This guidance specifically applies to charging bays typically located within the car park of another hereditament and crucially, requiring a separate entry in the rating lists. For assistance on the valuation of dedicated electric vehicles (EV) forecourts or hubs contact the Transport Class Coordination Team (CCT). Where EV charge points (EVCPs) and associated charging bays do not require a new rating list entry and are considered part of an existing hereditament, then the respective individual rating manual entry and practice notes should be considered to determine whether there are any value implications for that hereditament.

List Description: ELECTRIC VEHICLE CHARGING BAYS AND PREMISES

Regional Valuation Units (RVUs) are responsible for the assessment and valuation of sites of EVCP bays. Further guidance and advice if required should be sought from the Transport CCT.

The Transport CCT has overall responsibility for the co-ordination of this class. The team will deliver practice notes describing the valuation basis for revaluation and provide advice as necessary during the life of each rating list. RVU valuers and inspectors have a responsibility to:

• not depart from this guidance on CCA or list maintenance work without approval from the CCT

5.1 Under the Automated and Electric Vehicles Act 2018, a charge point includes any device used for supplying electricity to an electric vehicle.

5.2 Plant and machinery

The Valuation for Rating (Plant and Machinery) (England) (Amendment) Regulations 2022) established an exception to plant and machinery used mainly or exclusively for EVCPs. This applies to EVCP related plant and machinery used for power storage, transformation, and transmission.

This exception does not apply to the site of any EV charging bays which in many cases will form a rateable hereditament.

6.1 Identification of the hereditament

It is expected that identification of the hereditament will be straightforward in most cases. This will usually consist of one or more delineated or marked charging bays within a car park, utilised for charging electric vehicles. Charging bays will usually be contiguous and easy to identify using marked lines and branding in the car park. Although excepted, any charging equipment should also be noted and will normally show the name of the EVCP brand, but who may not necessarily be the rateable occupier.

The number of charging bays should be noted along with the number of EVCPs themselves. Sites can vary from having one charge point for every charging bay, to a single charge point serving multiple charging bays.

Other information to be acquired should include the location and setting of the landlord host hereditament where appropriate. For example, whether the EVCP bays are located on a primary or secondary route, or what the car park setting consists of for example a prime retail park, restaurant, convenience store or hotel. These details are important to obtain as if forming a separate hereditament, they will likely impact value along with the number of charging bays. Any other plant and machinery not directly related to any EVCP function should also be recorded for example CCTV.

6.2 EVCP bays located on the public highway or on street

In most cases sites falling under this description will not require entry into the rating lists. Having considered contractual agreements for sites of this nature, typically between local authorities and EVCP operators, as well as established case law including Milton Keynes Council v Alexander (VO) [2018] UKUT 366 (LC) and Dorset County Council v Mr J. Reeves (Valuation Officer) [2014], whilst a hereditament may be able to be identified due to delineated charging bays, the lack of a rateable occupier suggests these are not rateable hereditaments.

In summary any associated public authority does not ‘own’ the highway in a traditional sense. The road is only vested in that authority to the extent necessary for the control, protection, and maintenance of it for public use. Any ‘ownership’ of the highway is simply a statutory formulation for the purpose of its control and maintenance and although the local authority may determine who can occupy the bay, this does not mean they themselves are in rateable occupation.

As for the EVCP operator, the fact that they may benefit from there being an EVCP bay present does not mean they are in rateable occupation of the charging bay. Importantly it is not the EVCP operator who is allowing someone to charge their car, rather it is the local authority who allow the charging in performance of its statutory powers regulating the public highway and as stated, the local authority in such circumstances is not in rateable occupation. Therefore sites of EVCP bays on this basis are not considered rateable hereditaments.

6.3 Rateable occupation and unit of assessment

Once a recognisable hereditament has been identified, the next question to be considered is who has rateable occupation and general control of the charging bays? Research has shown that occupation of sites of EVCPs bays can vary significantly, mainly due to the different types of occupational agreement between parties with examples including leases, licenses, tenancies at will, call off contracts, service agreements, hosting agreements or concessions.

As such and when determining if a new entry to the rating lists is required, careful consideration is needed to review the terms of any agreement and whether either a host landlord or third party EVCP operator has rateable occupation of the charging bays.

Although not exhaustive, this sections explains typical examples of contractual arrangements and indicators of whether a separate list entry for any EVCP bays may be required.  

6.3.1 Lease

The existence of a lease will normally be a strong indicator that a host landlord has parted with possession of one or more parking bays, and that a separate EVCP operator has rateable occupation and control with use as EV charging bays. The presence of a lease will usually provide the tenant with a covenant of quiet enjoyment which will normally confer exclusive possession and general control to that tenant.

Therefore where EVCP bays are occupied under these terms and leased from a separate host landlord, this will likely result in a separate hereditament and a new entry into the rating lists required for the charging bays.

6.3.2 Licence or hosting agreement

Where the agreement is something other than a lease, it is likely there will not be a separate entry in the rating lists required for any charging bays. The nature of these agreements will normally specify that the landlord has retained control and exclusive possession of the site, and that no tenancy exists. It may also state that the landlord is able to relocate the charging bays under certain circumstances and whilst this may not be exercised, the existence of such rights is of relevance alongside other factors.

Therefore in this scenario, there would likely not be a separate list entry for the EVCP bays which remain in occupation of the host landlord.

6.3.3 Management and digital services type agreement

These agreements are typically where a host landlord purchases charging equipment from an EVCP company. The EVCP company brand may be shown on the equipment, however it is owned by the host landlord, who also sets the charging price and retains the charging income. A commission is paid to the EVCP company for equipment management and digital billing support, but rateable occupation of the charging bays remains with the host landlord.

Therefore in this scenario, there would not be a separate list entry for the EVCP bays which remain in occupation of the host landlord.

6.4 Rateable Value (RV) of host hereditaments adding EVCPs

As in paragraphs 6.3.2 and 6.3.3, it is not uncommon for EVCP bays to be in rateable occupation of a host landlord. Host property types can vary from retail, leisure or hospitality, as well as local authority type premises for example schools or libraries.

Whether there is any impact on the wider RV of these hereditaments due to the added provision of EVCP bays will depend on the individual circumstances and where this is the case, valuers should contact the relevant class coordination team for the host hereditament type. However there are general factors to consider.

Although EVCP bays may have been added to an existing hereditament, they may have replaced parking bays which have effectively been lost.

The presence of the EVCP bays may be deemed reflected in enhanced footfall the hereditament may benefit from. However, if the operator charges for use of the charging bays and makes an income due to a margin gained on power sold, this will likely be separate from any enhanced footfall impacting existing income streams.

The addition of EVCP bays may be insignificant in the wider RV of the subject. For example, a supermarket with extensive buildings and large parking bay numbers, may consider the addition of a relatively small number of EVCP bays to be insignificant in terms of overall RV.

Land located at the host hereditament may already been deemed reflected in the value of the buildings. With plant and machinery excepted, a simple change in use of some spaces from parking to charging may be deemed insignificant in overall value impact. This may also be the case when charging is offered for staff or to maintain business operations for example maintaining the charge on a fleet of electric vehicles. This is naturally different compared to a public EVCP site running the charging as a business for profit.

Each case must be considered on its merits.

7.1 Notes made from inspection should be compiled and saved in the relevant property folder in EDRM. Due to most hereditaments simply being one or more EVCP bays it is expected any survey data in RSA will be minimal. The relevant practice note will provide details on the appropriate sub location to adopt.

When creating survey data, the line code ‘PKS’ must be used with the subsequent line entry description amended to electric vehicle charging bays.

7.2 Where EVCP bays require entry into the lists that have been added to the car park of an existing hereditament, it is recommended that that a reconstitution of the host hereditament takes place. Naturally a review of the host rateable value who has parted with possession of the bays may be required in certain circumstances. Where the charging bays are located in a car park which is shared between different occupiers for example a retail park setting, then it is likely the EVCP bays will form a new hereditament rather than a result of a reconstitution.

8.1 Sites of EVCPs are valued by reference to rental evidence which should be obtained accordingly. Research has shown that rental evidence for EVCP charging bays may be affected by:

• location of the charging bays, for example whether on a prime or secondary route or location type for example retail park, food and beverage or garden centre
• any consideration of rental evidence must take place bearing in mind the potential for rents being agreed without consideration of any rates liability

Headline rents may have historically been set based on the assumption that no rates would be payable by the tenant, potentially leading to a higher rent than would otherwise have been paid if rates were payable. This view may likely have been formed either by EVCP companies assuming host landlords would be responsible for any rates liability, or that following the Plant and Machinery regulation changes in 2022, all aspects of EVCPs including charging bays would be excepted from rating, which they are not.

Details of the valuation schemes for sites of EVCPs are shown within the relevant rating list practice notes.

8.2 EV forecourts or hubs

Where a site of EVCP bays is more in the nature of an EV forecourt or hub, advice should be sought from the Transport CCT. Such examples may include additional facilities that may or may not be in occupation of the EVCP operator, for example supplementary retail or catering facilities. Other potential value significant items may include plant and machinery not part of the EV charging process, canopies or valeting. Valuation guidance on any elements like these should be obtained from the CCT.

8.3 Advertising rights at EVCPs

The Transport CCT can provide guidance and support on sites of EVCPs alongside the relevant practice notes and Rating Manual entry. Sites are to be valued in the central database with the relevant practice notes providing information that should be adopted.