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
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
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
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;
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
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
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
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
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
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
For further information contact: Daniel Isichei,
The Institution of Highways & Transportation, 6 Endsleigh
Street, London WC1H 0DZ, 020 7391 9961 Daniel.Isichei@iht.org
29 September 2005