Select Committee on Transport Written Evidence


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



 
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