Charging points in communal car parks for existing blocks
A retrofit charging installation in an existing block sits outside Part S. What Part 2 of the GPDO permits, how supply capacity is established, and why section 20 consultation matters.
Retrofitting charge points to the communal car park of an existing block of flats rarely needs planning permission, and it almost never triggers the Building Regulations requirement for electric vehicle charging. Part S applies to new buildings and to buildings undergoing major renovation, so a standalone charging installation in an existing car park falls outside it. What governs the project instead is the capacity of the electrical supply, the terms of the leases, and whether the bays are allocated.
What consent a retrofit installation needs
Two permitted development classes in Schedule 2 Part 2 of the General Permitted Development Order 2015 cover most installations. Class D permits an electrical outlet mounted on a wall or building within an area lawfully used for off-street parking. Class E permits a free-standing upstand serving one parking space, subject to a height limit and a restriction on proximity to a highway boundary.
Both carry conditions. Neither applies within the curtilage of a listed building. Both have conservation area restrictions on positions visible from or fronting a highway. Both require removal when no longer needed. And both have been amended more than once since 2015, so read the current text of Part 2 rather than a summary.
What falls outside those classes needs an application: a canopy over the bays, a new substation or switchroom building, a bank of rapid chargers with its own enclosure, or anything involving works to a listed structure. A solar canopy is a separate proposition again, covered in our note on solar canopies over car parks.
An Article 4 direction can remove Part 2 rights, which is unusual but does happen in high-quality conservation areas. Check before you order equipment.
Electrical capacity in an existing supply
Capacity is the constraint that decides how many bays can be served, and it is the first thing to establish rather than the last.
Most existing blocks have two kinds of supply. Individual metered supplies to each flat, sized for domestic load, and a landlord supply serving lighting, lifts, pumps and communal areas, which is often modest. Neither was designed with 7 kW per bay in mind.
Three routes exist and they cost very different amounts:
- Use spare capacity on the landlord supply with active load management, so the chargers share whatever headroom exists and throttle when lift or heating demand rises. This is the least costly route and usually the right first move.
- Apply to the distribution network operator for an increased capacity on the existing connection. Cost and lead time vary enormously depending on whether the local network needs reinforcement, and the DNO quotation is the document that determines project viability.
- Take a new dedicated supply for the car park. Cleanest technically, most expensive, and the one most likely to need a substation and therefore planning permission.
Commission a maximum demand assessment on the existing supply before any of this. A competent electrical engineer measuring actual demand over a week, rather than applying diversity factors to a schedule of connected load, frequently finds more headroom than the paperwork suggests. Where the block has other infrastructure ambitions, a Utilities Assessment covering supply capacity as a whole is worth doing once rather than repeatedly.
Allocated against unallocated bays
This is the decision that shapes everything else, and it is a legal question as much as a technical one.
Where bays are allocated to individual flats under the leases, the natural arrangement is a charge point per bay, wired back to that flat's own consumer unit and metered through the resident's own supply. Each resident pays their own electricity, there is no billing infrastructure, and the installation is simpler. The difficulty is cable routing from a flat on the fourth floor to a bay in the basement.
Where bays are unallocated, the charge points have to sit on the landlord supply with back-office metering, an access method such as an app or an RFID card, and a tariff. That brings a recharge mechanism through the service charge or a separate user payment, and it brings data and payment obligations the managing agent has to administer.
A middle route works well in practice. Install shared chargers on the landlord supply serving a small number of bays on a first-come basis, with load management, and keep the option of dedicated points later. It suits a block where demand is uncertain, which is most blocks.
Cable routes, trenching and reinstatement
Cable routing is where budgets are lost. Surface-mounted containment along a car park wall costs little. A trench across a resin-bound forecourt is not.
Four practical points. Survey the existing services before you specify a route, because an unrecorded drainage run or an incoming gas main will change it. Use existing risers, ducts and voids wherever they exist, since a spare duct is worth more than a lower-cost cable. Specify reinstatement to match, because a patched trench across a communal forecourt will generate more complaints than the chargers solve. And install spare ducts and containment capacity now for the bays you are not electrifying yet.
Where the car park is at basement level, ventilation and drainage interfaces need checking, and a trench in a basement slab is a structural question rather than an electrical one.
Lease and freeholder consents
The consents that actually stop these projects are private rather than public.
A leaseholder wanting a charger in their allocated bay usually needs the freeholder's consent under the alterations covenant in the lease, and the lease may say nothing at all about car park bays or electrical works, which makes the answer a matter of construction rather than a simple yes.
Where the freeholder or a resident management company is carrying out the works and recovering the cost through the service charge, the consultation requirements in section 20 of the Landlord and Tenant Act 1985 apply to qualifying works where any leaseholder's contribution exceeds £250. Getting that consultation wrong limits recovery, and it is the most common failure on communal installations.
Practical sequence: read the leases, establish who owns the car park and the walls you intend to fix to, confirm whether the works are qualifying works, run the statutory consultation if they are, and only then place the order. Buildings insurance notification belongs in that sequence too.
Fire separation and siting considerations
Fire risk in car parks attached to residential buildings has had a great deal of attention, and a retrofit installation needs to engage with it properly rather than defensively.
The installation itself is governed by BS 7671 and the relevant section for electric vehicle charging, which covers protective devices, earthing arrangements and the specific requirements for charging equipment. Beyond the electrics, the fire risk assessment for the building under the Regulatory Reform (Fire Safety) Order 2005 has to be reviewed once charging equipment is installed, because the assumptions in the existing assessment no longer hold.
Siting principles that reduce risk are straightforward. Keep charge points away from the only means of escape and from escape route openings. Prefer open-sided or naturally ventilated parking to enclosed basement parking where there is a choice. Do not site charge points beneath or immediately adjacent to a single staircase serving the block. And keep equipment clear of dry riser inlets and fire service access positions.
For a building where the fire strategy is already complex, a Fire Safety Strategy prepared by a fire engineer is the right document, and a fire engineer is legally the appropriate author for that work rather than an electrical contractor.
Phasing installation as demand grows
Demand in an existing block grows unevenly, and over-installing at the start wastes money that could have gone into capacity.
The approach that works is to put the expensive, disruptive elements in once and the low-cost ones in repeatedly. Install the supply upgrade or load management controller, the containment, the ducts and the distribution board capacity for the eventual number of bays. Then fit sockets in small batches as residents ask for them.
Set a written policy at the outset covering who may apply, how the cost is apportioned, what happens when a resident with a dedicated point sells the flat, and how a bay reverts if a resident stops needing it. A managing agent without that policy ends up arbitrating between residents.
And review the tariff annually. Electricity costs move, and a fixed per-kilowatt-hour charge set two years ago will either be subsidised by the service charge or be visibly above market. Grant funding for landlords and flat owners has existed in various forms, so check the current gov.uk scheme rates before budgeting. The same discipline about supply capacity and lead times applies to other retrofit plant, as our piece on ground source heat pumps and borehole permitting sets out.
This article is general guidance, not legal advice; lease terms, consultation duties and permitted development rights all turn on the specific facts, so check the position with your local planning authority and a qualified professional before relying on it. PlanScope provides AI-assisted draft reports for planning applications. Reports should be reviewed before submission. We do not guarantee planning approval.
Enter your postcode on PlanScope to see which reports a car park installation at your block is likely to need.
Frequently asked questions
Does Part S apply to retrofitting charge points in an existing block?
No. Approved Document S applies to new buildings and to buildings undergoing major renovation, so a standalone charging installation in an existing car park does not trigger it. The constraints are the capacity of the electrical supply, the terms of the leases and whether bays are allocated, rather than a Building Regulations requirement.
Do communal car park charge points need planning permission?
Usually not. Schedule 2 Part 2 of the GPDO 2015 permits a wall-mounted outlet under Class D and a free-standing upstand serving one bay under Class E, subject to height limits, highway proximity rules and conservation area restrictions, with no right within a listed building's curtilage. A canopy, substation or enclosure needs an application.
How do I find out whether the existing supply has capacity?
Commission a maximum demand assessment measuring actual demand over about a week, rather than applying diversity factors to the schedule of connected load. That frequently reveals more headroom than the paperwork suggests. If there is not enough, the options are active load management, a capacity increase from the network operator, or a new dedicated supply.
Does section 20 of the Landlord and Tenant Act 1985 apply?
It applies where the freeholder or management company carries out qualifying works recovered through the service charge and any leaseholder's contribution exceeds £250. Getting the consultation wrong limits cost recovery, and it is the commonest failure on communal charging projects. Read the leases and confirm ownership of the car park and walls first.
Where should charge points be sited in a basement car park?
Away from the only means of escape and from escape route openings, clear of dry riser inlets and fire service access positions, and preferably not beneath or beside a single staircase serving the block. Open-sided or naturally ventilated parking is preferable to enclosed basement parking, and the building fire risk assessment must be reviewed afterwards.
Sources and further reading
This article is general guidance about the planning system in England and, where stated, the rest of the UK. It is not legal or professional advice. Check your local planning authority’s validation requirements and take professional advice for your specific site.