Electric vehicle charging standards in local plans

Two regimes set charging requirements on the same scheme and they do not agree. Part S of the Building Regulations, through Approved Document S, sets a national baseline in force since June 2022. Local plan parking standards, adopted separately and often earlier, frequently ask for more. An application that satisfies one and ignores the other will be conditioned into satisfying both, usually at the point when the electrical design is already fixed.

Reconcile them at the design stage. The cost of doing it late is a substation you did not budget for.

What Approved Document S already requires

The national baseline, in outline:

• Every new dwelling with associated parking within the site boundary gets a charge point.
• Residential buildings undergoing major renovation with more than ten parking spaces get a charge point for each dwelling with associated parking, and cable routes for the remainder.
• New non-residential buildings with more than ten spaces get at least one charge point and cable routes for a proportion of the remaining spaces.
• Charge points must meet a minimum rated output, and cable routes must be capable of taking the later installation without structural work.

There is a cost exemption. Where the cost of connecting to the existing electricity supply exceeds a stated figure per charge point, currently set at £3,600 in Approved Document S, the requirement is relaxed to the number achievable within that limit. It is a real exemption, and developers reach for it more often than it applies. Evidence it with a quotation from the distribution network operator rather than an estimate.

Where local plan standards go further

Local standards commonly express provision as a percentage of spaces rather than as a per-dwelling rule, and they distinguish active from passive. The London Plan, for example, sets a proportion of spaces with active charging facilities and a further proportion with passive provision, and several authorities outside London have adopted similar language in parking standards documents.

That produces a practical conflict on flatted schemes. Part S works from dwellings with associated parking. A local standard works from the parking count. On a block with 40 flats and 20 unallocated spaces, the two produce different numbers and different physical arrangements.

Read both, then design for the higher requirement and say so in the submission. Arguing that Part S is a Building Regulations matter and therefore not a planning consideration is a losing position, because the council can and does condition provision through the permission.

Active against passive, and what passive really means

Active provision is an installed, working charge point. Passive provision is everything needed to add one later without digging up the car park: containment, cable routes, spare ways in the distribution board, and, critically, capacity in the incoming supply.

The third column is common and it is the reason so many schemes cannot be upgraded. A duct with no spare capacity behind it is not passive provision, and an officer who asks the right question at discharge of conditions will find out.

Substations, supply capacity and lead times

Charging load is the item that pushes a scheme over its existing supply capacity. Once that happens you need either a new substation on site or reinforcement of the network, and both bring programme risk that has nothing to do with planning.

Practical sequence:

1. Calculate the connected load including charging at the design rate, with a defensible diversity factor.
2. Apply to the distribution network operator early for a budget estimate, because quotation timescales are measured in weeks and reinforcement in months.
3. If a substation is needed, find space for it on the layout at concept stage, with the access and clearances the operator requires.
4. Consider load management, which spreads charging across the night and can substantially reduce the connection you need to buy.
5. Record the assumptions in a Utilities Assessment so the numbers behind the layout are legible to the case officer.

The same discipline applies to heat, and the reasoning is set out in heat network zoning and the connection requirement.

Flats, communal parking and allocation

Unallocated parking is where charging strategies fall apart. If nobody owns a bay, nobody owns a charge point, and the management company inherits a billing problem it was not set up to handle.

Options that work in practice: allocate a subset of bays as charging bays with a booking or tariff system run by the management company, install a shared load-managed system so the supply is used efficiently across whoever plugs in, or allocate specific bays to specific flats and let residents hold their own connections. Each has consequences for the service charge and for the lease drafting.

Fire safety in covered and undercroft car parks is a live issue, and guidance in this area has been developing. Design for ventilation, detection and access now rather than assuming the position will stay as it is.

An illustrative example

Illustrative only: a 60 flat scheme with 30 undercroft spaces, 18 of them unallocated. Part S requires a charge point for each dwelling with associated parking, so 12 points for the allocated bays. The local standard requires active provision on a percentage of all spaces plus passive on a further proportion, producing a higher figure across the whole car park.

The design team installs a load-managed system serving all 30 bays, with 12 charge points fitted from the outset and containment plus board capacity for the rest. Total connected load is held within the existing supply by managing charging overnight, avoiding a substation. The saving on the connection paid for the load management equipment.

Conditions and how they are discharged

Expect a condition requiring details of charging provision to be submitted and approved before occupation, and sometimes a further condition requiring the provision to be retained. Draft the details so they match what Part S will also require, and submit them once.

Two drafting points. Ask for the condition to refer to provision being made available rather than to a specific product, so equipment can be substituted. And where the local standard refers to passive provision, define what passive means in the discharge submission, because the undefined version invites a disagreement at the worst possible moment.

Keep the charging narrative consistent with the Energy Statement and the Sustainability Statement. If the regulated energy calculation and the charging load tell different stories about the incoming supply, someone will notice. The SAP evidence side of that is covered in SAP outputs an energy statement has to show.

This is general guidance, not legal advice; check the position with your local planning authority or 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.