Memorandum submitted by Westminster City
I am pleased to provide Parliament's Transport
Committee with the City Council's response to your press release
dated 9 August 2005. Our reply deals with the points in the order
they appear in the press notice.
Are local authorities carrying out parking
control reasonably, fairly and accountably? How is performance
We can not answer for other local authorities,
although the City Council believes that we provide reasonable,
fair and accountable parking controls. Although it is difficult
to quantify these factors, especially as Westminster operates
probably what is the largest parking service in the UK.
Our performance is evaluated through correspondence,
regular area-based forms, annual parking surveys and consultation
exercises of varying scope. The City Council's Parking Service
has issued our parking charter which promises to provide the best
parking service in the UK, and also to provide firm, fair and
excellent enforcement and ancillary services.
What action would raise the standard of parking
enforcement activity? Is Statutory Guidance needed to promote
Regular review of the enforcement protocols,
such as conducted by the City Council. In the past year we have
revised our own protocols, to assist business servicing and to
stop strict enforcement of meter feeding.
The Association of London Government's recent
announcement to review the Code of Practice for Parking Enforcement,
could potentially have a large impact, as this document has not
been substantially reviewed since 1993.
Use of the British Parking Association's model
enforcement contract or similar (such as Westminster's) that do
not incentivise parking attendants to issue more penalty charge
notices (PCNs). Westminster's enforcement contractor is rewarded
for the quality of their PCN issue, ie the rate of cancelled PCNs,
the volume paid, upheld, unchallenged, etc, not the gross number
The retention of suitable enforcement staff
is another problem and there is a combination of low pay, poor
working conditions and public hostility (and even violence), that
undermine staff morale. The City Council has attempted to resolve
these problems by encouraging our contractor to offer improved
pay and working conditions and to incentivise staff with payments
for the quality of their work.
The City Council is actively embracing new technology
and plans to photograph all ticketable acts by April 2006. This
is part of our process of moving towards a fairer and more customer-focused
service by embracing new technology, utilising digital cameras,
mobile phone payment, and cashless parking.
The City Council is facilitating this process
with Vertex SW1, in our Transformation of Parking Services (TOPS)
programme. TOPS is introducing a new IT solution for our PCN processing
and this has also involved further system enhancements to allow
the City Council to transform it's end to end business processes
within Parking. The new solution and transformed business will
allow the City Council to operate more efficiently and in a more
The project has been running since April 2004
and has involved all side of the Parking service within Westminster
and it is hoped that we will be leaders in the provision of back
office processing and customer handling. The TOPS programme went
live in March 2005.
Is the appeals process fair and effective?
How could it be improved?
Generally speaking the City Council believes
that the appeals process is fair and effective, although it is
difficult for the parking enforcement authority to assess objectively
these qualities. Nevertheless, the City Council on occasion believes
that some adjudicators' decisions are perverse, and the process
to challenge these is cumbersome and time consuming. We would,
therefore, seek a greater consistency in the adjudicated decisions
in accordance with the law, and streamlining the appeal process
to allow local authorities to challenge perverse and poor adjudicator
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 decriminalised
parking enforcement has inappropriately influenced authorities
parking policy and enforcement activity?
Since the inception of decriminalised parking
enforcement in 1994, the City Council has supported the retention
of the parking revenue by the enforcing local authority, particularly
given the restrictions on the spending of any surplus.
There is no evidence that parking controls and
enforcement is inappropriately influenced by the desire to raise
revenue, and this has certainly never influenced the City Council.
In the past when considering the introduction of parking controls
we had consulted all residents and businesses in a given area
for their views. We would also conduct parking surveys to assess
the situation before an informed decision was taken.
In addition the City Council has recently taken
decisions on our enforcement policies that have led to a decrease
in revenue, but are seen to be fairer to the public. These include
the extension of observation times for loading/unloading vehicles,
in 2003, and in 2005 relaxation of the enforcement of meter feeding.
In June 2005 the Greater London Assembly's Transport
Committee produced the report "Parking Enforcement in London".
The Committee found no evidence in Greater London that parking
policies and enforcement were led by or influenced by the wish
to raise revenue. Of this report's 20 recommendations, of which
17 were down to the boroughs, the City Council either has already
implemented them or is in the process of doing so. Only recommendation
17 for a "London Delivery Disc" is not being considered
as we have already relaxed our enforcement of loading/unloading
vehicles. We believe that the proposed "disc" is unnecessary
and would be subject to fraud and misuse.
What criteria should be used to determine
the level of parking provision that should be provided?
For the City Council the main aim of parking
controls and enforcement are to:
To control and co-ordinate on-street and off-street
parking to reduce the overall level of parking, while maintaining
adequate availability of parking space for essential and priority
users. (Westminster's Unitary Development Plan, December 2004.)
The City Council has six main reasons for controlling
1. to support the overall objectives of traffic
restraint/reduction by helping to minimise the adverse social,
economic and environmental impacts of vehicular traffic;
2. to improve road safety;
3. to establish and maintain a fair system
which protects special needs where these exist, such as the needs
of residents, doctors, hospitals and people with disabilities;
4. to acknowledge the unsuitability of some
areas for parking, especially by heavy vehicles;
5. to reduce congestion for all road users,
particularly on A roads and busy bus routes; and
6. to promote development which supports
more sustainable travel choices and reduces the need to travel.
What are the wider impacts of current parking
policy and illegally parked vehicles?
Parking controls play an important part in the
Council's transport strategy by regulating the amount of traffic
within the City and encouraging the use of public transport. Parking
controls also assist by ensuring that local amenity is protected
by controlling the class of vehicle allowed to park. This is particularly
important in respect of coaches and goods vehicles. The Council
operates an on-street residents' parking schemeResparkwhich
allows bona fide residents to obtain permits allowing them to
park near their homes. We also operate a disabled parking permit
scheme for residents and some non-residents (employees, hospital
patients and students).
What role should parking policy play in traffic
management and demand management?
By discouraging car/vehicle commuting and other
unnecessary vehicle journeys in Westminster, parking controls
and enforcement are a valuable and effective traffic and demand
management tool. Parking controls are also useful in maintaining
traffic flow, preventing obstruction of the highway, keeping important
junctions clear of parked vehicles, ensuring the safe use of pedestrian
crossings, and aiding highway safety plans.
How can public understanding and acceptance
of the need for parking policy be achieved?
Through full consultation when major changes
are being considered, eg extended hours of control, new parking
controls, etc. In the past the City Council in 1994 and 2002 consulted
residents, business and visitors on a whole range of parking issues.
These exercises led to a number of new initiatives that had been
suggested through this process.
Ensure that the hours of parking control, the
on-street tariffs and the on-street regulations are regularly
reviewed to ensure that they meet the parking and loading demands
of each local area. It is also helpful to respond promptly to
correspondence and to establish local forums to listen to the
Education of the public and press (if possible)
of the benefits of parking controls, particularly in busy town
It is important that on-street the signs, lines,
and the regulations are straightforward and clear. It is also
important that the signs, lines and on-street equipment should
be fully maintained and replaced when necessary.
Utilise customer based initiatives to enhance
the reputation of the parking controls and their enforcement regime.
For instance the City Council has recently issued its Parking
Charter. The Charter pledges that the City Council's Parking Services
will be Firm, Fair and Excellent.