical Transportation Impact: Transportation is often part of mission critical operations. Under the 625.54 text, it is impossible to achieve coordination of fault tripping between the branch circuit’s GFCI or SPGFCI device, the EVSE, and the connected vehicles. Without coordination, important reliability functions like automatic reclosure required by UL 2231 cannot work.
  • Resource Waste: First responders, maintenance personnel, and installers will waste resources responding to EV stranding incidents.

2. Section 2(c) - Lack of Scientific and Technical Soundness​

The Guide requires promoting "codes and standards that are scientifically and technically sound." The proposed language ignores documented technical incompatibilities and creates requirements that cannot be met:

Technical Incompatibilities:

  • Multiple public comments and ballot statements identified incompatibilities between GFCI and EV charging personnel protection systems. When comparing the conducted immunity test between UL 943 Section 6.9.1 and UL 2231 Section 24.5, EVSE are required to function with no unwanted tripping at test levels 40 times higher than UL 943.
  • UL 2231-2, Section 18 explicitly states that EVSE will cause unwanted tripping of Class A GFCI devices.
  • Vehicle on-board chargers use high-frequency components, and per the Committee statement on Second Revision No. 8447 from Code Making Panel 17 on 422.5(C), are known to cause "unwanted tripping" with Class A GFCI. The committee statement is as follows: “UL 943 is anticipated to be updated to include new specifications for a High Frequency (HF) GFCI. This GFCI will be required due to efficiency regulations which will require incorporation of High Frequency components in these appliances. Use of an updated GFCI on an appliance will help to reduce instances of unwanted tripping. An effective date was included since currently there are no listed products meeting this requirement."
Existing EV-specific Interrupting Device Standards Ignored:

  • Current EVSE safety standards already incorporate Charge Circuit Interrupting Device (CCID) technology with frequency-adjusted trip levels based on established let-go and fibrillation curves documented in UL 2231-2.
  • This personnel protection method is already incorporated into all UL listed AC EVSE's CCID functionality and is supported with auto reclosure to increase reliability.
  • The 625.54 text requires introduction of conventional GFCI/SPGFCI where they were not used before, directly conflicting with the standards and the design and operation of millions of operational EVSEs already deployed.
Multi-EVSE Installation Conflicts:

  • Per 625.42, multiple EVSE are allowed on the same branch circuits.
  • Since each vehicle will source some apparent leakage in a multiple EVSE installation, the upstream protection required by 625.54(B) makes installations per 625.42 unfeasible.
  • Additionally, per UL 2231-2, EVSE can be required to have a ground monitor/interrupter (GM/I) that source small currents to continuously monitor ground continuity. This function conflicts with upstream Class A GFCI protection as required by 625.54, and may cause the equipment to trip without any EV connected and without any electric shock hazard present.
No Path for Compliance:

  • Per UL 2231-2, Section 18, only EVSE rated 15A or 20A with cord and plug connections are allowed to contain means to make the EVSE and EV compatible with Class A GFCI, and describes supply circuits that have Class A GFCI protection as inherently incompatible with CCID20 causing “unwanted tripping.” CCID20 is used by all known permanently wired public charging stations.
  • Contrasting this with the HVAC unwanted tripping issues:
    • UL standards did not specify a maximum leakage current requirement for HVAC units. Industry debate then ensued as to what the appropriate level of allowable leakage should be.
    • In the case of EVSE and EV products standards, a specific maximum apparent leakage has been specified since 1996. The new 625.54 limit contradicts the foundational EVSE product standard referred to by the NEC for listing.
  • Unlike HVAC units which can be updated with new construction and code requirements, charging stations need to be designed to be backwards and forward compatible. This is especially important to support the age range of vehicles which are designed to operate with the existing CCID20 functionality under the existing standards. As acknowledged in UL 2231-2, EVSE following UL standards are expected to exceed the 4-6mA leakage current levels required by Class A GFCIs, effectively stranding vehicles that depend on these systems.
  • There is no path for reliable operation under the proposed text, even if EVSE were redesigned.
Lack of Specified Upper Limits on Current (Ampere) Ratings:

  • Other NEC sections requiring GFCI protection, such as 210.8(D), 210.8(F), 422.5, and 680.5, limit requirements to circuits of 50-60 Amps or less, aligning with commercially available products.
  • Language proposed in 625.54(B) contains no Ampere limit, requiring single-phase GFCI breakers above 60A which are not commercially available.
  • This results in an effective ban on new installations of common AC EVSE types.

3. Section 3.3(c) - Failure to Consider All Issues​

Section 3.3(c) requires Committee members to be "familiar with all issues relating to Public Inputs and Public Comments." The issues identified above and lack of substantive responses in the ballots indicate members approved language without proper familiarity and consideration of all technical issues raised.

Multiple Public Comments Explicitly Identified Technical Incompatibilities:

The public comment record demonstrates that numerous stakeholders raised the exact technical concerns that now plague the approved text. Public Comments 1962-NFPA 70-2024, 1963-NFPA 70-2024, and 1965-NFPA 70-2024 (submitted by Joel Frangquist, Armin Karcher, and Charles Sullivan respectively) pointed out that the code-making panel failed to adequately consult with the EVSE manufacturing industry regarding the consequences of the new requirements. These commenters specifically noted that many hardwired Level 2 EVSEs have manufacturer instructions disallowing upstream GFCI protection - a critical fact that was not addressed in the panel's response.

Public Comments 1962-NFPA 70-2024 and 1965-NFPA 70-2024 highlighted that the panel failed to investigate fundamental feasibility questions, including:

  • EVSE covered by the expansion do not have 5mA (Class A) GFCI protection?
  • Whether it is feasible for EVSE exceeding certain voltage/current limits to operate with GFCI or SPGCI protection?
  • Does the new text conflict with ANSI UL EVSE safety standards?
Public Comment 1964-NFPA 70-2024 (Dean Hunter, member of CMP 7 and the NEC Correlating Committee) highlighted potential compatibility issues and unwanted tripping due to existing protection systems within EVSE equipment.

Technical Substantiation Concerns Raised but Not Addressed:

Public Comment 1962-NFPA 70-2024 specifically stated that the panel "ignored technically substantive statements" and failed to provide clear technical substantiation for the revisions. These well-documented technical concerns from industry experts were submitted through the proper channels but do not appear to have been given adequate consideration, as evidenced by the technical problems that remain in the approved text.

4. STATEMENT OF THE PRECISE RELIEF REQUESTED​

We respectfully request the Standards Council to reject Second Revision 7875 and any related first revisions and first correlating revisions, as requested by CAM 70-58/70-77/70-147/70-151/70-178, which causes NFPA 70 section 625.54 to revert to the 2023 edition.

5. REQUEST FOR HEARING​

We would like to confirm that, yes, a hearing is necessary. We hererby request a hearing on this appeal to present technical evidence, field testing results, and discuss the safety implications of the current text.
 
Well that was interesting.

Remember this was a hearing about PROCESS not the technical details.
And the presentation was clean, all about PROCESS.

----------------------------
However it got muddy with the actual technical details fast.

The strongest justification for GFCI expansion was from Schneider Electric who said that since 20%
of public EVSE are broken, technicians will need to repair them.
Apparently those technicians don't know how to work with wires ¹.

The same Schneider Electric representative said that he charged his personal car for 2 years in his garage
and did not trip the EVSE....
as evidence that there's no problem with GFCI. Sigh.

That's sad. Schneider had just listened to SAE describing how higher amperage brings higher problem,
and school buses can't charge at all. It's as if he was not listening, and he never responded to any other point in the room.
He was insensitive to the ease a single family homeowner has resetting a GFCI vs. an apartment resident.
And he never addressed the in-built protection EVSE have. SAE on the other hand described both the upstream and downstream protection afforded by EVSE which are after all just an intermediate device in the charging process.

An EVSE is basically a special purpose GFCI with a few tricks like amperage communications.
 
brycenesbitt said:
The strongest justification for GFCI expansion was from Schneider Electric
Click to expand...
I wonder what department he was from. The safety departments from big corporations are insane. If they had their way in the world we would all be wearing crash helmets to take a shower because of the possibility of slips, trips, and falls.
 
ActionDave said:
I wonder what department he was from. The safety departments from big corporations are insane. If they had their way in the world we would all be wearing crash helmets to take a shower because of the possibility of slips, trips, and falls.
Click to expand...
Sales department. His bonus is calculated based on sales increase of GFCI breakers.
 
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