The Raging EV Policy Fire That's Proving Tough to Extinguish - Fire Risk and the Part S Building Regs Exemption
A diesel Range Rover Sport (NB: not an EV) catches fire at London Luton Airport, the multi-storey car park partially collapsed. Picture: SWNS
Part S success, in part
One of the more successful policy campaigns we ran at Pod Point saw us working with the govt and the Home Builders Federation to get Part S of the Building Regs into law. In essence, it compels developers to install an active chargepoint in a parking bay associated with a new dwelling (or one undergoing major renovation).
[If you have a pressing EV (charging) policy concern, idea, or problem to solve, please don’t hesitate to contact Rapid Charge Paradox (RCP) Ltd for expert advice and support.]
Part S went live on 15th June 2022, and has proven very effective, where it has been incident. However, there was a complication.
I understand that shortly prior to launch, the govt was asked where the evidence was that charging cars in "covered car parks" didn't elevate fire risk to an unacceptable level. The govt had not collated that data, and with time running out before the committed publication date they simply released Part S with an exemption for any covered car park.
The govt then ran an initial data collection exercise, presumably in the hope of removing the exemption, contracting Arup to produce this document. Despite some encouraging words, e.g. "Most available empirical evidence to date suggests that fires in EVs are less likely to occur than in hybrid vehicles and petrol or diesel vehicles", there were lots of other inconclusive words within it and the govt felt it insufficient to lift the exemption.
What's the problem?
The kernel of truth behind the hesitancy is that battery fires are nasty things that take a good while to put/burn out. If such a fire breaks out in the undercroft car park of a large building this could be sub-optimal. Thus some consideration of best practice for fire risk in a world with lots of BEVs parking in these locations is appropriate.
The happy news is that EV fires are rare. Exactly how rare is hard to ascertain. We still don't have a ton of data, as the cars are still relatively new… and we've not (despite countless claims that turn out to be ICE fires, see Luton Airport) had many fires. But it could be ~20-80 times rarer than fires in ICE cars (which carry tanks of liquified explosive and accidentally catch fire ~100 times a day in the UK alone).
There are some higher risk battery powered transport systems out there, notably cheap, lithium-ion powered scooters etc, which really are causing a headache for London Fire Brigade. But proper EVs that charge on proper chargers - not so much.
Fire risk mania spreads
From the spark of the Part S exemption, a growing fire has spread. The built environment sector and associated stakeholders have - not wholly unreasonably - drawn the lesson that there must be something different and risky about charging points being installed in covered car parks.
This has seen some fire risk assessors, the insurance sector and facilities managers take increasingly draconian measures to reduce exposure to these risks. Below are some examples:
Some insurance firms are refusing to insure buildings if chargepoints are installed in their covered car parks. Incidentally, the very same insurance firms that gladly insure buildings with chargers installed in them in Europe, because this phantom problem hasn't been created there.
I have seen a fire risk assessor for an NHS trust state that no chargepoint can be installed within 3 metres of a building in the trust estate. Thus destroying a project to rollout much needed workplace chargers across a suite of hospital sites, that had already had funding assigned and was set for installation. Please note that none of these sites even had covered car parks!
Pod Point had several residential car park projects cancelled, and were even made to shut down installed chargepoints at least one site.
There are plenty more examples, and this is getting worse, not better.
But what's this even got to do with chargepoints?
This is the thing - not a whole load. EVs are going to park in ever increasing numbers in covered car parks whether chargers are installed there or not. So banning chargepoints does not remove this risk.
Furthermore, chargepoints are essentially electrical switchgear, and are regulated like other electrical switchgear to ensure the risk of them causing a fire is extremely low.
Arguably the most legitimate concern is the idea that an EV gets damaged, e.g. in a crash, enough to compromise the integrity of the battery pack, manages to limp back home, the owner plugs it in, and the act of charging the vehicle triggers a fire. This series of events is clearly unlikely, exactly how unlikely may need to be gauged.
Electric Vehicle impedance
This is a bigger problem in terms of impeding EV uptake than most probably realise.
The impact of having a chargepoint at your parking space at home on the viability of living with an EV is huge. If charging infrastructure provision represents a barrier to EV uptake, then access to regular home (and/or workplace) chargers all but entirely removes that barrier. So this is a genuinely impactful matter to would-be EV drivers. And the UK govt's Department for Transport (DfT) know this is an important part of the charging infrastructure, hence OZEV offer "Electric vehicle chargepoint and infrastructure grants for landlords" for these scenarios - whilst impeding their installation by other means. Not exactly joined-up government.
Cosmic Charging estimates that there are ~4 million households that live in apartments in the UK, with an estimated ~1 million households that park in these covered car parks. These are now struggling to have chargepoints installed at home because of this rogue fire risk issue. And that’s before we consider the knock on effects on sites beyond the covered car parks scenario (see the NHS Trust example above).
With ~1 million households’ ability to switch to EVs compromised, this fire risk matter is one of the largest charging infrastructure barriers to EV uptake in the UK today.
It is not a trivial matter. But it doesn’t require vast sums of tax payer cash to fix. And fixing it would also directly support the government's own Zero Emission Vehicle (ZEV) Mandate, which requires manufacturers to ensure ZEVs (almost entirely EVs) make up an increasing percentage of their sales (22% in 2025, rising to 80% by 2030). By removing this barrier, the government could enable ~1 million more households to realistically consider EV ownership, thereby increasing demand and helping vehicle OEMs meet their mandated sales targets.
It is time for the UK govt to act
The first step to putting out a fire is to recognise its existence and severity, and to notify the organisation best placed to put it out. Having hosted a roundtable of stakeholders from fire brigades, fire risk expert academics, insurance firms, Local Authority members who had devised their own best practice to continue installation, and representation from central govt, it became clear that while all must work together to fully fix this, the UK govt have a unique capability to act and the other parties have limited agency without govt leading.
While the fire risk mania has spread far beyond the Part S exemption, the best first step is surely to remove the exemption that started the problem and then have the govt confirm that it fully supports the installation of this most impactful charging infrastructure in locations it is most needed.
In order to do this, it needs to take the following actions:
1. Assess
It is incumbent on the govt to determine whether the level of risk that fitting charging points in covered car parks represents is acceptable. To do so, the govt will need to gather relevant evidence, laser-focused on this matter. Either sufficient insight is readily available, or they will need to commission research to gather further evidence.
The govt must keep its assessment specific to the matter at hand. In this instance the govt need not assess the risk of EV fires in general, but specifically fires triggered by EV chargepoints and the process of charging an EV (e.g. scenarios like charging a damaged vehicle).
[Having previously convened a roundtable of key stakeholders to discuss issues of fire risk, Rapid Charge Paradox (RCP) Ltd stands ready to assist in any aspect of this project.]
2. Lead
Though one mustn't draw a conclusion before the results of the above assessment are in, given the specificity of the matter at hand, it seems likely that a non-zero, but very low level of risk is identified. If so, the govt must show leadership.
There is never a zero risk option in life. Weighing up the damage being done to EV uptake by the status quo, the material fire risk represented by alternative, legacy ICE and hybrid vehicles (see image above), against any material risk impact of the chargepoints - it is unlikely that there is a strong case to continue to impede the installation of charging infrastructure in covered car parks.
Should that be the case, the govt - meaning the Minister currently holding the brief - will have to make the call on removing the Part S exemption and firmly state the govt's support for installing charging points in covered car parks, so that the industry can adapt.
This may involve a degree of personal, ministerial courage, but the material harm being done to EV uptake makes this fundamentally necessary.
Wider industry response
Government action will enable the wider industry stakeholders to act. The insurance industry, in particular, needs to develop more nuanced approaches to risk assessment rather than sleepwalking into a de facto ban on chargepoint installations in these locations. By working with fire safety experts and EV/EV charging manufacturers, practical guidelines can be established that balance safety concerns with the need for infrastructure development.
Conclusion: Time to extinguish the fire
In an attempt to mitigate a largely theoretical fire risk, we've created a very real barrier to decarbonizing transport. This policy fire is burning through potential industry investment, and EV uptake.
We either have, or can readily - and affordably - obtain all the required insight and determine the best practices to sufficiently mitigate the risks. What's missing is the political will to act. For the sake of the viability of EV uptake, that must change - and quickly.
By removing the Part S exemption, undertaking proper evidence-based assessment, and providing clear leadership, the government can help extinguish this fire before it causes irreparable damage to the UK's EV transition.
