APPENDIX 13
Memorandum submitted by Transport for
London
A. INTRODUCTION
This paper sets out Transport for London's (TfL's)
response to the Transport Committee request for information on
parking enforcement policies and practices.
The enforcement of traffic contraventions is
integral to TfL's strategic objectives for the delivery of real
time traffic management on the Transport for London Road Network
and the wider policing and enforcement strategy for London's transport
network. TfL has never used the number of penalty charge notices
issued as a performance indicator. The key performance indicators
used are improved compliance and journey times for all traffic.
By delivering increased compliance with parking controls TfL seeks
to maximise the capacity of the Transport for London Road Network,
reduce congestion and improve journey times for all road users
especially buses.
B. BACKGROUND
Responsibility for parking enforcement on the
Transport for London Road Network was passed to TfL on 15 November
2004. Prior to this the Metropolitan Police Service (MPS) were
directly responsible for parking enforcement of the red route
network (with the City of London Police responsible for the few
red routes in the City).
Red route parking enforcement was decriminalised
on 15 November 2004 with TfL now the responsible authority. TfL
discharges its enforcement duties through a Special Services Agreement
with the MPS. As a result, 350 Traffic Wardens and 450 Transport
Police Community Support Officers of the TfL-funded MPS Transport
Operational Command Unit enforce parking restrictions on the Transport
for London Road Network. They issue £100 Penalty Charge Notices
for parking contraventions which are processed by TfL's contractor.
Representations are handled by TfL, with appeals heard by the
independent Parking and Traffic Appeals Service.
TfL has delivered an enforcement service in
respect of bus lanes on the Transport for London Road Network
using decriminalised powers since April 2001 and since June 2004
in respect of other decriminalised moving vehicle contraventions.
C. ANSWERS TO
QUESTIONS POSED
BY TRANSPORT
COMMITTEE
1. Are local authorities carrying out parking
control reasonably, fairly and accountably? How is performance
evaluated?
1.1 TfL seeks to improve compliance with
parking controls on the Transport for London Road Network in order
to reduce congestion, improve journey times (especially those
of buses) and to secure and improve road safety in respect of
all road users.
1.2 When the red route network was introduced
during the 1990s, the then Traffic Director for London decided
to retain enforcement of the network by the Metropolitan Police
Service's Traffic Wardens. This was intended to significantly
improve enforcement as boroughs used their new powers to "decriminalise"
parking enforcement on their roads. Therefore, Traffic Wardens
who had previously patrolled these roads could be redeployed entirely
onto the red route network.
1.3 However, it became apparent towards
the end of the 1990s that enforcement of the red route was decreasing
as Traffic Warden numbers began to decline significantly. Consequently,
since the establishment of the Transport for London Road Network
in 2000, TfL has looked closely at how best to ensure its effective
enforcement.
1.4 In June 2002, the Mayor launched the
joint TfL/MPS Transport Operational Command Unit to deliver additional
transport policing services to 26 key bus corridors across London.
The Transport Operational Command Unit now numbers a total of
930 officers (police and Traffic Police Community Support Officers)
with responsibility for tackling crime and disorder on key bus
corridors, reducing congestion at key locations, improving bus
reliability and enforcing the taxi and private hire sector.
1.5 The review of the Transport for London
Road Network parking enforcement took into account TfL's focus
on improving the functioning of the road network, improving our
real time capacity to respond to incidents and our commitment
to a wider visible police presence on the transport network. The
review concluded that parking enforcement should be decriminalised
in order to transfer accountability for enforcement to TfL and
to enable it to lever in additional resources to the enforcement
and management of the Transport for London Road Network.
1.6 TfL's overall goal in managing the Transport
for London Road Network is to reduce congestion allowing for more
efficient movement of goods and people and particularly to improve
bus reliability (4A.3 of Mayor's Transport Strategy).
1.7 As part of TfL's preparation for decriminalisation,
an "enforcement demand matrix" was constructed to identify
the locations on the network which require higher levels of enforcement.
The matrix is based on TfL's analysis on priority areas of the
Transport for London Road Network, including traffic congestion
hotspots and roads where bus services are impeded by illegal parking.
This matrix is used to guide the deployment of MPS Transport Operational
Command Unit resources on the Transport for London Road Network.
1.8 Conditions on the Transport for London
Road Network are continually assessed through the Traffic Wardens
and Traffic Police Community Support Officers as well as bus operators,
TfL's network managers and through our links with the London Boroughs.
In addition, feedback from members of the public and TfL's participation
in various stakeholder groups is fed back into identifying key
areas for deployment.
1.9 From the 15 February 2005 TfL has used
existing CCTV cameras to enforce parking restrictions at key locations.
This has enabled Transport Operational Command Unit resources
to deploy to other parts of the Transport for London Road Network
that are currently under-enforced.
1.10 TfL has never used the number of penalty
charge notices issued as a performance indicator. It has instead
monitored the impact of bus lane enforcement on bus journey times.
Generally, we have seen a 9% improvement on year-on-year bus journey
times on those bus lanes we are enforcing and approximately a
58% reduction in numbers of contraventions per kilometre (Jan
2004 vs. Jan 2003).
1.11 TfL has established a method of measuring
compliance with parking restrictions on the red route network
(and on the borough roads). Since March 2004 we have been routinely
measuring compliance using a contractor and have established a
compliance factor which indicates whether compliance is improving
with different levels of enforcement. We will be happy to expand
on this to the Select Committee.
2. What action would raise the standard of
parking enforcement activity? Is Statutory Guidance needed to
promote consistency?
2.1 TfL is working with the Department for
Transport on the production of Statutory Guidance that is being
prepared under the auspices of the Traffic Management Act 2004.
The guidance is intended to be issued by the Secretary of State
for Transport under Section 87 of the Traffic Management Act 2004.
It will apply to all local authorities in England that are exercising
decriminalised parking enforcement powers.
2.2 However, there are two general issues
which should be considered. Firstly, the need for authorities
to seek quality accreditations for their enforcement activities
as well as regularly reviewing and seeking to continuously improve
their services. TfL's operation is ISO 9000—compliant and
Charter Mark is being sought. The services are also being subjected
to Best Value reviews.
2.3 Secondly, the need for authorities to
closely liaise with their stakeholders who can be many and varied.
TfL has established a Red Route Enforcement Forum which brings
together all stakeholders on a quarterly basis. This provides
an opportunity to consult and involve people who are directly
affected by parking enforcement activities and also provides an
opportunity for different stakeholders to begin to understand
each other's point of view.
3. Is the appeals process fair and effective?
How could it be improved?
3.1 TfL is fully compliant with legislative
requirements relating to appeals against any parking penalty charge.
In accordance with guidance from the Association of London Government
and the Parking and Traffic Appeals Service, TfL considers all
representations and challenges made prior to a formal appeal and
attempts to assist enquirers with their queries at the earliest
stage possible to avoid the need to make formal representations.
3.2 One of TfL's objectives is to seek Charter
Mark for the notice processing service. As part of this TfL will
be reviewing customer satisfaction levels with this part of the
service. As indicated below, much of this work is already undertaken
in relation to our bus lane enforcement service.
3.3 TfL always extends the 14 day discount
period where a representation is made within the 14 day period
and where the representation is rejected.
3.4 Despite the wide geographical area which
TfL covers, we have established Parking Shops in association with
our borough partners to deliver a more accessible service to our
customers. It rarely serves any purpose in the longer term to
attempt to dissuade customers from making enquiries by making
the service less accessible so TfL would strongly recommend that
any barriers are firmly dismantled.
4. 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?
4.1 As stated in the introduction, TfL believes
that parking enforcement powers should be use solely as a means
of improving compliance with parking controls and thereby delivering
our transport objectives.
4.2 TfL recognises that this activity will
generate income and possibly a surplus. The retention by authorities
of income generated from parking enforcement activities is only
justified when any surplus is transparently accounted for and
the public can see where any surplus is spent. Existing legislative
controls ensure that surpluses can only be spent in specific ways.
Careful consideration should be given to the issue of excellent
authorities being able to spend any surplus in any way they choose.
Ideally, TfL would like to see the "status quo" maintained
with any surpluses from parking enforcement activities being spent
for relevant transport purposes.
5. What criteria should be used to determine
the level of parking provision that should be provided?
5.1 The Mayor's Transport Strategy highlights
the fact that authorities should ensure that their transport policies
and activities are developed in such a way as to enable planning
policy, including London Plan, to be integrated.
5.2 The Parking and Enforcement Plans, submitted
by the Local Authorities (as part of their Local Implementation
Plans), must give consideration to parking provision, charging
regimes, on-street controls, and parking standards. It should
be co-ordinated and compatible with surrounding authorities, support
the economic viability of town centres, whilst reducing the overall
availability of long stay parking, ensure that the needs of disabled
people, motorcycles, buses, coaches, business and freight are
taken into account, along with loading and signing issues in relation
to parking.
6. What are the wider impacts of current parking
policy and illegally parked vehicles?
6.1 The establishment of a User Forum (2.3
above) underlines the competing demands of different stakeholders
for kerbside space. A primary focus of TfL is to deliver improved
bus services with increased reliability. Much of our enforcement
activity has been aimed at improving bus journey times.
6.2 Increasingly, however, the use of parking
enforcement forums can improve road safety, reduce congestion,
and is instrumental in ensuring the effective movement of goods
in the capital.
7. What role should parking policy play in
traffic management and demand management?
7.1 Effective parking policy and enforcement
is essential to ensure that the road network can be used for the
movement of people and goods. Keeping stationary vehicles away
from critical parts of the network (such as approaches to signalled
junctions, bus stops and pedestrian crossings) is fundamental
for safety and to maximise the throughput of people and goods.
The evidence from the implementation of the red routes in the
nineties showed how the application of good parking policies and
enforcement produced significant benefits for bus operations,
and general traffic, whilst improving conditions for pedestrians
and reducing casualties.
It is also important that areas designated for
loading are kept clear of parked cars to allow for the efficient
delivery of goods to those premises which do not have off street
loading facilities.
7.2 The availability and cost of parking
is a key factor in the choice of mode for those who could potentially
use a car. The London Plan sets limits on the numbers of car parking
spaces that developers are allowed to provide, depending on the
land use, location and the quality of the public transport serving
the site. The London Boroughs have introduced controlled parking
zones to restrict the number of cars that are driven to and parked
within the zones, discouraging all-day parking by commuters in
favour of residents, shoppers and visitors.
More stringent controls on parking, from raising
prices for both on-street and off-street, extending the coverage
of controlled parking zones or by lower limits on spaces for developments,
could make a further contribution to reducing the use of the car
as part of a package of measures. This could be done through partnership
by the authorities concerned, in concert with improvements to
public transport and other travel demand measures.
8. How can public understanding and acceptance
of the need for parking policy be achieved?
8.1 TfL has conducted a range of research
on public perception of enforcement in relation to bus lanes (and
latterly in relation to parking and yellow box enforcement). The
research has shown that 98% of the public are aware of bus lane
enforcement and 56% approve of it. 61% of the public are also
aware that cameras enforce bus lanes.
8.2 TfL works closely with other organisations
in London. In 2000 we established an Enforcement Task Force to
represent TfL, the Association for London Government, the London
Boroughs and the Police so that a coordinated approach to enforcement
is established and maintained.
8.3 It is a stated intention that, following
the first six to 12 months of decriminalised enforcement, TfL
will conduct a thorough review of both the enforcement mix (ie
Traffic Wardens, Traffic Police Community Support Officers and
cameras) as well as a review of how well the combination of red
lines and parking and loading boxes work. This work is already
underway.
8.4 Parking controls on the red route have
not been comprehensively reviewed since their inception in the
early 1990s. As part of TfL's wider approach to the Transport
for London Road Network, a fundamental review of the operation
of the red routes and the nature of the restrictions has been
initiated. This review will engage the many road users and stakeholders
across London.
| 
