Memorandum by the RAC Foundation for Motoring
1. INTRODUCTION
The RAC Foundation for Motoring was set up in
1991 to conduct research and to campaign on issues of interest
and concern to responsible motorists.
In 2002, the Foundation published the report
(Motoring towards 2050) which looked at the prospects for car
ownership and use; ways of mitigating congestion and the environmental
effects of increased demand for travel. The Foundation complemented
this work with a report published in 2004 on "Parking in
Transport Policy." This report, which was produced with the
help of independent experts, including people from the parking
industry, local government, the University of Leeds, the Transport
Research Laboratory and others, looked at the broad issues raised
by parking policy including the conflict between needs for residential
parking and parking for access for other purposes; the provision
of off-street parking; the economics of parking, and the relationship
between parking policy and road pricing; and information to drivers.
The report is the basis for the Foundation's position on parking
policy. This is summarised very briefly in the following paragraphs:
the Committee's specific questions are addressed in section 3.
2. GENERAL
(a) Attitudes to parking
A survey conducted by NOP Automotive for the
report emphasises the growing car dependence in 21st century Britain,
with high levels of demand for low cost, or free, parking in the
vicinity of home, work, shopping and leisure facilities. Experience
of the difficulty or otherwise of parking near home varied with
the area concerned, but it is notable that 29% of respondents
indicated a willingness to move house and 24% a willingness to
leave or change job to avoid difficulties with parking: only 6%
would consider selling their car.
(b) Supply and Demand
The report notes a significant increase in demand,
reported in the National Travel Survey, for all forms of parking.
Perhaps the most significant factor is the sustained growth in
demand for parking associated with retail and leisure activities.
For increasing numbers of people lack of residential
parking is becoming an issue and the position is likely to worsen
significantly in the coming decades. Based on DfT statistics [Transport
Statistics GB] and the trend in growth of car ownership, the RAC
Foundation estimates that by 2,030 parking spaces for a further
12 million cars will be needed, nine million of them off street
and three million on street. The demand will, of course, be specific
to where people live.
Though on-street and off-street parking are
to a large extent substitutable, off-street parking is obviously
preferable as it avoids or reduces the danger (particularly to
children) and obstruction caused by parking on the street. The
Foundation considers that the Government's current guidance to
local planning authorities about the provision of off-street parking
spaces at residential developments is misguided. This guidance
(in PPG 3) lays down a maximum provision of 1½ spaces per
dwelling; and some local authorities have approved developments
with no off-street parking space at all. We think it most unlikely
that this would discourage people from owning cars: it will rather
increase pressure on street parking space.
(c) Economics
Work needs to be done to establish a sounder
basis for parking policy and charges. We suggest that the Department
for Transport should lead this. Parking restrictions, including
pricing are one of the major demand management tools in use in
UK cities and towns. The evidence suggests that most parking policies,
including enforcement, are a complex mix of aspirations including
demand restraint, provision of a revenue stream and environmental
targets, balanced by the fear of losing trade to competing commercial,
retail and leisure centres within an easy drive. Examples of this
are provided by the success of out of town shopping centres such
as the Bluewater, Metro and Trafford centres, often to the detriment
of established town and suburban centres within, say, a 20 mile
radius.
The importance of a soundly based policy dealing
with parking provision is clear, yet often there is a piecemeal
approach where parking and associated problems tend to be pushed
from urban centres to out-of town centres often poorly served
by public transport.
The Foundation feels that the present combination
of free workplace parking, mixed public and private ownership
of off street parking, multiple objectives on pricing and disparate
enforcement regimes do not constitute a coherent approach either
to sustaining the economic and social base of urban centres or
to the management of traffic demand. Road user charging would
be a more appropriate means of managing demand, but where it is
introduced, a radical review must be undertaken of the role of
city and urban centre parking. This has not yet been undertaken
in central London.
The condition of the off street parking infrastructure
is an important factor. Much of it needs, or will soon need refurbishment
or replacement. It is our understanding that many local authorities
have made no financial provision from parking revenue for this
essential work. The environment of off-street car parks is often
unattractive and sometimes threatening. At a time when other transport
facilities such as railway stations are being improved, car parks
should not be neglected.
Information for the Motorist
It is often very difficult for the motorist
to know where he or she can legally park. The signs governing
street parking are often sited some way from the street in question;
and the wording is often legalistic and unhelpful. In very few
cities is there a coherent policy about signs to off-street car
parks, and even fewer make any attempt to tell motorists whether
the car parks have any space or what are the regulations governing
parking on a particular street.
Technological developments are taking place
in some areas, for example, signs in central Nottingham indicate
the availability of parking spaces in the city centre car parks.
A number of authorities are testing different systems of payment,
including mobile phone and credit cards. Developments in mobile
phone, CCTV and microwave technology could simplify the process
of finding and perhaps booking a parking space, thereby introducing
a welcome element of predictability into what is presently an
uncertain and often frustrating process. Such developments will
necessitate a comprehensive policy; technical standards and wholehearted
commitment and area wide cooperation among separate, competing
service providers.
(d) Conclusions
The Foundation's conclusions are as follows
— Parking policy should be an integral
part of transport policy and should be used to make a positive
contribution, for example, by facilitating the operation of multi-modal
transport interchanges.
— The consumer should pay for what
he gets and get what he pays for, including adequate parking provision
and adequate information where restrictions are necessary.
— Parking policy and planning should
take account of likely future trends including road pricing, especially
in urban areas.
— There is a need for clear guidance
from central Government to local authorities on a range of parking
issues.
— It should be an objective that a
motorist, before setting out on his or her journey, should be
able to find out whether he or she is likely to be able to park
and, if so, where; and should be able to refine that information
as he or she approaches the destination. This would save wasted
mileage and aborted journeys.
3. RESPONSES
TO QUESTIONS
RAISED BY
THE TRANSPORT
COMMITTEE ON
THE CURRENT
EFFECTIVENESS OF
PARKING PROVISION
AND ENFORCEMENT
POLICY
(a) Quality of local authority performance
The RAC Foundation believes that local authority
performance in carrying out parking management and control, fairness,
accountability etc varies widely. The better performing authorities
such as Manchester, have introduced enforcement policies and practices
based upon compliance, reasonableness and proportionality, albeit
that in so doing they have significantly reduced enforcement revenue.
At the other end of the scale are local authorities whose parking
policy and enforcement regimes appear to be governed by ease of
operation and revenue generation. Indeed it appears that many
local authorities see revenue generation and not compliance as
the key enforcement performance indicator.
The question emphasises the absence of an objective
means of comparing performance of different local authorities.
A recent study undertaken by the University of Birmingham and
funded by National Car Parks dealt with the question of quality
of performance and developed a matrix within which the performance
across a wide range of parking policies and enforcement practices
of widely differing local authorities could be objectively compared.
(b) Raising the standard of parking enforcement
The RAC Foundation considers that central Government
has an important role in providing statutory guidance and disseminating
best practice to local authorities throughout the country.
Recent reports by Birmingham University and
the British Parking Association provide a valuable source upon
which Government could draw in providing effective guidance.
(c) The appeals process
The RAC Foundation considers that the appeals
process administered by the Parking Adjudication Services [NPAS
and LPATAS] is fair and effective. The majority of those who appeal
to NPAS and LPATAS are satisfied with the manner in which their
appeal is handled and heard, whether they win or lose.
The appeals process lies at the end of a process
administered by local authorities and their contractors and the
experience of all who have been through the process is that it
is bureaucratic, rigid and discouraging to users. For example,
the high percentage of appeals allowed by the parking adjudication
services and especially uncontested appeals, clearly suggests
either that local authorities deliberately refuse challenges to
penalties in the hope that motorists will eventually pay, or that
such representations are dealt with by contractors whose performance
falls short of that envisaged when the legislation was drafted.
The representation process by which penalty
charge notices can be challenged with the issuing local authority,
was clearly seen as an important safeguard and the 1991 Act granted
wide discretion to local authorities to cancel a PCN or discontinue
the process. The number of successful appeals and recent reports
suggest that this essential element of the process is not working
as effectively as it should. The RAC Foundation recommends central
Government intervention to research and monitor this aspect of
the appeals process.
A particular unfairness in the present system
is that motorists who appeal to the local authority against the
issue of a penalty in many cases usually lose the discount of
50% which is offered to encourage payment within 14 days. The
Foundation believes that appellants should be entitled to discounted
rates even if they are unsuccessful at appeal, in order not to
deter legitimate appeals.
(d) Revenue
Local authority income from parking was £939
million in 2003-04; the surplus was £350 million. The RAC
Foundation has no objection in principle to local authorities
keeping the revenue from penalty charges issued within a decriminalised
parking enforcement [DPE] regime. We recognise that such enforcement
must be self-financing if it is not to become a further burden
on local tax-payers. We consider that the surplus should be applied
in the first instance to providing, maintaining and upgrading
local authority car parks, for which adequate provision has not
been made. Anything left should go to roads or other forms of
transport.
DPE generates a great deal of emotion. Motorists
tend to assume that the purpose of enforcement is the generation
of revenue, whereas local politicians and officers assert the
legal and social benefits of enforcement. In practice DPE allows
much more effective enforcement of parking, waiting and loading
regulations than the police service can deliver and raises a great
deal of revenue for local government. The Foundation has, however,
two main concerns:
(i) that the charges have no economic rationale.
Originally, charges were to be set at a level that would ensure
sufficient turnover of parking for people needing access to premises
to be reasonably sure of getting it. An alternative would be to
set them at a level that reflected the cost of provision. But
in many authorities the objective seems to be to set charges at
the maximum that the market will bear.
(ii) local authority parking managers are
routinely asked to predict how much DPE operations will cost during
the coming financial year and how much revenue they will generate.
Though this is a routine procedure in local authority departments,
it necessarily puts pressure on parking managers to deliver the
revenue projections. Furthermore many local authority parking
enforcement contracts incorporate some form of target for PCN
issue and a penalty for failing to issue sufficient PCNs. Whilst
the local authority may or may not consider PCN numbers and revenue
to be the most important aspect of the contract, it is likely
that the contractor will and this pressure will be extended to
Parking Attendants employed by the contractor. Both Manchester
and the City of Westminster, two of the largest enforcement authorities
in the UK, say that they have identified the issue and introduced
measures to reduce the likelihood of inappropriate ticket issue,
albeit that their respective approaches are radically different.
(e) Criteria determining the level of parking
provision
The Foundation believes that parking provision
should take account of residential, commercial, retail and leisure
demand within an area and specifically their location and the
adequacy and quality of public transport links. Widespread complaints
from all sectors suggest that current policies are increasingly
failing to meet justified expectations for parking provision.
We believe that parking policy and planning
must also take account of likely future trends, including increased
car ownership and demand for personal mobility as well as the
likely introduction of road pricing and its potential to reduce
traffic demand.
(f) What is the wider impact of current parking
policy and illegally parked vehicles?
We consider that current parking policies lack
coherence and do not make the contribution that they could and
should do to transport policy. If nothing is done to improve the
present state of public parking provision the prospect for the
future is that many more cars will spend longer and longer driving
around looking for somewhere to park; conflicts between residents'
and commercial needs will be sharpened; and local authorities
will feel driven to take stronger and more punitive enforcement
measures.
(g) How can public understanding and acceptance
of the need for parking policy be achieved?
The RAC Foundation believes that more can and
should be done to explain the purpose of parking policy and enforcement.
The communications process requires a commitment
by local authorities to fairness and openness in the development
of parking and transport policies, charges and enforcement, including
a willingness to provide sufficient parking spaces to meet reasonable
demand. Issues such as the provision of parking at transport interchanges
should be openly addressed.
The best way to improve public understanding
and acceptance of the need for a parking policy is for local authorities
to have clear concise objectives based on the need to keep traffic
flowing and clear concise signs explaining parking restrictions
to the public.
The present institutions may not be the best
that could be devised to collect and disseminate the information
that people need. It may be desirable to set up partnerships,
comprising local authorities, parking operators and public transport
operators charged with this task and using the most up-to-date
technology.
RAC Foundation
September 2005
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