APPENDIX 21
Memorandum submitted by Transport for
London
1. INTRODUCTION
1.1 The primary role of Transport for London
(TfL) is to implement the Mayor of London's Transport Strategy
and to manage transport services across the Capital. TfL is responsible
for London's buses; London Underground; the Docklands Light Railway;
the management of Croydon Tramlink and London River Services;
the 580km Transport for London Road Network; the London Traffic
Control System; the central London Congestion Charging scheme;
and regulation of the city's taxis and private hire trade.
1.2 Other agencies delivering transport
to, from and within London have a statutory duty to have regard
to the Mayor's Transport Strategy and his London Plan (the spatial
development strategy). TfL has established effective working arrangements
with the Driver and Vehicle Licensing Agency (DVLA), Vehicle and
Operator Services Agency (VOSA) and the Highways Agency (HA).
TfL is keen to see the development of these partnerships which
contribute to the delivery of the Mayor's transport strategies
and welcomes the Transport Committee's inquiry into the work of
the Department for Transport's Executive Agencies—DVO Group
and The Highways Agency.
2. DRIVER AND
VEHICLE LICENSING
AGENCY (DVLA)
2.1 TfL has established a good working relationship
and effective and efficient partnership arrangements with the
DVLA. The main services provided to TfL are the provision of vehicle
and keeper information for the enforcement of Congestion Charging,
moving traffic and parking contraventions and aiding the inputting
of correct vehicle registration details for the payment of the
congestion charge and registration of discounted and exempt vehicles.
Untaxed Vehicles/Copied, Stolen or Tampered Number
Plates
2.2 TfL recognises that uninsured, unlicensed
and untaxed vehicles account for a significant share of traffic
and parking contraventions and in many cases are likely to have
incorrectly registered keeper details which further undermines
effective enforcement. To help reduce this problem the TfL Congestion
Charging On Street Clamping and Removal operation has, since April
2005, enforced against untaxed vehicles using delegated powers
provided by the DVLA. This arrangement has been successful with
over 925 untaxed vehicles issued with warning notices, clamped
or removed at no additional cost to TfL. TfL would like to see
greater priority be given by DVLA and other agencies to the enforcement
of uninsured, unlicensed and untaxed vehicles.
2.3 From TfL's road safety perspective,
"the coordination of systems and sharing of information between
agencies is of paramount importance". Unlicensed vehicles
and drivers are disproportionately involved in collisions (especially
those causing death and serious injury), so better information
to Police patrols is crucial. TfL would wish to see improvements
in accessibility of information from the DVLA to Police Forces,
in order to increase the likelihood of detection of unlicensed
vehicles and drivers.
2.4 Number plate tampering, copying and
theft also undermine effective enforcement using Automated Number
Plate Recognition Systems (ANPR). This has been addressed in part
by the introduction of regulations enforced by DVLA and Local
Authority Trading Standards agents governing the issue of number
plates. However more could be done and TfL suggests that the Department
for Transport (DfT)/DVLA consider the expansion of devolved powers
as highlighted in 2.2 above to include enforcement of vehicles
found on street to be displaying illegal, copied or stolen numberplates.
Consideration should also be given to the adoption of new technologies
to better control the issue of number plates and to prevent copying
and tampering.
Accuracy of data provided by DVLA
2.5 TfL currently issues around two million
Penalty Charge Notices (PCNs) per annum to vehicles which commit
civil traffic contraventions such as driving in bus lanes, driving
in the Congestion Charging zone without payment of the required
charge, other moving traffic contraventions such as non-compliance
with banned turns, and parking on red routes.
2.6 The provision of accurate, up to date
vehicle and keeper details from the DVLA is essential to the effective
and fair enforcement of these contraventions. Initiatives such
as continuous registration of keeper details and the issue of
penalties for untaxed vehicles directly from the DVLA record have
therefore been welcomed. However, TfL considers that further improvements
could be made. For example, TfL would like DfT/DVLA to consider
the greater use of new technology with existing partners, such
as the Post Office, to improve the accuracy and timeliness with
which the DVLA record is updated. This could be further enhanced
by new legislation that required the transfer of vehicle arrangements
to be conducted by both purchaser and vendor through the Post
Office as is the case in some other European Union (EU) states.
Foreign registered vehicles
2.7 The enforcement of civil traffic and
parking contraventions is limited by current powers in relation
to foreign registered vehicles. Whilst the impact on overall compliance
and the effectiveness of existing parking, charging and traffic
schemes is small; there is an urgent need to address two major
issues to change this situation, which is set to get worse as
more traffic and parking contraventions become decriminalised
across the UK and new initiatives such as the London Low Emission
Zone are introduced:
(i) The lack of availability and co-ordination
of vehicle and keeper information related to evading foreign registered
vehicles.
(ii) The lack of EU wide legislation that
enables the legal enforcement of civil penalties incurred by foreign
registered motorists in the UK to be enforced in their country
of residence (or vice versa).
2.8 The lack of keeper information and the
legislative framework to enforce means agencies, such as TfL,
resort to "best endeavours" to enforce contraventions
committed by foreign registered vehicles. In TfL's case this involves
the use of a contract with a European Debt Recovery Agency which
attempts to obtain the keeper information on a piecemeal basis
from each relevant EU DVLA equivalent.
2.9 The DVLA has extensive experience and
knowledge of such issues and has been an active participant at
various meetings, initiatives and discussions to identify possible
solutions to the problems. In addition the DVLA has been represented
at the Enforcement Task Force, a working group made up of TfL,
the Police, the Association of London Government and other interested
parties which was established to co-ordinate, at a high level,
the enforcement activities and initiatives being undertaken across
London. TfL believes that the DVLA is ideally positioned to take
a more active role in the effective delivery of short and long
term remedies to these issues.
2.10 In particular TfL would like the DfT/DVLA
to take a more direct and leading role in (i) the provision of
one single interface and database of vehicle and keeper data for
all UK based enforcement agencies into other EU States licensing
agencies so that such data can be used for following up contraventions
incurred by foreign registered vehicles and (ii) lobbying for
the speedy implementation of EU wide legislation for the enforcement
of civil penalties incurred by non UK registered motorists (and
vice versa).
Low Emission Zone
2.11 TfL is currently working on developing
proposals for the introduction, subject to two rounds of public
consultation, of the Mayor's proposed Low Emission Zone (LEZ)
for Greater London. The proposed scheme would discourage use of
the most polluting vehicles by introducing a significant daily
charge for driving in Greater London for non compliant vehicles
and a proportionally high PCN for non compliance with charge payment.
The proposed emission standard for the LEZ will be Euro III for
particulates (PM10). All vehicles manufactured since January 2001
comply with the Euro III standard or greater and these would be
able to operate in the proposed LEZ without a charge. In addition,
pre Euro III vehicles would be allowed to operate in the zone
without charge if steps had been taken to meet the Euro III standard,
for example by fitting particulate traps to their vehicles. It
is currently proposed that from early 2008 the LEZ would apply
to diesel-engined buses, coaches and HGVs over 7.5 tonnes and
from mid 2008 for HGVs between 3.5 to 7.5 tonnes.
2.12 The support and co-operation of the
DVLA and VOSA is considered essential for the introduction and
effective operation of the LEZ. TfL is looking to use the existing
Congestion Charging interfaces with DVLA to provide the basis
for requesting and providing vehicle and keeper details and the
identification of non compliant LEZ vehicles. TfL is of the view
that the DVLA, with the remit of recording and provision of relevant
vehicle information for enforcement purposes are ideally situated
to record, retain and provide information relating to the Reduced
Pollution Certificates issued by VOSA to non Low Emission Zone
compliant vehicles which are subsequently fitted with approved
types of abatement equipment.
3. VEHICLE AND
OPERATOR SERVICES
AGENCY (VOSA)
3.1 VOSA currently provides an inspection
service to issue annual Reduced Pollution Certificates (RPCs)
for UK vehicles fitted with Particulate Abatement devices, or
re-engined to reduce harmful emissions. The continuation of this
role is vital and, in order to facilitate the effective introduction
and enforcement of the LEZ, TfL is looking to VOSA to introduce
effective online interfaces to enable "real time" updates
of RPC information onto the DVLA database and for this information
to be made available to TfL.
3.2 VOSA also provides an inspection service
to monitor vehicle maintenance standards within the bus industry.
For London bus contractors, TfL supplements these inspections
with its own inspection programme undertaken on our behalf by
the Freight Transport Association. We understand that it is VOSAs
intention to improve the targeting of its own checks by concentrating
resources on those most likely to be breaking the law; this approach
is welcomed.
4. VEHICLE CERTIFICATION
AGENCY (VCA)
TfL has no comments on the services provided
by the VCA.
5. DRIVING STANDARDS
AGENCY (DSA)
5.1 London Buses has been fully involved
with the DSA as part of the consultation for the implementation
of the EU Training Directive which will impact on the role of
the DSA with regards to driver licensing. TfL supports the EU
training directive but believes that the DSA needs to be given
adequate resources to implement and support the Directive.
5.2 The DSA also provide a Driver Quality
Monitoring service under a commercial contract to TfL. This contract
is one of the key methods used by TfL to monitor bus driver standards.
5.3 Driving standards are an important factor
in road safety and TfL regularly uses data from DSA. We would
like to see data on the "number of tests before passing"
and "drivers banned" (for various reasons), available
by age and geographical location. TfL hopes as well that the review
will look into the possibility of DSA promoting on-going Continual
Professional Development for driving instructors.
5.4 DSA has two publications—"Dispatch"
and "Drive on"—which we think could have their
scope extended and be made more general, to the wider benefit
of road safety professionals.
6. HIGHWAYS AGENCY
(HA)
6.1 TfL acknowledges that the HA is rightly
changing its emphasis from purely asset management to include
strategic operational management and this is welcomed.
6.2 The HA is not bound by the requirements
of the Traffic Management Act that relate to the Network Management
Duty (NMD). This requires local traffic authorities, such as TfL
and the London Boroughs, to work together to achieve the expeditious
movement of traffic (all modes). TfL was pleased, however, to
note an assurance from the Secretary of State that the HA would
comply with the NMD.
6.3 The HA is responsible for the M25 and
the motorway and trunk road spurs within the M25 that connect
directly with the Transport for London Road Network (TLRN). Development
plans and operational strategies for these can have a direct and
very significant impact on traffic operations on London's strategic
road network and vice versa. It is thus imperative that early
effective and on-going engagement takes place between the HA and
TfL to ensure that:
— policy objectives for the Capital's
motorway and trunk roads and the TLRN is clear, coherent and consistent
with the Mayor's Transport Strategy;
— proposed network developments are
well-coordinated and executed to minimise disruption to road users;
— operational and information strategies
are coherent and well-communicated; and
— information systems and protocols
are compatible and efficient.
6.4 TfL is developing LondonWorks, a system
and protocol for the planning and coordination of works, events
and other activities that can disrupt traffic operations on the
Capital's road network, for use by all highway authorities and
utility companies active on the London network. LondonWorks will
provide visibility of all such planned (and, indeed, emergency)
activity, to enable a step change in the potential for coordination
of works (and "trench sharing") and enable the London
Traffic Control Centre to plan traffic operational contingency
plans in advance, to minimise inconvenience to road users. It
is imperative that all such activity on the M25 and motorways
and trunk road spurs within the M25 is incorporated within LondonWorks
as it develops—TfL is in dialogue with the HA to this end.
7. CONCLUSION
7.1 TfL believes that the services provided
by the DVO agencies make a real contribution to the effective
delivery and enforcement of DfT and TfL policies. TfL also believes
that the DVLA and the VCO are ideally positioned to support the
expansion of civil enforcement of parking, traffic, air quality
and charging schemes in London and across the UK.
7.2 TfL considers it essential that the
relevant agencies are provided with clear direction by the DfT
in respect of the effective deployment and use of new technologies
and facilities that ensure more accurate recording and provision
of up to date vehicle and keeper data; the on going development
of vehicle emission testing and certification; the introduction
of flexible systems and expansion of databases; facilitating the
effective enforcement of foreign registered vehicles, and in particular
TfL requests that:
— Greater priority is given by DVLA
and other agencies to the enforcement of uninsured, unlicensed
and untaxed vehicles.
— DfT/DVLA consider the expansion of
devolved powers to include enforcement of vehicles found on street
to be displaying illegal, copied or stolen number plates.
— Further consideration is given to
the adoption of new technologies to better control the issue of
number plates and to prevent copying and tampering.
— DfT/DVLA consider increased use of
new technology with existing partners such as the Post Office
to improve the accuracy and timeliness that the DVLA record is
updated. This could be further enhanced by new legislation that
required the transfer of vehicle arrangements to be conducted
by both purchaser and vendor through the Post Office as is the
case in some other EU states.
— DfT/DVLA take a more direct and leading
role in (i) the provision of one single interface and database
of vehicle and keeper data for all UK based enforcement agencies
into other EU States licensing agencies so that such data can
be used for following up contraventions incurred by foreign registered
vehicles and (ii) lobbying for the speedy implementation of EU
wide legislation for the enforcement of civil penalties incurred
by non UK registered motorists (and vice versa).
— VOSA introduced effective online
interfaces to enable "real time" updates of RPC information
onto the DVLA database and for this information to be made available
to TfL.
7.3 TfL believes that significant advantages
to road safety could be gained through DSA considering sharing
unlicensed vehicle data, driver licence data and investigating
promoting on-going Continual Professional Development for driving
instructors. TfL similarly considers that DSA might broaden the
scope of its publications, to the benefit of road safety professionals.
7.4 TfL welcomes the HA's shift in emphasis
towards operational management. TfL is seeking full, effective
and on-going dialogue with the HA in regard to the M25 and motorway
and trunk road spurs within the Capital on:
— policy and plans for their development
and operation;
— forward visibility and coordination
of works;
— operational and information strategies;
and
— compatibility of information systems
and coherence in information provision.
10 January 2006
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