Putting a plug on an HPWC (Code Violations and Insurance)

TexasEV said:

HPWC doesn't plug into a 14-50. It has to be hard wired.

Click to expand...

Mine does, as do others, as you can see in the pics here:

Tesla HPWC On EBay from Canada - Page 4

Putting a NEMA 14-50 on a HPWC is explicitly against the NEC. Good luck with any insurance claims...

TexasEV said:

OK, I'll rephrase that. The HPWC doesn't plug into a 14-50 unless you modify it and don't install it according to the installation instructions. I'll leave it to others to comment on how that may or may not comply with the electrical code, but that doesn't sound like something I would want in my garage.

Click to expand...

Why? It has dip switches to control the amps and it's wired according to the installation instructions, except that it goes to a 14-50 instead of directly to a breaker, or junction box first then breaker, like my Clipper Creek CS-60 installed outside. The HPWC cable and handle do not heat up at all, unlike my UMC. This is basically a heavy duty UMC since it can't charge at 80 amps. To me, it's safer than the lightweight UMC, which Tesla seems concerned about and at least one Fire Authority connected to a garage fire, although Tesla disputes it...

While the Fire Authority's report stated the most likely cause was a "high resistance connection at the wall socket or the Universal Mobile Connector from the Tesla charging system", Tesla says its own data shows the car was charging normally, with no fluctuations in the temperature and no malfunctions capable of causing a fire."
http://www.greencarreports.com/news/1089229_tesla-irvine-fire-dept-disagree-over-cause-of-garage-fire

Tesla disputes the UMC / fire connection, but it did change the software after that fire and fluctuations now cause the car to dial down the amps much more readily than in the past, and they seem to keep tinkering with it. That's qwk's point in starting this thread, I think. I've also read here about, and seen pictures of, burned or melted UMC's 14-50 adapter whereas the plug and socket connected to my HPWC don't get the least bit warm:

Burned 220V Adapter

Melted Charging Adapter/Cord

- - - Updated - - -

wk057 said:

Putting a NEMA 14-50 on a HPWC is explicitly against the NEC. Good luck with any insurance claims...

Click to expand...

Ha! I'm an insurance defence lawyer. It always amazes me when people think doing something against code voids your insurance. Yes, with some policies it may but not for most. Many claims involve breaches of code. People remove a railing because their staircase looks better, then uncle Johnny falls down. Or you pull that third prong off your plug so it fits in your extension cord, then your fish smoker burns the building down, etc. etc. Are you telling me there's no coverage for these code violations in the third party (first example) or first party (second example) coverage sections of your policy? Well, there sure is in mine!

A denial of coverage would result in an action for bad faith and punitive damages against my insurer since I know every word of my policy and there is no exclusion for code violations. I would never buy such a policy and you should not either.

By the way, there's also laws against such exclusions (such as State Farm's anticoncurrent causation clauses) in certain jurisdictions. You can read more about this issue in my posts #148 and 150 in this thread:

FAQ: Home Tesla charging infrastructure QA - Page 15

Read your insurance policies people and stay away from any that exclude code violations!

Canuck said:

Ha! I'm an insurance defence lawyer. It always amazes me when people think doing something against code voids your insurance. Yes, with some policies it may but not for most. Many claims involve breaches of code. People remove a railing because their staircase looks better, then uncle Johnny falls down. Or you pull that third prong off your plug so it fits in your extension cord, then your fish smoker burns the building down, etc. etc. Are you telling me there's no coverage for these code violations in the third party (first example) or first party (second example) coverage sections of your policy? Well, there sure is in mine!

A denial of coverage would result in an action for bad faith and punitive damages against my insurer since I know every word of my policy and there is no exclusion for code violations. I would never buy such a policy and you should not either.

By the way, there's also laws against such exclusions (such as State Farm's anticoncurrent causation clauses) in certain jurisdictions. You can read more about this issue in my posts #148 and 150 in this thread:

FAQ: Home Tesla charging infrastructure QA - Page 15

Read your insurance policies people and stay away from any that exclude code violations!

Click to expand...

Regardless of whether or not insurance will eventually cover it, putting a plug on a HPWC is a code violation. If the insurance will cover it after the place burns to the ground because of the violation seems a little less relevant when you consider the whole burning to the ground part could have just been avoided in the first place by sticking to the code...

Relevant portion of the NEC 2014 code book:

---

625.44 Electric Vehicle Supply Equipment Connection.Electric vehicle supply equipment shall be permitted to be cord- and plug-connected to the premises wiring system in accordance with one of the following:
All other electric vehicle supply equipment shall be permanently wired and fastened in place to the supporting surface, a wall, a pole, or other structure. The electric vehicle supply equipment shall have no exposed live parts.


---

For the most part, the NEC isn't just written to be a hassle. There are relevant safety considerations behind 99.9% of the code. In this case part of the issue is not being listed for this use, where the terminals and such aren't designed to have a cord attached and the force of a moving cord, even under light use, could potentially/eventually dislodge a connection, resulting in a hazardous condition. You'll notice inside the HPWC the output cable to the car is mounted in place and has a position to do so that it can't be moved from outside the unit. Both ends of the UMC have the same setup. The input to the HPWC, however, has no provisions for doing so with the input wiring.

Is using the HPWC with the proper 50A breaker setting and with a proper 14-50 male plug and cord likely to result in a hazardous condition, IMO? Probably not if done correctly with appropriate wire, plug, and fastening inside the HPWC. Have I done it temporarily? Yep. Would I ever do it permanently? Not a chance. It doesn't seem worth the risk in an effort to save a couple of dollars in an effort to avoid hard wiring. If you're only looking to wire it for use at 40A charging (50A breaker), hard wiring is a piece of cake and would be dirt cheap especially if you already have the NEMA 14-50 where you want to put it... just do that instead of violating the code.

Canuck said:

Read your insurance policies people and stay away from any that exclude code violations!

Click to expand...

Interesting. So I also had an All State policy until I figured out the hard way that they are quite willing to spend many times more money to deny a claim than it would be to pay it out.

As a condition for insurance, All State made us perform a set of alterations to our roof and building structure. And then they subsequently denied a claim - they spent over $3500 in order to get various inspectors and assessors in, in order to deny a claim that ended up being $400 - lower even than the policy deductible.

And in the end I've had the All State agent basically admit to me that, even though they made us perform alterations as a condition to insurance, that there was not a single hypothetical situation that he could think of in which they would ever pay out any claim to our roof or building structure (I don't have flood insurance). "Even if a plain crashes into the house, you have to sue the airline". They will always go out their way to look for some code violation somewhere, which virtually any house will have, and I have plenty off.


So coming back to electrical, 3 years ago I had an electrician running an electrical outlet for me. He ran it through my (very damp) crawlspace, using romex wire, cutting diagonally across joists, and running underneath water pipes. 3 code violations in 20 feet - impressive. I just discovered it recently when I went into the crawlspace. However, it was all done by an electrician, permitted, and signed off by an inspector (I found out since that inspectors don't generally go into crawl spaces).

So if something goes wrong, and I still was with All State, they would obviously not pay anything out. So what does that leave me? I can't sue the electrician - he's out of business. I can't sue the inspector, he has indemnity. I can't sue the city - this is my building. But I did everything by the book!


If it wasn't a precondition of having a mortgage, I would seriously just stop my building insurance.

wk057 said:

Regardless of whether or not insurance will eventually cover it, putting a plug on a HPWC is a code violation. If the insurance will cover it after the place burns to the ground because of the violation seems a little less relevant when you consider the whole burning to the ground part could have just been avoided in the first place by sticking to the code...

Click to expand...

My good buddy is an electrician and he helped me with the plug and wiring. He also helped me build my extension cord for my cabin (as he rolled his eyes and had me label it "EV charging only") and he wired my Clipper Creek CS-60. He initially put in the 14-50 outlet for my UMC. He shook his head at the heat generated by the cable and said it was "mickey mouse" compared to the CC CS-60. I found it odd that the cable was always warm to the touch while charging, and I looked at pictures of burned and melted 14-50 adapters here. When I bought the HPWC, he said it was much better, but I needed to upgrade my electrical panel if I wanted him to install it to run at 80 amps, which I don't really need. He told me that technically it is not a code violation to plug it into the 14-50 because it's connected to a 50 amp breaker and set at 40 amps, which allows for it. Now, with the dip switches being changed, and with the ability to change the dips, it could be considered a code violation. I deal with code violations all the time in my work, and I know there are a lot of grey areas. Not everything is black and white as you seem to suggest.

More importantly, I would never put my family at risk of a fire. I did this to avoid a fire. I am certain I am much safer now than with the flimsy UMC that Tesla is obviously very concerned about -- hence this thread. I also don't buy Tesla's explanation that the UMC was not involved in the fire by reading the logs. Why not look at the device itself? That's what investigator's opine on in fire cause and origin reports. Even it if was totally burned, they can often tell cause and origin by the remnants and burn patterns. Tesla's conduct after the fact in changing the software also speaks volumes to me.

Canuck said:

My good buddy is an electrician and he helped me with the plug and wiring. He also helped me build my extension cord for my cabin (as he rolled his eyes and had me label it "EV charging only") and he wired my Clipper Creek CS-60. He initially put in the 14-50 outlet for my UMC. He shook his head at the heat generated by the cable and said it was "mickey mouse" compared to the CC CS-60. I found it odd that the cable was always warm to the touch while charging, and I looked at pictures of burned and melted 14-50 adapters here. When I bought the HPWC, he said it was much better, but I needed to upgrade my electrical panel if I wanted him to install it to run at 80 amps, which I don't really need. He told me that technically it is not a code violation to plug it into the 14-50 because it's connected to a 50 amp breaker and set at 40 amps, which allows for it. Now, with the dip switches being changed, and with the ability to change the dips, it could be considered a code violation. I deal with code violations all the time in my work, and I know there are a lot of grey areas. Not everything is black and white as you seem to suggest.

More importantly, I would never put my family at risk of a fire. I did this to avoid a fire. I am certain I am much safer now than with the flimsy UMC that Tesla is obviously very concerned about -- hence this thread. I also don't buy Tesla's explanation that the UMC was not involved in the fire by reading the logs. Why not look at the device itself? That's what investigator's opine on in fire cause and origin reports. Tesla's conduct after the fact in changing the software also speaks volumes to me.

Click to expand...

Unfortunately, your electrician friend is simply wrong. The HPWC is not listed for use with a plug and cord connection at any current/breaker combination. Period.

I quoted the exact code above, and why it is a violation, and even explained why the code exists in the first place. I don't think it can get much more black and white than that.

Edit: Noting your location, I'm not 100% sure what code applies. I've been working under the assumption that the NEC would apply, and this could be an incorrect assumption.

wk057 said:

Unfortunately, your electrician friend is simply wrong. The HPWC is not listed for use with a plug and cord connection at any current/breaker combination. Period.

Edit: Noting your location, I'm not 100% sure what code applies. I've been working under the assumption that the NEC would apply, and this could be an incorrect assumption.

Click to expand...

Different code but it's probably similar to your code. But I disagree with your interpretation. I complied with the section you posted since my HPWC, with the switches set to 40 amps, meets the rating. Now, with the dip switches set to 80 amps it does not meet the rating. That's why my electrician said it technically meets the code. It's not as black and white as you think it is by reference to the code wording itself that you posted. There is a strong argument to make that if the code was meant to apply to devices capable of exceeding 50 amps, then it would read that way. With the dips set at 40 amps it is rated at 40 amps. It is the intent of the legislation that must be met. If you can show you have complied with the intent of the code, then that does not mean you have breached the code. If you take apart a UMC, and HPWC correctly wired to a plug and set to 40 amps, I highly doubt any Electrical Engineer would tell you that you are safer with the UMC.

And isn't that the intent of the Electrical Code, being safety? You need to tell me why I am not safer than a UMC. I really would like to hear it because I don't want to put my family at risk. Saying breach of code doesn't tell me I'm not better off because I am not running the HPWC at 80 amps. That would be insane.

Canuck said:

Different code but it's probably similar to your code. But I disagree with your interpretation. I complied with the section you posted since my HPWC, with the switches set to 40 amps, meets the rating. Now, with the dip switches set to 80 amps it does not meet the rating. That's why my electrician said it technically meets the code. It's not as black and white as you think it is by reference to the code wording itself that you posted. There is a strong argument to make that if the code was meant to apply to devices capable of exceeding 50 amps, then it would read that way. With the dips set at 40 amps it is rated at 40 amps. It is the intent of the legislation that must be met. If you can show you have complied with the intent of the code, then that does not mean you have breached the code. If you take apart a UMC, and HPWC correctly wired to a plug and set to 40 amps, I highly doubt any Electrical Engineer would tell you that you are safer with the UMC.

And isn't that the intent of the Electrical Code, being safety? You need to tell me why I am not safer than a UMC. I really would like to hear it because I don't want to put my family at risk. Saying breach of code doesn't tell me I'm not better off because I am not running the HPWC at 80 amps. That would be insane.

Click to expand...

I don't think it's a matter of having a wrong current rating, but using wiring intended for fixed installation inside a pluggable environment. You similarly cannot make an extension cord out of romex cable - it's not designed to be turned and twisted all the time.

I would bet that the HPWC uses solid core wiring, and the UMC uses stranded core, so if you unplug each one of them daily and throw them in the back of your car, the UMC is going to last a LOT longer.

PS: "I promise not to unplug it" is not a valid response to this, any more than "I promise to switch off my main circuit breaker before starting the generator". Code has to assume people will make mistakes.

deonb said:

PS: "I promise not to unplug it" is not a valid response to this, any more than "I promise to switch off my main circuit breaker before starting the generator". Code has to assume people will make mistakes.

Click to expand...

Yes, you are right. Mine is permanently affixed to the wall with screws so it's not going anywhere even though it can be unplugged. But I understand the concerns raised and I am not recommending anyone else do what I did. I can tell you, however, that I never felt safe feeling the warm cord of my UMC and seeing the burned out 14-50 adapters here, and reading about garage fires that may or may not be related to UMC failure. A firmware solution somewhat alievates those concerns but there's still room for failure that I feel I have eliminated with my set up. So for me, at least, I am confident that I safer with my set up. But to each their own and I appreciate the replies.

Canuck said:

Different code but it's probably similar to your code. But I disagree with your interpretation. I complied with the section you posted since my HPWC, with the switches set to 40 amps, meets the rating. Now, with the dip switches set to 80 amps it does not meet the rating. That's why my electrician said it technically meets the code. It's not as black and white as you think it is by reference to the code wording itself that you posted. There is a strong argument to make that if the code was meant to apply to devices capable of exceeding 50 amps, then it would read that way. With the dips set at 40 amps it is rated at 40 amps. It is the intent of the legislation that must be met. If you can show you have complied with the intent of the code, then that does not mean you have breached the code. If you take apart a UMC, and HPWC correctly wired to a plug and set to 40 amps, I highly doubt any Electrical Engineer would tell you that you are safer with the UMC.

And isn't that the intent of the Electrical Code, being safety? You need to tell me why I am not safer than a UMC. I really would like to hear it because I don't want to put my family at risk. Saying breach of code doesn't tell me I'm not better off because I am not running the HPWC at 80 amps. That would be insane.

Click to expand...

I'm not so sure the code is open to that particular interpretation.

625.5 Listed. All electrical materials, devices, fittings, and associated equipment shall be listed.

Ignoring any other portion of section 625, putting a 14-50 plug on a HPWC is already a violation of the code because it is not listed for this.

The above and my excerpt of 625.44 are just two places the HPWC violates. Let's go with another.

625.17 Cords and Cables.
So, ignoring that it's not listed for this in the first place, if the length of your cord and plug is > 12" (pretty likely) than you're in violation of 625.17(A)(3)(a) since the GFCI protection device is located inside the HPWC and you're increasing the possibility that under a fault condition the HPWC would not cut power as it should. Notice how short the supply side cable is on the UMC? It's because of 625.17(A)(3)(a) and 625.22 (see below).

Lets also jump to 625.17 part C
625.17(C) Overall Cord and Cable Length. The overall usable length shall not exceed 7.5 m (25 ft) unless equipped with a cable management system that is part of the listed electric vehicle supply equipment.

Another section about this:

625.22 Personnel Protection System.
The electric vehicle supply equipment shall have a listed system of protection against electric shock of personnel. Where cord-and plug connected electric vehicle supply equipment is used, the interrupting device of a listed personnel protection system shall be provided and shall be an integral part of the attachment plug or shall be located in the power-supply cord not more than 300 mm (12 in.) from the attachment plug.

The cable on the HPWC is 25'. So, when you add another cable, you instantly violate 625.17(C) if it is not fastened in place permanently. 625.17(C)(2) allows the 25' cable + 12" of connection cord for a listed device if it is fastened in place.

Another part of the code violated:

625.42 Disconnecting Means.
For electric vehicle supply equipment rated more than 60 amperes or more than 150 volts to ground, the disconnecting means shall be provided and installed in a readily accessible location. The disconnecting means shall be lockable open in accordance with 110.25.

The HPWC is rated for 80A on a 100A breaker per the continuous load requirement, regardless of whether you set some dip switches or not. While I'm sure you could convince an inspector against a disconnect if using it at 40A.... the code is still there. However the purpose of this provision is partly because the conductors and such in equipment like the HPWC are capable of causing a much heavier load under a fault condition. For example, the dip switch setting doesn't apply when you short out the output conductors... which are rated for an 80A continuous load....


Basically, hard wiring the HPWC or using the 14-50+UMC doesn't violate any codes. Just do it right, folks.

wk057 said:

... if the length of your cord and plug is > 12" (pretty likely)

...

For electric vehicle supply equipment rated more than 60 amperes...

Click to expand...

It's not more than 12". You can see it in the pictures I posted at the link to the other thread, a few posts back. Again, the rated rate is irrelevant since I have set the dips below that rating.

wk057 said:

Basically, hard wiring the HPWC or using the 14-50+UMC doesn't violate any codes. Just do it right, folks.

Click to expand...

I agree. I don't recommend that anyone do what I did. I also use an extension cord at my cabin with the UMC which is against code, or at least Tesla's recommendations, and I would not recommend that too but a lot of people here do it.

Canuck said:

Again, the rated rate is irrelevant since I have set the dips below that rating.

Click to expand...

The dip switches don't change the rating. They just change what they tell the car it can use. The wiring and equipment in the HPWC are still rated for 80A continuous draw, and the UMC wiring and equipment is rated for 40A continuous draw.

Again, the code keeping in mind other scenarios. Examples being a short on the charge connector or in the vehicle or anywhere on the HPWC side of the circuit, as well as someone just not setting the dip switches (the generator example someone posted above is a good one to that effect).

Also, an extension cord with the UMC is not against code, assuming the extension cord is listed and rated for the load.

Edit: Looked at your pic in this thread... definitely more than 12". The HPWC is 15" long, and your cord runs the majority of that length from the side and then at least 5" past the HPWC.

Thanks, Nigel, for carving this out.

wk057 said:

The dip switches don't change the rating. They just change what they tell the car it can use. The wiring and equipment in the HPWC are still rated for 80A continuous draw, and the UMC wiring and equipment is rated for 40A continuous draw.

Again, the code keeping in mind other scenarios. Examples being a short on the charge connector or in the vehicle or anywhere on the HPWC side of the circuit, as well as someone just not setting the dip switches (the generator example someone posted above is a good one to that effect).

Also, an extension cord with the UMC is not against code, assuming the extension cord is listed and rated for the load.

Edit: Looked at your pic in this thread... definitely more than 12".

Thanks, Nigel, for carving this out.

Click to expand...

Are you looking at the one on the ceiling? That one is mine, not the one on the wall. If it's greater than a foot, it's not by much. I'll have to measure it when I get home from my cabin tomorrow.

Again, however, the issue is safety. This debate has become an idiomatic antithesis:

The letter of the law versus the spirit of the law is an idiomatic antithesis. When one obeys the letter of the law but not the spirit, one is obeying the literal interpretation of the words (the "letter") of the law, but not the intent of those who wrote the law. Conversely, when one obeys the spirit of the law but not the letter, one is doing what the authors of the law intended, though not necessarily adhering to the literal wording.

Letter and spirit of the law - Wikipedia, the free encyclopedia

I underlined the last part since that's the camp I'm in when it comes to our debate. There is a principle at law that the breach of a code or legislation, or "best practice", does not determine fault or negligence in and of itself. It is simply one factor the Court can consider and assign weight to. That can vary from no weight at all to enough weight to meet the common-law test for burden of proof being on a "balance of probabilities". That is because if you meet the intent of the law, but not the letter of the law, there is often found to be no breach.

Thanks for the interesting debate. I don't disagree with you, I just don't think I am doing anything dangerous and, in fact, I think that my setup is less dangerous than a UMC. But I respect all of your points, which are good ones.

Canuck said:

Are you looking at the one on the ceiling? That one is mine, not the one on the wall. If it's greater than a foot, it's not by much. I'll have to measure it when I get home from my cabin tomorrow.

Again, however, the issue is safety. This debate has become an idiomatic antithesis:

The letter of the law versus the spirit of the law is an idiomatic antithesis. When one obeys the letter of the law but not the spirit, one is obeying the literal interpretation of the words (the "letter") of the law, but not the intent of those who wrote the law. Conversely, when one obeys the spirit of the law but not the letter, one is doing what the authors of the law intended, though not necessarily adhering to the literal wording.

Letter and spirit of the law - Wikipedia, the free encyclopedia

I underlined the last part since that's the camp I'm in when it comes to our debate. There is a principle at law that the breach of a code or legislation, or "best practice", does not determine fault or negligence in and of itself. It is simply one factor the Court can consider and assign weight to. That can vary from no weight at all to enough weight to meet the common-law test for burden of proof being on a "balance of probabilities". That is because if you meet the intent of the law, but not the letter of the law, there is often found to be no breach.

Thanks for the interesting debate. I don't disagree with you, I just don't think I am doing anything dangerous and, in fact, I think that my setup is less dangerous than a UMC. But I respect all of your points, which are good ones.

Click to expand...

Yeah, it was the one on the ceiling.

Well, as I said before, I've personally done this with the HPWC before, also. There are worse ideas out there, I'm sure.

The intent of the NEC, by their own definition, is safety. If not abiding by a portion of the code can result in an unsafe condition that wouldn't otherwise exist if the code was followed, I'd say that the would violate both the intent and the letter of the NEC. In general, I think the engineers, volunteers, and multitude of input and review that goes into the NEC outweighs any one person, including myself, thinking that what they're doing is safer than what is in the NEC. If that is the case, then you may consider submitting a suggestion/amendment for review.

That said, in this case, I think as long as the wire is #6 or better, is < 12"-ish, the dips are set for a 50A breaker or less, and most importantly a 1" NM or similar connector on the HPWC side is used to ensure that the plug cord can't be pulled out of the HPWC while it is hot... then for the most part, it's going to be at least as safe as the UMC. The UMC may run hotter than a HPWC under load, but I've FLIR'd the UMC several times, and while it may feel hot, it was never out of spec or close to it. The contactor driver inside the HPWC, on the other hand, is way hotter than anything in the UMC under any load while it is closed... and running the HPWC at under 80A causes it to run for longer with the larger contactor and contactor driver.......... but that's an argument for another day.

Anyway, I'd just be concerned if the last word on a thread like this is someone posting something like "an electrician said it isn't a code violation to use the HPWC with a plug". Then later, as a morbid example, someone with less know-how will do this, their kid will hang on the cable, pull it out of the HPWC and get electrocuted. I'd feel pretty badly not having posted against such a setup.

Your particular setup is probably fine, since no one is going to accidentally grab the 14-50 cord up on the ceiling I would think, but I don't see any pull out protection from the photo so nothing to stop something from getting snagged on it, for example. The one photo below yours in that thread is a problem waiting to happen with that upside down HPWC. The contactor in the HPWC isn't, by default, designed for reverse orientation and will have slightly higher resistance upside down. The part number they use is custom, so, it may be... but the default is upright only. He also said he put something inside to prevent pull outs, but that wont stop the opposite. If his method is metallic it could potentially short a leg to ground or worse if someone fiddled with the cable.

Honestly, I think the whole matter it is something Tesla should address in the documentation to better cover their asses and to better inform people of what is generally permitted. But in the end, people are going to do what they're going to do regardless of what the code or Tesla says anyway if they're determined.

wk057 said:

... thinking that what they're doing is safer than what is in the NEC...

Click to expand...

No, I don't think that. You've misunderstood me. I'm quite certain you are right that it's safer to be hardwired than to have a plug and socket in between.

The point I was making is that I think my setup is safer than the light weight UMC. I also think it's not necessary or required, if the HPWC is dip switch limited to 40 amps, that it be hardwired, and that when limited to 40 amps, my setup complies with the intent of the NEC. That's all I am saying. I agree with what you are saying is the best practice.

wk057 said:

But in the end, people are going to do what they're going to do regardless of what the code or Tesla says anyway if they're determined.

Click to expand...

Yes, I agree. Tesla says "no extension cords" but that's simply not practical for a number of people, including myself, who have charged fine using extension cords ('knock wood') at places where we wouldn't have otherwise been able to charge.

Then there's another matter: jurisdiction of the NEC as it applies to appliances vs. infrastructure. Now, I admit I haven't looked to see if there are any examples of case law where this has been escalated to an official review, but the NEC is intended to cover wiring infrastructure. The code-making panel for article 625 will likely tell you that they believe the car is the appliance and the EVSE (even pluggable EVSE's) is infrastructure gear. This would mean that article 625 must be followed even for cord-and-plug connected devices. However, if you were to look at the EVSE as the appliance rather than the car, then you could make an argument that all the provisions of extension cords and even the entirety of article 625 don't apply, because it's impossible for it to be governed. What are you going to do, bring an inspector over each time you want to charge?

Article 110 says you must follow manufacturer's instructions. Is there an instruction (other than article 625) that says the HPWC *must* be cord-and-plug connected?

Another example is my air compressor for my shop - it's intended to be hard-wired, but there is no instruction that specifically says it must be. So I put a cord set on it with a NEMA 6-30 plug on it, and installed a 6-30 outlet. NEC only has jurisdiction to the outlet in this case.

This is why I got far more careful with my wording - there may be liability and insurance implications when you do something that is not per manufacturer's instructions. Is it safe to attach a cord set onto an HPWC configured for a 50A breaker? My belief is "yes" and since cord-and-plug connected devices aren't overseen by inspectors, then no one can stop you. However, the question at hand is whether or not the insurance company is willing to try to use that as a denial of insurance benefits to you. If you suffer a loss, and the insurance company denies your claim stating a code compliance issue, you may still win -- but you'll be spending months or years going through all the processes against a company with deep pockets who has plenty of time on its hands. It's your choice, of course - there's nothing stopping you from lopping off the two ends of a 10-gauge extension cord and stuffing 50A ends onto it to create a lightweight extension. It won't be inspected. Good luck.

So that's why I leave it as I do. I'm always going to recommend you do something safely, and there are reasons for most of the items in the code. Just because something works doesn't mean it's safe. I will always speak up when someone recommends something unsafe to another person, but in the end it's the end-user's own decision (or if subject to inspection, the AHJ's).