Thanks to all for the clarifying feedback. Much appreciated.
Can I ask for a bit further clarification ? I've marked up Bryce's
letter, below.
Peri
<< Annoyed by leaf blowers ? https://quietcleanseattle.org/ >>
------ Original Message ------
From: "Bryce Nesbitt via EV" <[email protected]>
To: "Electric Vehicle Discussion List" <[email protected]>
Cc: "Bryce Nesbitt" <[email protected]>
Sent: 27-Jan-26 00:23:09
Subject: Re: [EVDL] January 27, 2026 : Deadline for comments on TIA
#1874
...
Dear National Fire Protection Association,
While I ultimately am writing in support of TIA 1874 because it sands
a few rough edges off a sharp section of new code: this work is not
nearly done.
The new 625.43(D) was created without substantive consultation or
input from on-the-ground EV charging installers and electricians,
particularly not those working in multifamily situations such as
apartment complexes. Those who work in EV charging do care about
safety, do care about safety for first responders, and do care about
property safety and liability. There are better ways to do all this
that offer greater certainty to first responders, and have less second
order safety effects.
625.43(D) mandates manual shutoffs for equipment that already
automatically shuts itself off.
[why is an automatic shut off sufficiently reliable that a manual one
isn't needed ?]
These regulations were very clearly
based on an analogy to NFPA 30, where there are indeed case stories of
everyday hero customers pressing the e-Stop button and stopping the
dangerous flow of liquid fuel into a bad situation. Electrons don’t
work like that. We don’t need this. We could on the other hand use a
requirement like China has imposed for self-exquinishing batteries for
EV.
[what is china's requirement ?]
And perhaps a requirement for emergency cabinets with deployable
temporary fire blankets (if research in the end proves that to be
sufficiently valuable in real incidents). And increased use of
personal voltage safety devices. First responder personnel need
reliable granular ways to shut off power, but not just EV power.
[what do you mean by granular ways to shut off power, relevant to an EV
fire ?]
I urge the NFPA to create a focused and balanced task group on
625.43(D) to help understand the impact of this regulation, and to
help balance the tradeoffs in e-Stop. The impacts and solutions are
almost totally different for Level 1, Level 2 public, Level 2 private
and Level 3 public fast charging. 625.43(D) does not properly
distinguish.
That task group should look at the record and see what’s substantiated
in terms of risk. But not just focus on that risk, but take a step
back and see how charging can be arranged to minimize overall risk,
weighing impact on consumers as well as that of first responders. UL
standards for EVSE do retries for good reasons: to balance safety
against stranding risk, something not incorporated into 625.43(D).
This regulatory cake is not properly baked, as a TIA so soon after
release of the 2026 code has demonstrated.
Signed,
Bryce Nesbitt, January 27, 2026
Note 1:
One of the unavoidable hazards of a readily accessible e-Stop is
haters. Haters are going to press the button. As a charging operator
I shudder at the impacts. With no ability to remotely reset that
event, the station will be down.
[Great point !]
Then, someone’s going to come along and try to charge. Emergency
providers can be trained to understand how to determine if a station
is delivering power, and how to get the automatic shutdown electronics
to activate.
[Examples how ?]
Retail drivers can’t be taught. Some number of them
will stretch their battery and try to reach the next station, and end
up hopefully at least on the shoulder, creating a hazard for
themselves and others. Vehicles are safety critical systems.
Note 2:
Well on one hand this seems like a mild improvement to a baleful rule
which every state should delete from NEC. It looks like mostly
language changes except it grants
Note 3:
Shut trip breakers are not available for many common apartment panels.
This rule can bring a cascade of impacts that appear disproportionate
to the stated benefit.
[Did you mean "shunt trip" ?]
Ref: https://www.nfpa.org/codes-and-standards/nfpa-70-standard-development/70
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