Accessible EV Chargers in Old Garages: The Proposed 80-Inch Rule

The 98-inch wall

Here's the thing: your existing garage deck has 84 inches of headroom, and today that fails for every accessible EV charging station you want to put under it.

CBC 11B-812.4 is blunt about it:

Verified against the live 2025 CBC text (11B-812.4): "Vehicle spaces, access aisles serving them, and vehicular routes serving them shall provide a vertical clearance of 98 inches (2489 mm) minimum. Where provided, overhead cable management systems shall not obstruct required vertical clearance."

Ninety-eight inches, no exception. That's the rule for accessible EVCS vehicle spaces — van accessible, standard accessible, and ambulatory alike — the access aisles serving them, and the drive routes that reach them.

Parking spaces got a break years ago. 11B-502.5 carries an exception for existing multistory garages: car parking spaces, access aisles and vehicular routes serving them may provide 80 inches minimum, as long as any existing clearance between 80 and 98 inches is kept, and van spaces are carved out. Accessible EVCS never got the matching language. So the same 84-inch deck that's fine for a striped accessible car stall has been failing for an accessible charger in the next bay over.

What DSA is proposing

DSA-AC 01/25, Item 23-1, adds the missing exception to 11B-812.4. The proposed text:

Verified against the DSA-AC 01/25 Final Express Terms (Item 23-1): "In existing multistory parking facilities, ambulatory accessible EVCS and standard accessible EVCS shall provide a vertical clearance of 80 inches (2032 mm) minimum. Existing vertical clearance in excess of 80 inches (2032 mm) and less than 98 inches (2489 mm) shall be maintained. This exception shall not apply to van accessible EVCS or vehicular routes serving them."

Read it for what it is. DSA's statement of reasons says the vertical-clearance requirement at EVCS in existing facilities is "often determined to be technically infeasible, per Section 11B-202.3, Exception 2, by local jurisdictions," and that the new exception "mirrors" the one parking spaces already have. In other words: plan checkers were already granting relief for accessible EVCS in old garages — case by case, through a technical-infeasibility finding instead of a line in the code.

It's not law yet — and that matters

Big caveat, and it's load-bearing: this is a proposal, not adopted code. The Final Express Terms went to the Building Standards Commission for its August 2026 meeting. Item 23-1 sits on the Commission's "yellow" (challenged-items) matrix — the accessibility committee recommended Approve and the agency agreed, but the item drew recorded disapprove comments during public comment. The matrix records no Commission action.

So until it's adopted, 98 inches still governs, and the only relief is the one that's been there all along: a technical-infeasibility finding under 11B-202.3, Exception 2, which the enforcing authority has to record and enter into its files. If the Commission does adopt it, it would take effect with a future supplement to the 2025 code. Confirm the timing — and any stricter local amendment — with your jurisdiction before you lean on it. None of this is legal advice.

Two of three types get in. Not the third.

Here's the practical shape of the thing, even once it's adopted:

• Van accessible EVCS: no relief. The exception explicitly doesn't apply to van accessible stalls, or to the vehicular routes serving them. Van stays at 98 inches.
• Standard accessible and ambulatory EVCS: 80 inches minimum in an existing multistory garage.
• Keep what you've got. Any existing clearance between 80 and 98 inches must be maintained — you can't claw it back with new work.

And remember the order in which accessible EVCS get required. Under Table 11B-228.3.2.1, the first accessible stall any facility owes is a van accessible one (1 to 4 total EVCS: one van, nothing else). Standard accessible shows up at 5 to 25 EVCS; ambulatory at 26 to 50. So the one type that gets no break is the one you're required to provide first.

How to lay out the retrofit

• Put the required van accessible EVCS on the level or bay that has a full 98 inches — and make sure the drive route to it from the entry holds 98 inches the whole way.
• Put the standard and ambulatory accessible stalls on the lower-clearance decks (80 to 98 inches).
• Do not lower an existing 90-inch soffit with new conduit, raceway, or overhead cable management. 11B-812.4 already bars cable management from obstructing required clearance, and the exception requires existing clearance to be maintained.

One more thing to pin down: confirm which stalls are van accessible, standard accessible, or ambulatory against the definitions in 11B-812.6 — the clearance you owe follows the type. And for how many EV spaces a project triggers in the first place, that's a CALGreen question, not an 11B one; we've covered the existing-multifamily parking trigger and EV-capable labeling separately.

What CrossBeam does with it

CrossBeam reads an EVCS retrofit against the full accessible-parking picture — vehicle-space type, the clearance each type owes, and which stalls can sit on a low deck versus which need the full 98 inches. When a change like this is still pending, it tells you what governs today and what's coming, so you design for the code that's actually in force.