APPENDIX 27
Supplementary memorandum submitted by
the Association of International Couriers and Express Services
AICES provided a written submission to the Transport
Committee ahead of the two evidence sessions held in December
(submission attached). We were pleased that as Chairman you took
up our concerns as expressed in our original memorandum with the
witnesses who attended the first oral evidence session to represent
those contracted by local authorities to provide on-street enforcement
services.
However, as we were not able to attend to give
oral evidence, we wish to submit this further written submission
to clarify our position in light of the statements made at the
committee by Mr Macnaughton, the Chief Executive of National Car
Parks.
In Question 49 (from the first draft transcript
of the meeting) you asked Mr Bob Macnaughton from NCP about our
concerns regarding the way that loading and unloading guidance
is interpreted by local authorities. Mr Macnaughton is recorded
as stating that "one of the issues with the express delivery
people is that they have a little knowledge about the rules, but
they do not have a lot of knowledge".
We would like to make it clear that as an industry
we have much more knowledge that Mr Macnaughton claims. We fully
accept that some penalty notices are issued quite correctly where
the rules are infringed and in these cases we do not appeal.
However, it is now the position that a large
number of penalty notices are issued where loading restrictions
(as designated by one or two yellow "blips" marked at
90 degrees to the main yellow line) do not apply, but the warden
cannot see someone with the vehicle and chooses not to wait to
verify whether loading or unloading activity is taking place.
In these circumstances our members regularly appeal against the
PCN.
When offences do occur it is usually because
there is simply too little (or no) space allocated in a street
for loading and unloading to take place.
The issues arising from this are:
(1) it is very often the wardens who do not
know what the law and/or guidance is on loading and unloading
and they are mis-applying the regulations with reference to unattended
vehicles; and
(2) there is simply too little loading and
unloading space provided leading to the rules being broken through
necessity not choice. This is primarily a central London issue.
In relation to point 1, it is clear that where
livened delivery vehicles are concerned (and all our members operate
clearly marked delivery fleets) there should be a presumption
that the livened delivery vehicle is in the process of making
a pick-up or collection. It should be obvious from an enforcement
point of view that our livened express delivery fleets are a high
value asset primarily concerned with the business of collecting
and delivering as expeditiously as possible and will not be parked
for any other reason.
In relation to point 2, we would reiterate that
there needs to be a fundamental review of parking space usage
across the Boroughs in central London post-congestion charge.
as presently there is a significant under-utilisation of current
on-street parking bays designed and designated for car users.
It is our view that significant scope exists in central London
for creating new loading/unloading spaces on the street to address
the lack of space for delivery vehicles and to reflect the reality
of significantly reduced demand for on-street car parking. However,
as noted during the second day of oral evidence to the committee,
there are revenue implications for the local authorities who maintain
the extensive network of street parking spaces in converting some
of that capacity to loading bays. We believe though, that the
focus of parking and vehicle management is supposed to be the
free flow of traffic not local government income and that such
a conversion of road space would greatly benefit that flow.
I am pleased that the second day of oral evidence
provided some discussion of both these points. Nonetheless, we
hope that when framing your final report our additional points
are taken into account and recorded as supplementary written evidence
to address the comments made by witnesses on the first day of
evidence in response to our original submission.
13 January 2006
| 
