Illinois Modular & Manufactured Home EV charging Requirements

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Recently we have become aware of some issues with how the Modular & Manufactured Home requirements interact with the EV charging requirements in Illinois.

Based on our review, other agencies, and experts we were able to consult, the laws as written (see below) currently requires that all new manufactured or modular single-family dwellings shall be provided with an EV-capable parking space. Unfortunately, no current agency has legal authority to provide interpretation powers per the Electric Vehicle Charging Act  which limits any project or type of dwelling to be exempted from EV charging requirements.

This document reviews the impact of the following state laws:

  • (430 ILCS 117/) Manufactured Home Quality Assurance Act.

  • (430 ILCS 115/) Illinois Modular Dwelling and Mobile Structure Safety Act.

  • (765 ILCS 1085/) Electric Vehicle Charging Act.

Our conclusion stems from the requirements listed in the Electric Vehicle Charging Act (765 ILCS 1085/20):

… A new single-family residence or a small multifamily residence shall have at least one EV-capable parking space for each residential unit that has dedicated parking, unless any subsequently adopted building code requires additional EV-capable parking spaces, EV-ready parking spaces, or installed EVSE. …

In the same act the term single-family residence is defined as “a detached single-family residence on a single lot”. Neither the dwelling units covered from the Manufactured Home Act nor the Modular Dwelling Act are excluded from the single-family residence definition in the EV Charging Act. The regulation in the EV Charging Act is about the parking space and its features and, in our opinion, does not regulate the Manufactured Home; therefore, no federal exemption would apply. Additionally, the state laws currently regulate utility, foundation, and modifications to a Manufactured Home. While this situation may or may not have been anticipated, we see potential complications and have gathered that information into this document.

How does this impact Manufactured Home and Modular Home projects?

Manufactured Homes must take into consideration the following:

  • Parking Spot Location

    • The charger is required to be within three feet of the EV capable parking space

    • If the parking spot is remote from the power pedestal and panel a raceway would need to be provided with an enclosure or outlet

    • Any mounted electrical equipment mounted near the expected vehicle path may require impact protection

  • Power

    • The most likely scenario for Manufactured home would require the manufactured units electrical panel to be treated as a sub-panel.

    • The meter and pedestal would now be required to have the meter, primary disconnect, and weather tight (NEMA rated) panel.

    • The service would have to be sized for the required 40 amp for the EV charger and the rating of the manufactured home.

    • The manufactured home’s panel would have to be set as a sub-panel (green screw removed)

  • Replacement of Manufactured Home

    • This would be considered a new residence and would require the EV capable parking space be brought up to code.

Modular Homes must take into consideration the following:

  • Pre-approved designs that do not already contain EV capable provisions no longer meet state design requirements and appear to require redesign and approval.

  • Projects that cannot wait for re-application and reapproval from the state can be built as modular construction to the local building code and amendments with EV capabilities.

 

While we are aware of the impact this has had on current and future projects, we do not see an alternative path to enforce the construction standards outlined by the state legislature. We here at B&F Constructions will continue to reach out and work with public and private agencies to ensure this impact is understood and how it could be addressed in future legislation. Additionally, until a state agency tasked with EV charging interpretation, state attorney general’s office, or new legislation is enacted, it is B&F Construction Code Services, Inc. interpretation that Manufactured Homes nor Modular Homes are exempted from Electric Vehicle Charging Act requirements.

 

LINKS:

(430 ILCS 117/) Manufactured Home Quality Assurance Act.

(430 ILCS 115/) Illinois Modular Dwelling and Mobile Structure Safety Act.

(765 ILCS 1085/) Electric Vehicle Charging Act.