Despite only 5% of people supporting the proposed Emissions Based Parking charges, Croydon Council has today announced that intends to plough ahead with the proposed changes.
Croydon Council has today advised residents:
The Council Members of the Traffic Management Advisory Committee, at their meeting on 24th July 2019, have considered the comments received and have recommended the introduction of emission-based parking permit charges. The process concluded in a formal decision on 15 August 2019.
The new charges will apply when a resident permit is next up for renewal after 1st October 2019 and after 1st April 2020 for other permit types.
A public report on the consultation outcome and decision process is available as a pdf download (3Mb).
The statutory procedure for consulting on the revised charges structure requires that the Council responds to all the comments received, which is the reason behind the lengthy nature of this communication.
Background
The proposal was developed to help meet an objective from the Parking Policy 2019-2022, which addresses national, regional and local drivers:
- The national Clean Air Strategy 2019, with aims to clean up the UK’s air and reduce the damaging impact air pollution has on public health, including the harmful emissions from vehicles amongst other sources.
- The national Road to Zero Strategy aims for 50-70% new car sales to be Ultra Low Emission Vehicles (ULEVs) by 2030.
- The London Mayor’s Transport Strategy 2018, which prioritises public health and aims to reduce car use throughout London.
- Croydon’s Air Quality Action Plan 2017-22, which aims to reduce exposure to air pollution and raising awareness for those who live and work in Croydon.
- A survey the Air Quality Action Plan (AQAP) in July 2017 found 76% of 356 respondents rated their views on air pollution as ‘very important’ and a further 14% rated their views as ‘important’. 88% agreed that the AQAP healthy streets initiatives are important.
A survey on the future of transport for the draft third Local Implementation Plan (LIP3) in September 2018 found that 74% of 994 respondents are concerned about air quality in Croydon and 72% agreed that traffic levels should be lowered. - The Council has a duty under the Road Traffic Regulations Act 1984 to exercise its power to secure the expeditious, convenient and safe movement of vehicles and other traffic (including pedestrians) and having regard to the amenity, the national air quality strategy and any other relevant traffic management matters.
The emission-based charges will address these objectives, by helping to encourage a switch to lesser polluting cars and also help influence the choices of those who are able to give up a car.
Consultation Responses
The number of responses received to the consultation represents about 10% of active parking permit holders, bearing in mind that not all respondents would have been permit holders. The following sections list the comments received and the Council’s response to these comments. Some respondents made more than one comment.
19% of respondents said they believe the Council’s has made the proposal as a means to raise income.
Using parking schemes as a means to raise income would be inconsistent with the Road Traffic Regulations Act 1984. The charges are determined in accordance with the Act to help secure the traffic management objectives for reducing air pollution and the number of cars on the road. Any surplus from parking charges are ring-fenced and, for example, contribute to sustaining public transport fare concessions such as the Freedom Pass.
The new charges are considered necessary to influence emissions levels and the otherwise continuing increase in the number of parked and driving cars on the road in the Borough. Since the permit charges were last reviewed in 2013 there has been a 7% growth in the number of vehicles registered in Croydon. This has meant that there is an increasing pressure for parking spaces and drivers have become desensitised to the charges applied, hence reducing their effectiveness for demand management. The permit charges set in 2013 are currently too low for achieving the parking management objectives. This is evident in the number of respondents to this consultation saying it is too difficult to find a parking space. This results in residents circulating the neighbourhood in search for a parking space which inevitably adds to congestion and air pollution.
13% of respondents said the proposal is unfair to those who cannot afford a newer car, which includes the poorest, elderly and vulnerable.
Some respondents added that the proposal would result in personal financial hardship.
Any change to fee structures will have an impact on local residents and it is important to note that the forecast model based on assumptions of changing car ownership shows a net increase across all the proposed charging bands of 13.5%. This remains less than the 15% ONS Retail Price Index, since the permit charges were last reviewed in 2013.
The permit charge will remain a relatively modest element of the total cost of car ownership. Compared to all other associated costs of owning a car, permit charges would be a minimal percentage of the overall cost.
Residents and local businesses for whom parking and road congestion have adverse economic and quality of life implications include people who cannot immediately afford to replace their older cars. We must also consider fairness to residents who are vulnerable to air pollution, which disproportionally are the young, the elderly and those who live in some of the poorest areas of the borough. They represent groups that tend to have lower car ownership.
Active encouragement of lower emission vehicles and the underlying reduction in car use, benefits all individuals, families and neighbourhoods. Air pollution is an important and increasingly more high profile public health issue, contributing to illness and shortened life expectancy. It disproportionately impacts on the most vulnerable in the population, in particular the sick, young and elderly. Those at higher risk include those with existing respiratory problems and chronic illnesses such as asthma and chronic obstructive pulmonary disease. People who live or work near busy roads are at particularly high risk of exposure to the health harms of air pollution.
Any surplus from parking permit charges are ring-fenced and, for example, contribute to sustaining public transport fare concessions such as the Freedom Pass scheme for the elderly. The parking permit charges therefore indirectly support the portion of the elder population that do not have a car or who choose to use public transport.
The holders of 11,459 individual and 71 organisational disabled blue badges issued in Croydon are exempt from the parking charges.
In context of the 148,256 (in 2016) vehicles registered in Croydon, the higher £300 band on resident permits accounts for 371 vehicles in the highest emission group and 413 that predate March 2001. This equates to 8.7% of all active resident parking permits (9,048) as at the end of 2018, which are issued to residents across the whole income spectrum. Proportionally, the higher charge will apply to a very small number of residents on low income. The proposed charges can therefore not be generalised as having a disproportionate effect on residents with low income.
11% stated their opposition to the scheme [but without providing any specific reason].
The objections were counted and noted, but do not have any point to consider.
10% said they are concerned about fairness to owners of little used cars, who offset pollution by frequent walking, cycling or public transport use. Some said that parked cars do not pollute and that the proposal is therefore inconsistent with the polluter pay principle. An additional 2% specifically highlighted pre-2001 cars that have low emission or low mileage. 1% mentioned unfairness to classic and historic car owners.
Firstly, the charges are not only increased for the high-polluting vehicles, but they are also substantially reduced for low-polluting vehicles. This presents an opportunity for people who use the car infrequently, to eventually lower their parking costs by choosing a lower emission model at their next car choice.
Cars are generally owned for purpose of driving. When the parked car is driven, it contributes to pollution. All car ownership therefore contributes to pollution, in various amounts. The adoption of lower emission vehicles amongst parked cars will contribute to improved air quality.
Infrequently used cars also occupy the over-subscribed kerb side space in residential roads. They therefore contribute equally to access difficulties and impact on the public realm. A sizable number of respondents in this consultation express concern about daily problems of not being able to find a parking space near to home. Non-essential cars, including second and third cars, can needlessly obstruct access for those residents who have more essential needs for a car. Other respondents tell that they too often have to drive around the block until a bay becomes vacant. The high rate of car ownership, including infrequently used cars that spend a disproportional time taking up kerb side space, is a principal contributor to traffic circulating in search for a parking space and adding to congestion and air pollution.
Some of these little used cars, and second or third cars, could be candidates for conversion to shared pool car uses or other alternatives to car ownership. The emission-based charges will help encourage this. The Council has a policy to support the expansion of car share schemes.
The permit charge must be an influencer for those who are able and willing to consider the alternatives to non-essential car ownership and the emission-levels in their next car choice. If permit charges were to be set at a lower level then it would not influence a sufficient number of owners in their next car choices or support the objectives for the scheme.
Standards for measuring and declaring emissions were not introduced in a controlled way until 2001. The DVLA does therefore not hold verifiable CO2 emissions data for older vehicles. Older cars were designed to lower standards and generally pollute significantly more than newer cars.
6% said that drivers are taxed enough and 6% said that parking permits are expensive enough already. 2% added that they already pay council tax and don’t want more tax. Less than 1% said the scheme is a form of double taxation.
The parking permit charges do not form part of general taxation. They are introduced to influence and achieve traffic management objectives, which include air quality considerations that form part of the national air quality strategy. Any surplus from parking charges are ring-fenced to highways and transport schemes and, for example, contributes to sustaining public transport fare concessions.
The continual growth in the number of cars on the road indicates that ownership is overall becoming more affordable. Many elements of car ownership and usage costs are already being used to influence behaviours, including road tax, diesel fuel duty and differential congestion charges in London. However these are national or regional schemes, which tend to be moderated for the general national denominator and Central London. These measures are insufficient to help stem the number of cars on the roads in Croydon, where the number of vehicles registered in the borough has grown 7% since 2013.
The permit charges set in 2013 are currently too low to support access and to encourage a switch to lower emission cars. The differential in the charging bands must be sufficient to encourage low emission and to discourage high emission. Narrowing the charging differential, to lessen the permit charge for high-polluting vehicles and second cars, would detract from meeting the parking management objectives. The new charges are required to influence a necessary change.
The proposed permit charges for the 2 lower emission bands are lower than the current pre-existing charges of £80, for residents, and this represents an opportunity to obtain a lower priced parking permit when next choosing a car. The other 3 bands serve as an encouragement to adopt cars with lower emissions or to reconsider non-essential car ownership.
5% of consultees say diesel is getting unfair press and owners were encouraged to buy diesels.
The diesel surcharge will only apply to vehicles that are more than 4 years old.
The national policy on favouring diesel started to progressively reverse in 2009, when the then scrappage scheme was also introduced for older cars. According to the Society of Motor Manufacturers and Traders, the growth in the registrations of new diesel cars levelled off in 2015 and has since been in decline. Diesel currently continue to have a positive role in the wider CO2 reduction, in particular for motorway driving where pollution disperses more easily. Older diesel cars, however, contribute disproportionally to NOx in build-up urban areas.
The national Clean Air Strategy 2019 has devolved responsibility for further reducing urban NOx emissions mainly to a local level. The Mayor has introduced ULEZ in Central London and there is a requirement that the outer London boroughs implement local Air Quality Action Plans. NHS data shows that Croydon currently have the highest rate of hospital admissions for childhood (0-9 years) asthma in London. 7.5% of premature deaths in Croydon are linked to air pollution. Failing to address NOx and particulate matter emissions from older diesel (and older petrol) cars in Croydon would deprive many local people of their ability to breathe safe air.
Several manufacturers currently operate diesel scrappage schemes, offering between £2,000 and £6,000 discounts. A national grants scheme for electric vehicles currently covers up to 35% (to max £3,500) of a car’s price, or 20% (to max £8,000) for vans. This subsidy opportunity is available to owners of older diesel vehicles.
4% of consultees say the scheme is unfair to residents living in a CPZ, while not addressing high-polluting cars outside CPZs. 3% added reference to those who drive into or through the borough from the outside.
The CPZ represents a location where residents have reported significant parking congestion and requested that such congestion is managed. In non-CPZ locations, the congestion either does not exist to the same level or has not been raised as a concern yet and therefore does not need managing at this point in time. The Council does not implement CPZs where they are not necessary. In most cases the need for CPZs are within the higher density geographical areas and less so in lower density areas.
The first phase of emission-base parking charges addresses the most parking congested roads within residential CPZs. The next phases of the proposed emission-based parking charges will look to additionally address polluting vehicles traveling within and into the borough, to public parking places in general. These new proposed charges cannot be immediately implemented, as they depend on the prior uptake in mobile parking payment technology, which is being addressed separately to emissions-based permit charges in CPZs.
4% of consultees say that residents have received insufficient forewarning and time to adjust, when considering that the normal car replacement cycle. The charges could wait until next time a permit holder replaces the car, to enable a fair choice.
The national Clean Air Strategy 2019 and the London Mayor’s Strategy require further actions to reduce urban emissions mainly to a local level. These actions are required to start showing measurable results by 2021. Public Health (NHS) data shows that Croydon currently have the highest rate of hospital admissions for childhood (0-9 years) asthma in London and 7.5% of premature deaths in Croydon are linked to air pollution. Delaying the new charges until the next car replacement would encourage a proportion of car owners to keep their current high-emission vehicle for longer. Failing to address emissions in a timely manner would deprive many local people of safe air.
3% of consultees said there are too few EVCPs (Electric Vehicle Charging Points) to support the transition to electric vehicles.
The Council is currently rolling out on-street charging points and plan to reach 400 public charging points by 2022.
The government currently offers a £500 grant for home charging points for category 2 and 3 plug-in hybrid vehicles, which are available to new low emission vehicle owners.
3% agreed that emissions need lowering, but state the scheme is the wrong way to go about it [not specifying an alternative solution].
The Council will keep an open mind and support emissions-reduction solutions as they are identified in all fields. New solutions could be considered for replacing the emissions-based permit charges. For the emissions and car reduction to start showing their required effects by 2021, however, the recommended emission-based charges cannot be delayed for yet unknown alternative solutions to be discovered and developed. Without the introduction of emissions-based parking charges it is considered that there would be insufficient measures to influence car ownership and to timely address the public health concerns locally. Private car transport is just one aspect of local air pollution, but is also a major contributor to local traffic and parking congestion.
3% said the scheme is unfair to essential car users who work unsocial hours, must drive their children, are vulnerable, carry loads and live in a hilly part of the borough.
Any change to fee structures will have an impact on local residents and it is important to note that the forecast model based on assumptions of changing car ownership shows a net increase of 13.5%. This remains less than the 15% ONS Retail Price Index, since the permit charges were last reviewed in 2013.
The permit charge will remain a relatively modest element of the total cost of car ownership. Compared to all other associated costs of owning a car, permit charges would be a minimal percentage of the overall cost – in particular to essential car users who tend to incur costs associated with higher mileages. It is, however, important to seek to influence a choice in lower emission vehicles for essential use.
The scheme does not automatically assume that the transport of children as being essential. The Third Local Implementation Plan reflects the Croydon local plan and the London Mayors Transport Strategy, including that all local Councils must help children and parents to use cars less and walk, cycle and us public transport more.
The proposed scheme has concessions for disabled blue badge holders and care charities and others.
2% said public transport infrastructure is inadequate, too pricy or too unfriendly to substitute for the car and will need improving first.
The Council has an ongoing programme of works with the Mayor, Transport for London, Network Rail and Train Operating Companies to improve public transport links to our local high streets, including introducing new routes to better connect Croydon’s places and to increase capacity.
2% said the scheme is unfair to residents who do not have private driveways.
Most homes in Croydon were built in a comparatively car-free age when house builders in denser populated areas did not need to consider space for private driveways. Traditionally there was a difference in the nature of higher density urban living and lower density sub-urban living. In the future as demand for homes grows there will be an intensification of our suburbs which will require forward planning to manage the parking infrastructure.
The lack of private driveways was not a problem at the time when most residential streets in Croydon were laid out. The problem has only arisen as result of an excessive increase in car ownership proportionate to the available road space. The solution today should look to stall or reverse the continued growth of the number of cars requiring a parking space and the impacts of car ownership relative to the impact on air quality. The emission-based permit charges are intended to help residents re-consider non-essential car ownership.
2% said that the scheme just increases parking costs but does still not guarantee a parking space near to home.
As the borough continues to grow in population and density the introduction of emission-based parking charges aims to address overarching national, regional and local drivers with an aim of reducing emissions. Such charges would encourage a lesser reliance on cars and a switch to lesser polluting cars, which on average tend to be smaller in size and impact less on available space and public realm
The solution to better assuring availability to a parking space is to reduce the number of cars requiring a parking space. This would mean that some residents and businesses giving up non-essential car ownership. Infrequently used cars and second and third cars are for example disproportionally occupying the over-subscribed space in residential roads. The residents who have a rarely needed car, including a second car, are candidates for considering the alternatives to car ownership. The emission-based charges will help encourage this.
2% said there is too much development being permitted in Croydon, which results in more cars.
Of the developments currently taking place across Croydon, the highest intensity projects are located close to transport and commercial centres. Residents in such developments will be within walking distances of shopping, leisure, work and public transport. The planners have therefore been able to restrict their access to permit parking bays and require more car share schemes. Although the number of residents in Croydon will increase, the developments will help dilute car ownership per head of population.
2% said the higher £300 represents 375% increase and is unreasonably high.
In context of the 148,256 (in 2016) vehicles registered in Croydon, the higher £300 band on resident permits accounts for 371 vehicles in the highest emission group and 413 that predate March 2001. However, these vehicles add disproportionally more to emissions in congested residential CPZ streets. It is therefore considered important to enhance the perception of the permit charge differential, to effectively influence car ownership choices.
2% said the scheme will not reduce emissions. People need their cars and there will still be cars on the road.
The debate that the current proposal has spurred is already proving helpful. This is exemplified by a few of the respondents to the consultation declaring that they will now give up their cars. A respondent has expressed thanks to the Council for its decision to encourage the respondent to give up one of the family cars.
The scheme is intended to result in the cars travelling on the road being lower emission on average. A further phase of emission-based parking charges is being developed to address polluting vehicles traveling within the borough to public parking places in general (i.e. on and off street parking spaces), and not just in residential CPZs. These new proposed charges cannot be immediately implemented, as they depend on the prior uptake in mobile parking payment technology, which is being addressed separately to emissions-based permit charges in CPZs.
1% said that enough is being done to reduce emissions already and 1% said new parking charges are not needed. A small number (less than 1%) added that there is no evidence that congestion and air quality is a concern. 1 respondents said that Air Quality within Croydon is well within EU limits and 1 respondent commented “there is currently no evidence that air pollution causes asthma, although it is likely to be a ‘trigger’ and can worsen symptoms”.
The national Clean Air Strategy 2019 and the London Mayor’s Strategy require further actions to reduce urban NOx and particulate matter emissions be taken mainly at the local level. In Croydon an Air Quality Management Area (AQMA) has been declared for the whole of the borough, for failing to meet the EU annual average limit for air pollutants.
Public Health (NHS) data shows that Croydon currently have the highest rate of hospital admissions for childhood (0-9 years) asthma in London. Asthma related exacerbation, triggered by air pollution, can be a cause of death. 7.5% of premature deaths in Croydon are linked to air pollution. Failing to address NOx and particulate matter emissions in Croydon would deprive many local people of safe air.
1% said high charges will put off people visiting Croydon and district high streets. A further 1% of respondents, who identified with representing a business, commented that the proposal is a burden on local businesses at already difficult times and can drive away business. 1 respondent compared the scheme to a business tax. Another respondent expressed concerns about levels of traffic and the ability of small and micro businesses to continue in operation.
The proposed parking permit charges do not apply to or alter the parking charges for visitors to Croydon and the district centres. A future phase extension to the emission-based parking charges will be consulted on separately.
Business will become negligibly affected (in the range from positive to negative) by the scheme. There are just 285 business permits in use and each presents an opportunity for a permit charge reduction. The later phase of emissions charges proposed for destination parking comes with new Smart Parking technology, which has potential for better guiding drivers to vacant parking bays. This is designed to reduce congestion and air pollution from cars circulating in search for a space; but it also seeks to make the visit to Croydon easier. The reduced parking difficulties has potential to support traders and businesses in Croydon.
1% said that if the Council is serious about air pollution then it would shut down the Beddington incinerator.
The Council does not consider the emission-based parking proposal to be in conflict to the waste service provided by its contractor, which operates an Energy Recovery Facility in compliance with the Industrial Emissions Directive and regulated by the Environment Agency.
Private car transport is of course just one aspect of local air pollution, but is also a major aspect of local traffic and parking congestion. Regionally, the London Mayor’s requirement for car use reduction in outer boroughs are devolved to local levels. Without the introduction of emissions-based parking charges it is considered that there would be insufficient measures to influence car ownership and to address the public health concerns locally.
1% stated their objection because the scheme does not aligned with the London ULEZ (ultra low emission zone), which uses road charges and exempt older cars. A few respondents said such a scheme should be London-wide and some assumed it will come to Croydon anyway in the next 2 years.
The proposed scheme is not the same as the London ULEZ, which is a binary charge and is concerned with moving traffic. The Central London type congestion charging is very complex and expensive to operate. Introducing such a scheme in Croydon would practically need to be joined up to a London-wide scheme – but the Mayor does not currently have any plan for extending the ULEZ to Croydon. The Mayor instead requires the outer boroughs to define and implement their own schemes, whether they call it ULEZ or something else and to use measures that that are appropriate for local conditions. The Mayor’s aim is a reduction in car ownership and use in the outer boroughs.
Considering that every car journey starts and ends with a parking space, the parking charges structure is considered to be an important means to influencing car ownership and use in Croydon.
In addition to the objections:
5% of respondents stated their support for the proposal.
This support was counted and noted but the various supporting comments do not require a detailed response.
4% of respondents made statements that cannot be reliably interpreted as either opposing or supporting the scheme, including some commenting on unrelated matters.
These statements could not be considered in relations to the proposal for emission-based parking permit charges.
Consideration was given to all of the above. In conclusion, the consultation has not identified material objections that would invalidate the objectives for introducing emission-based parking charges.
