APPENDIX 12
Memorandum submitted by the Road Haulage
Association Ltd
INTRODUCTION
The Road Haulage Association (RHA) was formed
in 1945 to look after the interests of haulage contractors in
various areas of the country, in effect, amalgamating local organisations
that had been established. The Association has subsequently developed
to become the primary trade association representing the hire-or-reward
sector of the road transport industry. There are now some 10,000
companies in membership varying from major companies with over
5,000 vehicles down to single vehicle owner-drivers.
BACKGROUND TO
THE INDUSTRY
The road haulage industry plays a pivotal role
in the UK economy carrying over 80% of all domestic freight. In
2003 this amounted to:
— 1,053 million tonnes carried in hire-or-reward
vehicles;
— 590 millions tonnes carried in own-account
operators' vehicles;
— a total of 1,643 million tonnes of
goods going by road;
— 152 billion tonne kilometres on road
transport;
— an average length of haul of 46 kilometres
for rigid vehicles, 133 kilometres for articulated vehicles and
92 kilometres as an overall average.
There are around 52,000 businesses in the industry
and between them they operate some 430,000 vehicles over 3.5 tonnes
gross vehicle weight.
GENERAL COMMENTS
With ever increasing demands on road space in
urban areas, attention has in recent years been focused on better
enforcement of parking regulations. The decriminalisation of parking
enforcement has resulted in more and more local authorities taking
over responsibilities previously exercised by the Police. The
ability for those local authorities to retain any surplus raised
by parking fines has been an added incentive to maximise their
efforts and has, on occasion, led to over-zealous enforcement
activity.
This situation is particularly problematical
for freight operators. Every business on the modern day high street
will, to varying degrees and frequencies, require servicing and/or
deliveries. Some of these activities will be undertaken in small
van sized vehicles but many require the presence of lorries. Such
vehicles have a legitimate need to stop in order to provide a
service to those businesses. However, vehicles being loaded or
unloaded are frequently targeted by parking attendants and issued
with penalty charge notices (PCNs) for being "illegally parked".
As a result, the costs of doing business in these areas increase
significantly.
SPECIFIC QUESTIONS
Are local authorities carrying out parking control
reasonably, fairly and accountably?
The RHA believes that in many areas—particularly
London—parking control is not being undertaken in a reasonable
way. Parking attendants seem to be motivated to issue as many
PCNs as possible at the expense of ensuring the legitimacy of
the PCN. This is resulting in huge increases in the costs associated
with doing business in a particular area. Some operators in London
are facing fines which amount to hundreds of thousands of pounds
per annum.
What action would raise the standard of parking
enforcement activity? Is statutory guidance needed to promote
consistency?
There are a number of actions that would improve
the situation:
— contracts for providing enforcement
activity should not reward parking attendants according to the
number of PCNs issued—accuracy should be more important;
— adequate training must be given to
staff, including proper guidance on how to deal with vehicles
being loaded/unloaded;
— statutory guidance would help to
ensure consistency across authorities;
— local authorities should be required
to review the parking and loading/unloading restrictions that
apply and the signing in place prior to being allowed to take
over enforcement.
Is the appeals process fair and effective? How
could it be improved?
The RHA has no reason to believe that the appeals
procedure is unfair. However, we must question its effectiveness.
Many freight operators—particularly those that deliver regularly
into central London—choose to pay the PCNs (and add these
costs to their customers' bills) rather than challenge them. There
are two reasons for this—the sheer number of PCNs they receive
(sometimes on a more than daily basis); and the administrative
burden involved.
Is it appropriate that local authorities should
keep the revenue generated from parking fines?
The RHA is not opposed to this as a principle.
What concerns us is where this leads to contracts that are based
on the number of PCNs issued. Local authorities should be required
to demonstrate that this is not the case, that proper training
is in place for enforcement staff and that the restrictions that
apply are still relevant and properly signed. If they are unable
to demonstrate this then the ability to retain the revenue should
be removed.
What criteria should be used to determine the
level of parking provision that should be provided?
The RHA believes that the local authorities
are the most appropriate bodies to determine the desired level
of parking provision within their areas. However, the needs of
freight operators are frequently overlooked not only in terms
of requirements for deliveries to businesses in the area but also
the legal requirement for HGV drivers to take breaks and rests.
Sufficient safe parking provision must be provided to facilitate
this. The RHA believes that meeting these requirements should
be an integral part of the local authorities' transport planning
processes.
CONCLUSIONS
Parking policies and their enforcement have
an important role to play in traffic management/demand management
for urban areas. Illegally parked vehicles increase congestion,
cause unnecessary disruption and on occasions can represent a
road safety risk. However, in determining the restrictions that
should apply and how they are to be enforced, local authorities
should take account of the needs of all road users. In addition
they must look at how parking policies interact with other areas
of transport/planning policies to ensure that there are no conflicts,
for example restricting loading/unloading to certain times of
the day when there are actually lorry bans in force.
October 2005
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