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Canterbury City Council

Parking Enforcement

Annual Report 2007/08

Fourth Draft
20 June 2008
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Introduction

The City Council became responsible for the implementation of both on and off-street
parking enforcement in January 2000. In addition to its own (previous) responsibilities for off-
street parking, an agreement with KCC was entered into enabling on-street functions to be
undertaken on behalf of the County Council. These functions were carried out under the
provisions of the Road Traffic Act 1991 and were known as Decriminalised Parking
Enforcement (DPE). On 31 March this year, Civil Parking Enforcement (CPE) replaced DPE
functions under provisions contained in Part 6 of the Traffic Management Act 2004.

These matters are dealt with in more detail in this report.

This report provides details of the Council’s parking enforcement arrangements for the year
2007/08.

1. Purpose of the Annual Report

The Traffic Penalty Tribunal (TPT), formerly the National Parking Adjudication Service
(NPAS), is an independent tribunal that oversees the operation of DPE/CPE across the
country and ensures that fairness and propriety are maintained. To this end the TPT has
meetings and seminars and publishes bulletins and reports, it provides guidance on best
practice in the enforcement realm, setting standards and seeking improvements in service
delivery.

The Head of the TPT, Chief Adjudicator for England and Wales, Caroline Sheppard, has
strongly encouraged local authorities to openly report upon their management of DPE. The
TMA goes further, making the publication of annual reports mandatory.

This annual report is intended to explain to the public and stakeholders how the service is
managed in the Canterbury district and to provide information regarding its performance.

2. Aims and objectives of the Service

The current Parking Service was established in 1999, under statutory decriminalised
arrangements with Kent County Council, as Highway Authority, to ensure effective, efficient
and economic enforcement of parking regulations throughout the district in accordance with
the appropriate legislation and government guidance.

There is a clear requirement for both on and off-street functions to be separately

accountable and careful planning and management are essential to achieve this.

The Service aims to help deliver the Council’s objectives as set out in its approved
corporate, parking and transport strategies: specifically:
• The Corporate Plan,
• The Canterbury Parking Strategy,
• The Herne Bay Parking Strategy,
• The Whitstable Parking Strategy,
• The Canterbury District Transport Action Plan.

The Primary aims of the service are:

• To maintain public safety
• To assist the free movement of traffic
• To ensure compliance with parking regulations
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In order to refine and inform the aims and objectives of the Service, it has been subject to a
number of reviews; a Best Value Review in 2001; a Member Scrutiny Review in 2003 that
concluded there was a need to provide:
• An effective deterrent to parking contraventions;
• Improved compliance with parking and traffic regulations;
• A fair and even-handed service in the eyes of the public;
• A service in which parking attendants fulfil an “ambassadorial” role for the district and
the council.

And in 2007/08 an Efficiency Review that recommended a number of actions to streamline

the service and save costs; these related to both the administrative and enforcement
processes.

3. Indicators of success

The indicators of success should be based on measurements of the effectiveness of

enforcement as a deterrent and the efficiency and application of the processes.

These will be measured by the following

Number of formal complaints in relation to parking enforcement as recorded by the council’s

official complaints procedure
Average PCN income per enforcement officer
Number of enforcement officers (equivalent FTE on CPE account) per Km of yellow lines
PCN cancellation rate
PCN cancellation rate due to PA error
Percentage of appeals upheld by an independent adjudicator (TPT)
Percentage of appeals dismissed by an independent adjudicator (TPT)
Average number of days lost due to absence per enforcement officer

4. Canterbury District Parking Profile

4.1 Car Parks

There are a total of 61 car parks of different types, in different parts of the district, with a total
of 6,524 spaces:

In Canterbury: 27 car parks total spaces 2984

3 park and ride sites total spaces 1850

In Herne Bay: 9 car parks total spaces 738

In Whitstable: 19 car parks total spaces 824

In villages: 3 car parks total spaces 128

4.2 On Street

On street enforcement is carried out in Canterbury, Herne Bay, Whitstable and some rural
villages in areas where Traffic Regulation Orders (TROs) exist.

Canterbury:
Number of controlled parking zones 12
Number of on street parking bays (pay and display) 161
No. of on street bays (voucher) 563
No. of limited period free bays 1119
No. of residents’ parking bays 146
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No. of disabled persons bays 30
No. of loading bays 6
Total length of double yellow lines 28 Kilometres
Total length of single yellow lines 26.7 kilometres

Herne Bay:
Number of controlled parking zones 1
No. of time-limited free bays 1261
No. of residents’ parking bays 626
No. of disabled persons bays 13
No. of loading bays 2
Total length of double yellow lines 15.6 kilometres
Total length of single yellow lines 7.8 kilometres

Whitstable:
Number of parking bays (pay and display) 9
No. of residents’ parking bays 67
No. of limited period free spaces 108
No. of disabled persons bays 18
No. of loading bays 6
Total length of double yellow lines 14.3 kilometres
Total length of single yellow lines 6.6 kilometres

Villages:
No. of time-limited free bays 54
No. of residents’ parking bays 13
Total length of double yellow lines 7.1 kilometres
Total length of single yellow lines 0

4.4 Parking Income

Total Parking Income for 2007/2008 £6,177,761

This figure is made up of: £

Off street Car Parks Income 3,700,727

Off Street PCN income 334,020
Off street other income (permits etc) 349,549
On Street PCN Income 311,244
On street Pay and Display income 88,463
On Street other income 235,364

Park and ride Income £1,158,394

The city of Canterbury has the greatest concentration of parking provision in the district,
generating 90% of parking income (non-PCN) and 75% of all penalty charge notices issued.

4.5 Enforcement staff

There are currently 27 enforcement posts, 5 at Supervisor level the remainder are Civil
Enforcement Officers. In addition, there is one technical “support” post.

Staff deployment is undertaken in shifts using a system of “beats” to cover areas where
enforcement is carried out. Beats are generally attended on a daily basis subject to availability
of staff resources and the vagaries of the weather. Higher priority beats have been identified,
e.g. Canterbury city centre, and these are attended every day. Some outlying areas are covered
less frequently.
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4.6 Times that orders and charges apply

Off street parking orders apply at all times but there are specific times during which on street
TROs apply and these vary from location to location. Details are contained in the current Off-
Street Parking Places Order (OSPPO) and Traffic Regulation and Street Parking Places Orders.
Copies of these are available on request.

Except for free car parks, off street charges apply at all times in most car parks. There are a
small number where other provisions apply and these are identified in the OSPPO. Where on-
street charges apply, the times vary from location to location.

Both the off street and on street orders are reviewed annually and there are often interim
amendments that are introduced throughout any year.

5. Current initiatives

5.1 Traffic Management Act

Part 6 of the Traffic Management 2004 (TMA) deals specifically with civil enforcement of
traffic and parking contraventions. The TMA replaces the Road Traffic Act 1991; Civil
Parking Enforcement (CPE) replaces DPE and Civil Enforcement Officers replace Parking
Attendants. The implementation date for Part 6 of the Act was 31 March 2008. From that
date, parking enforcement will be undertaken under the provisions of the TMA. This
necessitated the introduction of a number of changes for the service, and a great deal of
work during the lead up period in 2007/08.

The Act introduces a number of new contraventions to be managed through the civil
enforcement process; these include enforcement of:
Bus Lanes
Dropped kerbs
Double parking
Vehicle drive-aways (VDAs)
Pedestrian crossing zigzags
Some moving traffic contraventions
Not all of these contraventions will be enforced from the outset, and discussions are being
held with Kent County Council on the scope of future enforcement duties.

The TMA also, and importantly, introduces a system of differential penalty charges; based
upon the severity of a contravention, higher-level contraventions will be charged at £70 and
lower level at £50.

Currently, 30% of PCNs issued in Canterbury fall into the higher (£70) bracket, whilst 70%
fall into the lower (£50) rate. It is anticipated that there will be a significant reduction in
income as most of the contraventions committed within this district are at the lower rate. The
estimated loss in PCN income will be of the order £44,000, or 7% of PCN income.

In response to the legislation it was necessary to undertake the following tasks: -

• Make appropriate changes to IT systems.
• Appraise Traffic Regulation and Off Street Parking Places Orders, to ensure that they
are compliant with the new legislation.
• Ensure traffic signs and road markings conform to the new legislation, and are consistent
with the Orders.
• Advise the public of changes to enforcement, and the changes to penalty charge levels.
• Make changes to uniforms.
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• Ensure printed stationery and standard letters are updated to reflect the requirements of
the new Act.
• Ensure that personnel are properly trained and aware of the new legislation.
• Consult with stakeholders about the implications of the new legislation.

The TMA 2004 also requires authorities to publish, in the form of an annual report, certain
items of financial and statistical information, which should include the following:

a) Total income and expenditure of the on-street and off-street parking account.
b) A breakdown of income by source (pay & display, permits, PCNs etc).
c) The total surplus or deficit of the on street parking account (this money is ring-
fenced for use on transport or environmental projects).
d) Number of PCNs issued, and at what rate.
e) Number of PCNs paid and at what rate.
f) Number of PCNs against which a formal or informal representation has been
made.
g) Number of PCNs cancelled.
h) Number of PCNs written off.
i) Number of vehicles clamped.
j) Number of vehicles removed.
k) These requirements have been introduced to make parking and traffic
enforcement more accountable, open and transparent.

5.2 Kent Parking Protocol

In an endeavour to improve operations across the county, parking managers have agreed a
policy guidance document. This is intended to promote consistency of process as well as
clarity and transparency as councils will work to an agreed set of policy and operational
guidelines. This approach will result in greater public understanding of and confidence in the
enforcement processes, it will also move towards compliance with the aspirations of both the
TPT and the Local Government Ombudsman. This document is now accessible to the public
via the council’s web site.

In the Joint Report of the Parking Adjudicators for England and Wales 2006, in a section of the
report entitled “Local Authorities Working Together to Share Best Practice and Develop
Guidance”, Caroline Sheppard the Chief Adjudicator, states

“I was delighted to receive a report from the Kent Parking Managers’ Group…. the
document includes a wide range of policies for the purposes of informing the public and
providing guidance to council employees…The Adjudicators are encouraged by such
cooperation between councils on projects which provide clarity, consistency and
transparency within the parking enforcement process. I understand that these policies will be
subject to ongoing review and would welcome feedback on their implementation”

This joint initiative was recognised by the British Parking Association with a national award
for innovation in April 2008.

All recording procedures and observation times are undertaken in accordance with the
Policy Guidance issued by the Kent Parking Managers Group.

5.3 Schools

There are a number of schools across the district with serious parking and traffic related
problems. Continued engagement is required with schools, their staff, governors and parents
to address problems and provide advice about parking and traffic management issues and
assisting with the development of school travel plans.
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Resources do not permit regular enforcement outside all schools. A list of priority schools
(maximum 10 per term) will be agreed for a targeted campaign with the Police. It is
anticipated that these measures will result in about 25 school visits per term.

5.4 Targeted enforcement campaigns

Special campaigns of targeted enforcement activity for short periods can be effective in
enhancing deterrence in problem areas. A list of known problem areas will be reviewed on a
6 monthly basis and an action plan drawn up. However, it will be necessary, on occasions at
short notice, to accommodate targeted activity at specific locations from time to time.

Typically a single campaign will last 1-2 weeks and involve heightened levels of enforcement
with daily visits.

There is a specific requirement implicit within the Traffic Management Act that the
enforcement of traffic and parking regulations should be aimed at maintaining public safety
and the free passage of traffic, pedestrian, cycle and motor vehicle (See 2 above). To this
end it is proposed that certain streets, where it is known that the free-flow of traffic is
particularly sensitive to interruption as a consequence of inconsiderate parking acts, should
be identified for high priority and more rigorous enforcement. These streets will be closely
monitored and their classification reviewed from time to time.

5.5 Ancillary functions

Civil Enforcement Officers fulfil roles ancillary to the enforcement of traffic and parking
orders’ for example, by acting as a first point of reference for the public as they are a
uniformed and highly visible presence providing support for major events, often in a non-
enforcement capacity, either on a planned basis or in rapid response.

5.6 Staff training

All Staff should achieve minimum standards of City and Guilds accreditation for Parking
Enforcement (1885). Additionally all staff should achieve as a minimum Level 2 NVQ in
Parking Control. Supervisory staff should achieve as a minimum Level 3 NVQ in Parking
Supervision.

These minimum training standards meet the requirements of the Traffic Management Act,
which also introduced the need for CPD in respect of enforcement staff; a detailed training
record must therefore be maintained. A programme of TMA compliant training must be
developed and the South East Parking Managers Group is developing this.

Additional training must be evidenced in respect of good customer care; breakaway

techniques; conflict management and basic first aid.

Progress towards achieving the desired training and qualifications is set out in section 7.

6. Prioritisation

6.1 Review process

The prioritisation of enforcement activity will be reviewed every 6 months and will take
account of a number of issues:

1. Public safety
2. Freedom of traffic movement
3. Problem schools
4. Other problem areas for hot spot campaigns
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5. Support for major events (planned)
6. The cost effectiveness of enforcement
7. Continued assessment of performance
8. Requests from Council members and the public

6.2 Data assessment

The 6 monthly reviews will include an assessment of data, PCN issue rates at different
locations, results of special campaigns, requests and complaints from members and the
public.

To establish the cost effectiveness of enforcement, it will be necessary to assess levels of

non-compliance and PCN issue. It will be important to identify any “displaced” non-
compliance. A key indicator to help optimise future enforcement activity will be the number of
PCNs per visit per location.

7. Performance 2007/08

The following data is provided as required by the Traffic Management Act 2004 – see
section 5.1 of this report.

Details of Penalty Charge Notices issued in 2007-2008 (April–March)

Total Issued 24,108

On Street 11,531 47.8%

Off Street 12,577 52.2%

Canterbury 17,744 73.6%

Herne Bay 3,016 12.5%
Whitstable 3,324 13.8%
Rural areas 24 0.1%

Cancelled PCNs 3,572 14.8%*

Valid PCNs 20,536 85.2%

PCNs paid 15,795 76.9%

PCNs registered as debt 2,923 14.2%
with county court

Value of registered debt £277,685

Costs of registration at county court £ 14,615
Total debt £292,300
Orders for debt recovery issued to bailiffs 2,384
Amount of debt this represents £226,480
Amount recovered (to date) £ 46,143
Value of PCNs written off £148,570

* The council operates a cancellation policy that has been agreed by most
authorities across Kent and Medway. In excess of 70% of cancellations are allowed
in accordance with this policy. The policy can be viewed on the council’s web site.
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Formal Appeals for the previous year – Source NPAS Annual Report 2006

2006/07 “East Kent”

average
Number of 40 28
appeals
Appeals 14 35% 10 32%
allowed
Appeals 11 28% 11 42%
dismissed
Appeals not 15 38% 7 25%
contested
Cases 5 0
pending

“East Kent” includes Ashford, Dover, Shepway, Swale and Thanet councils.

Comparison with other authorities is possible but the many differences between each district
in terms of their approach to the issue of enforcement and more importantly towards the
appeals process can mean that direct comparison has only limited value.

That is not to say that comparison is without merit and Kent authorities share a common
approach to benchmarking. The 2007/08 benchmarking results are attached as an appendix
to this report.

Other performance measures include:

In the Kent Wide VFM Price Book 2007/08 analysis, Canterbury CC’s Parking Services was
identified as the best match of price and performance and is used as the base price for other
authorities to calculate potential improvement.

On staff training and qualifications

11 enforcement staff have achieved NVQ2
A further 4 are currently undertaking training to this level
4 Supervisors have achieved NVQ3.

Car Park Safety

58 car parks have received ACPO accreditation in the Safer Parking scheme that is
administered by the British Parking Association. In percentage terms, this is the highest
achieved by any local authority in the country.