Supplementary memorandum submitted by
the Department for Transport
ADDITIONAL QUESTIONS FROM THE COMMITTEE
1. Has the Department measured the cost of
illegal parking to the economy and the impact on local economies
in particular? What has analysis shown?
It would only be possible to estimate this meaningfully
if there was accurate information on the number of parking contraventions
and the impact they had on traffic flow and the road traffic casualties
that could be directly attributed to them. In England and Wales
in 2003 the police service issued 1,043,000 fixed penalty notices
(FPNs) for obstruction, waiting and parking and local authorities
issued 7,123,000 penalty charge notices (PCNs) for waiting and
parking. No further action was taken on some 396,000 of the PCNs
issued and a further 32,000 were allowed on appeal, so somewhere
in the region of 7,700,000 parking contraventions were detected
in 2003. It is likely that the actual number of contraventions
was in excess of this figure. However, there is no information
about their impact on traffic flow or road traffic casualties.
It might be feasible to do this at the local
level but we are not aware of any such analysis.
2. What action, if any, does the Department
take when it becomes aware that a local authority which operates
decriminalised parking enforcement has Traffic Regulation Orders
that are not fully compliant?
Traffic Regulation Orders (Traffic Management
Orders in London) are made under the Road Traffic Regulation Act
1984. A traffic regulation order is required to introduce restrictions
such as banned turns, bus lanes, pedestrianisation and parking
controls. The legislation does not provide for the Secretary of
State to be involved at any stage in the process of publishing
and subsequently making an order on a local road unless it involves
a trunk road. The Secretary of State has only limited reserve
powers to intervene in the way local authorities exercise their
traffic regulation functions and these powers have rarely been
invoked. The process is the responsibility of the local authority
and it is for them to ensure the traffic regulation orders required
for parking enforcement are fully compliant.
There is, however, a strong incentive for a
local authority to ensure that its traffic regulation orders are
fully compliant because an order might prove to be unenforceable
if it were shown, for example on an appeal to a parking adjudicator,
to be legally defective in a material respect.
3. Whose responsibility is it to check that
local authorities are meeting the requirement to have correct
and up-to-date Traffic Regulation Orders? What role does the Department
for Transport have?
Departmental guidance (Circular 1/95) advises
local authorities to undertake a thorough review of their parking
policies and the way that those policies are implemented before
applying for decriminalised enforcement powers. This includes
the traffic regulation orders to implement those parking policies.
If a local authority has already formulated its parking policies,
the guidance advises a review before applying for decriminalised
enforcement powers.
Circular 1/95 goes on to say in paragraph 11.20
that after the introduction of decriminalised parking enforcement,
local authority officers will still be responsible for reviewing
the effectiveness of their authority's parking policies as a whole
and making recommendations for improvements to members. This advice
was reiterated by the Department in November 2004 when it issued
to local authorities the Network Management Duty Guidance
covering their responsibilities under Part 2 of the Traffic Management
Act 2004. Page 21 of Annex A—the good practice guide—sets
out the steps that authorities should take to manage parking and
other traffic regulation. It is the responsibility of the local
authority, accountable through councillors to their electorate,
to ensure that this is done. Legislation does not provide for
the Department for Transport to have a role in this.
4. How successful have the parking capacity
guidelines in PPG 13 and PPG 3 been, and are any changes planned?
PPG13 (March 2001) Transport Annex D
sets out parking standards for specific non residential land uses.
PPG3 (March 2000) Housing advises that car parking standards
that result, on average, in developments with more than 1.5 off
street parking spaces per dwelling are unlikely to reflect the
Government's emphasis on achieving sustainable residential environments.
This does not mean all dwellings should have 1.5 parking spaces
but that the local authority-wide average provision should be
1.5 car parking spaces, with the actual level of car parking depending
upon on the type of housing and its location. Both PPGs emphasise
that standards should be expressed as maximum rather than minimum
standards.
No evaluation of PPG13 policies has yet been
done, and there are no plans at present to revise it.
The PPG3 Implementation study "Delivering
Planning Policy for Housing" (July 2003) identified the
following concerns regarding PPG3's approach to car parking:
— it was thought to be targeting car
ownership, rather than car usage;
— it was thought to result in on-street
parking and `fly' parking, which was unattractive (conflicting
with the policy objective of good design) and which local authorities
did not always have the levers to combat;
— it was considered a "blunt tool"
that was not appropriate in all areas of the country, in particular
outside London and the South East (where public transport accessibility
was perceived to be superior); and,
— overall, the approach was judged
inappropriate for many types of housing, including family and
executive housing.The research also identified confusion in applying
the standards, particularly:
— whether the 1.5 standard applied
as an average is to be achieved over the plan period (and what
that meant), over the whole plan area or parts of it, or for individual
developments; and
— whether driveways and garages constituted
a parking space (inconsistent decisions were found on this).
The Government is currently reviewing its policy
on planning for residential car parking. We commissioned research
in this area following the implementation study. Draft PPS3, published
in December 2005, proposes a more flexible, evidence based approach.
Paragraph 20 states that local planning authorities should develop
parking policies for their plan area, working with local stakeholders
and communities, having regard to expected car ownership for planned
housing in different locations, the efficient use of land and
the importance of promoting good design. This approach would replace
the 1.5 average for a local planning authority area in PPG3.
The public consultation upon draft PPS3 closes
on 27 February. The Government is hoping to finalise PPS3 in summer
2006.
5. At Question 349 in the transcript it was
mentioned that DfT funded the BPA to produce a model contract.
Could you provide the Committee with a copy of this contract.
A copy of the model contract is attached. This
was sent to us by the BPA for our personal use only and they have
agreed that we send it to the Committee. They have asked that
the Committee respect that the document is commercial in confidence
and BPA copyright.
6. How have the requirements for local parking
strategies changed between the first Local Transport Plans and
LTP2? Why have the requirements been changed? Have the requirements
been weakened?
The parking strategies contained in the first
local transport plans were one of 27 criteria used by the Department
to assess the quality of the plans. The Department published guidance
setting out the evidence that it would consider in its quality
assessments of which strategies met minimum requirements and the
extra that would characterise strategies in good plans.
The Department has changed its assessment methodology
for second local transport plans and emphasised the importance
of plans addressing 4 key policy priorities in its guidance on
second local transport plans. One of these is tackling congestion
and guidance indicates that plans should consider demand-side
strategies, including related to parking.
The guidance for second plans is different from
the previous guidance for a number of reasons, including because
there is greater experience in local authorities in producing
transport plans and in relation to transport planning more generally.
Since 2000 central government's relationships with local authorities
have become more focussed on outcomes as opposed to processes
and strategies and hence the second guidance concentrates the
outcome of tackling congestion and less on the component processes
(such as parking strategies).
The different guidance to local authorities
for second plans does not imply that parking is a less important
issue than it used to be. Demand management (including parking)
has an important bearing on the Department's assessments of second
plans, as it did with the first plans. This has been emphasised
in the feedback to many local authorities on their provisional
second plans, including the general feedback published on the
DfT website and sent to all the local transport plan authorities.
The Department's assessments continue to influence funding allocations
for the second plans.
7. At Question 414 in the transcript the Transport
Innovation Fund was discussed. Which of the successful TIF bids
are based largely on parking strategies? Do you anticipate there
will be TIF funding for schemes based mainly around parking strategies?
The seven successful applicants for TIF pump-priming,
announced on 28 November 2005, will consider a range of demand
management measures. These include parking controls, the workplace
parking levy and road user charging. None of the successful bids
looked at parking strategies exclusively and a key feature was
that all the bids featured feasibility work on road pricing.
The pump-priming decisions followed the TIF
pump-priming criteria, published on 5 July 2005, which made clear
that we are particularly looking for packages of measures combining
demand management and better public transport to tackle congestion. The
criteria said "all other things being equal we will give
preference to road user charging schemes over those which incorporate
workplace parking levies, and in turn prioritise these over those
which incorporate other forms of parking control". This priority
reflects the Department's view that local and regional pilots
are essential if we are to explore and understand the possibilities
of road pricing at national level. We therefore expect it to persist
through the TIF programme.
January 2006
| 
