Repave a Multifamily Lot With a Permit, and Altered Spaces Owe EV Access

The permit you pulled to restripe the lot just changed scope

Here's the thing: most people find CALGreen's EV rules by looking at new construction. New apartments, new hotels — everyone knows those parking lots come with EV requirements. What gets missed is the section that reaches existing buildings, and it's hiding in plain sight.

CALGreen §4.106.4 is titled "Electric vehicle (EV) charging for new construction." Its first two subsections — 4.106.4.1 and 4.106.4.2 — govern new dwellings, new multifamily, new hotels and motels. Read the heading and you'd assume the whole section stays in the new-construction lane. It doesn't. §4.106.4.3 sits right under that same heading, and its own title is "Electric vehicle charging for additions and alterations of parking facilities serving existing multifamily buildings, hotels and motels." It's a retrofit trigger wearing a new-construction jacket.

What actually pulls the trigger

The trigger is one sentence, and every clause in it matters:

Verified against the live code text (§4.106.4.3, 2025 CALGreen, effective January 1, 2026): "When existing parking facilities are altered or new parking spaces are added to existing parking facilities, and the work requires a building permit, each parking space added or altered shall have access to either a low power Level 2 EV charging receptacle or Level 2 EV charger, unless determined as infeasible by the project builder or designer and subject to concurrence of the local enforcing agency."

Break it into the parts that decide whether it lands on your job:

• Existing parking, altered or expanded. The building doesn't have to be new. Rework an existing lot, or add spaces to it, and you're in scope.
• The work requires a building permit. No permit, no trigger. But a permitted restripe, resurface, or reconfiguration at an existing multifamily property, hotel, or motel is exactly the kind of routine work that reads as "not an EV project" — until you read this section.
• Each space added or altered needs access. Not the whole lot — the spaces the permit touches. And note the exact words: access to a low power Level 2 receptacle or a Level 2 charger.

What do those mean in the code? The definitions are precise:

• A low power Level 2 EV charging receptacle is "a 208/240-volt 20-ampere minimum branch circuit and a receptacle."
• A Level 2 EV charger is "a 208/240-volt 30-ampere minimum electric vehicle charger connected to the premises electrical system …"

Either one satisfies the base requirement. Both are 208/240-volt work — which is the whole point. A job priced as asphalt and paint quietly acquires an electrical scope.

The two outs

The section hands you two off-ramps. Know both before you bid.

Out one — infeasibility. The requirement falls away where it's "determined as infeasible by the project builder or designer and subject to concurrence of the local enforcing agency." Read that carefully: you don't self-certify infeasibility. The designer or builder makes the call, and the local enforcing agency has to concur. It's a documented conversation with your jurisdiction, not a line you write on the plans and move past.

Out two — the Level 1 exception. There's an explicit carve-out:

Exception (§4.106.4.3): "Where work requiring a permit is being performed for the installation of 120-volt electrical receptacle(s) for Level 1 EV charging."

If the permitted work is itself the installation of 120-volt Level 1 receptacles — defined as "a 120-volt 20-ampere minimum branch circuit and a receptacle" — the Level 2 access requirement doesn't attach. The code doesn't force you to jump from a Level 1 job up to Level 2.

Why this bites at bid time

The damage here is a pricing surprise. A property manager wants the lot resurfaced and restriped. It needs a permit. Nobody reads past "grading and paving," so the estimate is asphalt, striping, and a mobilization line. Then plan check asks where the Level 2 access is for the altered spaces, and the job grows a 208/240-volt electrical scope that was never in the number the client signed.

So the move is simple: before you price parking-lot work at any existing multifamily building, hotel, or motel, read 4.106.4.3 and decide which door you're walking through — full Level 2 access, a documented infeasibility case your jurisdiction will concur with, or a scope that stays inside the Level 1 exception. Cities can amend, and none of this is legal advice, so confirm the trigger and any local wrinkles with your enforcing agency before the fee estimate goes out.

What CrossBeam does with it

CrossBeam reads a parking or site permit against the whole of §4.106.4 — including the 4.106.4.3 retrofit trigger that lives under a "new construction" heading — and flags when altered or added spaces at an existing multifamily, hotel, or motel property owe Level 2 EV access. It surfaces the two outs, the infeasibility path and the Level 1 exception, so the electrical scope shows up in the estimate instead of at the counter.