Memorandum submitted by National Car Parks
Limited
INTRODUCTION
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.
QUESTIONS
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.
Accountability
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.
Evaluation
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.
Measurement
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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