Memorandum by National Car Parks Limited
(UWP 09)
THE PROPOSED URBAN WHITE PAPER
1. National Car Parks (NCP) is the UK's
leading private off-street car park operator, with 500 car parks
nationwide. We employ 2,400 people in 100 towns and cities across
the UK. The vitality of the urban environment is a key concern
for the company; we believe that despite—or perhaps because
of—the increasing prevalence of out-of-town sites, urban
centres have to be developed and enhanced.
2. The aim of this submission to the Committee
is to point out our disquiet at the fact that the Government's
aims and policies on urban regeneration, which we applaud, are
being undermined by its policies in other areas—notably
in transport policy.
3. The proposals contained in the Transport
Bill to introduce a workplace parking levy (WPPL) threaten to
help destroy the commercial and social vitality of the UK's urban
centres. The WPPL will impose costs on businesses which many will
find impossible fully to absorb. Consequently, customers, suppliers
and stakeholders of these businesses will be asked to pay higher
prices and may find that goods and services can be acquired more
cheaply at out-of-town sites which, it appears, will be outside
the scope of the levy. At a stroke, the whole of the Government's
agenda for urban renaissance, which NCP has hitherto strongly
endorsed, will be threatened by these new charges.
4. As a perceived solution to the problem
of traffic congestion, WPPL totally fails to tackle the effect
of through-town traffic, which is, of course, one of the prime
causes of congestion. For instance, London Chamber of Commerce
figures indicate that of the 1.5 million vehicles entering Central
London each day, only 2 per cent are travelling to a workplace
parking space. To state the obvious, imposition of WPPL would
not address 98 per cent of the problem!
5. Perhaps worse than that, the WPPL proposal
does not address the significant congestion and pollution caused
by on-street parking, both legal and illegal. Indeed, the impact
of WPPL may actually be to increase on-street parking as a proportion
of the total parking population, thus exacerbating the congestion
and pollution problems.
6. WPPL also impacts upon urban vitality
in that it will force car park operators to pass extra costs on
to its customers. It is now clear that the Government also wishes
to capture all private off-street car park operators within the
remit of the Bill because of concerns that, if left outside of
the ambit of the levy, they would derive a windfall gain through
increasing their charges in line with it. This assertion of windfall
gains is entirely refuted by NCP, given that:
(i) there is substantial unutilised capacity
in the off-street market;
(ii) private off-street operators have a
relatively small market share;
(iii) there is sufficient competition built
into the off-street market to make it commercially impossible
for operators to "hike" their prices.
7. WPPL will therefore act as a direct tax
on off-street car park operators, including local authorities,
and it is certain that this tax will have to be passed onto our
customers. Furthermore, on top of this new tax, there is also
the strong likelihood that WPPL will lead to massive extra costs
being borne by off-street car park operators, if they are to ensure
it is implemented correctly. The Bill states that a licence for
any off-street car park must specify the maximum number of motor
vehicles which may be parked at those premises at any one time.
For car park operators that offer workplace and shopping-related
car parking, this is entirely impracticable since the numbers
of occupied spaces fluctuates wildly during the day. A prediction
of demand is therefore required by the Bill in every segment of
parking customers (business, shoppers, leisure) which, unless
exactly accurate, will either result in the operators being levied
too heavily, or becoming liable for prosecution.
8. Quite apart from the extra charges that
will fall upon regular car park users as the WPPL tax is passed
onto them, WPPL is also potentially unfair in that it will be
payable by many workers who use car parks at non-peak hours when
public transport may not be available; for instance, nurses and
policemen. Customers parking at local authority car parks may
well be effectively paying three times for that privilege: through
the council tax, through which many authorities subsidise their
car parks; the economic rate reflected in the price; and the new
levy.
9. Despite Government claims to the contrary,
this is a direct attack on the motorist and an attack on the economic
sustainability of town centres.
10. NCP has fully supported the Government
in its aims to promote urban regeneration and to create an integrated
transport policy, within which the need for urban areas to increase
the attractiveness of non-car modes of travel is clear. NCP's
role within this framework is to mitigate the congestion effects
of those people who have to travel to city centres by car, by
means of providing off-street parking and allowing car traffic
to be effectively channelled to those sites. However, the WPPL
threatens to undermine some of the improvements already being
achieved by local authorities as it could well contribute to congestion
and will certainly reduce the attractiveness of the town centre
as a place to work and shop.
11. We wish these concerns to be placed
on record with the Committee and hope that, in conducting its
oral evidence sessions, it might ask other witnesses their views
on the apparent contradictions at the heart of urban policy.
January 2000
| 
