Select Committee on Transport Minutes of Evidence

Memorandum submitted by the Institution of Highways & Transportation

  1.  The Institution of Highways & Transportation (IHT) is grateful for the opportunity to submit a memorandum to the Transport Committee.

  2.  The Institution welcomes the Transport Committee's inquiry into the current effectiveness of parking provision and enforcement parking. This memorandum expresses our concerns regarding the challenges that have to be met in developing policy and in seeking to manage a range of objectives (some of which conflict with each other) and setting them in a context which is appropriate and deliverable for a local community. We also have concerns about poor practice and inconsistent application of polices particularly between competing centres.

  3.  Parking is a key element of Transport strategy but is all too often seen as a financial issue rather than for its contribution to the environment, economy and safety of a community. Parking policy covers not only parking as an activity in the overall process of travel, but also the infrastructure for the "storage" of vehicles. Parking policy and provision must provide for cars, lorry, cycle, motorcycle, coach, bus users. It is also associated with business, leisure, education and commercial activity.

  4.  The Committee has raised a number of questions it wishes to examine. The following are the Institution of Highways & Transportation's specific responses.

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

  5.  The Institution believes that local authorities seek to carry out parking control in a reasonable, fair and accountable manner. Often policies and proposals, while welcomed by some, will be unpopular with others. Clear guidance on good practice in setting policy will help. Problems often occur due to unclear and inconsistent practice and where adjacent authorities operate different strategies. This can be particularly confusing for visitors.

  6.  The Institution has no information on performance evaluation. However we have concerns that public perceptions of performance are significantly influenced by the high profile given by the media to reportedly unsatisfactory practice that is presented as being the norm when it is usually the exception.

  7.  The Institution does not condone bad practice or irregular parking enforcement activity and welcomes industry initiatives that seek to reduce and eliminate such practice. The introduction of performance evaluation would have to be based on clear uniform guidance and, importantly, not require significant diversion of resource.

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

  8.  The Institution believes that several actions can raise and maintain standards of enforcement activity:

    —  on-street enforcement personnel are in the front line and it is imperative that they are well trained and customer focussed. The Institution welcomes industry initiatives such the licensing of individuals working as vehicle immobilisers with the Security Industry Authority and the British Parking Association Parking Industry Training Qualifications;

    —  it is essential that a parking scheme and associated signing is clear if it is to be effectively and fairly enforced. It is therefore essential that local authorities have well trained staff and designers familiar with good practice. It is also essential that good quality guidance is available to practitioners;

    —  it is also incumbent on local authorities to ensure that the parking and waiting restrictions are appropriate as many will have been put in place up to 40 years ago and may no longer be relevant to current community and traffic needs; and

    —  the Institution welcomes the BPA initiative to introduce a Model Contract for Parking Enforcement. Developed with input from experts from local authorities, enforcement companies and consultants, this document can provide a uniform base for all authorities involved in the civil enforcement of parking.

  9.  The Institution believes that Statutory Guidance must be sufficiently flexible to deal with different situations (Central London Boroughs have totally different problems to those of local authorities in the West Country). The industry needs to be consulted closely on any guidelines to ensure they are appropriate.

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

  10.  The Institution supports the principle of independent adjudication on appeals against penalty charges and commends the work of the National Parking Adjudication Service for England and Wales, the Scottish Parking Appeals Service, the Traffic and Parking Appeals Service in London and the proposal for independent adjudication in Northern Ireland. It is essential that the services liaise with each other and experiences are exchanged.

  11.  There may be benefits in providing a more uniform system if there was only one service. We recognise that this would be difficult to achieve as the legislative basis for enforcement varies between jurisdictions.

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?

  12.  We believe that local authorities should retain revenue generated from both parking tariffs and parking charges. Parking is a service and the enforcement of parking and waiting restrictions is carried out to support local economies, to reduce traffic delays and to improve road safety. It is therefore fair, on the principle of "the polluter pays", that offenders should bear the cost and that the resultant revenue should be reinvested to the benefit of the disadvantaged community.

  13.  The Traffic Management Act 2004 provides for revenue to be used for environmental purposes. While we welcome this in terms of providing commitment to the public realm we believe this may be too broad a remit and that reinvestment of any surplus of revenue over cost should be prioritised to the support of transport related infrastructure and services over other environmental initiatives.

  14.  The Institution does not have access to any evidence to suggest that local authorities' parking policy and enforcement activity is influenced by the opportunity to raise revenue through decriminalized parking enforcement.

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

  15.  Parking is a complex issue and it is not possible to define a formula on the basis of "one size fits all". The Institution finds it is regrettable that local transport authorities are no longer required to prepare parking strategies as part of their Local Transport Plan and would encourage all authorities to prepare a strategy that meets the following criteria:

    —  consistent with national and regional guidance and objectives;

    —  reflects and contributes to the vision of the area;

    —  well rooted in relevant local policies and contributes to wider community objectives, both transport and non-transport related;

    —  responds to local issues and public concerns with clear objectives;

    —  takes account and complements related strategies such as economic regeneration, crime prevention, streetscape enhancement, etc;

    —  consistent and technically robust;

    —  based upon sound consultation and wide stakeholder involvement;

    —  has strong political and local support;

    —  has a realistic implementation timetable;

    —  includes a business plan that enables parking costs to be covered by revenues; and

    —  includes a framework to monitor performance and achievement.

  16.  As noted previously, parking policy and provision must provide for a range of users and uses throughout the day. While the focus of parking schemes is mainly on cars, appropriate provision is required for deliveries and servicing of local businesses. The Institution considers that more should be done to provide appropriate facilities for drivers to take the mandatory breaks required by the Working Hours Directive. Such facilities must provide not only suitably sized parking bays but also for driver refreshment and vehicle security, and be convenient to the strategic road network.

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

  17.  Most private vehicles are driven for only a small proportion of their life; the rest of the time they are parked. Parking takes up a lot of land and costs money to provide and maintain. Parking affects us all, whether we are looking for somewhere to park, or coping with the impact of other people's parked vehicles. A survey of British households found that parking was the single most frequent cause of disputes between neighbours. Effective parking management is also very important to the economic, environmental and social well being of communities.

  18.  Taken in isolation individual acts of non-compliance usually have little measurable effect. However, when non-compliance becomes the norm, the result is adverse impact on road safety, on accessibility, on the local environment and on the economy while the financial and policy base for providing off-street parking can be undermined. Public transport users and the elderly and disabled are among those that are disadvantaged by inconsiderate and "illegal" parking.

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

  19.  Local parking policy/strategy is a key element of effective traffic management and should be developed within a framework of national and regional guidance and objectives. The Institution believes that demand management will become an increasingly essential tool for urban transport planners and this needs Government support. Pricing mechanisms such as parking management and tariffs with appropriate enforcement will have a primary role together with congestion charging and workplace parking charges.

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

  20.  The Institution believes that the public are entitled to clear guidance on how local parking strategies are devised and how they will be enforced. Clarity and consistency of signing contributes to public confidence. Clear guidance for designers is essential. The Traffic Signs Regulations and General Directions 2002 (TSRGD) specify the purpose for which signs are to be used. The resultant signs are often overly complex and any review of the TSRGD should address this problem.

  21.  Comprehensive public consultation during the development of parking proposals provides a way of ensuring that parking interventions meet the council's objectives and respond to people's concerns and are not just a way of keeping the council out of trouble with the courts. Clear objectives for the strategy/policy must be defined.

  22.  Public confidence in enforcement will be raised if all parking attendants are trained to an appropriate standard and are seen to operate within an operational framework that is transparent and accountable.

  23. Although expensive it is worthwhile to undertake a public awareness campaign to ensure that the objectives of any parking initiative are understood. Some of the more successful decriminalised parking enforcement schemes have been supported by good PR.

  24.  The Institution has recently published good practice guidance entitled "Parking Strategies & Management" drawing on a wide base of industry experience. We are will positioned in the industry to be able to offer our expertise and network to the future development of guidance and policy on parking.


  25.  The Institution of Highways & Transportation was founded in 1930 and this year celebrates 75 years as a learned Institution with professional connections worldwide. It is a learned society concerned specifically with the planning, design, construction, maintenance and operation of land based transport systems and infrastructure. It serves the transport profession for the benefit of society and members. With over 10,000 members, and continuing to grow, it works across a wide range of disciplines including design, construction, maintenance and operation of transport systems and infrastructure across all transport modes in both the public and private sectors. It aims to promote the exchange of knowledge, improve policy formulation, stimulate debate on transportation issues, recognise individual competence and encourage best practice in the industry. The IHT promotes excellence in transport systems and infrastructure.

  For further information contact: Daniel Isichei, The Institution of Highways & Transportation, 6 Endsleigh Street, London WC1H 0DZ, 020 7391 9961

29 September 2005

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