Select Committee on Transport Minutes of Evidence

Memorandum submitted by National Car Parks Limited


  NCP is the leading provider of parking enforcement services in the UK, supplying around 3,000 parking attendants to more than 30 local authorities.

  The company is also the biggest commercial car parks provider, with more than 600 off street sites around the country, and 75 years' experience in the planning, design, building and management of car parks.

  Parking is one of the least scrutinised activities undertaken by local authorities, yet one which generates great external attention. This imbalance is at the heart of the challenge that enforcement activity faces.

  The external attention is often media driven and appears to cover a wide range of issues, but generally at the heart of any issue are the local authorities' parking policies. These are complex and poorly understood, because they seek to balance many competing needs for the scarce resource of parking spaces, eg local residents, businesses, road users, emergency vehicles and many others.

  NCP moved into the parking enforcement market five years ago. In a short period we have become the industry leader. This has been achieved because NCP has brought a new focus on quality to delivery of the service through improvements to training, customer service and strict adherence to quality-based key performance indicators.

  As an operator we focus on two core strategies—firstly to achieve a stable and experienced workforce—which we seek to achieve through detailed training, proper remuneration and a well-defined career structure—and secondly an effective stakeholder strategy to ensure all those affected by a parking enforcement operation understand what it is tasked to achieve. The stakeholder strategy is essential, because parking enforcement is a complex operation seeking to balance conflicting demands, which are often poorly understood by stakeholders.

  We understand that as the industry leader we have a role to play in moving the industry forward. A recent initiative we have been involved in to raise awareness of best practice and to improve the quality of the parking enforcement industry was to sponsor a report by the University of Birmingham's School of Public Policy.

  This research resulted in an assessment model—compiled to Audit Commission standards—to enable Local Authorities to monitor the success of their parking enforcement operations based entirely on quality criteria. Although NCP sponsored the report, we had no control over its contents, and it is our hope that it becomes adopted as the industry standard.

  We feel that the Transport Committee could help achieve this by recommending that local authorities adopt a quality measurement system.

  The University of Birmingham research sits alongside and complements the review commissioned by the British Parking Association (BPA) and conducted by Richard Childs. A key theme of the BPA review findings is the need for greater transparency in the service. The University of Birmingham Quality Assessment model is effectively the tool which will enable this.

  NCP is a member of the BPA—our chief executive Bob Macnaughton sat on the steering group for the Richard Childs report—and strongly supports its work in this area, especially its work on encouraging:

    —  Greater transparency and reporting of performance in parking enforcement regimes.

    —  The need for more detailed statutory guidance to enhance the requirements of the local authorities in the management of its parking policies.

    —  More stakeholder engagement, particularly public opinion surveys.

    —  More active management of policies, including an obligation to regularly review policies and ensure consultation.

    —  Defining more clearly certain behaviours, eg the way Local Authorities deal with representations from members of the public.

  Our submission gives our views on each of the questions posed and is summarised as follows.

    —  The University of Birmingham's School of Public Policy report—Local Authority Parking Enforcement; Defining Quality—Raising Standards—is compiled to Audit Commission standards to provide a template for a future national standard for parking operations.

    —  Regular, detailed public surveys and effective stakeholder strategies demonstrate public support for fair and reasonable parking operations.

    —  Quality based Key Performance Indictors are the best way of measuring effectiveness.

    —  On street parking provision should be priced to encourage people to park off street.

    —  There is a gap between public perception and reality in parking enforcement, which could be bridged by greater openness and accountability by some local authorities and a greater emphasis on quality-based Key Performance Indicators.


1.  Are local authorities carrying out parking control reasonably, fairly and accountably? How is performance evaluated?

  NCP has experience of delivering parking control services to more than 30 local authorities. Our role is to deliver the policy of the local authority client exactly as that policy is drafted.

  Every local authority seeks to deliver fair and reasonable parking controls, often adopting a "firm but fair" approach. In practice this is a difficult matter, which requires the local authority to bring its judgement to bear in managing complex and changeable traffic conditions. These must be constantly reviewed and policies must evolve to reflect changing conditions. For example, over the past two years, our clients Westminster City Council and Manchester City Council have made significant changes in policy to reflect the changing needs of their stakeholders, demonstrating that active management of policies are the key to successful delivery. The external perception of the parking regimes has been changed as a result of the new policies.


  Among the best practice examples for evaluating performance in our experience are public surveys such as those carried out by our clients Durham City Council and Bury Metropolitan Borough Council.

  These opinion polls receive extremely positive feedback which we believe shows that where parking control is carried out fairly and reasonably the public opinion of the service is very high. Polls such as these are very effective in demonstrating accountability.

  Local authorities are, of course, accountable to their electorates, and also face detailed scrutiny through media coverage. There are many examples, however, of press coverage which has distorted the nature of parking enforcement, either through inaccuracy or selective use of facts.


  In our experience a parking enforcement service is regarded as fair and reasonable when the contractor is assessed on quality-based Key Performance Indicators. We would always expect to be assessed on KPIs such as deployment levels of staff, customer service standards, accuracy of penalty charge notices issued, appearance, behavioural competencies and processes to reduce staff turnover.

Fair and reasonable

  A reasonable, fair and accountable parking control operation should also have a back office processing system assessed on KPIs such as response times to representations, customer complaints, disabled access in parking shops, and use of technology, in accordance with e-government guidelines, to enable customer interface via the internet.

  A back office processing operation which meets these KPIs would also be the appropriate point in the parking control operation to exercise discretion. It is our view that Parking Attendants should not be asked to exercise discretion, since to do so would make an already complex job more difficult, and place the PA under the risk of threats or bribes.

  Where there are reasonable extenuating circumstances surrounding the issue of Penalty Charge Notices, a properly-run back office operation should be able to take these into account when representations are made.


  Parking controls affect the whole community. Poor enforcement:

    —  contributes to congestion by allowing inconsiderate parking to restrict traffic flow;

    —  decreases road safety by allowing parking where it restricts the vision of pedestrians and motorists;

    —  reduces the quality of life for residents who are unable to use spaces allocated to them; and

    —  deters shoppers who find it difficult to park for short shopping trips.

  Any measure of quality of policy and enforcement must take all these factors into account and seek to balance the interests of the various sections of the community. The University of Birmingham proposals for measuring quality in parking enforcement are particularly relevant in this regard and we commend the report to the Committee. A copy of their report has been sent separately to the Committee.

2.  What action would raise the standard of parking enforcement activity? Is Statutory Guidance needed to promote consistency?

  There should be clear guidelines published at national level with measurable, quality-based Key Performance Indicators. These guidelines should make it clear to the public what parking enforcement is designed to achieve, who is responsible for the rules and regulations, and the standards they must achieve in enforcing those regulations.

  If the recommendations of the Birmingham team were to be put into effect, Local Authority members would be able to assess the effectiveness and fairness of their enforcement activity and benchmark it against other similar councils.

  The research was run by a steering group chaired by Robert Buchanan, Audit Commission Performance Specialist. The resultant report proposed a Quality Assessment System which followed Audit Commission standards in assessing local authority activities.

  We support the principal of national guidelines to promote consistency in the quality measurement—although we remain firmly of the view that these guidelines could not be extended to encompass a standardisation of parking regulations across the UK. It is our view that local authorities remain in the best position to assess the pressures on their local roads and design appropriate traffic management orders and the enforcement operations accordingly.

  It is also important that highways authorities responsible for maintaining road signs and lines do this to a high standard. Signage should be clear and well maintained so that motorists do not park unlawfully through confusion—and it is also worth noting that parking attendants' jobs are made more difficult by unclear or poorly maintained signs and lines.

  There should be proper, clear auditing of signs and lines, regularly reviewed, to an agreed national standard, as detailed in the Birmingham report.

  The Statutory guidelines could help ensure best practice, for example:

    —  Prohibiting the provision of incentives for contractors/attendants linked to PCN numbers.

    —  Creating an obligation on local authorities to publish detailed performance data.

    —  Creating an obligation to review all TRO/TRAs (the enforcement regime) on a regular basis, including consultation.

3.  Is the appeals process fair and effective? How could it be improved?

  In our opinion the appeals process is very fair and effective.

  In our view there is room for improvement in increasing the understanding of the appeals service with drivers. This also includes improving awareness of how drivers can make representations prior to the formal appeals process.

  Currently there is no accepted national standard for training of back office personnel, with the result that there can be inconsistencies in the way penalty charge notices are processed, and in the way the first stage of an appeal is handled.

  This is clearly reflected in the wide variation in the numbers of appeals and the success rates at appeal by local authority. Statutory guidance could be used to more clearly specify how representations and appeals should be dealt with. Also by publishing more information on local authority performance in dealing with representations and appeals it will deliver more visibility on quality of performance. As a general comment, the relationship between local authorities and the appeals service is often one of conflict rather than feedback and improvement.

4.  Is it appropriate that local authorities should keep the revenue generated from parking fines? Is there any evidence that the opportunity to raise revenue through decriminalized parking enforcement has inappropriately influenced authorities' parking policy and enforcement activity?

  We believe that Local Authorities should be discouraged from relying on Parking Penalty income as "budgeted income", but rather recognise that this income stream is entirely dependent on the behaviour of motorists and therefore is not a figure that can be increased at will. Indeed, there is much evidence to suggest that successful enforcement regimes result in a downturn in illegal parking, and by extension, a downturn in revenue from Penalty Charge Notices.

  We are also of the view that any surplus monies from the enforcement service should be directed towards improving parking arrangements in the first place—such as residents' parking schemes and Park and Ride and then in improving Public Transport services. There is evidence that the public are more willing to accept charges where they see the revenue directed at improvements that they appreciate. In this regard we do not believe that the relaxing of the hypothecation rules in the Traffic Management Act is helpful.

  We do believe that local authorities should be encouraged—possibly by statutory guidance—to exercise greater transparency in the way in which parking revenue is allocated, both receipts and expenditure.

  Public concern over how parking revenue—especially that from fines—is collected is at the heart of the debate about how parking enforcement should be carried out. There is little doubt that the public's perception of parking enforcement in some areas is simply as a revenue gathering exercise, highlighting a gap between public perception and reality. It is our view that greater openness on behalf of some local authorities would significantly change the public perception for the better.

  Greater visibility should include measurement by quality-based KPIs and publication of that performance data.

  We also believe that national quality standards should be introduced for all local authorities, and that the Committee should consider a system whereby only those authorities who achieve those quality standards are able to keep any surplus accruing from parking fines. We believe this could incentivise Local Authorities to improve quality and significantly improve the public's perception of the nature of a parking enforcement service.

5.  What criteria should be used to determine the level of parking provision that should be provided?

  It is our view that the level of parking provision allowed in most local planning authorities' policies does not adequately address the needs of the motorist. Criteria to ensure there is an adequate supply of parking should take into account traffic numbers, traffic flow, and projected traffic growth.

  It is important when drafting Local Transport Plans to ensure consistency among boroughs, and at the moment it is our view that this is lacking in some areas. Some local authorities' policies actively discourage additional parking provisions while others do not.

  We believe that local authorities' should be encouraged to view parking provision as an essential part of an integrated transport strategy, not an alternative.

  Parking provision has an impact on the health of the local economy and on the quality of life of the inhabitants. Adequate parking is required for shoppers and businesses and residents wish to park their cars in close proximity to their homes. Inadequate parking provision can result in traffic circulating whilst looking for a parking space, greatly increasing congestion and urban pollution.

  Since there are many conflicting interests, a balance should be sought which, if not satisfying all interests provides the best balance possible. In this regard the Quality Assessment system proposed by Birmingham University's School of Public Policy is extremely helpful.

  The balance between On-Street and Off-Street parking is also important, as is the relative pricing. Where there is on-street provision it is often free or less expensive than off-street and therefore preferred. This policy results in needless congestion, with motorists circulating to find a space on-street. In many towns where there is a perceived parking problem, car parks are operating below capacity. On-street charges should be introduced or adjusted to ensure existing car park capacity is fully utilised.

6.  What are the wider impacts of current parking policy and illegally parked vehicles?

  The impact of an ill-thought out or poorly enforced policy is:

    —  Unnecessary congestion caused by motorists circulating whilst looking for an on-street space.

    —  Unnecessary congestion caused by motorists parked illegally on yellow lines constricting traffic flow.

    —  Increased risk of road accidents caused by illegally parked vehicles.

    —  Reduced prosperity through a decline in shopping trade, businesses relocating to out-of town sites and a decline in town centre house prices through lack of residential parking provision.

7.  What role should parking policy play in traffic management and demand management?

  Every car journey ends with a parking act. Parking policy should support the traffic management and demand management policies by providing the necessary parking capacity and no more. Specifically, parking policy should support the preferred type of parker at different times of day and days of the week.

  Pricing policy should be designed to make off-street parking the preferred choice, leaving street parking for very short term parking and residents. Where on-street parking is inadequate, consideration should be given to parking residents' cars in off-street car parks as is the case in a number of other European countries.

8.  How can public understanding and acceptance of the need for parking policy be achieved?

  The onus is on private contractors to ensure that they have a stable and experienced workforce and the highest standards of training, with particular emphasis on communication and customer service skills, to ensure that parking attendants—the most visible face of a parking service, and the people most likely to interact with the public—are able to explain parking regulations effectively, and demonstrate professionalism and diligence to ensure that the service is perceived to be well-run.

  An effective stakeholder strategy is also important, and local authorities should also be encouraged to be proactive in explaining their policies to residents and stakeholder groups. It is clear that there is, in many areas, a lack of public understanding regarding parking policy. For example, there is often a perception that effective parking enforcement harms local businesses such as shops and restaurants. Local authorities should be encouraged to explain to stakeholders such as local chambers of commerce the benefits of effective enforcement—which can encourage more trade into town and city centres by keeping the streets clear and the traffic flowing.

  As we have mentioned elsewhere, there is often a noticeable gap between public perception and reality of the benefits effective parking policy can ring to communities. Local authorities could bridge that gap with greater visibility of parking revenue income and expenditure, clearer publication of rules, regulations and expected standards of service, and a greater emphasis on quality criteria such as those proposed in the University of Birmingham report.

  It may also be appropriate for the driving test to include some content requiring learner drivers to demonstrate an understanding of parking policy.

September 2005

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