APPENDIX 14
Memorandum submitted by FirstGroup plc
REPRESENTATION FROM
FIRSTGROUP
FirstGroup is grateful for the opportunity to
submit evidence to the Committee's inquiry into parking policy.
OVERVIEW
Successful parking policies are key elements
in delivering a number of important transport policy objectives.
For example, they can be major influencers in reducing traffic
congestion, creating a better environment in our cities and making
public transport a more attractive option.
Successful parking policies can free up road
space both by restricting parking and through price controls.
This in turn makes public transport both more competitive and
more attractive.
Parking is currently in a "disjointed"
state due to the differences in local authority policy under the
following broad headings:
SUPPLY
There are several categories of parking supply,
variously under different degrees of control by local authorities.
Parking includes public on street free, public
on street charged, public off street charged, private non residential,
residents" parking and fly parking. All of these can be controlled,
in terms of supply, but taking action to change the supply is
not always something that can be done with any speed. Councils
are generally able to directly control all on street parking and
a certain amount of public off street and private non residential
parking, and to take enforcement action against fly parking.
However, the establishment of public-private
partnerships for the supply of public off street parking, such
as those in Birmingham and Manchester, blurs the boundaries between
public policy and commercial enterprise. Whilst a council may
wish to promote modal shift and reduce car use, and parking policy
can be used to assist this through restricting supply, where such
partnerships exist there is a contrary pressure to maximise revenue
through the increase of parking supply.
Private non residential parking can be controlled
both directly, by reducing the availability of employee parking,
and through the planning process by setting maximum parking standards
for each class of development. This approach needs to be enforced
through follow up action both to ensure that the specified number
of spaces has not been exceeded, and by ensuring that areas planned
for service yards etc are not being used as overspill parking
areas. This approach is also not without problems, as some employers
remain convinced that the best way to attract an appropriate calibre
employee is to offer them a company car with a guaranteed parking
space, and this will exert some influence as to their location
plans if a local authority is reluctant to allow sufficient parking
supply. Very few local authorities have sought to address this
issue with vigour and where this has happened it has generally
not been applied to the customer parking for retail facilities.
The final type of parking supply is Park &
Ride, which can be entirely under a local authority's control,
or can be managed under a joint venture strategy with a public
transport provider. However there are certain criteria which must
be met for park and ride to be successful, and amongst these is
the relationship between the supply of park and ride spaces and
the overall parking supply. Whilst restricting the number of central
parking spaces will make park and ride more attractive, providing
insufficient park and ride spaces to meet demand can be counter
productive, both putting people off the concept and increasing
pressure upon central area parking.
PRICING
The total cost of parking to a motorist is either
the price paid to a meter, a machine or an attendant, or the cost
of the fine multiplied by the likelihood of detection and the
degree of effort put into recovery of the cash.
There is another pricing issue: the value of
time wasted recovering a vehicle impounded following detection
of illegal parking.
Different markets have different sensitivities
to cost. Leisure or occasional shopping visitors to a centre may
be reasonably expected to pay a high daily charge. More frequent
users such as commuters are more likely to resist a high charge
and seek alternatives. However the availability of season ticket
or contract parking at heavily discounted daily rates can undermine
such a policy of high pricing.
Business travellers may be more inclined to
risk paying a fine for illegal parking if they view this risk
as being outweighed by any potential increased convenience or
time saving. But if the risk involves the removal of the vehicle,
necessitating its recovery, this will act as a major deterrent.
There is concern that the high financial penalties levied by some
authorities for illegal parking represent a revenue generation
scheme, with little attendant benefit and little deterrent effect
for "hard core" offenders. This suggests that the optimum
solution is a relatively low fine but a high proportion of vehicle
removals.
DURATION OF
STAY
Market segmentation is the principle behind
offering long and short stay parking. The principal objective
of many urban areas is to preserve their relative attractiveness
in terms of the retail core. From a sustainability perspective
the principal problem is generally one of peak period congestion.
Therefore the parking strategy is based on dual pricing: high
charges for long stay parking (such as commuters), with relatively
cheap parking for those wishing to stay for only a few hours.
Restricting the maximum stay duration for most of the parking
supply is the simplest form of this policy, and need not include
a charge for the duration of this stay.
Such a policy can be effective in maintaining
the viability of the retail centre whilst making commuters think
seriously about their transport mode. It can however be seriously
undermined where privately run public off street car parks provide
all day parking at a similar price to that for the maximum short
stay duration. This is frequently the case in large city centres,
and can be a factor in pushing local authorities down the public-private
partnership route.
DECRIMINALISATION
Enforcement against illegal parking was traditionally
the preserve of traffic wardens, who form an element of the local
police force. Following the Road Traffic Act 1991 local authorities
have been able to apply to the Secretary of State for Decriminalisation
of Parking Enforcement (DPE) powers. This allows the authority
to take direct control of the parking enforcement activity and
to specify both the level of enforcement activity and the penalties
for illegal parking.
Take-up of these powers has been gradual and
inconsistent. For instance, within the Greater Manchester area,
of the 10 local authorities 9 have so far taken up the DPE powers
since 1999 and Tameside remains yet to do so.
Some authorities see DPE as an opportunity to
develop a more cohesive transport policy, with parking under greater
control and influencing modal choice. Others appear to have used
it as an opportunity to generate revenue, which is (under the
current legislation) ring fenced and to be hypothecated for transport
related purposes (including funding of the enforcement activity).
In summary there should be advantages to DPE
but until such time as all authorities are signed up to it and
there is greater consistency in its practical application, the
full advantages are yet to be realised.
ENFORCEMENT
The degree of enforcement which takes place
will be a key determinant of driver behaviour. The greater the
likelihood of detection of a parking offence, whether overstay
or parking where prohibited, the less likely such an offence is
to be committed. Where the local authority has adopted DPE, the
choice of the level of resource allocation is entirely theirs
to make, and the deployment of that resource is at their discretion.
It is, therefore, more likely that a cohesive and consistent approach
to parking policy will be taken by authorities who have adopted
DPE.
Enforcement activity does have a cost and the
availability of the revenue raised from this activity to be ploughed
back into the enforcement cost does give authorities greater scope
to act. Such hypothecation of revenue is clearly beneficial but
there is a serious problem with public perception of DPE and of
the revenue thereby generated. It is certainly the case in some
areas that allocation of resources is biased towards middle income
residential areas where the chances of payment without expensive
follow-up action are highest, whilst inner city areas where illegal
parking has the greatest adverse effect on the movement of traffic
see a far lower level of activity. Some guidelines linking the
ability to retain fine revenue to the relationship between enforcement
activity and the prevalence of illegal activity would be beneficial.
By this means the negative public image sometimes generated by
this activity could be alleviated, thereby assisting with compliance
and ensuring that the regime is of good repute.
Furthermore, public perception would be improved
by greater transparency regarding the costs and revenues of parking
enforcement. Publication of summarised accounts, explaining how
the revenue has been allocated, on an annual basis and including
this information with the Council Tax "pack" distributed
to households would achieve this.
Enforcement also applies to planning consents.
Whilst an authority may impose maximum parking standards for new
developments, these are only of value if they are enforced thoroughly.
If developers feel that they can ignore or flout such restrictions,
they soon will fall into disrepute and cease to have any value.
CONCLUSIONS
All these are important to public transport
operators as they affect the balance between the relative attractiveness
of private and public transport. When travellers make a choice
of mode for their journey they do that on the basis of the generalised
cost of travel. However general public awareness and perception
of generalised cost is, usually, poor. Therefore such choices
are, often, made on the basis of perceived changes to generalised
cost.
To explain this in more detail, motorists generally
see the cost of travel as being their fuel and parking costs.
The more enlightened will also consider servicing, taxation and
insurance as travel costs. However they are almost certain not
to include the costs of depreciation or the value of their time
whilst travelling, including time spent searching for a parking
space, and access time from the car park to their destination.
Conversely, the costs of travelling by public
transport are generally better perceived. Access to the bus stop
or station, waiting for the bus or train and any time premium
over the (perceived) car travel time are generally recognised.
The fare is clearly a visible cost. As activities such as waiting
time are perceived as time wasted, the value placed on these is
generally placed higher than on time spent "productively".
Therefore public transport is immediately perceived
as being disadvantageous for those who have a choice. From this
starting point any changes to travel behaviour are based on changes
in cost. For instance, bus fare increases or reductions in service
frequency will shift the balance in favour of the car. However,
increases in car parking charges, will be more likely to favour
public transport. A shift from a presumption that parking (legally
or otherwise) is free, to one where the fear of financial punishment
for illegal parking is endemic, will be likely to have a significant
effect.
There is however a further factor to take account
of. That is the need to retain some form of competitive local
advantage. Many local centres fear that the introduction of a
more draconian parking regime will weaken their retailing position
compared with out of town shopping centres with abundant free
parking. As the shopping activity tends to underpin other leisure,
catering and entertainment commerce, the fear is of collapse of
the commercial viability of the centre, with consequent collapse
of other employment. Such fears are to a certain extent well founded,
as exemplified by the initial depression of Sheffield City Centre
in the wake of the opening of Meadowhall in the 1990s. However,
rather than fighting shy of parking restrictions in the traditional
centres, the solution lies in tying customer parking charges into
planning consents for out of town centres.
RECOMMENDATIONS
In order to encourage a shift away from use
of the private car where there is a choice between public and
private transport, it is necessary to make public transport more
attractive whilst making the private car less appealing. There
is much activity at present examining road pricing schemes to
do this, but parking policy is just as important. In those towns
and cities constrained by parking restrictions within the central
area, such as Oxford, York, Chester and Brighton, the bus enjoys
a high market share. Learning from the lessons of these places
can help achieve a similar impact elsewhere.
While the introduction of the Transport Innovation
Fund is to be welcomed on the basis that it could assist in the
delivery of road user charging schemes, it is disappointing that
this may lead to workplace parking charging being moved down the
agenda as a result. Workplace charging will clearly need to be
an important element of parking policy if peak period congestion
is to be reduced and it is to be hoped that this review will recognise
this fact and address the current reduced emphasis on this policy
tool.
The key issues to consider are parking supply,
pricing and duration of stay for public spaces, together with
development control. A clear policy on enforcement levels, targets
and revenue usage is also required.
First considers that there is a need for a thorough
review of parking policy across the UK, identifying best practice
in all the above fields. This review should conclude with the
production of guidelines for local authorities governing all elements
of parking policy, with targets being set for LTP monitoring and
consideration of these in making funding awards. There is a need
for greater consistency of approach across authorities, and for
greater transparency, if we are to achieve a real impact in modal
shift.
FirstGroup plc
October 2005
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