APPENDIX 11
Memorandum submitted by the Disabled Persons
Transport Advisory Committee
INTRODUCTION
1. The Disabled Persons Transport Advisory
Committee (DPTAC) welcomes the opportunity to comment on the House
of Commons Transport Committee investigation Finding a Space for
Parking Policy.
2. DPTAC was set up under the Transport
Act 1985 to advise the Government on disabled people's transport
needs. We aim to ensure that disabled people can go where everyone
else goes, easily and without extra cost. We would like to see
this happen by 2020.
3. The absence of accessible, affordable
and available transport mean that disabled people are less able
to secure and retain employment, obtain medical treatment, enjoy
a full social and recreational life, or travel with whom they
want, where they want and when they want. Compared to others,
disabled travellers are likely to plan further ahead, use more
effort, pay more to travel, spend more time, experience embarrassment
and stigmatisation, and find themselves more tired at the end
of a journey. This will crucially affect their confidence and
preparedness to travel in future.
4. DPTAC uses four overarching principles
as the basis for its advice to Government, other organisations
and disabled people. These are that:
— accessibility for disabled people
is a condition of any investment;
— accessibility for disabled people
must be a mainstream activity;
— users should be involved in determining
accessibility;
— providers are responsible for achieving
accessibility for disabled people.
5. These principles are the basis of DPTAC's
response to consultations.
SPECIFIC RESPONSE
TO THE
CONSULTATION
Are local authorities carrying out parking control
reasonably, fairly and accountably? How is performance evaluated?
6. We note from the press release that the
emphasis in this inquiry appears to relate to on-street parking.
DPTAC, however, believes that any consideration of parking policy
has to take account of both on-street and off-street parking.
There are good reasons for this. Firstly, the overall supply of
parking places has a key bearing on the accessibility of any town
or city centre and this is particularly important for disabled
people. Secondly, if the supply, cost or enforcement regime applying
to on-street parking is changed, there is a knock on effect for
off-street parking and vice versa.
7. There is a further aspect to be considered.
While under current legislation, only a local authority has the
powers to provide and operate on-street parking places, a large
element of the off-street supply is owned and operated by the
private sector. We understand that in some town centres, this
can mean that almost 100% of the public parking supply is under
the control of the private sector. This will have a bearing on
any measures to evaluate the comparative performance of local
authorities.
8. Having said that, we recognise that parking
policy is an effective way for a local authority to manage the
demand for vehicular access to our towns and cities. With this
in mind, we note that there are currently no statutory best value
performance indicators relating to parking operations for local
authorities. The Transport Committee may wish to consider recommending
the introduction of such indicators. From the point of view of
DPTAC, we would expect such indicators to demonstrate the provision
made for Blue Badge Holders both on and off street and to give
an indication of the adequacy of that provision (including customer
satisfaction).
What action would raise the standard of parking
enforcement activity? Is Statutory Guidance needed to promote
consistency?
9. In reviewing the Blue Badge parking scheme
in 2001-02, DPTAC made a number of recommendations to the Ministers
for enhancing the scheme. These included measures to improve enforcement.
10. Abuse of the badge, particularly when
the holder is not present, is rife but it is difficult to check
unless the badge can be inspected by a traffic attendant or police
officer. Powers of inspection were included in the Transport Scotland
Act (2001) and, after consultation with DPTAC and with disability
organisations, were introduced in January 2004. Similar powers
relating to England were included in the Traffic Management Act
2004 and following consultation on new guidance for enforcing
authorities, we understand the powers should be introduced shortly.
11. There is no national database of Blue
Badges issued. We indicated to Ministers that we believed that
the establishment of such a database would help local authorities
and the police to enforce the scheme and assist in delivering
concessions. A research project into the practicalities of this
has been commissioned by the Department for Transport and is now
underway. However, assuming a successful outcome to the research,
we would seek assurances that the database will introduced at
a very early date.
12. The Blue Badge scheme also applies only
to on-street parking. In practice, most, if not all, local authorities
and private sector operators designate a number of off-street
spaces for use by Blue Badge holders. However, the new powers
of inspection apply to on-street parking only. There is a need
to consider whether the powers of inspection should be extended
to off-street parking. We believe there is also a strong case
for statutory guidance or at the very least, a Code of Good Practice,
to ensure that both operators and users recognise the importance
of encouraging the correct use of any spaces that may be provided.
13. The benefits that both we and the Government
expect to flow from the new powers of inspection will only follow
if the new provision is coupled with (a) effective training of
enforcement officers on good practice in using the powers, particularly
in relation to people with disabilities who are young and who
are from black and ethnic minorities whose experience with law
enforcement authorities may not be wholly positive; and (b) advice
to Blue Badge Holders that they may be asked to produce the badge
by enforcement officers; and (c) effective monitoring of how enforcement
works in practice. DPTAC is assisting the Department for Transport
in preparing guidance.
Is the appeals process fair and effective? How
could it be improved?
14. We have no comments to offer on this
issue.
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 decriminalised parking
enforcement has inappropriately influenced authorities' parking
policy and enforcement activity?
15. We would not wish to comment whether
the opportunity to raise revenue has influenced policy and enforcement
in an inappropriate manner. However, we are concerned that enforcement
is carried out both fairly and equitably. We believe that all
local authority revenues from parking fees and fines should be
retained by the authority and that they should first be devoted
to enhancing parking provision. For disabled people these enhancements
would include ensuring pedestrian routes to and from parking areas
were well maintained and accessible. We would also expect consideration
to be given to lighting and security/cctv and would encourage
adoption of such schemes as Secured Car Parks.
What criteria should be used to determine the
level of parking provision that should be provided?
16. From the point of view of disabled people,
there are two aspects to this issue—the number of spaces
and their location.
17. Meeting Government objectives for managing
the growth in traffic would imply restricting the number of new
parking places in our town and city centres and indeed reducing
existing numbers. We would contend that ensuring adequate access
by disabled people requires a careful consideration of the impact
of such policies on disabled people. This aspect is given greater
impetus by the new obligation that will be introduced in 2006
requiring public authorities to publish and promote a Disability
Equality Strategy.
18. Determining the level of parking provision
for Blue Badge holders and its location needs to be based on a
combination of surveys of the adequacy of existing provision and
consultation with local disability groups to see what changes
need to be made to meet future trip making requirements.
What are the wider impacts of current parking
policy and illegally parked vehicles?
19. Disabled people have two particular
concerns. These relate to the abuse of on and off-street parking
provision made for Blue Badge holders and poor enforcement of
on-street parking and waiting regulations adjacent to bus stops.
20. In the case of the former, the new powers
of inspection of Blue Badges should assist with the enforcement
of on-street parking. The powers do not, however, extend to off-street
parking provision and there is considerable abuse of provision
made for Blue Badge holders. The position is not helped when parking
providers (mainly in the private sector) also designate spaces
for parent with toddlers. DPTAC recognises the case for making
such provision but we are also aware that some operators do not
distinguish between the two categories in marking out spaces.
This encourages abuse and can seriously disadvantage genuine users
who are unable to access spaces adjacent to where they wish to
go.
21. Poor enforcement of parking and waiting
regulations adjacent to bus stops means that disabled people (and
wheelchair users in particular) are unable to realise the benefits
of the new low-floor buses that are now becoming increasingly
commonplace. Buses are unable to pull in to the kerb to allow
people to step easily from footway on to bus and ramps for wheelchair
users can not be deployed. There is therefore a need for much
better enforcement of regulations and better publicity for motorists
so they are more aware of the consequences of their actions.
22. We have also become aware of an apparent
inconsistency in the regulations pertaining to yellow line bus-stop
clearways and Red Route bus clearways. This is an issue that needs
to be addressed.
What role should parking policy play in traffic
management and demand management?
23. DPTAC believes that control over the
supply and price of parking is still the most effective and readily
available tool for local authorities in managing the growth in
traffic and demand for access to our town and city centres. Implementation
of a cohesive parking policy requires integration of highways
and planning policies through a combination of local transport
plan strategies, structure and local plan policies and development
control. We would seek to ensure that such policies acknowledge
the importance of both maintaining and enhancing access by disabled
people. This would include ensuring an adequate supply of on and
off street parking provision for Blue Badge Holders.
3 October 2005
| 
