Installing customer EV chargers on a commercial car park
The chargers themselves usually fall within Part 2 permitted development rights. The substation, the enclosure, the canopy and the totem are what need applications.
Most customer charge points on a commercial car park go in without planning permission, under the permitted development rights for electric vehicle charging in Part 2 of Schedule 2 to the General Permitted Development Order 2015. What usually needs permission is everything around them: the substation, the cabinet enclosure, the canopy, the lighting columns and the branded totem. Plan the application around those rather than around the chargers themselves.
Which installations are permitted development
Part 2 of Schedule 2 contains two relevant classes. One covers an electrical outlet mounted on a building for recharging vehicles. The other covers a free-standing electrical upstand with an outlet, within an area lawfully used for off-street parking.
Both are expressed as a set of limits rather than as a general right: a maximum height for the upstand measured from ground level, a maximum volume for the outlet and its casing, a minimum separation from a highway, and a limit of one upstand per parking space. Both carry a condition requiring the equipment to be removed as soon as reasonably practicable once it is no longer needed.
These classes have been amended more than once to support charge point rollout, and the figures have moved. Read the current consolidated text of Part 2 on legislation.gov.uk before you specify anything, and record the version you relied on in the file. That is less cautious than it sounds: a 7 kW post and a 150 kW rapid unit with an integrated cooling system are very different objects, and the second one is much more likely to fall outside the limits.
Permitted development rights do not apply to a listed building, and they are restricted where the building or land sits in a conservation area. On both, assume you are making an application.
Position relative to the highway
The separation requirement from a highway catches more schemes than the height limit does, because small commercial car parks tend to be shallow and the obvious place for a charger is the frontage.
Two practical points. The highway includes the footway, not just the carriageway, so measure from the back edge of the footway rather than from the kerb. And where the car park boundary is a low wall with no footway, check the extent of the adopted highway with the highway authority rather than assuming the title plan tells you.
Where the frontage is the only workable location, the application is usually straightforward on its merits. Visual clutter on a frontage in a conservation area is a different matter, and there the answer is often to accept a longer cable run to a rear bay.
Substations, cabinets and their siting
This is the part that derails programmes. Anything above a modest number of fast chargers, and any rapid charger, needs more capacity than an existing supply usually has, which means a new connection and often a substation.
Where the distribution network operator installs and owns the substation, it may benefit from the permitted development rights available to electricity undertakers under Schedule 2. Where you build the enclosure, the housing, the bund or the acoustic screen yourself, that is development on your land and normally needs permission. The distinction turns on who does the work and under what statutory undertaking, so get the network operator to confirm in writing which parts they are installing under their own rights.
| Element | Usual position |
|---|---|
| Charge point upstand within the parking area | Permitted development within the Part 2 limits |
| Wall mounted outlet | Permitted development within the Part 2 limits |
| Distribution network operator substation | Often permitted development for the operator |
| Enclosure, screening or kiosk built by the site owner | Normally needs permission |
| Canopy over charging bays | Needs permission |
| Branded totem or illuminated sign | Advertisement consent |
Cooling fans on rapid units and on the transformer are an amenity issue where homes back onto the car park. Where they do, a Noise Impact Assessment measuring the real background level at the nearest facade is worth doing before the units are ordered, for the reasons set out in our note on refrigeration plant noise.
Losing parking spaces against the standard
Charging bays are usually wider than standard bays, because the cable, the bollard and the accessible approach all take room. On a car park already at the local standard, converting four bays into three charging bays with a protected zone reduces capacity, and that is the point a highway officer will pick up.
PAS 1899 sets out what accessible charging provision should look like: bay dimensions, the approach, the height of the connector and the force needed to handle a cable. Designing to it from the start avoids a retrofit later and gives you something concrete to put in the submission.
Where the reduction in spaces is material, a short Transport Statement covering the existing supply, the observed occupancy, the proposed layout and the swept paths is the proportionate document. For a retail or leisure car park, say how long a charging customer dwells compared with a non-charging one, because the turnover argument is the one that answers a capacity objection.
Lighting, canopies and signage
Lighting is often improved at the same time, and new columns are development. Keep to the lowest column height that gives the lux level you need, specify a warm colour temperature with sharp cut-off optics, and check the spill at the boundary against the obtrusive light limits for the relevant environmental zone.
Canopies change the appearance of the site substantially and are assessed as a structure. A canopy that reads as a petrol filling station forecourt on a high street car park will attract design objections.
Totems and illuminated signs need advertisement consent under the Control of Advertisements Regulations 2007, which is a separate application on a different test. Submit it alongside the planning application rather than afterwards, because an approved layout with an unconsented sign is a common and avoidable snag.
Conservation areas and listed buildings
In a conservation area, the question is what the installation does to the character of the area. Charge points behind a wall in a rear yard rarely trouble anyone. A rank of units and a transformer kiosk on a frontage within a historic market square is a different proposition, and the realistic approach is to locate the plant where it cannot be seen and to accept longer cable runs and more civils cost.
On a listed building, any fixing into historic fabric needs listed building consent in its own right, and a cable route up a principal elevation will not be accepted. Route through existing penetrations, or along a ground level trench, and document the route on a measured drawing.
New build, major renovation and Approved Document S
Retrofitting an existing car park is a planning question. New build is a building regulations question first.
Approved Document S requires charge point provision in new buildings and in buildings undergoing major renovation. For new non-residential buildings with more than ten parking spaces, that means at least one charge point plus cable routes for a proportion of the remaining spaces. Check the current edition and the transitional provisions, because the thresholds and the exemptions are detailed and they interact with the building control route you are using.
As an illustrative example, a retail park operator installing six 22 kW posts in existing bays at the rear of a car park, with the distribution network operator installing its own substation in a compound beside the service yard, might need no planning application at all for the chargers, one application for the acoustic screen around the compound, and an advertisement consent for the totem at the entrance. The civils and the grid connection, not the planning, set the programme.
Before you order equipment, confirm the connection capacity, the network operator's programme and the current Part 2 limits. This is general guidance rather than legal advice, so check the position with your local planning authority before you rely on permitted development. To see which documents a car park or servicing application is likely to need, enter your postcode on PlanScope. PlanScope provides AI-assisted draft reports for planning applications. Reports should be reviewed before submission. We do not guarantee planning approval.
Frequently asked questions
Do I need planning permission for EV charge points on a car park?
Often not. Part 2 of Schedule 2 to the General Permitted Development Order 2015 permits a wall mounted outlet and a free-standing upstand within an area lawfully used for off-street parking, subject to limits on height, casing volume, separation from a highway and one upstand per space. Listed buildings are excluded.
Does the substation need permission too?
It depends who installs it. Where the distribution network operator installs and owns the substation, it may rely on the permitted development rights available to electricity undertakers. Where the site owner builds the enclosure, screening or kiosk, that is normally development needing permission. Get the operator to confirm in writing which parts it installs.
How is the distance from the highway measured?
From the extent of the adopted highway, which includes the footway rather than stopping at the kerb. Where there is no footway and the boundary is a low wall, check the adopted extent with the highway authority rather than relying on the title plan, because the two often differ by a metre or more.
Will losing parking spaces cause a problem?
It can, where the car park is already at the local parking standard. Charging bays are wider than standard bays once the bollard, cable and accessible approach are included. A short Transport Statement covering existing supply, observed occupancy and the proposed layout is usually the proportionate response.
Do charger totems need separate consent?
Yes. An illuminated totem or branded sign needs advertisement consent under the Control of Advertisements Regulations 2007, which is a separate application decided on amenity and public safety. Submit it alongside the planning application, because an approved layout with an unconsented sign is a common and avoidable snag.
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.