APPENDIX 16
Memorandum submitted by the British Retail
Consortium
1. The British Retail Consortium (BRC) is
the lead trade association of UK retailing and exists to defend
and enhance where possible, the economic, political and social
climate in which its members operate. BRC members sell a wide
selection of products through centre of town, out of town, rural
and virtual stores. Reflecting the diversity of modern retailing,
BRC members include the large multiples and department stores,
charity shops and small and medium sized independent retailers.
In 2004 retail sales totalled £246 billion representing 35%
of total consumer spending, channelled through 184,700 VAT registered
retail businesses. The retail industry employs nearly 3 million
people and accounts for one in nine (11%) of the total UK workforce.
SUMMARY
2. Transport is vital to success of the
retail industry. Retailers rely on access to transport for the
daily operation of their business—to access their customer
base, deliver goods, and to enable their employees to reach the
workplace. Weak transport links and inadequate parking provision
threaten the viability of the retail sector and jeopardise the
sector's contribution to the UK economy. Delivery restrictions,
charging schemes, car parking and public transport must take into
consideration retail needs to ensure that town centre and urban
developments continue to attract sustained retail investment.
3. Customers should be able to arrive and
leave easily by a variety of modes of transport, including by
car, particularly for goods that by virtue of their size or collective
weight cannot be carried on public transport. Clearly, the driving
public would prefer to have free, and unrestricted parking. However,
they will be prepared to accept some form of control if it is
delivered in the right way. If car-parking provision in the town
centre is poorly located, unfairly or badly managed or if it is
simply insufficient to meet demand, retail customers will literally
be driven away.
4. In order to ensure that retail continues
to make a vital contribution to the success of our towns, cities
and rural communities, the retail industry wants the Government
to:
— Promote a greater alignment between
planning policy and transport policy to maximise access and connectivity
between retail locations and the communities they serve.
— Maintain current parking standards—further
caps on parking spaces will act as a disincentive to new retail
development and will mean that in marginal locations development
will simply not take place.
— Encourage local authorities to enforce
parking control reasonably, fairly and accountably—car park
management should not be used simply as a means of raising revenue
through penalty notices.
— Promote convenient, well run and
safe town car parks; high quality car parks create an image for
the town and are essential for a vibrant retail centre.
— Ensure that local authorities structure
charging regimes and payment bandings carefully in order to maximise
car parking space use.
— Support the relaxation of local delivery
restrictions where appropriate—pushing delivery vehicles
into peak travel times contributes to congestion and increases
CO2 emissions.
PROMOTE A
GREATER ALIGNMENT
BETWEEN PLANNING
AND TRANSPORT
POLICY
5. Government policy should encourage local
authorities to develop a greater alignment between retail and
transport planning. Current planning policy is designed to meet
local needs by allowing local communities to shop locally but
says nothing of the barriers which make town centre operations
difficult. For retailers there are a number of reasons why the
town centre is not attractive, such as poor transport links, inadequate
parking facilities, and restrictions on deliveries.
6. Insufficient parking provision reduces
the viability of the town centre as a retail trading location.
Current planning guidance recommends as standard a maximum of
one parking space per 14m2 for food retail and one parking space
per 20m2 for non-food retail (for retail outlets in excess of
1000m2). Since the introduction of PPG13 in 2001, retailers have
come to accept these standards as being more realistic than previous
measures to manage parking provision.
7. Evidence suggests that the current standards
work quite well for out-of-town retail but are often inadequate
for mixed use or town centre developments since they do not take
account of the duration of stay—ie the turnover of spaces.
For example, a visit to do a main food shop might take 45 minutes
in an out of centre location. However, in a town centre or edge
of centre location shoppers will often carry out linked trips
to other shops or to access other town centre services and may
stay in that space for an hour and half or longer. Ideally, in
these locations, parking provision should be flexible enough to
provide some longer stay parking to give customers enough time
to shop locally and visit the town centre comfortably.
FAIR, WELL-RUN
LOCAL AUTHORITY
PARKING
8. The goal of car park management should
be to ensure that sufficient spaces are available for the intended
users—it should not be used simply as a means of raising
revenue through penalty notices. It is difficult to accurately
assess whether local authorities are carrying out parking control
in a reasonable, fair and accountable way since there have been
very few attempts to monitor enforcement practices. Many local
authorities now outsource parking control functions to parking
management companies and a study should be undertaken to evaluate
whether individual contracts are constructed in the public interest.
9. Statutory guidance might be helpful if
it clarified the purpose of parking control—namely to promote
the town centre and ensure that parking abuse is not taking place.
Guidance might also be able to suggest useful mechanisms such
as "free parking on Tuesday mornings" or free late night
or Christmas parking. It is important that local authorities retain
some autonomy to manage parking in a way that balances the needs
of their towns. Revenue generated by enforcement should be ring
fenced to provide improvement in the quality of car parking in
the town; improved security, lighting, landscape maintenance,
signage and ultimately towards increasing the overall parking
provision of the town.
AFFORDABLE AND
SAFE TOWN
CENTRE PARKING
10. Quality, convenient, well-run, and secure
car parks create an image for the town and are essential for a
vibrant and diverse retail centre. Unfortunately, the cost of
car parking is often prohibitive and in particular seems to penalise
short-stay customers. Car parking charges must be seen to offer
value for money if the town centre is to remain competitive and
retain a diverse retail offer.
11. Charging regimes and payment bandings
need to be structured carefully in order for the local authority
to manage car parking space most effectively. Many car parks charge
by the hour but this "one-size fits all approach" might
not be suited to all town centre requirements. In large centres,
retail customers may require up to three hours at reasonable rates.
Alternatively, in small market towns—where trips are shorter—price
bandings should be more flexible and allow customers to park for
brief shopping journeys.
12. Ticket and payment machines can issue
different price band tickets at different times of day or year
(eg special evening or Sunday rates). Charges can be levied in
three ways:
13. Pay and Display is cheaper to operate
but does not offer the vehicle security that the latter options
provide. If a customer uses Pay and Display they must predict
how long their shopping trip will take. An enjoyable shopping
trip can be brought to a hasty end in order to avoid "getting
a ticket" and often results in loss of revenue for some retailers.
Payment on exit and on foot allows customers greater flexibility
and increased security.
14. Vehicle security and personal safety
are of vital importance to the success of town centre car parks.
Well-lit, brightly painted and clean car parks, stairwells and
linkages go some way to alleviating these fears. Ideally, 24-hour
security cameras (CCTV) covering the whole of the car park should
be installed and monitored on a regular basis.
15. Fear of personal attack is matched by
a fear of car crime. The Home Office reports that although vehicle
crime is on the decrease there are still over 2 million reported
car thefts annually. Barrier operated car parks not only avoid
the need to display the return time on the windscreen (unlike
"Pay and Display") but prevent the vehicle leaving the
car park without the owner and their ticket. A "payment on
foot" policy where the customer obtains a ticket on arrival
and then pays at a self-service machine on their return to the
car park makes the need for barriers to be manned obsolete. A
visible security presence (combined with police patrols or Car
Watch schemes) also helps to allay customer concerns and deters
the opportunist criminal.
RETAIL DELIVERIES
16. Deliveries are important to all industries,
but particularly to the retail industry, where the primary business
function is to bring products and services to customers. The retail
consumer increasingly expects a full range of high quality products,
available throughout the year at reasonable prices. The challenge
for retailers is to balance the need to reduce cost and streamline
operations with the need to have products available at all times.
17. In striving to make deliveries as efficient
as possible, retailers seek to avoid traffic congestion and so
aim to avoid peak travel times, by making use of the road during
the night. However, store access can be restricted by delivery
curfews, as a result of planning restrictions established when
the store is built or noise abatement orders implemented by a
local authority after the store has opened. Almost one third of
retailers are affected in this way.
18. Freight transport technologies have
advanced in recent years to provide quieter deliveries. While
retailers are demonstrating good practice by investing in noise
abatement technologies and specific training for their drivers,
there is scope for local government to consider levying delivery
curfews on a case-by-case basis, when they are suitably justified.
It also strengthens the case for more flexible curfews, with a
relaxation of 1-2 hours on either side of the existing delivery
curfew time.
19. The removal of delivery curfews and
improving the operation of freight vehicles could potentially
offer significant benefits to everyone by reducing congestion
and bringing environmental benefits. Being able to deliver at
night would remove some lorries from the peak traffic travel periods,
allow optimisation of the road network and maximise the availability
of products for customers.
WORKPLACE PARKING
LEVIES
20. Workplace parking levies will have a
detrimental impact upon the viability of affected businesses and
will do little to tackle the real problems of congestion. By charging
business it does not target the motorist and in so fails the stated
objective of reducing congestion and instead it penalises business
and acts as a disincentive to investment.
21. It is recognised that whether or not
the charge is passed on to staff, businesses affected will incur
a severe administrative and financial burden, in assessing parking
and collecting charges. One particular anomaly will be that some
staff will be that some staff may wish to use their car more often
when they have "paid" for a car parking space. Currently
they may be a car sharer or occasional bus or cycle user. In which
case, rather than reducing congestion, workplace parking levies
could potentially create more congestion as car users take advantage
of their "paid for" car parking space.
22. Many retail employees work early morning
or late evening shifts, which are not covered by public transport
and so have no choice but to drive to work. This problem is further
exacerbated in rural and remote locations, where public transport
is not a viable alternative. Furthermore, as car parking spaces
are already part of the rating assessment for out of town retail
developments, a levy on these sites would represent a second charge
for the same parking provision.
ALTERNATIVE TRANSPORT
STRATEGIES
23. Retailers have explored a variety of
initiatives designed to promote alternatives to car based shopping.
Various measure include providing free bus services for customers,
provision of bicycle parks for customers and employees, and free-phone
links with local mini-cab drivers.
Park and Ride
24. Park and Ride schemes offer customers
a suitable alternative to in-town parking. When managed effectively,
Park and Ride schemes have the potential to alleviate congestion
and car-parking pressures in town centres by promoting commuter
parking outside of town and city centres. Location is key to the
success of every Park and Ride Scheme. They should be located
on the main routes into the town and should be integrated with
railway stations and other major public transport interchanges.
25. If a customer has to deviate from their
route to find a Park and Ride site the easy alternative is to
keep on driving into the town centre. Park and Ride must be prominently
signed; the signage should clearly state where to park, the cost
and the frequency of service. Security is paramount, both for
customers and their cars. CCTV should be combined with effective
lighting and security patrols.
26. The cost of Park and Ride should be
competitive versus town centre car parks to provide a clear incentive.
The service must be frequent—no longer than 10-minute intervals.
If Park and Ride buses can be given priority into a town centre
they have a visible, as well as timed, advantage over cars.
Green travel plans
27. The majority of retailers now have travel
plans in place to promote greener travel choices and reduce reliance
on the car. Retailers make every effort to ensure these plans
are successful in encouraging staff and customers to make use
of more environmentally friendly alternatives than driving alone,
at least for some of their journeys. Many retailers regularly
assess the performance of individual travel plans and adapt the
plan in accordance with the changing circumstances of their business
operations. Travel plans are now also a regular feature of the
planning process and retailers work very closely with local planning
authorities to agree the formulation of travel plans during Section
106 negotiations.
Cycling
28. It is essential that local authorities
take the lead in ensuring that there is adequate bike parking
provision in close proximately to shops on the high street. Provision
of good quality cycle parking in town centres and particularly
on the high street is a key element in encouraging people to cycle
more. In a study by the Automobile Association, 86% of cyclists
interviewed considered that there was insufficient cycle parking
in public spaces, and equally high numbers said that they would
cycle more if secure cycle parking were available.
29. Retailers are increasingly examining
the role cycling can play in reducing pressure on car parking
spaces and in order to meet criteria set out in their green travel
plans or as part of Section 106 agreements. Where appropriate,
retailers in town centre and edge of town locations have installed
secure cycle parking for both customers and employees.
CONGESTION
30. Congestion represents a significant
cost to retailers who rely on the road network for access to customers,
staff, and the delivery of the goods they sell. It is essential
however that charging schemes are developed in partnership with
the local retail and business community. With the high fixed costs
retailers pay to trade in town centre locations, even the smallest
variations in sales can have a disproportionate impact on retail
profits and hence on investment and location decisions.
31. Many town centres demonstrate the risk
that well-meaning traffic control measures or attempts to improve
the use of public transport may in fact achieve exactly the opposite.
Public transport plans are in the main designed to radiate to
and from town centres and little attention is given to how public
transportation can be managed differently to increase the connectivity
within the retail network and link underserved communities with
retail provision. Equally little attention is paid to find alternative
ways to manage the car use that will maximise accessibility and
meet environmental objectives at the same time.
32. The introduction of congestion charging
schemes and other traffic control measures can be a strong disincentive
to visiting town centres, while increasing parking charges simply
punishes motorists without achieving any impact on reducing congestion.
There must be real incentives to use public transport, rather
than costly deterrents from driving. A greater alignment between
planning for retail and transportation is essential if retailers
are to succeed in delivering a retail led urban renaissance.
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