Where's the "Outlet" under the 2020 NEC -- for outdoor hardwire EVSEs

[retirede]

But it is widely acknowledged that a requirement for protection can be provided by the equipment, and that pinpointing the outlet location is therefore irrelevant. No one claims that a GFCI receptacle does not provide GFCI protection because the outlet is on the supply side of the GFCI device.

One could argue that the exact outlet location of a receptacle outlet is where the plug mates with the slots, which is on the load side of the GFCI.

I know this thread is about the 2020 NEC, but once you’re on the 23 NEC, and the EVSE is installed outdoors on a hard-wired 50A or less branch circuit, the outlet must be protected. Then the outlet location becomes relevant.

We had a big thread about this with regards to HVAC units. Same thing should apply to an EVSE.

 

[wwhitney]

One could argue that the exact outlet location of a receptacle outlet is where the plug mates with the slots, which is on the load side of the GFCI.

Precisely.

I know this thread is about the 2020 NEC, but once you’re on the 23 NEC, and the EVSE is installed outdoors on a hard-wired 50A or less branch circuit, the outlet must be protected.

That requirement for dwelling units, 210.8(F), is already in the 2020 NEC.

Cheers, Wayne

 

[don_resqcapt19]

But it is widely acknowledged that a requirement for protection can be provided by the equipment, and that pinpointing the outlet location is therefore irrelevant. No one claims that a GFCI receptacle does not provide GFCI protection because the outlet is on the supply side of the GFCI device.

No protection for an outlet other than overload protection can ever be provided by the equipment as the equipment is on the load side of the outlet.

 

[retirede]

Precisely.

That requirement for dwelling units, 210.8(F), is already in the 2020 NEC.

Cheers, Wayne

Thanks for the correction.

 

[jaggedben]

No protection for an outlet other than overload protection can ever be provided by the equipment as the equipment is on the load side of the outlet.

Then a GFCI receptacle can not meet the requirements of 210.8(F).

 

[don_resqcapt19]

Then a GFCI receptacle can not meet the requirements of 210.8(F).

For cord and plug connected equipment the outlet is the slots in the receptacle and they are protected by the GFCI circuit on the line side of the slots.

 

[jaggedben]

For cord and plug connected equipment the outlet is the slots in the receptacle and they are protected by the GFCI circuit on the line side of the slots.

You just described a hardwired EVSE.

 

[retirede]

You just described a hardwired EVSE.

I disagree. The EVSE has to be considered utilization equipment. Its cord is not premises wiring.

 

[jaggedben]

I disagree. The EVSE has to be considered utilization equipment. Its cord is not premises wiring.

If the EVSE is utilization equipment, so is a GFCI receptacle.

(At least if we're talking about a typical Level II EVSE that simply passes AC power through.)

I kind of get the intuition notion that an EVSE might be utilization equipment if you just look at its size and shape and don't know what goes on inside. But there's no logic to that whatsoever under code definitions. With both the Levell II EVSE and the GFCI receptacle, the device consumes an miniscule amount of energy compared to the real load, which is plugged into it. The only function(s) the device performs are to determine if it's safe to pass current to the actual load. The EVSE's functions are a little fancier in this respect, but not different in kind.

 

[jim dungar]

Then a GFCI receptacle can not meet the requirements of 210.8(F).

Have you looked at the definition of a receptacle outlet?
I have no doubt that a receptacle is part of premises wiring but an ESVE connection point is not.

 

[don_resqcapt19]

You just described a hardwired EVSE.

I have no idea of how there are receptacle slots on a hard wired EVSE.

The outlet for a hardwired EVSE is the terminals in the equipment that the branch circuit conductors connect to.

 

[retirede]

If the EVSE is utilization equipment, so is a GFCI receptacle.

(At least if we're talking about a typical Level II EVSE that simply passes AC power through.)

I kind of get the intuition notion that an EVSE might be utilization equipment if you just look at its size and shape and don't know what goes on inside. But there's no logic to that whatsoever under code definitions. With both the Levell II EVSE and the GFCI receptacle, the device consumes an miniscule amount of energy compared to the real load, which is plugged into it. The only function(s) the device performs are to determine if it's safe to pass current to the actual load. The EVSE's functions are a little fancier in this respect, but not different in kind.

What an EVSE does is an order of magnitude more than a GFCI receptacle.
An installed GFCI receptacle is clearly part of the premises wiring. An EVSE is a piece of equipment. No different than a UPS. The NEC does not limit what comprises utilization equipment based on the power it consumes.
Honestly, I can see your point, I just don’t agree with it.

 

[jaggedben]

Have you looked at the definition of a receptacle outlet?

Yes. And what is the significance of that? 210.8(F) doesn't refer to receptacle outlets.

I have no idea of how there are receptacle slots on a hard wired EVSE.

Tell me how exactly how this doesn't meet the NEC definition of a receptacle. "A contact device installed at the end of an outlet for the connection of an attachment plug, or for the direct connection of electrical utilization equipment designed to mate with the corresponding contact device."


But also, again, what's the significance of receptacles to 210.8(F)? It doesn't mention them.

The outlet for a hardwired EVSE is the terminals in the equipment that the branch circuit conductors connect to.

Same for a GFCI receptacle then. You're not addressing my points.

What an EVSE does is an order of magnitude more than a GFCI receptacle.

I don't know how you think that can be quantified, but it's not important, because only a qualitative, definitional difference would matter. How are they different in terms of any NEC definition that matters to 210.8(F)?

An installed GFCI receptacle is clearly part of the premises wiring.

Then a level 2 EVSE is too. Just be consistent.

An EVSE is a piece of equipment.

So is a receptacle.

No different than a UPS.

No different than a receptacle.

The NEC does not limit what comprises utilization equipment based on the power it consumes.

Then a GFCI receptacle is too. Just be consistent. To be clear, if you guys want to take the stance that a GFCI outlet is utilization equipment, I will say "At least you're being consistent."

Honestly, I can see your point, I just don’t agree with it.

So you're just repeating your opinion without making a logical argument for it. Not that you are alone here in that.

 

[Fred B]

210.8(A)(B) is strictly receptacle related conditions.
210.8(C) specific lighting circumstance.
210.8(D) Specific Equipment listed in 422.5.
210.8(E) Again related to receptacles. And
210.8(F) is related to "outdoor outlets". That is the where kicker of it comes in, is the charger in the garage or not and then where is the "outlet" related to the charger? Is it the connector to the car or is it the base unit? If the "outlet" is the connector to the car then in some circumstances it could extend outdoors then falling under "F" of 210.8. But if the "outlet" is the base unit that is fixed to the wall inside the garage, It doesn't fit the criteria of "F" of 210.8.

But then, the requirement for GFCI directly related to the EVSE, is limited to the "all receptacles" the equipment might plug into, nothing in the requirement would indicate that a direct wired ESVE would require such per 625.54

From my perspective given the wall unit has electronic components that control or monitors the charging of the vehicle including the safety shut off for "if" the vehicle connection was to be inadvertently disconnected, from that standpoint the "outlet" is at the EVSE base or wall unit as a "utilization devise or equipment". Thus eliminating 210.8(F) from consideration for a direct wired EVSE unless it is 50A or less AND outdoors.

That brings another consideration IS the amp rating related to 210.8(F) the breaker size requirement or the listed max. Most level 2 that I've seen maxing out at 48A but are to put onto and wired to 60A breaker and wire. So What is the determining factor for the "50A or less" found in 210.8(F)?

 

[Little Bill]

Yes. And what is the significance of that? 210.8(F) doesn't refer to receptacle outlets.

Tell me how exactly how this doesn't meet the NEC definition of a receptacle. "A contact device installed at the end of an outlet for the connection of an attachment plug, or for the direct connection of electrical utilization equipment designed to mate with the corresponding contact device."

View attachment 2568264

That is not a receptacle where the utilization equipment connects to the power of the wiring system. The outlet is in the ESVE. that's where the system wiring meets the equipment. What you show is just a connection from the outlet to the charger in the car.

 

[jim dungar]

A receptacle is specifically defined as a 'contact device' not a piece of utilization equipment. There are specific Listing and construction requirements which receptacles must meet. The fact that some incidental power may be consumed by electronics in the receptacle, prior to its contacts, doesn't change that it is a 'wiring device'.

An EVSE connection 'box' is not a contact device. It does not fall into any of the 'wiring device' Listing requirements. As quoted above, the vehicle plug portion of the charging system is not part of premises wiring per the NEC.

 

[retirede]

So you're just repeating your opinion without making a logical argument for it. Not that you are alone here in that.

That just hilarious!

 

[wwhitney]

Electric Vehicle Supply Equipment.
The conductors, including the ungrounded, grounded, and equipment grounding conductors, and the electric vehicle connectors, attachment plugs, and all other fittings, devices, power outlets, or apparatus installed specifically for the purpose of transferring energy between the premises wiring and the electric vehicle.

At first glance, you might think that this definition defines the EVSE as not part of the premises wiring, since its purpose is "transferring energy between the premises wiring and the electric vehicle." But you can say the same thing about a NEMA 5-15 receptacle, its purpose is "transferring energy between the premises wiring and cord-and-plug-connected utilization equipment." It is commonly understood that a NEMA 5-15 receptacle supplied by permanently installed building wire is part of the premises wiring; if it weren't, GFCI receptacles could not be used to provide GFCI protection of the outlet. So this definition does not settle the question of whether the EVSE is before or after the outlet.

Then there's the definition of utilization equipment: "Equipment that utilizes electric energy for electronic, electromechanical, chemical, heating, lighting, or similar purposes." A typical J1772 EVSE is just a slightly smart high power switch and connector. Its job is not to utilize electrical energy but to pass it along unmodified to an EV. As such, the closest analogue would be a wifi-enabled smart receptacle that you could turn on and off remotely. That would not generally be considered utilization equipment.

One could argue that the use of a flexible cord indicates that the EVSE is not part of the premises wiring system. But we also have permanently installed overhead cord drops that terminate in a hubbed box with a receptacle--are those not part of the premises wiring system?

Lastly, we have this product from Eaton, which consists of a double pole breaker married to additional electronics that take up two more spaces in the panelboard and provide all the J1772 EVSE functionality. From the breaker you can directly connect an EVSE cord, or you can run the 5 conductors of the J1772 standard to a junction box using building wire, and at the junction box connect the J1772 cord and vehicle connector. That really, really looks like an EVSE that is part of the premises wiring system.

https://www.eaton.com/us/en-us/catalog/electrical-circuit-protection/ev-charging-smart-breakers.html

So the upshot, as far as I can see, is that there is nothing definitive in the NEC as to whether the outlet for a hardwired EVSE is where the building wire terminates in the EVSE wiring compartment, or at the end of the vehicle connector, or even somewhere in between.

However, this distinction would only matter, as far as I am aware, if you had an EVSE that implemented Class A GFCI protection of its J1772 cord and vehicle connector. Every EVSE on which I've checked the spec sheet only implements CCID20, which has a 20ma trip threshold. So for any such CCID20 EVSE, if the outlet requires GFCI protection, that will require a device in the branch circuit supplying the EVSE, regardless of where within the EVSE the outlet is located.

Cheers, Wayne

 

[jaggedben]

That is not a receptacle where the utilization equipment connects to the power of the wiring system.

Explain exactly why not. I think it is. Or at least, the definition of utilization equipment requires you to make an interpretation, and then be consistent from there.

The outlet is in the ESVE. that's where the system wiring meets the equipment.

Explain how a GFCI receptacle is different. For argument's sake, let's say it's one of those with the LED indicator that shows it has power.

 

[jaggedben]

A receptacle is specifically defined as a 'contact device' not a piece of utilization equipment. There are specific Listing and construction requirements which receptacles must meet. The fact that some incidental power may be consumed by electronics in the receptacle, prior to its contacts, doesn't change that it is a 'wiring device'.

If the power consumed by a GFCI receptacle is incidental, then so is the power consumed by a Level II EVSE. Or, neither are. There's nothing in NEC definitions that supports your making a distinction here.

An EVSE connection 'box' is not a contact device.

The thing I posted a picture of is.

It does not fall into any of the 'wiring device' Listing requirements. As quoted above, the vehicle plug portion of the charging system is not part of premises wiring per the NEC.

'Wiring device' is not an NEC defined term. If the plug portion of the charger (how is it a 'system'?) is not part of the premises wiring, then neither is a GFCI receptacle that consumes power to perform a function.

Just be consistent. Either admit that 210.8(F) doesn't say what you thought it said, or what you wish it said. Or admit that if an EVSE has GFCI protection for personnel then it would meet the requirements of that section. I think either interpretation is justifiable given the lack of specificity in the definitions of premises wiring and utilization equipment. But there's no justification for not being consistent.

I think a lot the issue here is demistifying what a Level II charging box actually does. It serves only to connect or disconnect the car from the mains voltage. It doesn't convert the power, control the current, convert it to a different form of energy, or do anything else that utilization equipment normally does.