Memorandum by National Car Parks (IT 107)
THE INTEGRATED TRANSPORT WHITE PAPER
1.1 National Car Parks (NCP) is the U.K.'s largest
private sector operator of car parks. The company operates just
under 500 car parks nationwide, employs 400 personnel and has
an annual turnover of £165 million (as at 31 March 1997).
However, in comparison to local authorities' parking operations,
we represent 10 per cent of the total car parking market.
1.2 In May 1998 NCP was acquired by the US-based
Cendant Corporation (Cendant) and now operates within the context
of one of the biggest and most diverse travel-related groups in
the UK. Other brands in the Cendant group are Green Flag
(breakdown recovery services), Cendant Business Answers
(vehicle fleet management and car leasing, formerly known as PHH),
Capital Logistics (a bus and coach operator) and RCI
(the European arm of the world's largest timeshare exchange operation).
Given this diversity of travel-related operations, the Transport
White Paper deeply affects our business environment in a number
1.3 This submission focuses on the NCP perspective
on urban transport policy and the implications for urban traffic
management. In particular, we consider parking controls, congestion
charging, workplace parking and retail parking charges.
1.4 In partnership with London First,
we are undertaking an extensive research project into the effect
of some of the White Paper's proposals on traffic in the capital.
We also work very closely with the Association of Town Centre
Management, of which NCP is a member, on a nationwide basis.
Through this research and with the expertise built up through
over 40 years of operation, NCP can continue to make a positive
contribution to the development of transport policy in our town
and city centres. We hope this paper can form part of that process.
2. NCP'S APPROACH
2.1 In NCP's policy document "The Role
of Car Parks in an Integrated Transport Strategy" published
in February 1998 (a copy of which is enclosed), we argue that
private off-street car parks are vital components in an integrated
transport strategy. In designing local transport plans which encompass
measures on congestion charging, workplace parking charges and
on-street parking, local authorities should have due regard to
the role NCP can perform.
2.2 NCP aims to promote the vitality of urban
centres which we see as both a quality-of-life and a commercial
issue. The car, along with other transport modes, is a key component
in delivering that vitality. However, as the White Paper says,
car use cannot be allowed to continue unfettered without threatening
the health of businesses and communities. There are many ways
to achieve this necessary management of car usage and the White
Paper analyses these in some detail. However, it overlooks one
of the most important methods: the off-street car park. This facility
is a vital tool for the following reasons.
2.3 Containment and Access
Off-street car parks perform the necessary dual
functions of keeping parked cars away from busy roads and limiting
the areas of a city centre through which they need to travel.
This ameliorates traffic congestion, together with pollution,
and allows freer movement of essential city centre traffic. By
focusing parking in a specific area, drivers have the ability
to go directly to an off-street car park and not make time-consuming
and inefficient journeys looking for on-street or illicit parking
spaces. Off-street parking provision is especially helpful for
drivers in unfamiliar city centres.
2.4 Integration Hubs
Within the objective of an integrated transport
policy, the car park can provide central points from which drivers
can transfer to other modes of travel. For instance, bus terminals,
train stations and car parks can be co-located. In this context,
car parks have the potential to become transport information points,
providing details on train and bus travel and aiding the "seamless
2.5 Security Against Crime
Off-street car parks afford a greater level
of security against car and personal crime than on-street parking
and our own research shows that this is very much part of their
appeal. Whilst it is clearly not within NCP's power to eliminate
crime totally on its premises, we are achieving significant results.
A high proportion of NCP car parks already have CCTV in place
and this number is increasing steadily; also most NCP car parks
are manned and regularly patrolled. This level of real and perceived
security is essential in attracting people into urban centres.
Off-street car parks are the only option for
many segments of society: large families, the old and infirm,
the disabled or anyone with large amounts of shopping. Car parks
thus play an integral part in creating an inclusive transport
infrastructure. Co-location of NCP car parks with retail and business
centres provides a vital advantage over park-and-ride schemes
for people who, for whatever reason, may find bus, train or tram
travel inconvenient or impractical.
2.7 Park and Ride
Park and Ride does not need to be an exclusively
edge-of-town phenomenon. Off-street car parks convey the ability
for drivers to access the heart of a city and connect with other
2.8 NCP believes also that discouragement of
car use and encouragement of use of public transport should not
be based solely upon penalising the car user. The use of cars
is for many a necessity and many rural communities rely solely
on this mode of transport in the absence of any real alternative.
2.9 The problem of urban congestion is getting
worse and there should be no delay in introducing legislation
requiring local authorities to produce comprehensive local transport
plans, working with companies such as NCP and other major retailers.
We urge the Government to make provision for this in the Queen's
Speech. The cost of delay is growing congestion and pollution
and a further reduction in the vitality of urban centres.
3. LOCAL TRAFFIC
3.1 We entirely concur with the view that local
authorities should "control on-street parking to prevent
vehicles obstructing traffic and pedestrians."
If sensibly implemented this policy will greatly contribute to
reducing congestion with clear benefits for the resident, commuter
3.2 However, there must be careful co-ordination
between town-centre partners, especially NCP, if the increase
in on-street parking controls is not to have inadvertent and possibly
adverse effects. Traffic management plans must be agreed between
all town centre partners and communicated effectively to the public
in order that their travel and parking options are clear to them.
Otherwise, restriction of perceived parking capacity in town centres
may have the effect of driving consumers towards out-of-town retail
3.3 The majority of drivers will use the off-street
alternatives offered by NCP and others. Demand for off-street
car parking may well rise in the short-term before alternative
transport modes impact upon demand. Whether this demand can be
effectively met will vary greatly from area-to-area and will depend
upon a range of factors including:
nature of the on-street controls;
existing off-street capacity and
the potential for development;
other policies in the local transport
levels of workplace charging and
ability of drivers to switch modes
3.4 Our message is that when local authorities
come to consider controlling on-street parking, they will have
to take into account the extent and availability of off-street
alternatives, including those generated by the councils themselves.
NCP will be ready and willing to act as consultees in the process
of designing these plans. In monitoring Local Transport Plans,
the Secretary of State should have regard to the extent to which
private car park operators have been consulted.
4. WORKPLACE PARKING
4.1 NCP recognises the need for introduction
of this policy. We strongly concur with the widely held view that
unless alternative travel modes are already in place the motorist
is being unduly penalised. In the long-term, reducing parking
spaces will increase the numbers of people walking, cycling and
using public transport. However, in the short-term, the White
Paper makes it clear that improvements in these alternatives will
depend on the new charges for funding; i.e., charges will precede
4.2 Around 18 per cent of NCP's business comes
from season tickets purchased by companies for their employees
use. The White Paper is short on detail as to how this practice
will be affected by workplace charging and we look forward to
the publication of the consultation document to clarify this issue.
4.3 NCP believes that private car park operators
providing workplace parking to companies should be exempt from
these charges, for four reasons:
in effect, the charges will operate
as a direct tax on the private car park operator for which parking
is the sole business activity;
the charges will be levied by local
authorities which are the chief competitors to the private sector
car park operatorsin effect giving councils strong monopoly
power over parking in their area;
local authorities' car parks, it
appears, may be exempt from the charging framework;
NCP provides many of its season-ticket
spaces to employees for whom public transport is not viable. Nurses
and other night-workers use their carsand our car parksbecause
no other options are available to them when they are travelling
to and from work. It would be wholly unfair to expect these groups
to pay more for their parking, especially as they are not contributing
to the day-time congestion problem.
4.4 We concur with the view that there should
be a strong presumption against local authorities operating both
workplace and congestion charges, for the same reasons as outlined
in paragraph 4.1 above. Also, it seems correct and consistent
with the aims of the White Paper that workplace charging should
apply to out-of-town as well as urban sites.
4.5 The impact of workplace charging on urban
businesses must be carefully monitored and the longest feasible
time given to assessing pilot projects and, if implemented, to
appropriate levels of charging.
4.6 We note with great concern that leisure
and retail developments are not to be subject to parking charging
initially and believe this relaxation should be extended to urban
businesses, with the same proviso that exempted businesses "make
significant progress . . . in the form of . . . reduced car dependency."
The charges will impose a cost on businesses at a time in the
economic cycle when they can least afford it and NCP, along with
other city centre retailers, is very concerned about the potentially
negative impact on the urban economy. Giving businesses the opportunity
to ameliorate workplace charges through the development of alternative
schemes should lead to more varied and imaginative approaches.
As companies come up with their own schemes, there will be the
possibility for best practice to spread around the country.
5. CONGESTION CHARGING
5.1 With London First, NCP is conducting research
into the effects of congestion charging on the capital. This will
be an important work in terms of its scope and topicality and
we hope that it will provide useful information for policy makers
centrally and in the regions.
5.2 NCP will explore ways in which car parks
can become integrated with congestion charging policies. They
could operate as payment centres of the charge; or entering an
urban centre could be made dependent upon having a pre-booked
parking space or, perhaps, just upon the availability of parking
spaces. There is the suggestion that local authorities may wish
to distinguish between through traffic and visiting traffic, although
it is not clear how, in which case the provision of parking spaces
becomes all the more important.
6.1 NCP is disappointed that the Government
has decided not to impose charges on non-workplace private non-residential
parking spaces. This means that out-of-town centres will continue
to attract people out of urban centres, threatening their vitality.
The stipulation to "identify appropriate measures" is
far less onerous than a parking charge and it is difficult to
see this as anything other than a soft option for these developments.
Out-of-town congestion and pollution is no less serious than its
urban counterpart and would be responsive to parking charges were
they to be imposed. In the interests of fairness and maintaining
a balance between urban and out-of-town developments we propose
that workplace parking charges be similarly exempted (paragraph
6.2 Limiting car parking space for new developments
to the "minimum necessary" is a very elastic clause
and may prove difficult for local authorities to decide upon.
Developers will be able to argue that it is necessary for parking
spaces to be provided for all the anticipated customers: they
may be allowed to get away with this as long as provision is also
made for public transport access. If the aim is to restrict to
parking spaces on new developments, then a more specific direction
should be given to local authorities.
7. OTHER MEASURES
7.1 In the interests of brevity we have not
commented in detail on the many other policies covered in the
White Paper, restricting ourselves instead to those areas which
most directly impact upon our business.
7.2 NCP would be delighted to expand upon these
views to the Select Committee if so required.
National Car Parks
25 September 1998
7 Chapter 3, p. 47. Back
Chapter 3, p. 59, "Local traffic Management: the potential"
Chapter 4, p. 118, para. 4.116. Back