Approved Document S: Infrastructure for charging electric vehicles, frequently asked questions
Answers to frequently asked questions on Approved Document S, which sets standards for installation of electric vehicle charge points or cable routes.
Applies to England
These frequently asked questions (FAQs) refer to the Infrastructure for charging electric vehicles: Approved Document S.
For the purposes of these FAQs, the term charge point shall be taken to mean an electric vehicle charge point.
Associated parking spaces
1. Does a building need to have a charge point even if it does not have a parking space?
No, the requirements only apply where a building has an “associated parking space” as defined in Approved Document S.
To be associated, a parking space must be:
- available for use by the occupant of the building or a visitor to it; and
- within the site boundary of the building.
2. Does an “associated parking space” only apply to those parking spaces provided exclusively for the use of one building or dwelling?
No, if a parking space is provided for the use by the occupant of, or a visitor to, a building then it will be deemed to be “associated” with that building for the purposes of calculating the number of charge points and cable routes required. The parking space may be:
- provided exclusively for the use of a particular building or dwelling. For example an allocated parking space; or
- provided for use by the occupier of or visitor to more than one building or dwelling. For example communal parking spaces or visitor parking spaces.
For the purposes of Approved Document S compliance it is likely that all parking spaces within a development site boundary will be associated with one or more buildings on a development. A ‘site plan’ or ‘block plan’ may be a useful way to demonstrate to building control which parking spaces are associated with which buildings.
In some circumstances, parking spaces may be associated with more than one building. When identifying the number of cable routes required in these scenarios, these spaces may be assigned on a pro-rata basis to the relevant buildings. This could be based on the number of dwellings in each building.
The examples below illustrate charge point and cable route requirements where parking spaces are associated with more than one building.
Diagram 1: Parking spaces that are associated with more than one building – example for blocks of flats
Block A containing 20 flats. Block B containing 10 flats. Car park C contains 36 uncovered communal parking spaces provided for the use of occupants and visitors to dwellings in both block A and block B on a first come, first served basis.
If using the pro-rata approach for designating which communal parking spaces are associated with which block of flats, the number of spaces may be based on the number of dwellings in each building. In this example:
- block A would have 24 associated parking spaces (20/30 × 36)
- block B would have 12 associated parking spaces (10/30 × 36)
As such, block A would require 20 charge points and 4 cable routes and block B would require 10 charge points and 2 cable routes.
Diagram 2: Parking spaces that are associated with more than one building – example for houses with communal parking
A new development consists of 20 houses. Each house has 1 uncovered parking space that is assigned to the house for sole use by its occupier or their visitors. This means there are 10 additional uncovered parking spaces that are for the communal use of occupiers from all 20 houses and their visitors.
If using the pro-rata approach for designating which of the communal spaces are associated with which house, then each house will have 0.5 associated communal parking spaces as well as the 1 space that is provided for the exclusive use of the house. In this example:
- each house will have 1.5 associated parking spaces so would require 1 charge point but no cable routes
- in total the whole development would require 20 charge points but no cable routes
3. For the purposes of these regulations, is a terrace of houses considered to be one or multiple buildings? What about a block of apartments?
A “building” is defined in Regulation 2(1) of the Building Regulations 2010 as “any permanent or temporary building but not any other kind of structure or erection, and a reference to a building includes a reference to part of a building.”
Approved Document S requires additional cable routes for all associated parking spaces without charge points if there are more than 10 associated parking spaces for a new residential building. These are required to simplify the installation of future additional charge points and minimise disruption in communal areas.
For a single detached house with either a drive or an allocated parking space, the requirement for cable routes will only be relevant if that building has more than 10 associated parking spaces which is unlikely in most cases.
For the purposes of these regulations, for semi-detached houses or terraced properties with associated parking spaces, the ‘building’ that the ‘more than 10’ parking spaces threshold relates to may be considered to be at individual dwelling level rather than the whole building. This means that the requirement for cable routes in parking spaces without charge points is unlikely to apply unless there are over 10 spaces for sole use by that dwelling.
For a block of apartments with communal facilities (eg car park, entrances, stairways, lifts etc), it would be more appropriate to consider the block as the ‘building’ as cable routes would minimise disruption during installation of future charge points. As such the ‘more than 10 spaces’ would relate to the parking spaces for the whole block.
The examples below illustrate how the interpretation of “building” will affect different types of housing
If a new detached house has 2 associated parking spaces then 1 charge point will need to be fitted. No additional cable routes will be required as the house does not have more than 10 associated parking spaces.
Diagram 3: An example of a terrace of new houses where each house is deemed to be the building
A new development consists of 6 terraced houses. Each house has 2 uncovered parking spaces provided for the sole use of its occupiers. In this example:
- each house will need to have 1 charge point, so a total of 6 charge points will be required
- no cable routes will be required because none of the buildings (in this case individual houses) has more than 10 associated parking
Diagram 4: An example for a block of flats where the block is deemed to be the building
Block A containing 10 flats. Car park containing 12 uncovered parking spaces provided for the sole use of occupants of block A. In this example:
- 10 charge points will need to be installed to reflect the number of new dwellings
- the remaining 2 parking spaces will need cable routes as there are more than 10 parking spaces associated with the building (the block of flats)
4. How do I determine what is the site boundary for the purposes of establishing which parking spaces will be “associated” with a building?
The site boundary of a building is defined on page 35 of Approved Document S. The site boundary will be determined at the point of depositing a full plans application/building notice or submitting an initial notice. The parking space will be within the site boundary if, at this point in time, it is located on land that is owned or controlled by the same party that owns or controls the land on which the building is being built.
For example, if a single house is being built on a standalone plot then the site boundary is likely to be the boundary of the plot on which the house is located.
If a development of 10 houses is being built, then the site boundary for each of the houses is likely to be the boundary of the whole development.
Where parking spaces are separated from the house by land that is under different ownership or control at the time of depositing building regulation plans, the parking spaces would not be considered within the site boundary. Therefore they would not be associated with that building for the purposes of the building regulations. An example of this would be where there is an existing adopted road or footpath.
Diagram 1.1 of Approved Document S provides an example where dwelling 1 and dwelling 2 are standalone plots and not being built as part of the same development. As such the site boundaries for dwelling 1 and dwelling 2 follow the boundary of the land upon which each dwelling is located.
Diagram 5 shows the same example as diagram 1.1 but has been amended to illustrate the effect on the site boundary when houses are built as part of a wider development. In this example, both houses and their parking spaces have all been built as part of the same development. At the point of depositing the full plans application/building notice or submitting an initial notice, the houses and parking spaces are under same ownership and/or control. The road shown is an existing adopted highway.
Diagram 5: Determining which parking spaces are associated for multiple dwellings built as part of the same development
Parking space 1, despite being separated from dwelling 1 by a garden, is within the site boundary for both dwellings 1 and 2 as it is land under the same ownership/control. Parking space 1 contains a parking space provided for the use of the occupiers of dwelling 1. This is a parking space associated with dwelling 1.
Parking space 2 is within the site boundary of both dwellings 1 and 2. It is provided for the use of the occupiers of dwelling 1. This is a parking space associated with dwelling 1.
Parking space 3 is provided for the use of the occupiers of dwelling 2 but is outside the site boundary for dwelling 2. In this example, parking space 3 is separated from both dwellings 1 and 2 by an existing public highway or a road that is not under the same ownership/control as dwelling 2. Parking space 3 is not an associated space for either dwelling 1 or dwelling 2.
Parking space 4 is provided for the use of dwelling 2 but is within the site boundary of both dwellings 1 and 2. Parking space 4 is associated with dwelling 2.
Garage/car port 1 is provided for the use of dwelling 1 but is within the site boundary of both dwellings 1 and 2. The parking space within garage/car port 1 is associated with dwelling 1.
Garage/car port 2 is provided for the use of dwelling 2 but is within the site boundary of both dwellings 1 and 2. The parking space within garage/car port 2 is associated with dwelling 2.
In this example:
- dwelling 1 has 3 associated spaces and is required to have 1 charge point installed but no cable routes
- dwelling 2 has 2 associated spaces and is required to have 1 charge point installed but no cable routes
Diagram 1.2 of Approved Document S provides an example where Car Park 4 is not advertised for the use of occupiers of Building 1 so is not associated with Building 1. They are also split by land that was under different ownership (an adopted highway) at the point of depositing a full plans application/building notice or submitting an initial notice. As such the requirements did not apply to car park 4 or the on-street parking spaces.
Diagram 6 shows the same example as diagram 1.2 but the variables have been modified to provide more detail on the definition of site boundary as ‘under the same ownership/control’. In this example the road shown is a new road built as part of the wider development and Car Park 4 is provided for the occupants of and visitors to Building 1.
Diagram 6: Determining which parking spaces are associated for a new block of flats
Buildings 1 and 2 are new blocks of flats. They were built as part of the same development and share the same site boundary as the developer owned all of the site at the point of depositing plans or submitting an initial notice. For this example we will only consider the parking spaces for building 1. Car parks 1, 3 and 4 are all uncovered and are being provided for the sole use of occupants of, or visitors to, dwellings in building 1.
Car park 1 is within the site boundary for building 1 and is provided for the use of occupants of, or visitors to, dwellings in building 1. Requirements apply relating to building 1.
Car park 2 is within the same site boundary as building 1 but does not contain parking spaces being provided for the use of occupants of, or visitors to, dwellings in building 1. No requirements apply relating to building 1, although they may regarding building 2 if the parking is considered to be associated.
Car park 3 is within the site boundary of building 1 and is provided for the use of occupants of, or visitors to, dwellings in building 1. The parking is considered to be associated, despite being separated from building 1 by vegetation/landscaping. Requirements apply relating to building 1.
Car park 4 contains parking spaces provided for the use of occupants of, or visitors to, dwellings in building 1. It is within the site boundary of building 1, as it falls within land under the same ownership/control at the point of depositing plans or submitting an initial notice. The road shown is new and part of the same development. Requirements apply relating to building 1.
On-street parking – the 3 designated spaces shown are provided for use of occupants of, or visitors to, building 1 and buildings within the wider development. The road is a new road proposed as part of the development so is under the ownership/control of the same developer at the point of depositing plans or submitting an initial notice. The on-street parking spaces are within the same site boundary as building 1. Requirements will apply in relation to all buildings that are associated with these spaces. The pro rata approach may be used to identify requirements.
Exemptions
5. If the cost of installing a charge point in a new residential building exceeds £3,600 is it exempted from requiring a charge point?
Not necessarily as it will depend on how that cost is reached. Regulation 44D(2) states that “the number of electric vehicle charge points that must be installed is the maximum number of electric vehicle charge points that it is possible to install at an average sum of £3,600 or less for the connection cost of each electric vehicle charge point connection”.
The connection cost is defined in Approved Document S as “the cost of upgrades needed to the electricity system in order to accommodate a charge point, excluding the cost of any building work or the cost of the charge point itself.” This connection cost is the extra cost of the incoming electrical supply per electric vehicle charge point connection compared to the cost without electric vehicle charge points.
If this average sum is reached, there is still a requirement to install the maximum number of electric vehicle charge points that it is possible to install at an average sum of £3,600 or less for the connection cost of each charge point.
Finally, for those parking spaces where you are you are unable to install charge points at a connection cost of £3,600 or less then you will need to provide cable routes that meet the requirements of paragraph 6.7 of the Approved Document S.
Example:
A housing development consists of 30 semi-detached houses with their own driveways which under these regulations would each require a charge point to be installed. The extra connection cost for the development is £120,000 which averages £4,000 per house. As this average cost exceeds the £3,600 threshold then charge points will not be required for all houses. The developer identifies that the cost of providing charge points to 20 houses would reduce the connection cost to £105,000 which is an average of £3,500 over the 30 houses. This is the maximum number they can install below the £3,600 threshold.
In this example the developer will need to provide charge points to 20 of the houses and a cable route to each of the remaining 10 houses.
Installation practicalities
6. Do any further regulations apply to the installation of electric vehicle charging infrastructure apart from Approved Document S?
In addition to the requirements of Approved Document S, the installation of charging infrastructure should also comply with all applicable requirements of the Building Regulations. Furthermore, certain product standards regulations and consumer protection standards may also be applicable, including the since introduced: The Electric Vehicles (Smart Charge points) Regulations 2021.
These require all charge points sold in Great Britain for private (domestic or workplace) use to have smart functionality to help manage the increase in electricity demand from the transition to electric vehicles. The Office for Product Safety and Standards (OPSS) is responsible for ensuring compliance with these regulations.
7. Can a single meter be used to supply electricity to multiple charge points? Can a single charge point serve multiple parking spaces?
A meter supplying more than one charge point may be an acceptable way to meet the requirements in certain circumstances, for example communal areas where it may be difficult to connect directly to the meter supplies of multiple dwellings. Furthermore, a single charge point with multiple outlets may serve more than one parking space, as long as each parking space served by the charge point has its own outlet, can be used simultaneously and can meet the minimum requirements of Approved Document S.
8. Where ‘cable routes’ are required is it acceptable to terminate these adjacent to street furniture (e.g. lampposts)?
Any future connection location should meet the requirements of paragraph 6.7 of Approved Documents S to ensure that a compliant charge point can be fitted in the future.
If a lamppost or similar is proposed as the future connection location for the charge point, then it should either be metered or capable of being metered for future connection. When assessing whether a lamppost or similar is capable of being metered, consideration should be given to the future ownership, likelihood that permission will be given to connect and suitability for adaption to host a charge point.
All cable routes should be laid as straight as possible and with suitable access points, so that cables can be pulled through in future as per paragraph 6.10 of Approved Document S.
9. A building which only has covered parking spaces is exempt from the requirement to install charge points but will instead need cable routes to facilitate future installation. If I choose to install charge points rather than just cable routes, do the charge points need to be compliant with section 6 “Standards for electric vehicle charge points and cable routes” of the Approved Document?
If you choose to install charge points in covered parking spaces rather than just cable routes, then you will be going beyond the minimum requirement that is legally required by these regulations. As such, the guidance in section 6 does not apply to these charge points. However, we recommend that charge points outside the scope of the regulations meet the guidance wherever possible. You should note that the charge points will still need to meet other relevant standards including those for electrical safety.
Other requirements
10. Do diagrams 6.4 and 6.5 of Approved Document S stipulate minimum space requirements for charge points installed under these regulations?
No, diagrams 6.4 and 6.5 show minimum space requirements for the future connection location of a floor- and wall-mounted charge point. The location will need sufficient space to enable access for both installing and maintaining the charge point and also recharging vehicles with charging inlets in different places.
When installing charge points at the point of construction, the charge point should comply with the requirements laid down in paragraph 6.2 of Approved Document S and the location of the charge point should be suitable for use by electric vehicles with charging inlets in different places. Consideration of space requirements should be made when accessible parking spaces are provided.