APPENDIX 5
Memorandum submitted by the Campaign for
the Protection of Rural England
1. CPRE welcomes the opportunity to contribute
to the Committee's timely inquiry, Finding a Space for Parking
Policy. We have long been concerned by the increases in pressure
for parking provision resulting from rising traffic levels. The
Government's Transport White Paper forecasts for future traffic
illustrate that this will only intensify unless action is taken
to address it. By 2010, there is forecast to be a 26% increase
of cars on 2000 levels. By 2025, this figure rises to 37%. Those
holding a driving licence are also forecast to increase from 70%
of the adult population in 2000, to 75% by 2010, and 81% by 2025.
2. CPRE does not have expertise in the area
of enforcement activities and we have, therefore, not commented
on this aspect of your inquiry. We are particularly interested,
however, in the role parking policy should play in traffic and
demand management, and in land use planning. It is on these issues
that our submission concentrates.
WHAT ROLE
SHOULD PARKING
POLICY PLAY
IN TRAFFIC
MANAGEMENT AND
DEMAND MANAGEMENT?
Policy should recognise that parking is land hungry
3. In considering parking policy, CPRE believes
it is important for Government and local authorities to recognise
that parking adds considerably to total land-take for transport
infrastructure. This is highlighted in our leaflet, Parking Mad
(copy enclosed). The Government's Transport White Paper commits
to ensuring that "the amount of greenfield land taken for
development is kept to a minimum". While this clearly applies
to housing, new roads, railway lines and other infrastructure,
we believe it needs to explicitly embrace "Park and Ride"
(P&R) schemes and conventional parking too.
4. Land is a limited natural resource. There
are many pressures placed upon it from society. On the basis of
survey work undertaken in 1993, CPRE calculated that an area twice
the size of Birmingham was already devoted to parking in the UK.
Within towns and cities, the more land that is set aside for parking,
the less is generally available for other competing—and
often more beneficial uses—like housing.
5. Since 1993 the number of vehicles on
the road has increased. CPRE has calculated that if all private
cars and light goods vehicles licensed in Great Britain in 2003
were parked in single file, they would cover over 80% of the entire
classified roads network. Put another way, if all private cars
and light goods vehicles in Great Britain occupied parking spaces
in a line, they would fill all six lanes of motorway from London
to Manchester, with the vehicles piled 68 high.
Parking policy is an important part of delivering
sustainable transport
6. CPRE believes that levels of parking
provision and the costs of parking play a leading role in influencing
car use and traffic patterns. The Government acknowledges this
in planning policy. Planning Policy Guidance (PPG) 13: Transport
specifically states that the "availability of car parking
has a major influence on the means of transport people choose
for their journeys".
7. We see parking policy as forming an integral
part of a co-ordinated approach to traffic and demand management.
Despite increases in the cost of fuel, the real cost of motoring
has fallen while the real cost of public transport has risen.
This sends out the wrong message to people and makes it harder
to deliver a sustainable transport policy. In considering the
costs of parking, it is important to examine the issue in this
wider context. The report, Smarter Choices, commissioned by the
Department for Transport (DfT), examined the potential of so-called
"soft factors" in changing travel behaviour. A key conclusion
was that the success of such measures was reliant on the delivery
of a coherent approach for managing transport demand.
Integrating parking and planning policies is essential
8. The provision of parking is a key factor
which should be considered in the development of planning policies.
Strong policies are needed to encourage the urban renaissance,
promote more sustainable communities, and reduce the need to travel.
These objectives are all compromised when large volumes of parking
are provided out of town, or on the edge of urban areas. Any relaxation
in policies which encourage sprawling development would not only
damage the countryside, but also undermine the existing and future
potential of public transport, as well as the investment by others
in town-centre development.
9. There is considerable debate about the
need for fuller consideration of the transport infrastructure
requirements arising from the implementation of the Communities
Plan. This has largely focused on whether new road or rail links
are required and where the funding for these is to come from.
Yet, if the housing levels which are proposed in draft Regional
Spatial Strategies for the East of England, and South East are
adopted, this will also add a considerable burden to existing
pressures for parking.
10. CPRE warmly welcomed publication of
PPG13 in 2001 with its emphasis on maximum rather than minimum
parking standards. Our primary concern with PPG13 currently lies
not in its content, but with its implementation. We attach particular
importance, therefore, to how the Government ensures that the
policies and standards set out in PPG13 are adhered to on the
ground. This should involve a more hands-on approach to the delivery
of the new policies and approach than has previously been evident.
11. CPRE is concerned that the implementation
of the approach in PPG13 has not been as consistent as it needs
to be. We urge the Committee during the course of its inquiry,
to look carefully at whether the standards set out in PPG13 are
being met. This should cover the extent to which the Government
monitors their implementation, and intervenes when developers
or authorities propose developments which conflict with these
standards. Moreover, under the Planning and Compulsory Purchase
Act 2004, the Regional Spatial Strategy (and Transport Strategy
which is embedded within it) become statutory documents. We would
also be interested to know how this might affect the policies
in place to ensure authorities adopt a strict approach to reviewing
the need for parking provision.
Opportunities for improvement
12. Ways in which Government could strengthen
its delivery of parking policies in PPG13 on the ground include:
— developing a training programme for
civil servants (especially in Government Regional Offices, other
Government departments, Regional Development Agencies, Regional
Planning Bodies, and the Highways Agency) on the need for an approach
to parking provision based on demand management;
— producing a "Frequently Asked
Questions and Answers" briefing on the DfT website which
responds to the common issues arising over new development, and
associated traffic issues (as the DTI has for renewable energy
for example);
— producing a best practice guide on
developments which exhibit low parking intensity and high spatial
efficiency;
— DfT and ODPM jointly producing a
"compatibility analysis" of existing plans at regional
and local level against the parking standards in PPG13;
— improving the place of parking policy
within the new approach to transport appraisal (NATA);
— exercising the use of call-in powers
more frequently to emphasise the importance the Government attaches
to effective parking policies;
— increasing resources to Regional
Planning Bodies so that they can ensure new Local Development
Frameworks deliver strong, demand management policies relating
to parking; and
— developing an action plan to address
problems associated with specific generators of car-dependent
developments (eg airports, football stadiums, retail) involving
local authorities, the DfT, ODPM, outside stakeholders, the Highways
Agency and public transport operators.
13. In our experience, Regional Planning
Bodies are frequently not acting sufficiently strategically in
their decision-making on parking issues. They have generally not
been able to overcome the obstacle of different local authorities
competing for business and customers through increasing the availability
of parking. In this sense, incentives need to be improved for
local and regional planning bodies considering adopting a more
effective approach to parking based on demand management. Consideration
should also be given to penalising authorities who fail to embrace
this agenda, for example through a reduction in financial support
for major transport schemes, or possible downgrading in performance
assessments. There might even be a case for establishing a new
body, or tasking an existing body, with the capability of intervening
in disputes between neighbouring authorities over parking provision
to ensure they are resolved, without resorting to lax policies
and standards.
14. There are a number of ways in which
parking policy can help achieve wider traffic and demand management
objectives. These include:
— strengthening the parking standards
for new developments, especially in the Government's Growth Areas;
— implementing car-free housing developments,
such as those currently promoted in the London Borough of Camden,
on a wider scale; and
— promoting car sharing initiatives,
for example pooled community vehicles, particularly through Residents
Associations in existing suburbs.
15. We hope the Committee will be able to
consider the potential of such measures during its inquiry.
"Park and Ride" is not a panacea
16. In examining the role of parking and
demand management, it is vital to consider the place of "Park
and Ride" (P&R) schemes. The use of P&R by local
highway authorities has grown considerably in recent years. The
Ten Year Transport Plan estimated 100 new bus-based P&R schemes
by 2010. Just two years later, the DfT were forecasting 150 new
P&R schemes between 2001-02—2005-06.
17. These schemes have been identified as
a good way of reducing congestion in town centres. CPRE does not
contest that many P&R proposals, coupled with the significant
investment which goes with them, have brought benefits to town
centres. We are concerned, however, that the net effect can be
simply to displace transport problems, rather than solve them
as these schemes are generally dependent upon access to and use
of a car.
18. In determining the overall effect of
a P&R scheme, it is important to consider the effect on the
"host settlement" and on the surrounding area. P&R
can conflict with policies to protect the countryside, especially
Green Belt land. They can urbanise the countryside on urban fringes,
and generate additional traffic overall. In CPRE's view, out of
sight should not mean out of mind. Yet, the structure of local
government in many areas can exacerbate this problem, with benefits
being experienced in the centres of an urban authority, but negative
effects in the surrounding areas outside of its boundaries.
19. The DfT Guidance on Methodology for
Multi-Modal Studies states of P&R, that "The impacts
on the environment and traffic outside urban areas is less clear.
In some circumstances, park and ride may generate longer journeys
and take part of its demand from passengers who previously used
public transport for their whole journey" (paragraph 4.4.12).
A key determinant of its transport, as opposed to environmental,
impact will be the extent to which any P&R scheme is accompanied
by measures to reduce parking in the town centre. While there
may be occasions when P&R is an appropriate response to an
identified problem, we believe a much more cautious approach is
needed before schemes are realised. We hope such an approach will
be reflected in forthcoming decisions by the DfT on Local Transport
Plan proposals.
Private non-residential parking
20. The Transport Act (2000) contained provisions
enabling local authorities to introduce congestion charges, and
levies for private, non-residential parking areas, such as those
found in out of town superstores. Currently, the use of such levies
for reducing car use and parking demand is minimal. We urge the
Committee to explore the reasons this policy approach is not being
implemented and to propose measures to overcome any obstacles
to its adoption.
Conclusion
21. CPRE notes the Committee's observation
in the Terms of Reference for the Inquiry that "most drivers
have experienced difficulties finding a place to park". While
this may be a problem for individual motorists, the consequences
for society of addressing this through relaxing standards and
increasing parking provision could be severe for the wider quality
of life of local communities and the development of sustainable
transport policies. Indeed, rather than furthering the Government's
objectives to reduce the need to travel, it could lead to increased
car use and greater land-take, and contribute to the erosion of
the character of the countryside and the "liveability"
of our urban areas.
September 2005
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