Parking charges consultation - Merton Lib Dem response


parking_2018.jpegPlease find the response of Merton Liberal Democrats and the Liberal Democrat Council group on Merton Council below.

In addition, we would like to submit the (currently) 1092-strong petition stating “We, the undersigned, call on Merton to scrap its plan to double parking charges in Wimbledon and Raynes Park. Any replacement scheme should be based on clear evidence that it will improve air quality, and not unproven assertions” attached.

Executive summary:

We believe Merton Council should scrap its plans to massively increase parking charges based on where people live. We believe it should instead bring forward proposals for parking charges based on emissions, testing and shaping these proposals using evidence from its planned review of the diesel levy and emissions based charges (expediting that review if necessary), and learning lessons from similar schemes adopted by other London Boroughs. For us, a key factor is providing real, practical help to enable residents to switch to greener transport options.

Please find our responses to the set questions below.

Q1. To what extent do you agree or disagree with the following statements:

1a. “Merton has a key role to play in tackling the challenges to Public Health we are currently facing”

Response: Strongly agree

1b. “Merton Council should encourage motorists towards more sustainable and active modes of transport such as walking and cycling, which contributes to improved air quality and public health”

Response: Agree

Comments: Parking charges policy cannot legally be a revenue raising strategy. While we agree that the Council has a key role to play in encouraging people to use sustainable and active modes of transport, it’s clear that some residents will need help switching to greener transport options.

Any policy should bear in mind that people with young children and / or mobility issues may not easily be able to use public transport / walk / cycle. Equally, there are parts of the borough that lack effective public transport options.

1c. “Merton Council should prioritise lower polluting vehicles by offering a lower parking charge over highly polluting vehicles”

Response: Agree

Comments: Changing to less polluting vehicles should clearly be prioritised, but (as for 1b above) we recognise that some residents will need help switching to greener transport options. This is especially true for those who bought diesel vehicles on the understanding that they were more environmentally friendly, based on Government advice.

There are other forms of action that the Council could use to help encourage the purchase of lower polluting vehicles beyond simply the application of higher or lower parking charges, for example scrappage schemes for older cars, or 'sunrise provisions' ie only applying emissions-based charges to new applications for residents parking permits (with appropriate sunset provisions).

Q2. What other things would you like to see Merton Council do to address public health and air quality issues.

Comments: As per 1c above, there are other forms of action that the Council could use to help encourage the purchase of lower polluting vehicles, for example scrappage schemes for older cars, or only applying emissions based charges to new applications for residents parking permits (with appropriate sunset provisions).

We would like to see genuine consideration of the extension of the Mayor of London’s ULEZ or a mini ULEZ. Action to limit the number of high polluting HGVs travelling through the borough, and Low emission bus zones, like in Putney, should also be considered.

We feel that an Air Quality Scrutiny Champion, as we proposed in the Council meeting on 6th February, would improve the monitoring and implementation of Merton’s air quality action plan.

Q3. To what extent do you agree or disagree with the following principles for managing parking in Merton.

3a. “Charges for parking and permits should relate to the ease of access to public transport with areas close to the best transport links charged more”

Response: Strongly disagree for residents’ and visitor permits.

Comments: We strongly disagree that charges for parking and permits should depend on the area that the vehicle happens to be parked in.

The Council has failed to provide any evidence that its specific proposal will lead to residents giving up cars, use them less frequently, or use public transport more (instead of simply driving somewhere else), so it seems unlikely that this additional charge will improve air quality or provide any other public health benefit. Anecdotally, when asked at both the Raynes Park and Wimbledon Community Forums, no resident felt that the proposed charges would lead to them giving up their vehicle (which is the only way that any scheme the links charges to area could improve air quality).

3b. “Charges for parking should relate to the level of congestion with the most congested areas charged more”

Response: Disagree

Comments: There is a lack of evidence supporting the idea that increasing - especially residents - parking charges reduces traffic / congestion (although we note that Merton's proposals aren't to link charges to parking to levels of congestion).

3c. “The Council should develop the use of our car parks to support more sustainable forms of transport, such as secure cycle parking, improved motorbike security, electric charging points and improved lighting”

Response: Strongly agree

Comments: In particular we would like to see rapid electric car charging points installed in town centres, to encourage both electric car usage, and use of local businesses.

Q4. To what extent do you agree or disagree that car park season ticket charges should offer discounts for the following:

Comment: Discounts should be applied where they support local workers’ contribution to the local economy, or the use of more environmentally friendly vehicles.

4a. Longer term season tickets

Response: Agree

4b. Electric vehicles

Response: Strongly agree

4c. Residents

Response: Disagree

4d. Local workers

Response: Agree

Q5. To what extent do you agree or disagree that car park season ticket charges should be higher for the following

5a. More polluting vehicles

Response: Strongly agree

5b. Rail heading (those driving into Merton to join the rail network)

Response: Disagree

Comments: It seems illogical to penalise those who are utilising public transport for part of the journey. Plus “rail headers” use local shops.

5c. In areas with higher levels of demand

Response: Agree

Comments: Car parking charges can legitimately be used to help manage demand.

Q6. To what extent do you agree or disagree with the following approaches to residents parking permits.

6a. “Charges for residents parking permits should be lower for zones with shorter hours of operation and higher for longer hours of operations”

Response: n/a

Comment: There is some logic to the idea that zones with longer hours of operation require greater resources to manage. However, when CPZs have been brought in at residents’ request this hasn’t been a factor. So it seems unfair to penalise residents who live in existing CPZs in this way, although it could make sense for new schemes.  

6b. “The accessibility of local Public Transport links should be a factor in the setting of charges for residents parking permits”

Response: Strongly disagree

Comments: We strongly disagree that the cost of residential and visitor parking permits should depend on geographical criteria.

Furthermore, the Council has failed to provide any evidence that increasing residents’ parking permit charges on a geographical basis will lead to residents giving up cars or using them less frequently, so it seems unlikely that this additional charge will improve air quality or provide any other public health benefit. Anecdotally, when asked at both the Raynes Park and Wimbledon Community Forums, no resident in attendance felt that the proposed charges would lead to them giving up their vehicle (which is the only way that any scheme the links charges to area could improve air quality).

6c. “Charges for residents parking permits should be lower for electric vehicles and least polluting vehicles and higher for the most polluting vehicles”

Response: Strongly agree.

Comment: As vehicle emissions have a direct relationship to air quality and emissions-based charging conforms to the ‘polluter pays’ principle, there is a clear logic that action should be taken to encourage the switch to less polluting vehicles. However, our position is that alongside this strong and suitable “mitigation” should be offered to assist residents - especially the lowest earning families - to change to greener vehicles.

Q7. To what extent do you agree or disagree that the proposed charges have been set at a level which will help achieve the objectives to encourage active travel and sustainable transport, and help reduce congestion and air pollution.

7a. On-street parking

Response: Strongly disagree

7b. Car parks

Response: Strongly disagree

7c. Residents permits

Response: Strongly disagree

7d. Car park season tickets

Response: Strongly disagree

Comment: See responses to other questions above, and response to qu 8 below.

There is an equality issue that does not seem to have been adequately addressed by the Council’s proposals: properties with off-street parking will be unaffected by these changes, and the majority of these will be bigger/more expensive properties occupied by those with higher incomes. As such, the scheme disproportionately impacts those on middle and lower incomes. This seems especially unjustifiable when the charges are applied on the basis of geographical criteria (ie not something that the resident can easily control). We might also raise the impact across the borough seems unbalanced, with more CPZs in the west of the borough.

Furthermore, we feel that the huge additional cost being applied to annual visitor permits is unjustifiable if no separate/different provision is made for residents who have only an annual visitors’ permit, but who don’t have any residents’ permits. The scheme could therefore be said to discriminate against those without cars but who need regular visitors, such as some older people and some people with disabilities.

Q8. Do you have any further comments about how we propose to manage parking in Merton in the future?

Response: Merton Council has not demonstrated that their proposed parking charges will reduce car ownership or traffic movements, and thereby improve air quality.

At the Sustainable Communities Overview and Scrutiny Panel on 9 January 2019, officers were asked what evidence they had to to support the hypothesis that an increase in parking charges would lead to reduced pollution. They referred to “academic studies” and in subsequent correspondence with Cllr McGrath about this he was sent the link to a study from the Institute of Transport Studies at Leeds University. What that said was: "The responsiveness of the demand for vehicle travel in relation to parking charges varies depending upon the availability of alternatives. Figures for price elasticity of demand for parking activity with respect to parking charges are quoted as being in the range -0.1 to -0.4 (Feeney, 1989; Pratt, 1999), meaning that a 10% increase in parking charge will result in a 1%-4% reduction in parking activity."

We have reviewed both of these papers. Feeney refers to a paper produced in 1988 and the paper is "largely but not exclusively on the effect of parking policy measures on commuting travel". The paper includes a table referencing 19 studies, a number of which it states it has not been able to use. These studies range in date from 1956 to 1979 with the majority being in the 19960s and 1970s. They range in location from Karachi to Sydney with a majority in the US. Only one study refers to the UK and that is from Livingston in Scotland.

Feeney says that there is “very little evidence of the effects of changing parking charges at specific locations". The do quote one study of municipal car parking in Chicago where an increase in parking charges causes a reduction in long term parking but an increase in short term use - possibly due to the increased availability of parking.

Feeney also looks at the effect of abolishing free parking for work site parking in particularly three cases in Canada and Los Angeles where very substantial reductions were found. This is of interest given that half of Merton Council's own employee have free parking.

It should be noted that this paper does not in fact provide any estimates for the elasticity of demand for parking charges.

Pratt’s paper Traveler Response to Transportation System Changes is a substantial paper produced for the Transportation Research Board in the US. It says "Research appears to corroborate conventional wisdom that parking demand, as measured strictly by number of cars parking is inelastic with respect to price. Empirically derived as well as modelled parking demand elasticities for areawide changes in parking price generally range from -0.1 to -0.6, with -0.3 being the most frequently cited value. Most such elasticities have been established on the basis of commuter (work purpose) travel, with little useful information on the sensitivity of non-work travel to the price of parking."

There is very little evidence for the effects of increase parking charges on non-commuter parking: the study says "Some insight on non-commuter parking is offered by a single study of effects at San Francisco parking facilities of a 25 percent parking tax levy in the early 1970s."

Pratt also says "Price elasticity can be a deceptive gauge when taken at face value without applying it to a particular price change situation" and perhaps most telling to the current situation "Nevertheless, because parking demand is normally inelastic with respect to price, imposition of or increases in parking fees are generally met with an increase in total revenue".

In summary, the Council have produced no evidence that increasing parking charges will reduce the amount of traffic, and hence air pollution in Merton. We do not feel, therefore, that there is a lawful basis for these increases.


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