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Legal guide to UK motoring, sections for law enforcement, Driver licensing, learner and new drivers, buying and selling, speeding fines, owning a vehicle, wheel clamping, traffic information.
Transport - Seventh Report
INTRODUCTION 
ENFORCEMENTLOADING AND UNLOADING
 Police inaction
Civil parking enforcement
Two systems of parking enforcement
Advantages of a single decriminalised enforcement system
 Definitions
Provision of loading capacity
STATUTORY GUIDANCEPARKING STRATEGIES
 The advantages of specific guidance
The need for revised guidance
 Parking as a traffic management tool
Guidance for local transport planning
Good practice guidance on parking strategies
TRANSPARENCYPARKING ACCESSIBILITY
 Publication of annual statistics
Parking as an income generator for local authorities
Enforcement contracts and incentives
Scrutiny of local authority parking operations
 Pavement parking
Road safety
’Blue Badge’ scheme
Parking space: capacity and demand
Planning Policy Guidance
REPRESENTATIONS PUBLICITY AND CONSULTATION
 Timeframes
Grounds for considering representations
Fourteen day discount
Professional service, costs, compensation
 Publicity
Consultation, consent, engagement
APPEALS TO THE PARKING ADJUDICATORS TECHNOLOGY AND DATABASES
 Independence of the adjudicators and quality of service
Lack of awareness of the right to appeal
Powers of the adjudicators
Investigating maladministration
The importance of developing the adjudication service
 Driver and Vehicle Licensing Agency (DVLA) register
Continuous vehicle registration
Access to DVLA data
New technologies for parking
Real time information
Technology for enforcement
Technology for processing tickets
PROPORTIONALITY CONCLUSION
 Police inactio
Civil parking enforcement
Two systems of parking enforcement
Advantages of a single decriminalised enforcement system
REPORTS FROM THE TRANSPORT COMMITTEE SINCE 2005
STAFF
LIST OF WRITTEN EVIDENCE
 Training and recruitment
’On-street discretion’

ANNEX - VISIT NOTE
TRAFFIC REGULATION ORDERSFORMAL MINUTES
 Training and recruitment
’On-street discretion’
WITNESSES

8 STAFF


172. Local authorities that have adopted civil parking enforcement have either in-house or contracted parking attendants. In addition, councils have teams of administrative staff who undertake the follow-up enforcement work including, issuing ’Notices to Owner’, handling representations, and preparing evidence for cases that are subject to appeal.

173. The current reputation of civil parking enforcement staff is generally low. The parking service must demonstrate substantial and sustained improvement. To achieve this, it will be essential to raise the professionalism of those who are responsible for applying the rules - the attendants and ’back room’ parking department staff - in parallel with improving the quality of the rules themselves. If this does not happen then the effort to improve parking enforcement will fail.

Assaults on staff


174. The British Parking Association estimates there are 15,000 parking attendants working either as direct council employees or as employees of private contractors. Parking attendants are at the ’sharp end’ of delivering decriminalised enforcement and are the most visible face of a parking service.

175. The vast majority of parking attendants have pride in their work and act in a professional manner. But the nature of their job inevitably puts them at risk of confrontation. On average, three parking attendants are assaulted every day in London. Worse, we heard from the director of the NCP company that attacks on parking attendants increased after negative coverage in the press:

It is a very challenging job, it is a difficult job, and there is the public’s attitude to the job. We support all of the initiatives to improve the perception of quality… This makes a better job for our attendants. But we do see a very strong correlation between the very aggressive coverage of activity by the media and assaults on staff.
Although the press have been effective in reflecting public concern and drawing attention to the poor quality of some civil parking enforcement operations, they should be aware that the vilification of a workforce can serve to promote assaults and victimisation. There are no centrally collected national figures of the instances of victimisation of parking attendants.

176. The function of parking attendants means that they are the public face of the parking service. Because the parking enforcement service is widely unpopular, parking attendants are frequently the focus of confrontation and the targets of abuse. Many are assaulted. This is completely unacceptable. Parking attendants carry out the rules of the regime. Inadequacies in the regime should be addressed vigorously and within the law to those directly responsible, the local authorities and the Department for Transport.

177. It does not help that parking attendants are often portrayed as ’hate figures’ in parts of the press. This exacerbates the problem of the generally low public status of attendants, reinforces unhelpful stereotypes, and does a disservice to motorists who believe that they have been unfairly penalised by deflecting attention from the systemic regime faults which are often to blame. The parts of the press who are guilty of this must refrain from the vilification of a workforce already experiencing levels of violence and abuse which are already far too high.

Training and recruitment

178. For decriminalised parking enforcement to be conducted effectively it is crucial that the parking attendants have the necessary skills and support to do their work professionally. NCP is the leading provider of parking enforcement services in the UK. It employs around 3,000 parking attendants who work in more than 30 local authority areas. The company saw training as a priority:
The onus is on private contractors to ensure that they have a stable and experienced workforce and the highest standards of training, with particular emphasis on communication and customer service skills, to ensure that parking attendants… are able to explain parking regulations effectively, and demonstrate professionalism and diligence to ensure that the service is perceived to be well-run.
179. Precisely the same issues of training and professionalism apply to office staff who deal with representations and appeals. This work requires technical and legal expertise in addition to administrative and communications skills. Thorough recruitment processes, combined with carefully devised initial and on-going training, and excellent supervision and support arrangements are called for. Easy access to advice from legally qualified and other specialist staff is important.

180. All councils and contractors must pursue recruitment and training practices that ensure a professional approach to parking enforcement work. Rigorous recruitment processes should be applied to ensure that all those appointed can be trusted to work with integrity. Parking attendants need to be appropriately trained to ensure high levels of understanding of the parking regulations in force, and what constitutes best practice in their enforcement. In addition to technical knowledge, the training needs to include inter-personal skills, and techniques of minimising conflict in carrying out their duty. As front line staff, it is important that parking attendants have good communication skills and an ability to relate well to members of the public.

Remuneration

181. The research by Richard Childs on behalf of the British Parking Association identified that that parking attendants were "generally poorly paid with poor conditions". NCP recruits parking attendants at an hourly rate which varies across the country, for example £5.46 in Manchester, and £7.21 in Lewisham. This is typically for 40 hours per week arranged on a shift basis.

182. An inspection regime overseen by the Audit Commission, as recommended earlier, will include incentives for a local authority to perform well and provide a high quality parking enforcement regime. Good pay and positive working conditions for parking attendants form a key part of the process of achieving success.

183. Specific evaluation of parking departments within the Comprehensive Performance Assessment would mean that strong performance would be directly reflected in the assessment rating, with consequent benefits of raised status, and extra freedoms and flexibilities. Conversely, underinvestment in staff, low pay, and minimal training provision, while perhaps saving money in the short term, will quickly show itself in poor performance, poor public reputation, and ultimately in additional costs through more recruitment drives and cases going to appeal. These are misplaced economies.

184. Parking attendants should be paid salaries that match equivalently responsible roles within other fields of local government. It is in local authorities’ interests, and the interests of motorists, pedestrians and all those who use the streets, to employ, and require their contractors to employ, high calibre, professional, and personable staff, capable of enforcing traffic regulations calmly and without error.

A national qualification

185. Last year the British Parking Association launched an accredited qualification for parking attendant training. The qualification was launched in conjunction with City and Guilds and was developed to ensure that certificate holders have the essential knowledge required to carry out the parking attendant role effectively. This is designed to raise the standard of enforcement and increase professional development for parking attendants, and it should serve to raise the status of the role in general.

186. We warmly support the introduction of the British Parking Association’s national structured programme of training for parking attendants; and national qualifications in parking enforcement. This is a key to raising the quality of parking enforcement. Attainment of appropriate standards by parking attendants and administrative staff, through a rigorous and uniform training and testing process throughout the country, should be a fundamental requirement to work in this area. The Department’s statutory guidance should mandate such training for staff.

Retention of staff

187. We heard that high staff turnover is a problem for enforcement teams and makes training efforts more difficult. The Childs review estimated that the rate of staff turnover was as high as 70 per cent per year in some city areas. Westminster City Council told us:

The retention of suitable enforcement staff is another problem and there is a combination of low pay, poor working conditions and public hostility (and even violence), that undermine staff morale. The City Council has attempted to resolve these problems by encouraging our contractor to offer improved pay and working conditions and to incentivise staff with payments for the quality of their work.
188. There are imaginative proposals to extend the role of parking attendants to include wider ’street management’ responsibilities. Such an extension to an ’ambassadorial’ role could improve the status and public image of parking attendants. Manchester City Council has moved in this direction:

Manchester City Council sees its parking service as a key part of a Street Management group … this means that Parking Attendants are also reporting liveability issues, such as flytipping, or broken lights, and can also have a major impact on untaxed and abandoned vehicles. This has had a knock on effect of increased job satisfaction for parking attendants and the concept of parking as a liveability issue has helped to raise the public profile of the service.
’Living Streets’ suggested that parking attendants could be trained in the powers of the new Clean Neighbourhoods and Environment Act 2005 and be given the power to issue Penalty Charge Notices for dropping litter and dog fouling.

189. A key objective in making the parking regime better will be to develop the present highly unstable parking attendant workforce into a stable and experienced body with a well grounded and deepening sense of its own potential to exert a positive influence on the streets. There is some way to go before that is achieved.

190. It will be essential to reduce the high rate of ’churn’ in the profession. Such a reduction will itself be an index of success in applying the measures necessary to raise the status and professionalism of the attendants’ role. If the standard of enforcement activity is to be raised, local authorities and contractors must work hard to achieve stability.

191. The move to include street management and neighbourhood ’ambassadorial’ roles within parking attendants’ duties seem a generally positive development. Care will be needed however to ensure that these broader responsibilities do not deflect local authorities and the Department from the central objective of improving parking enforcement activity.

’ON-STREET DISCRETION’


192. A number of the witnesses involved in the operation of civil parking enforcement told us that parking attendants should not use discretion on the street when carrying out enforcement as this could lead to accusations of discriminatory practice, corruption and inconsistency. There was also a fear that it could expose parking attendants to further threats and assaults. While local authorities are required to exercise discretion in the process of parking enforcement, the view of many is that this is best left to back-office staff when consideration is given to informal and formal representations.

193. Notwithstanding these arguments, we were also impressed with the evidence from Manchester City Council, which from having been one of the worst performing authorities with very high rates of appeal by motorists to the Adjudication Service, had recently taken steps to improve its public perception. Among these steps, Manchester City Council has encouraged its parking attendants to exercise discretion. The Council explained that:
This philosophy has… helped drastically improve the Service’s public image. This has given absolute discretion to Parking Attendants in ’borderline’ cases, allowing common sense to be employed before issuing a ticket. This has led to a reduction in the number of parking tickets issued for more innocuous offences, and helped to reduce conflict with motorists… Processing staff are empowered to make the decision on an appeal that they feel is reasonable, and each case is judged on its own merits, rather than following the restrictions to the letter of the law.
194. The fears of other witnesses, that assaults and corruption would increase, have not been borne out in Manchester so far at least. During 2003/04, the number of Penalty Charge Notices issued by Manchester City Council fell by 6.8 per cent on the previous year. The number of appeals fell by 30.3 per cent, implying that the number of tickets issued which were considered by drivers to be unfair had dropped significantly.

195. We do not dismiss the counsel of those who warn that giving parking attendants discretion when issuing Penalty Charge Notices could lead to problems of assaults and corruption. This has not happened however in the case of Manchester City Council which allows its attendants such discretion. There, the introduction of discretion has been accompanied by a substantial fall in the number of Penalty Charge Notices issued and a drastic fall in the number of appeals.

196. It is too early to say whether the Manchester experiment should set a pattern for parking enforcement throughout the country. But there is clearly a case on empirical grounds for the Department for Transport and local authorities to look seriously at allowing parking attendants, in addition to back-office staff, to exercise the discretion that is a responsibility of each council in law. Any such move must be accompanied by systemic improvements in recruitment, training and management to inspire confidence in the public that all staff understand the need to exercise such a duty with diligence and expertise. Excellent monitoring will be necessary to ensure that incidences of abuse, intimidation, and corruption do not rise.



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