-
Item 14 annex 1
Surrey County Council Runnymede Borough Council
Decriminalised Parking Enforcement
in Runnymede
Financial appraisal
Report prepared for Surrey County Council and Runnymede Borough
Council by
Harrison Webb 1 Hillside Cottages Blackheath Guildford Surrey
GU4 8QU tel/fax: 01483 892137 email: [email protected] uk
47D Greencroft Gardens
London NW6 3LL
tel/fax: 020 7372 2760 email: [email protected]
Status Draft Job no/issue
0087/6
Prepared by
dah
Date 24.10.03
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Surrey County Council Runnymede Borough Council
Financial appraisal of Decriminalised Parking Enforcement in
Runnymede: Draft Report 24 October 2003
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Contents
Page No.
1 Background Purpose of the Study 1 DPE 1
Conduct of the Study 3
Layout of this report 4
Status of this report 5
2 Assumptions Introduction 6 Permitted and Special Parking Areas
7 Trunk Roads 8 Reviewing parking policies 9 Enforcement resources:
on-street 9 Enforcement resources: off-street 10 Enforcement
resources: overall 11 Enforcement income 12 Other sources of
potential income 16 Employment costs 16 Council on-costs 17
Additional revenue expenditure assumptions 17 Capital (start-up)
expenditure 22
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3 Financial implications Financial model 24 Cash flow 24 Tests
25
4 Conclusions Optimistic Scenario 28 Pessimistic Scenario 28 The
impact of additional charges 29 Conclusions 29
Appendices
A PCN Contravention Codes B Glossary of terms
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Surrey County Council Runnymede Borough Council
Financial appraisal of Decriminalised Parking Enforcement in
Runnymede: Draft Report 24 October 2003
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Background This Section explains the purpose of the Study, the
principles of DPE and the conduct of the Study.
Purpose of the Study 1.1. The purpose of this financial
appraisal is to compile a picture of the
possible financial consequences of implementing Decriminalised
Parking Enforcement (DPE) in Runnymede.
DPE 1.2 The Road Traffic Act (RTA) 1991 provides for the
decriminalisation
of most non-endorsable parking offences in London and it enables
similar arrangements elsewhere. The essence of DPE is that local
traffic authorities (in this instance Surrey County Council) may
apply to the Secretary of State for orders decriminalising the
offences within particular geographical areas. Then, as the
offences are no longer criminal in those areas:
• enforcement ceases to be the responsibility of the police
generally using the powers of the Road Traffic Regulation Act
(RTRA) 1984 and becomes the responsibility of the local traffic
authority or its agent
• uniformed Parking Attendants (PAs) place Penalty Charge
Notices (PCNs) on vehicles contravening parking regulations and
can, in appropriate circumstances, authorise the towing-away or
wheel clamping of the vehicles (not an option to be pursued
immediately in Runnymede although it will be appropriate to apply
for such powers alongside DPE)
• the penalty charges are civil debts, are due to the local
traffic
authority or its agent and enforceable through a streamlined
version of the normal civil debt recovery processes
• motorists wishing to contest liability may make
representations to the local authority or its agent and, if
these are rejected, they may have grounds to appeal to independent
adjudicators, whose decision is final
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• the local traffic authority or its agent retains the proceeds
to help fund the enforcement resource and administrative
systems
• any financial surpluses must be used for certain other traffic
management purposes as specified in section 55 of the Road Traffic
Regulation Act (RTRA) 1984
• key changes resulting from substituting the 1991 Act for
the
1984 Act are set out below with notes describing certain key
abbreviations:
Parking restriction (examples)
1984 Act 1991 Act
parking or loading restriction
police enforcement via FPN, removal or prosecution
residents’ parking or other permit
police enforcement via FPN or removal, or local authority
enforcement via NIP
metered parking local authority enforcement via an ECN for
staying beyond the initial period, followed by NIP, or police
enforcement via FPN or removal for non-payment or staying beyond
the excess period
clearway police enforcement via FPN or removal or
prosecution
local authority enforcement via PCN or clamping or removal
pedestrian crossing double white lines down the centre of a
carriageway
police enforcement via endorsable FPN or removal or
prosecution
police enforcement via endorsable FPN or removal or
prosecution
Notes:
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FPN: Fixed Penalty Notice, allowing a motorist to pay a fixed
penalty (fine) to avoid prosecution without admitting the alleged
offence
Endorsable FPN: as above but for more serious offences and
includes 3 penalty points and the possibility of mandatory
disqualification if the limit is exceeded
NIP: Notice of Intent to Prosecute, as (unlawfully) used by some
local authorities to attach a fine and suggest that prosecution can
be avoided on payment; NIPs have no face value and can only be
processed via the Magistrates Court
ECN: Excess Charge Notice, allowing a motorist to pay a fixed
charge (fine) for parking beyond a paid-for period
PCN: Penalty Charge Notice, which is pursued as a debt (whereas
an FPN is pursued as an offence)
Clamping: clamping powers are available to authorities that
adopt DPE; drivers must pay a release fee to recover the vehicle
and pay the related PCN
Removals: removals powers are available to authorities that
adopt DPE; drivers must pay a release fee to recover the vehicle
and pay the related PCN; removals and clamping can be used to
punish offenders that have not registered their vehicles with the
DVLA (thus blocking the debt collection process) but does not allow
the following up of outstanding charges
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• it is possible, but not recommended by the Government,
that
the area designated for DPE can exclude off-street car parks
owned and operated by the local planning authority; the Government
considers that this negates many of the benefits of unified
enforcement (see paragraph 1.3 below)
• however, the designated area for DPE usually excludes high
speed roads on which parking is not a problem and enforcement
best carried out by mobile police resources
• endorsable offences typically involving dangerous or
obstructive parking, some other traffic offences such as parking
at pedestrian crossings (outside London), and all moving traffic
offences will remain criminal and be enforced by the police
• PAs cannot direct traffic.
A full list of contraventions (there are no offences, merely
contraventions under DPE) amenable to PCNs under DPE are listed in
Appendix A, as supplied by the National Parking Adjudication
Service (NPAS). A Glossary of legal terminology is included in
Appendix B, from the same source.
1.3 The advantages claimed for DPE are numerous:
• local authorities can ensure that their parking policies are
implemented effectively, thus improving traffic flow and road
safety, providing a fairer distribution of available parking spaces
and improving the environment
• the integration of most parking enforcement under a single
authority, hence…
• improved integration of enforcement and parking policy
responsibilities
• a unified system for processing on and off-street parking
contraventions following the “disappearance” of ECNs and FPNs
under DPE
• the potential for additional revenues to fund improved
enforcement and possibly other transport-related schemes
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• the ability to sanction additional parking control measures
previously in abeyance because of inadequate police enforcement
resources.
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Conduct of the Study 1.4 The appraisal is one of a number of
tasks commissioned by the
Borough Council to assist the implementation of DPE in the
Borough. The commission was awarded on 1 July 2003, based on
Harrison Webb’s proposal dated 25 June 2003. The work is to be
carried out under two orders, one from the Borough Council and one
from the County Council.
1.5 The tasks commissioned comprise:
• undertaking a financial appraisal of a DPE operation in
Runnymede Borough (the subject of this report) • consider the
deployment of enforcement resources
• document a suitable parking plan for inclusion in the
application to Government for DPE powers
• compile the application for DPE powers on behalf of the County
Council
• participate in discussions between the Borough and County
Councils on issues raised by the application
• assist with additional documentation tasks concerned with
enforcement procedures and codes of practice
• assist with the necessary consultation exercise
• undertake peer review checks to ensure best practice is
followed.
Layout of this report 1.6 Section 2 of this report sets out the
input assumptions on which the
financial appraisal is based. Section 3 describes the financial
model and presents the test results. Section 4 summarises the
findings of this work.
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Status of this report 1.7 This report has draft status. It is
based on the best estimates of
costs and incomes currently available. These estimates will be
progressively up-dated with new information as the DPE project
moves from planning to implementation and thereafter as a result of
annual audit.
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Assumptions This Section develops and justifies the assumptions
used for the appraisal. It first considers enforcement resources
and income,
then revenue costs and capital costs.
Introduction 2.1 The financial model for this appraisal is based
on assumptions and
simple mathematical relationships that compile and compare cost
and income streams over time, using a custom-built Excel
spreadsheet.
2.2 The cost stream distinguishes between:
• capital account start-up costs, and… • revenue account
operating costs. This is an important distinction because start-up
costs are incurred only once, as the name suggests, whilst
operating costs are incurred continuously. The distinction is also
important because Surrey County Council has agreed to fund DPE
start-up costs from its Local Transport Plan account. Operating
costs will be charged to an on-street parking account set up by the
County Council, as DPE will be operated locally on behalf of the
County Council as highway authority. The County Council offered to
extend the terms of its financial support on 16 September 2003. It
offered to meet all the costs (ie capital and revenue) of an agreed
enforcement scheme for the first two years. During this period, it
will retain all the income from penalties and County Court actions.
Adoption of this offer has yet to be confirmed.
2.3 The financial appraisal is undertaken on a marginal cost
basis. That
is, only those costs and incomes attributable to DPE are used in
the calculation. The appraisal therefore does not seek to replicate
the entire parking business run by the Borough Council. For
example, the appraisal does not include the operating costs
incurred in enforcing orders currently applying in the off-street
car parks operated by the Council. It does not include current
income from this source. Furthermore, it does not include any
increase in off-street car park income that may accrue from more
rigorous on-street
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enforcement under DPE. SCC does not require any such additional
income to be added to the on-street (DPE) parking account. It will
therefore remain part of the Borough Council’s off-street parking
account.
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2.4 The appraisal does not assume perfect knowledge and it
is
accepted that the inherent uncertainties mean that a best (or
most likely) estimate is also an elusive concept. In this
appraisal, two scenarios are presented. The Optimistic Scenario is
based largely on the most favourable financial outcomes assumed in
earlier research on DPE undertaken by Harrison Webb for Surrey
County Council, supplemented by more up-to-date information
obtained for this current commission. This scenario basically
assumes low costs and high incomes. The Pessimistic Scenario is the
reverse.
2.5 It can be assumed that the most likely result lies
somewhere
between these two Scenarios but it not possible to state, on the
basis of reliable statistics, the probability of the outcome of DPE
lying outside the two scenarios or, hence, the probability of it
lying between the Scenarios. Our judgement is that the probability
of it lying between between the two Scenarios is of the order of
80% or more.
Permitted and Special Parking Areas 2.6 RTA 1991 enables
authorities to apply for orders creating Permitted
Parking Areas (PPAs) and Special Parking Areas (SPAs). Within a
PPA, previously criminal parking offences associated with permitted
on-street parking places (meter bays, residents’ bays, disabled
persons’ bays and free parking bays) will be decriminalised and
subject to new enforcement arrangements.
2.7 Within a SPA, previously criminal non-endorsable parking
offences
will be decriminalised and subject to the new enforcement
arrangements. These offences include:
• contraventions of permanent, experimental and temporary
traffic regulation orders made under RTRA 1984 prohibiting or
restricting waiting or relating to loading or delivery or
collections
• contraventions of the Road Traffic Act 1988 prohibiting
the
parking of heavy commercial vehicles on verges, central
reservations and footways etc
• contraventions of RTA 1988 prohibiting parking on cycle
tracks
• contraventions or non-compliance with an order under RTRA 1984
in relation to local authority off-street parking places
• contraventions of a designation order under RTRA 1984
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• contraventions of off-street loading area orders under
RTRA
1984. 2.8 It has been confirmed (August 2003) by the Department
for
Transport (DfT) that: • the offence of stopping on a part of a
road identified as a
stopping place for a bus has now been decriminalised (Statutory
Instrument 2003 No.859)
• the following offences are to be decriminalised in an
Order
later this year (2003):
- parking at taxi stands - parking offences during special
events - parking on pavements in Hereford and Worcester.
2.9 The DfT has also confirmed (August 2003) that there are no
plans to
decriminalise road tax disc enforcement. This offence has just
been added (June 2003) to the list of offences for which the police
can issue an FPN, together with failing to supply driver details
when required and driving without insurance or an MOT certificate.
However, there are plans to allow enforcement via camera evidence
(eg CCTV). This will require primary legislation.
2.10 It is the norm for PPAs and SPAs to overlap and have the
same
boundaries. In Runnymede, it is assumed that:
• the PPA and SPA overlap, have the same boundary and that that
boundary is the Borough boundary
• the only exclusions from the PPA/SPA are high speed roads,
such as urban clearways and motorways, on which police mobile
enforcement is preferred; these roads include:
- insert******************************** - -
2.11 The above assumption offers unified enforcement of
non-endorsable
on and off-street parking contraventions by the local traffic
authority or its agent. It is assumed that:
• Runnymede Borough Council will operate the system on
behalf of Surrey County Council.
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Trunk roads 2.12 Notwithstanding the above assumption, it is
possible for a local
traffic authority to enforce decriminalised parking on a trunk
road within a PPA/SPA under RTA 1991. This would apply to an
unimproved trunk road on which parking was a problem and
enforcement could be undertaken safely by parking attendants on
foot. In Runnymede, it is assumed that:
• there are no trunk roads (other than any specified for
exclusion from the application in paragraph 2.8 above) for which
DPE powers will be sought under RTA 1991.
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Reviewing parking policies 2.13 The Government states that local
authorities should undertake a
thorough review of parking policies and related orders before
applying for DPE powers. In reviewing Traffic Regulation Orders
(TROs), the authorities should consider their validity and
relevance. Inconsistent or invalid TROs (caused for example by
incorrect signage or lining) should be rectified. Unnecessary TROs
should be rescinded. This review process is currently underway.
2.14 There will also be a need, in any case, to ensure remaining
TROs
are technically correct under RTA 1991. Typically this will mean
existing orders will need to be modified to remove any reference to
“initial” or “excess” parking periods. Parking meters (including
Pay and Display ticket dispensers) will need to be converted by
removing notices on them referring to “excess charges” etc. TROs
should include a provision relating to “anything done with the
permission or at the direction of a police constable in uniform” to
cover emergency situations.
2.15 Simplified procedures exist for changes to TROs that are
simply
required to reflect new powers under RTA 1991. 2.16 It is
assumed in Runnymede that:
• no substantive changes to the extent or scope of TROs will be
initiated alongside the introduction of DPE.
This should allow simplified procedures for order changes and
allow the impact of DPE to be assessed in isolation. DPE will
probably change parking behaviour to some extent and it is useful
to be able to identify such changes before introducing further
parking restrictions. The financial spreadsheet model allows for
the introduction of on-street Pay and Display machines but only for
testing purposes (see paragraph 2.48 et seq).
Enforcement resources: on-street 2.17 It is generally assumed
that the appropriate level of enforcement is
related to the seriousness of parking problems, based on the
authorities’ policy objectives. A PCN for a parking contravention
can only be issued by a suitably authorised Parking Attendant (PA)
as defined under RTA 1991 section 44. A PA should not use
discretion but enforce the regulations as stated. Representations
by a motorist (pleading special circumstances) may be considered by
a more senior person in due course. Patrolling an area or beat on
foot, or sometimes by bicycle or moped, should involve:
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• a random pattern so that the next visit is unpredictable •
monitoring patterns of parking behaviour to focus on the most
serious enforcement problems
• rotation of beats to ensure equality of workload and minimise
familiarity with the local community, including traders, to ensure
less pressure for leniency.
As noted in paragraph 2.9 above, legislation is planned that
will also allow enforcement outside London via CCTV, with PCNs
posted to alleged offenders. Bus lanes could be enforced via this
legislation. CCTV output will also help direct the mobile on-street
enforcement resource.
2.18 The deployment of enforcement resources should reflect:
• the level of controls (for example, a residential street near
a station may only need patrolling twice week but a shopping street
with a maximum stay of 2 hours may require patrolling every
hour)
• the duration of regulations
(for example, a weekday period from 0830 to 1830 results in 50
hours if control whereas including weekends can increase the
control period beyond 80 hours)
• the level of service required
(PAs can also be sources of help and information)
• the level of contravention (as non-compliance is driven down
by increased enforcement, a point is reached where the level of
enforcement can be reduced whilst maintaining adequate
compliance)
• the consequences of non-compliance
(more frequent patrols may be needed where legal loading is
impeded by illegal parking, leading to dangerous double
parking).
Enforcement resources: off-street 2.19 RTRA 1984 gives local
authorities powers to provide and charge for
off-street car parking and set conditions for its use. This is
generally undertaken using Pay and Display machines. Local
authority officers patrol the car parks and enforce the
conditions.
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2.20 Failure to comply with the relevant order constitutes an
offence
under RTRA 1984 section 35(a). However, unlike under RTA 1991,
breach of the conditions set out in the order is a criminal offence
subject to penalty only by prosecution. There is no provision in
RTRA 1984 for authorities to impose fines. Most authorities specify
a tariff that includes an excess charge for initial non-payment or
for over-staying.
2.21 In 1995, the powers in RTA 1991 were extended to apply to
off-
street car parks regulated by an order. These powers allow the
use of PCNs, clamping and removal as for the on-street
situation.
2.22 Municipal car parks may be operated without an order by
relying on
Pay on Foot systems. The user is required to pay the advertised
sum for the parking they use and failure to do so could lead either
to a civil action to recover the debt or to a criminal offence.
Barrier systems preclude the need for conventional enforcement
although staff are still required for security and customer
assistance. Pay on Foot equipment is more expensive than that for
Pay and Display. It is therefore likely that Pay and Display will
continue to be used for smaller car parks outside the major towns
and cities and thus maintain a need for conventional enforcement.
It is assumed in Runnymede that:
• Pay and Display will continue to be the normal method of
control in off-street car parks
• unified enforcement of off and on-street parking will be
undertaken via DPE
• a patrol may involve a mixture of on and off-street
parking
• all enforcement staff will be conversant with procedures
for
both on and off-street enforcement.
Enforcement resources: overall 2.23 The Borough Council will
need to reorganise its existing off-street
enforcement patrols to include on-street activities. This is not
the document in which to record this but the overall resource costs
and associated start-up costs need to be assessed here.
2.24 Normally, this exercise would be led by levels of
non-compliance.
Patrols would then be designed to reduce non-compliance to
an
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acceptable level. This would determine the number of additional
PAs required to extend enforcement to on-street areas.
2.25 However, in Surrey, the County Council has resolved (17
February
2003) to fund capital start-up costs from the Local Transport
Plan and to manage the finance of DPE thereafter on a countywide
basis. The County Council has also offered (16 September 2003) to
fund the first two years of enforcement operations. Research for
the County Council undertaken in late-2002 by Harrison Webb showed
that the DPE operation was likely to run in overall annual revenue
deficit at County level. In principle, the County Council will meet
any such deficit from the Transportation budget. The
boroughs/districts will run DPE on a day-to-day basis.
2.26 In reaching these resolutions, the County Council assumed
that the
level of enforcement sought for on-street parking would,
initially at least, replicate that theoretically provided by Surrey
Police in the past (prior to the recent run-down of this
resource).
2.27 Given the County Council’s crucial financial role, it is
seeking initially
to control the number of additional PAs employed under DPE to
cover on-street locations. In Runnymede, this implies that the
number of additional PAs is two. It is noted that an earlier desk
study of Runnymede by Harrison Webb suggested that the additional
resource should be three PAs, a similar order of magnitude.
2.28 It is therefore assumed that:
• in Runnymede, the introduction of DPE will involve two new PA
posts
• these posts will be integrated into the existing off-street
car
park enforcement resource, which comprises of 1.5 FTE (full-time
equivalents)
• this resource will be deployed reactively and not to a set
routine. 2.29 SCC accepts that once DPE is established and
actual costs and
incomes known, the enforcement resources may be amended.
Enforcement income
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2.30 The introduction of DPE will not, of itself, change the
output of car park enforcement, ie the number of PCNs issued under
a unified DPE regime. We discuss below how the deployment of DPE
on-street may affect car park usage, and hence income, at the
margin. Paragraph 2.3 confirms that any such additional income will
accrue to the Borough Council’s off-street parking account rather
than the County Council’s on-street parking account.
2.31 However, DPE will certainly change the output of
on-street
enforcement. It will introduce a revenue income stream based on
the payment of debts incurred via PCNs. The amount of income will
depend on the number of PCNs issued and income per PCN. The latter
varies according to the time taken for motorists to pay penalty
charges and the value of a PCN.
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2.32 It is now adopted policy in Surrey that the PCN rate is £60
and that
this applies countywide. There is a 50% discount for payment of
a PCN within 14 days of its issue by a PA. A maximum of 28 days is
allowed for payment of a PCN at face value. Non-payment after 28
days results in the issue of a Notice to Owner (NtO) by the local
authority. This requires access to DVLA to obtain the address of
the vehicle keeper. A 50% increment on the PCN face value applies
for payment after 28 days of the NtO issue, the point at which a
Charge Certificate is served for initial non-payment. A motorist
may choose to make representations via an appeal to a Parking
Adjudicator as an alternative response to a Charge Certificate.
Appendix B lists the grounds for an appeal against a PCN (under
Grounds). If there is no response to the Charge Certificate within
14 days of its issue, the authority may apply to the County Court
to recover the charge as if it were a debt under a County Court
order. This may ultimately involve bailiffs acting under a Warrant
of Execution issued by the local authority having been granted
authority by the Parking Enforcement Centre of the County
Court.
2.33 It is assumed that the following income will derive from
every 100
PCNs issued, based on the adoption of £60 PCNs:
Time PCN is paid
Discountor
increase
Incomeper
PCN
Number of
PCNs
Incomeper 100
PCNs within 14 days -50% £30 50 £1500between 15 days and Notice
to Owner
0%
£60
15 £900
between NtO and Charge Certificate
0%
£60
2 £120
after Charge Certificate via County Court/bailiffs
+50% £90 3 £270
PCN cancelled/waived 30 £0Total PCNs/income 100 £2790Total
income per PCN £27.90
2.34 Overall, it is expected that some 70% of charges would be
paid
eventually. The average for England and Wales is 72% (in 1997,
based on the latest Home Office statistics for non-endorsable
offences where the driver was absent). In Surrey, the recorded
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proportion paid in 1996 was 80% according to Home Office
statistics.
2.35 For this appraisal, the following assumptions are made:
Scenario Income per
PCN issued
Optimistic £30.00 Pessimistic £23.00
These assumptions are broadly compatible with earlier research
by
Harrison Webb for, and accepted by, the County Council. These
sums are assumed to remain stable over time in real terms. These
assumptions have been validated against experience in Kent in the
course of this current commission.
2.36 The other major factor in determining the total income from
PCNs is
the number issued. Key variables affecting this output are:
• the number of additional PAs employed under DPE • the public
reaction over time to enhanced enforcement and,
hence, the number of offences and contraventions committed now
and in future.
2.37 We have explained in paragraph 2.28 above that 2 additional
(FTE)
PAs will be employed initially under DPE. 2.38 One of the most
critical assumptions in any financial assessment of
DPE is the number of PCNs issued by each PA. This depends on the
level and nature of contraventions and, sometimes, the aggression
with which enforcement is pursued.
2.39 There is wide variation in the assumptions used for the
various
Surrey DPE studies, as reported by Harrison Webb in late-2002. A
number of these studies also assume that the volume of
contraventions will not change in future. This may be thought to be
a curious assumption, given that the main objective of DPE is to
reduce parking contraventions. It is argued by some practitioners
that issue rates should be assumed to be relatively stable over
time, partly because of new parking restrictions being feasible
with the advent of DPE. However, we note that this stability
assumption was
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one reason for widespread over-estimation of enforcement income
in the initial forecasts undertaken for/by London Boroughs.
2.40 Our judgement is that it is reasonable to assume that
improving on-
street enforcement resources from a perception (and reality) of
virtually zero in Runnymede to a significant presence will reduce
the number of contraventions for a given number of parking controls
but not eliminate them because the number of parking attendants
will be limited below the level at which that could occur. Two PAs
simply cannot provide a presence across the Borough on a daily
basis. Assuming a reduction in contraventions is also a
conservative approach that reduces the risk of over-estimating
income and setting targets that are unrealistically high.
2.41 This appraisal assumes that all the Surrey authorities will
employ, at
least initially, relatively small teams of attendants that
reflect the number of contraventions but also their disposition
across the authority. This places a larger burden on the most rural
authorities because the number of contraventions will be modest but
very widespread.
2.42 In 1989, each Warden in Surrey issued an average of 1820
Notices
a year. By 1999, this had fallen to 980 Notices a year as
Wardens were increasingly used for other duties. In London, issue
rates can exceed 4000.
2.43 However, for this current Runnymede appraisal, the
following
assumptions are made about PCN issue rates based broadly on our
understanding of the latest experience in Kent, where DPE has been
operating for over two years in all authorities:
Scenario PCNs issued
per PA per annum
PCNs issued per PA per day
Optimistic 1500 7.5 Pessimistic 900 4.5
It is assumed above that each PA will work about 200 days a
year,
compatible with a 9-day fortnight. 2.44 As explained above in
paragraph 2.40 above, it is to be hoped that
DPE will reduce the number of contraventions for a given number
of parking controls. However, the advent of DPE may well unlock
additional parking control schemes that could not previously be
implemented because of a lack of enforcement resources. This is
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thought likely in Runnymede over the next 5 years, as pressure
on the permitted parking supply increases. As a result, the income
stream from on-street PCNs is assumed to change over time in real
terms as follows:
% of test income achieved
by year of operation Scenario
1 2 3 4 5 Optimistic 100% 100% 100% 100% 100% Pessimistic 100%
95% 90% 85% 80%
It should be noted that the scenarios are based on financial
performance. In enforcement terms, the Pessimistic Scenario is
more successful than the Optimistic one. These assumptions are
built into the cash flow projections set out in Section 3.
2.45 The number of attendants drives the assumed number of
PCNs
issued. In turn, this drives the ticket processing resources
needed. It assumed initially that one processing clerk can deal
with at least 5,000 PCNs per year. This results in fractions of a
full time equivalent (FTE) post. It has been pointed out that
whilst the total resource needed may be less than one clerk,
sickness and leave will demand a minimum establishment of, say, 1.0
FTE clerk, a resource provided by two trained staff. This ensures
that processing is less likely to generate a back-log that could be
difficult to clear.
Other sources of potential income 2.46 DPE is simply a means to
an end. It is not a policy tool in that it
should not be a variable. If Traffic Regulation Orders are in
place, they should be effectively enforced or rescinded.
2.47 However, there are instances where the introduction of DPE
will be
accompanied, sooner or later, by new CPZs and other parking
management measures, as noted above.
2.48 The biggest initial impact on the financial context of DPE
is the
potential introduction of parking charges where none currently
apply (eg on-street) or increases in existing parking charges.
Parking charges are not necessary for DPE to work operationally,
although it is much easier to enforce charged parking than free
limited waiting. It has been argued above that DPE should,
initially at least, be introduced in isolation in order to gauge
its impacts accurately.
2.49 Introducing new sources of income at the same time as DPE
would
help underwrite the operation financially. Pay and Display
parking quickly pays off the initial investment in the ticket
machine and easily
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covers future maintenance. For example, a £3,000 machine would
be paid for in about 6 months if it controlled 10 parking spaces
that generated 40p per hour for 5 hours a day for around 300 days a
year. This disregards income from PCNs incurred for Pay &
Display contraventions.
2.50 The financial scenarios tested in this appraisal are based
on the
introduction of DPE in isolation, with no new income from
on-street parking charges accruing. This is compatible with SCC
policy ie that DPE should be introduced on its own with no other
TRO changes in the area at the same time. Any decision to introduce
on-street charging would a local one and any consequent financial
surpluses/deficits would also be locally accountable. Section 4
discusses the amount of such income necessary to ensure a high
probability of DPE viability in Runnymede.
Employment costs 2.51 Employment costs are not just the direct
salary cost. Employers
have also to pay National Insurance, make pension contributions
and pay for holiday and sick leave. Premises costs are also
sometimes included.
2.52 In this appraisal, the following remuneration and
employment cost
assumptions have been made, based on the assumption that there
will be no augmentation of the existing management structure:
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Salaries
• parking attendants: £17,000 plus £1,000 overtime •
supervisors: £n/a • clerical staff:
ticket processing (0.5 FTE) £7,000 management support (0.5 FTE)
£9,000
• managers: £n/a
These salary assumptions seek to take account of potential
recruitment difficulties in the South East and the proximity to
London, where PA salaries approach £20,000.
Employment costs • increase direct salary costs by 25% but add a
separate
accommodation overhead elsewhere. As noted above, we have
assumed that the two additional on-street PAs and the additional
processing clerk can be grafted onto the existing car parks
enforcement team without a need for enhanced management resources.
We note that this is a significant increase in management
responsibility and that it will incur training costs. The Borough
Council considers that this change should be accompanied by a
minimum 5% increase in salary scale. At this stage, we assume this
will amount to £2,000 per year. We have also assumed that overall
staff costs increase in real terms over time, as set out in the
cash flow projections in Section 3 and summarised below. This
increase is over and above cost-of-living increases. Scenario Real
increase in
salaries by end of year 5
Optimistic 10% Pessimistic 20%
Council on-costs 2.53 Runnymede Borough Council will incur
additional management
support and service costs as a result of taking on DPE
operations on behalf of the County Council. These are included in
the model as a £3,500 per year revenue cost.
Additional revenue expenditure assumptions 2.54 Some additional
assumptions have to be made about revenue
expenditure incurred in a DPE operation.
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2.55 PAs will require hand-held ticket writers and personal
radios. The
following costs have been used to cover annual revenue
expenditure incurred for maintenance and replacement of this
equipment (based on 33% of the capital cost of ticket writers and
radios set out in paragraph 2.72 below):
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Item Annual revenue
expenditure per PA (£)
Hand-held ticket writer, incl. battery charger, with integral
digital camera etc
908
Personal radio, including base station 330 Other items, incl.
stationery and consumables, training, uniform replacement,
recruitment, telephone expenses, computer system up-grades,
software licences, IT support
4000
These costs are applied only to the on-street team in the model
and are assumed to remain stable over time in real terms in the
Optimistic Scenario but increase in the Pessimistic Scenario, as
set out in the cash flow projections in Section 3.
2.56 It is not always possible to absorb additional enforcement
staff in the accommodation currently used for car park enforcement
and related activities. It will be necessary to offer the public a
“Parking Shop” facility to pay PCN-related debts and make related
inquiries. This may even entail additional staff. It is possible
that existing arrangements will suffice but this will not always be
the case. It is assumed in Runnymede that the Parking Shop
operation will take place at the existing Technical Services desk
in the Civic Centre, Addlestone. An allowance has been made under
“premises” revenue costs for additional furniture, lockers and
uniforms for Parking Attendants of £2,000 per year per Attendant
plus £1,000 for the additional 0.5 FTE ticket processing clerk. A
further allowance of £1,000 has been made to equip off-street
enforcement staff with matching uniforms when DPE becomes
operational. The future cost of this item will be borne by the
Borough Council via its off-street parking account.
2.57 It is assumed that NPAS will fund a local venue for the
adjudication
service to undertake its appeals process. This requires regular
use of a suitable room, usually for a set number of days per month.
Previously, the local authorities were responsible for funding this
accommodation.
2.58 Some means of transport will be necessary to enforce the
more
distant TROs efficiently. Leasing and operating expenditure will
be incurred. The following assumptions have been made for
accommodation and transport costs in Runnymede:
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Item Annual revenue expenditure (£)
Premises £2000 per member of the DPE resource
Transport leasing 4WD van at £4,000 per year
These costs are expected to remain stable over time in real
terms, as set out in the cash flow projections in Section 3.
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2.59 Processing PCNs involves costs associated with DVLA
inquiries,
postage, cheque processing, credit card premiums, Charge
Certificate registration at the County Court (£5 per Certificate)
and bailiff services. These are in addition to staff employment
costs. The following assumption has been made, based on current
experience in Kent:
Item Annual revenue
expenditure (£) PCN processing
£2.50 per PCN
These costs are expected to remain stable over time in real
terms, as set out in the cash flow projections in Section 3.
2.60 It is assumed that appeals will be incurred at the
following rates per
1000 PCNs issued:
Scenario Appeals per 1000 PCNs
issued Optimistic 2.5 Pessimistic 7.5
These assumptions are based broadly on current experience
outside the major conurbations, noting in particular recent
experience in Kent. The current tariff for adjudications is as
follows:
Item Annual revenue
expenditure (£) Cost per PCN £0.65 Annual cost £250
These costs are expected to remain stable over time in real
terms, as set out in the cash flow projections in Section 3.
2.61 It is generally the case that the introduction of better
enforcement results in increased use of public parking facilities.
This will generally occur in off-street car parks, provided they
have the capacity to cope with additional usage. It is often
assumed that income from off-street car parks will increase by the
order of 5% as a result of DPE. It is assumed that some motorists
would chose to pay car park charges rather than incur the increased
risk of being caught committing an on-street contravention. Where
car parks are likely to remain free (eg Tandridge) this is not a
source of additional
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income. Woking Council does not accept that such an increase is
likely, given very high car park occupancy levels and the existence
of on-street charging. Elmbridge’s, Guildford’s and Waverley’s car
parks also run near capacity. This would limit any potential
increase.
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2.62 In Runnymede, the following changes in car park income as a
result
of increased usage under DPE may be expected:
Scenario Increase in car park income from usage (%)
Optimistic 7.5 Pessimistic 2.5
The assumed annual car park income in Runnymede is about
£200,000 per annum after the deduction of VAT. This income
stream may reasonably be expected to increase in real terms over
time in an Optimistic Scenario as charges increase.
2.63 It should be noted that this income is excluded from the
DPE
appraisal as it will accrue to the Borough’s off-street parking
account and not the County Council’s on-street parking account.
2.64 Car park charges are periodically adjusted for price
indexing and
other reasons. Current charges are shown overleaf and apply to
some 1045 spaces.
2.65 The September 2003 increase took the up-to-5 hours tariff
(where
applicable) to £1.00 from 80p. The tariffs for shorter periods
also increased eg from 20p to 50p for two hours.
2.66 However, as noted in paragraph 2.50, SCC is not seeking
the
introduction of additional parking charges alongside DPE. 2.67
We have therefore assumed no increases in car park income
resulting from increased charges in association with DPE.
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Current car park charges (from 01 September 2003)
charges2
short stay medium and long stay Location number
of spaces1 up to 2
hrs 2 to 3
hrs 3 to 4 hrs 4 to 5 hrs over 5 hrs
Addlestone Garfield Road 1583 50p 60p 80p £1.00 £2.00
max 17 hrs
Chertsey Beomonds, Heriot Road
51 50p 60p 80p £1.00 £2.00 max 6 hrs
Chertsey Library, Heriot Road
190 50p 60p 80p £1.00 £2.00 max 17 hrs
Gogmore Farm 51 50p 60p 80p £1.00 max 5 hrs Egham Hummer Road
(inc. S’field store4)
118 50p 60p 80p £1.00 £2.00 max 6 hrs
Precinct, Church Rd.
87 50p 60p max 3 hrs
Precinct extension (Saturday only)
32 50p 60p max 3 hrs
Waspe Farm 157 50p 60p 80p £1.00 £2.00 max 17 hrs
Virginia Water Bourne, Station Approach
153 50p 60p 80p £1.00 £2.00 max 17 hrs
Memorial Gardens, Station Approach
48 50p 60p 80p £1.00 £2.00 max 6 hrs
Notes to above table: 1 excluding disabled spaces, for which no
charge is made if a valid orange/blue
badge is displayed 2 charges apply 0800 to 1800 Monday to
Saturday 3 capacity is restricted by a market on Saturdays 4
Somerfield customers can stay a maximum of 3 hrs
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Capital (start-up) expenditure 2.68 Having described the DPE
resource to be deployed, it is possible to
estimate start-up costs, to assist the County Council in its
capital budgeting. An allowance has been made for fixed and
variable capital (start-up) expenditure.
2.69 Fixed capital expenditure could potentially comprise:
• TRO review • signs and lines modification following the TRO
review
• car park signs modification
• computer installation/up-grade
• DPE-compatible software installation
• on-street Pay and Display installation (for financial
testing
only)
• consultation
• publicity
• staff training.
No allowance has been made in this appraisal for fixed capital
expenditure on enforcement staff accommodation or Parking Shops;
these are assumed to be revenue expenditure items. The TRO review
has been paid for out of the local non-works budget and an SCC
local allocation but is included in this appraisal in order to
provide a complete cost picture. The review cost is set at £40,000.
It is envisaged that any necessary rectification work will be paid
for out of local (LTS) “signs and aids to movement” and central DPE
budgets and is therefore excluded from this DPE model. The
currently estimated cost of this rectification work is £50,000. An
allowance is included in the model for costs associated with making
the Consolidation Order, the legal foundation for modified signs
and lines. A revenue cost of £1,500 per year is included for
maintenance of on-street signs and lines relating to parking
regulations. A capital start-up cost of £1,000 has been included to
allow for up-dating car park signs/plates. SCC would, if required,
fund the capital cost of new/augmented accommodation for all
parking enforcement staff.
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2.70 Computer software up-grading for DPE remains an area of
under-performance by suppliers that has haunted DPE since its
inception. An allowance of £30,000 has been included in the model
under capital start-up costs.
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2.71 A nominal capital start-up cost of £5,000 has been assumed
for
consultation and publicity, based on use of the SCC media
adviser. A further £5,000 has been included under revenue costs in
the financial model, falling to £2,000 from year 2 onwards. This
on-going revenue cost reflects the value of on-going publicity to
maintain the profile of DPE despite the relatively small on-street
presence currently planned.
2.72 Good training courses are available for about £5,000 each
for the PA team, the processing team and management, a total of
£30,000 based on 4 Attendants in total, a Clerk and a Manager. SCC
advises that this is a revenue cost item. It is assumed that staff
turnover will require on-going training costs. These are assumed to
be stable at £10,000 from year 2 onwards in the optimistic scenario
but increasing from this level in the pessimistic scenario.
2.73 Variable capital expenditure is incurred for items such as
hand-held
ticket writers and personal radios used by PAs, varying
according to the size of the overall enforcement team under DPE.
The unit cost assumptions for variable capital expenditure are
based on a current quotation (07 August 2003) from Langdale Systems
Ltd at the request of Runnymede Borough Council:
Item Capital start-up
expenditure per PA
(£ excluding VAT)Cassiopeia IT500 hand-held ticketing terminals
with integral digital camera, including allowance for download
cabling, multi-battery charger etc
2750
Personal radio, including base station 1000 2.74 It is assumed
that all enforcement staff (2 existing plus 2 additional)
will be equipped with ticket writer and radio equipment and that
thus four sets will be needed.
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Financial implications This Section describes the spreadsheet
model used, the cash
flow assumptions and the test results.
Financial model 3.1 A spreadsheet “model” has been built to
apply the assumptions set
out in Section 2. The model applies to year 1 of DPE operation
and is largely self-explanatory. Input assumptions from Section 2
are highlighted in yellow boxes. The model framework allows for the
inclusion of costs and revenues associated with additional and
increased parking charges for sensitivity testing purposes only.
The basic test scenarios exclude any such allowances, as explained
in Section 2. It should be noted that a proportion of the revenue
cost items in the model will be incurred in advance of year 1 of
DPE operation, as will capital start-up costs.
Cash flow 3.2 The model includes a cash flow table for revenue
costs and income
because better enforcement under DPE may reduce the number of
contraventions over time and, hence, the number of PCNs issued (see
paragraph 2.44). Some other costs and incomes are also expected to
change over time in real terms. The cash flow projection is based
on current prices (ie excluding cost-of-living increases) and the
following assumptions, for each of the two test scenarios:
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Optimistic scenario cost index based on year 1 =
100 Revenue cost item (on-street enforcement)
year1
year2
year 3
year 4
year5
staff 100 102 105 107 110 Council on-costs 100 100 100 100 100
equipment maintenance 100 100 100 100 100 premises and transport
100 100 100 100 100 uniforms (off-street enforcement)
100 0 0 0 0
PCN processing 100 100 100 100 100 adjudication 100 100 100 100
100 publicity 100 40 40 40 40 training 100 33 33 33 33
cost index based on year 1 = 100
Revenue income item (on-street enforcement)
year1
year2
year 3
year 4
year5
on-street PCNs 100 100 100 100 100 on-street Pay & Display
PCNs 100 100 100 100 100
Pessimistic scenario cost index based on year 1 =
100 Revenue cost item (on-street enforcement)
year1
year2
year 3
year 4
year5
staff 100 105 110 115 120 Council on-costs 100 100 100 100 100
equipment maintenance 100 100 105 105 110 premises and transport
100 100 100 100 100 uniforms (off-street enforcement)
100 0 0 0 0
PCN processing 100 100 100 100 100 adjudication 100 100 100 100
100 publicity 100 40 40 40 40 training 100 33 40 50 60
cost index based on year 1 = 100
Revenue income item (on-street enforcement)
year1
year2
year 3
year 4
year5
on-street PCNs 100 95 90 85 80
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on-street Pay & Display PCNs 100 95 90 85 80
Tests 3.3 The spreadsheet model tests of the two scenarios are
set out below.
Each scenario comprises two pages, the first being the year 1
calculation, the second being the cash flow projection for the
period to the end of year 5.
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insert page 26, Optimistic scenario
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Financial appraisal of Decriminalised Parking Enforcement in
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insert page 27, Pessimistic scenario
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Conclusions This concluding section considers the implications
of the assumptions used and results of this appraisal.
Optimistic Scenario 4.1 The Optimistic Scenario is based on
“high” income and “low” costs
and results in the steady accumulation of a financial deficit.
Revenue costs exceed incomes by over £45,000 in year 1.
4.2 The key variable is the number of PCNs issued per PA per
year.
We do not think it is likely that this number will exceed 1500
in Runnymede. The parking controls are scattered but small in
extent and the observed number of contraventions appears not to be
great. On-street enforcement productivity will be held down by the
absence of charged on-street parking, which is much easier to
enforce (via ticket observation) than free limited waiting (via
repeated registration number recording). It is assumed that this
income will be stable over time, partly as a result of new or
extended parking controls being introduced.
Pessimistic Scenario 4.3 The Pessimistic Scenario shows a rapid
accumulation of a large
deficit as the result of a large annual difference between total
revenue costs and incomes. The former exceeds the latter by over
£90,000 in year 1.
4.4 This result is largely the result of a PCN issue rate of
only 900 per
PA per year. This is compatible with the lowest recorded in
Kent, based on combined on and off-street enforcement. Off-street
enforcement is usually more productive than on-street because of
the use of Pay and Display technology in car parks, which makes
inspection much quicker. It is also assumed that income will fall
over time as fewer contraventions will be committed and, by
implication, no significant extensions of parking controls are
introduced in Runnymede, at least in the first five years of DPE
operations. Certainly we are not aware of major suppressed demand
for such additional controls.
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The impact of additional charges 4.5 Sensitivity tests of the
Pessimistic Scenario show that either of the
following changes would substantially reduce the risk of an
annual deficit:
• 225 on-street spaces subject to Pay and Display controls
at
20p per hour (equivalent to a 22% increase in charged spaces in
the Borough), or
• a 40% increase in existing car park charges.
Obviously, much smaller changes would be needed to balance
finances if the Optimistic Scenario prevailed.
Conclusions 4.6 It is concluded that:
• DPE in Runnymede is much more likely to run in deficit than
surplus under current policies and protocols
• any annual deficit is unlikely to exceed £90,000
• any annual deficit is unlikely to be less than £45,000
• enforcement should be managed such that each PA should
seek to achieve an initial on-street PCN issue rate of at least
1,200 per year, a target midway between the Optimistic and
Pessimistic Scenarios and broadly what is currently achieved in the
Borough’s car parks
• PCNs should be issued and processed accurately and
promptly enough to ensure an income of at least £30 per PCN, a
target compatible with the Optimistic Scenario
• capital start-up costs could be of the order of £130,000.
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Decriminalised Parking Enforcement in Runnymede: Financial
appraisal Draft Report 24 October 2003
Appendix A
PCN Contravention Codes
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Surrey County Council Runnymede Borough Council
Decriminalised Parking Enforcement in Runnymede: Financial
appraisal Draft Report 24 October 2003
Appendix B
Glossary of terms