APPENDIX 15
Memorandum submitted by the Association
of International Couriers and Express Services
BACKGROUND—AICES
AND THE
EXPRESS INDUSTRY
1. AICES is the trade organisation in the
United Kingdom for companies handling international express documents
and package shipments. Our membership (which includes household
names such as DHL, FedEx, TNT and UPS) employs over 29,000 people
directly in the UK, supports a further 68,000 jobs indirectly,
and is responsible for over 95% of the international courier and
express shipments moved through the UK every day. Our services
provide the "just-in-time" information and goods that
organisations from hospitals to major financial institutions rely
upon.
2. The provision of cost effective express
services is one of the key factors making London competitive as
a world financial and business centre. Businesses dealing in high
value products need to be able to access delivery services to
locations around the world on a next day basis—this is what
our members provide.
3. The importance of the provision of express
services was shown by an Oxford Economic Forecasting report
in 2002 which demonstrated that whilst the direct economic benefit
of the express industry in 2001 was £544 million, its additional
catalytic impact (enabling other firms to do business) was over
£1.2 billion. This report also estimated that the impact
of the express industry will grow to over £5 billion per
year within the next 20 years. As the major centre of express
services use in the UK, London stands to benefit immensely from
this development.
SCALE AND
IMPACT OF
PARKING ISSUE
4. The key issue for business as regards
parking is central London—this relatively small area accounts
for a large percentage of the total fines incurred by our industry.
Furthermore it is in London that our industry has seen a large
and unsustainable rise in the level of parking fines issued since
decriminalisation. If the situation in London is left unchecked,
the actions of the Councils there may come to be seen as a model
by Councils in other areas of Britain—meaning that businesses
in cities across the UK could come to face the kind of difficult
situation that now exists in London.
5. We believe that a significant problem
has developed in central London over the last few years as regards
parking enforcement. AICES members saw the level of Penalty Charge
Notices (PCNs) issued more than double between 2002 and 2004.
This is not due to any significant change in operations by our
members.
6. It would appear that some local authorities
may be using the PCN regime as a revenue raising measure. Parking
attendants have been incentivised to issues PCNs. Due to our operating
patterns (regular times of deliveries etc), express delivery vehicles
are often seen as a "soft target" for the issuing of
PCNs.
Table
PARKING FINES IN LONDON FOR THE EXPRESS INDUSTRY1
|
| 2002
| 2003 | 2004
|
|
| Total (£) | 696,500
| 1,041,400 | 1,484,400
|
| Total % increase | —
| 49.5 | 113
|
| Year on year % | —
| 49.5 | 42.5
|
|
7. Such a steep rise in operating costs is making it
increasingly expensive for AICES members to service businesses
based in central London. It is clearly unsustainable for the express
delivery industry to continue to absorb this kind of cost without
it impacting upon prices paid by businesses in central London.
CAUSES OF
THE CURRENT
SITUATION
8. It is vital for the provision of our service that
road transport around London is as effective as possible—consequently
we fully support the efforts of parking enforcement officials
to keep arterial and strategic routes free of traffic impeding
parked vehicles. However we do not believe that the massive increase
in fines we are facing reflects such offences.
9. We believe a change of culture is need within parking
enforcement to ensure that delivery vans are not seen as a soft
target.
10. A further contributor to the current problems are
the policies on parking spaces of the central London local authorities.
We believe that to accommodate business demand, there is a need
for increased levels of kerbside parking spaces and loading bays.
Whilst these do not generate funds for the Local Authorities in
the same fashion as private parking spaces, it would fit with
the strategic needs of central London. Given the decrease in traffic
in the central London congestion charging zone we would argue
that there is a strong argument for shifting provision further
towards commercial use. Some Councils are examining this, and
we welcome this development.
11. The express industry is being penalised by rules
on use of loading spaces. It is usually specified with these spaces
that to qualify as legitimate delivery use, the vehicle be in
"constant use". Whilst this may be practicable for large
scale freight vehicles, express delivery vans are often manned
by just one person, and to meet our requirements as a regulated
agent under the Maritime and Aviation Security Act, and for insurance
purposes, must be locked when the driver is delivering the package.
12. We believe that appropriately liveried express delivery
vans should be automatically deemed to be active. Given the degree
to which our business is time sensitive (as opposed to the case
with standard freight) we do not believe this would cause a problem
in terms of lengthy use of loading spaces.
THE MOVE
FROM "QUANTITY"
TO "QUALITY"
13. Following discussions between industry groups and
the local authorities, such incentivisation has, in many cases,
been amended to measure "quality" rather than "quantity".
However, this still assesses number of tickets issued—albeit
taking in to account the number of tickets successfully challenged.
For example, the latest British Parking Association (BPA) Model
Contract for parking enforcement still lists "number of tickets
issued" as a potential key performance indicator, although
making allowance for those successfully challenged.
14. Using the number of PCNs not successfully challenged
as an indicator of quality is not necessarily reliable. The extent
to which PCNs are challenged may depend on general corporate policy.
More importantly, it does not address the issue of targeting minor
infringements that will produce large numbers of PCNs, as opposed
to focusing on major infringements that disrupt traffic flow or
cause a hazard but may only produce a few PCNs.
15. We believe therefore that un-challenged (or unsuccessfully
challenged) PCNs are not appropriate measure of quality and thus
should not be used as the basis for any future guidance on parking
enforcement.
THE POTENTIAL
ROLE OF
PLANNED DFT
GUIDANCE
16. AICES understands that the DfT will this Autumn be
developing new guidance for local authorities on parking policies.
The purpose of parking enforcement is, and should remain, to prevent
impediment to traffic flow, to protect the health and safety of
road users/pedestrians and to preserve access for local residents
and businesses. We believe that there is a need to reassert this
proper focus for parking enforcement in any future guidance.
17. Most of the measures proposed by the BPA in their
Model Contract (and currently used by local authorities) are output
rather than outcome driven and we believe a step change is needed
in this regard to prevent parking enforcement continuing to be
used as a covert means of revenue raising. AICES ask that the
Committee urge the DfT to examine the possibilities for using
measurements of traffic flow or incidents of disruption caused
by inappropriate parking, and assess their suitability as alternative
measures for remuneration of parking attendants. For example,
we believe there may be opportunities in London to use information
currently available to the Traffic Control Centre regarding traffic
speeds and congestion. This information is available in real time
and as historic data and could be used to assess how successful
the traffic management has been across the metropolis. If the
real objective of parking restrictions and the use of penalties
to enforce them is to ensure the free flow of traffic and safety
then the local authorities shouldn't really have any objection
to this measure.
18. Revenues raised by PCNs are current ring-fenced and
we would argue they should remain so. We have already seen the
impact on parking fine levels from Councils being able to retain
the revenue raised for spending on transport projects. Therefore
we would strenuously disagree with any measures which might increase
the desire of Councils to use PCNs as a revenue raising device,
such as removing the limitation to which the funds can be put.
19. The guidance also represents an opportunity to assert
the importance of parking provision for deliveries. Councils are
not financially incentivised to provide facilities for loading/unloading
(as opposed, for instance, to parking meter spaces for private
cars). The revised guidance needs to ensure that the business
community in general has sufficient access to loading facilities.
OTHER POTENTIAL
SOLUTIONS
20. We believe there may be benefits to be gained from
these following measures, and we would urge the Select Committee
to consider their potential merits:
— A "Code of Practice" for those involved
in the parking issue, including Local Authorities—setting
out appropriate enforcement practices, ensuring focus on protecting
traffic flow and other appropriate aims, rather than revenue raising.
Ideas on this subject are being developed by London First.
— A study of provision, and relative need for, parking
spaces in central London—loading bays and kerbside parking
versus car parking spaces.
— Increased provision of loading/unloading spaces.
— Improved signage of loading and non-loading areas—this
is frequently unclear at the moment. The time restrictions on
loading areas should also be made more clear—through an
increased number of "time plates".
— A change to the "in use" rule—as
set out above.
— Uniform parking regulations across central London—dealing
with differing regulations in each local authority area places
a significant burden on business.
21. These options are being developed by business groups
such as the Freight Transport Association CBI, London Chamber
of Commerce, London First, as well as sectoral bodies such as
ours. AICES supports these initiatives and commends them for the
Committee's consideration.
CONCLUSION
22. AICES welcomes this inquiry by the Select Committee
and hopes that it will be a step towards resolving the current
difficulties business is facing as regards parking and deliveries.
23. The massive increase in parking fines for express
delivery companies is a crucial issue faced by central London
business and by the UK as a whole. We hope the Committee will
be able to play a crucial role in promoting constructive developments
in this field to the benefit of business and local authorities.
24. We are willing to supply any further information
the Committee may find useful, and to give oral evidence if that
would be helpful.
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