Solar Carport Over an Existing Lot? Only Covered Stalls Owe EV Charging

The code never said which stalls count

Here's the thing: put a solar canopy over part of an existing nonresidential lot and the 2025 CALGreen doesn't tell you plainly how much EV charging you owe.

The trigger lives in Section 5.106.5.4, "Additions or alterations to existing buildings or parking facilities." One of the events that pulls an existing lot into the new-construction EV tables is this:

Verified against the live 2025 CALGreen text (5.106.5.4, item 2): "When a new photovoltaic system is installed covering existing parking spaces."

Install PV over existing stalls and the lot has to provide EV charging per Section 5.106.5.3 and Table 5.106.5.3.1 (or the power-allocation method in Section 5.106.5.3.6). But the follow-on section, 5.106.5.4.1, only says to size that charging "for the total number of actual parking spaces being added or altered." A PV canopy doesn't re-stripe anything. So which spaces are "added or altered" — the ones under the panels, or the whole facility?

Put panels over 40 stalls of a 300-stall lot and the code, as written, won't tell you whether you owe EV charging for 40 spaces or 300. That's the difference between sizing EV infrastructure for a few dozen stalls or for a few hundred — different table row, different reserved panel capacity, different cost. A solar-carport contractor couldn't price it from the code text.

What the Commission is being asked to approve

The Green Code Advisory Committee flagged exactly this gap. In the BSC 03/25 cycle it marked the item "Further Study Required" and recommended clarifying "that EV parking is to be located beneath the new PV canopy." The agency then amended the text as recommended.

The final express terms add one sentence to that trigger:

Verified against the BSC 03/25 Final Express Terms, Part 11 (Sub-item 4-3): "Only parking spaces physically covered by the new photovoltaic system panels shall count toward the EV charging requirements."

Read it for what it is: a clarification of an ambiguity, not the narrowing of a rule that was ever clearly whole-lot. The 2025 text simply never said which spaces count; now it will. So count the canopy footprint, not the property line, when you scope EV charging on a carport job.

One housekeeping change rides along. The accessible-EVCS pointer — when EVSE is installed, accessible EVCS per California Building Code Chapter 11B, Section 11B-228.3 — moves out of the 5.106.5.4 body into its own subsection, 5.106.5.4.3. Same requirement, cleaner address.

The ALMS minimum is being restated in kilowatts

The same Part 11 package touches Section 5.106.5.3.3, the automatic load management systems (ALMS) rule. Today an EVSE on an ALMS "shall deliver a minimum 30 amperes to an EV when charging one vehicle." The express terms strike "30 amperes" and replace it with 6.2 kW:

Verified against the BSC 03/25 Final Express Terms (Sub-item 4-2): "Each EVSE controlled by an ALMS shall deliver a minimum 30 amperes 6.2kW to an EV when charging one vehicle and shall deliver a minimum 3.3 kW while simultaneously charging multiple EVs."

The committee's stated reason is narrow: "change the unit of measurement from the current amperes to kW." The 3.3 kW floor for simultaneous charging does not change.

Don't read the new number as a loosening or a tightening — the record gives no rationale beyond the units. For scale, here's our own arithmetic, not the code's: 30 A x 208 V = 6.24 kW; 30 A x 240 V = 7.2 kW; and 6.2 kW at 240 V works back to about 25.8 A. Depending on service voltage, 6.2 kW lands in the neighborhood of the old 30-amp figure. The practical takeaway is simpler: specs and single-lines that state the ALMS minimum in amps will need a kW figure on nonresidential (BSC-CG) jobs.

Two limits on scope

This is the BSC-CG nonresidential package only.

The DSA-SS public-school and community-college provisions are untouched: Section 5.106.5.6.2.3 still reads "minimum 30 amperes," and the PV trigger at 5.106.5.6.4.2 is unchanged. The HCD residential ALMS language isn't in these express terms either. Working a school or a dwelling? Nothing here moved.

And on status: these are the final express terms that went to the Building Standards Commission for its August 25–27, 2026 meeting (BSC 03/25) — proposed, not yet adopted law. If the Commission approves them, they would land with the July 1, 2027 supplement to the 2025 code. Verify the recorded action, and any local amendments, with your jurisdiction before you lean on the new sentence — cities can go stricter, and this isn't legal advice.

What CrossBeam does with it

CrossBeam reads a solar-carport or parking permit against the whole of Section 5.106.5.4 and tells you how many stalls actually owe EV charging — the ones under the panels — so your scope matches the code instead of the whole lot. It also flags ALMS minimums written in amps that a BSC-CG job will want restated in kilowatts.