Additional Parking Charges in
Greater London
2010 consultation
Summary of Results
1
Introduction
On 1 July 2010, London Councils and Transport for London (TfL) issued a joint consultation on
the level of parking and other penalties in Greater London. The purpose of this consultation was
to meet the statutory need to consult with each other, as well as with other stakeholders and
the public, on the level of these penalties. The consultation closed on 30 September 2010. This
document is a summary of the results received, broken down by question.
Background to the consultation
London Councils’ Transport and Environment Committee (TEC) is made up of representatives of
the 33 local authorities in London, as well as TfL. Under the terms of the Traffic Management
Act 2004, TEC is responsible, subject to agreement by the Mayor of London and the Secretary of
State, for setting additional parking charges on London borough roads.
These additional parking charges include:
 penalty levels for contraventions of parking regulations
 charges for release from wheel clamps
 charges for removal of vehicles
 storage charges
 disposal charges
TEC also has the responsibility, with regard to borough roads, for:
 setting penalty levels in respect of contraventions in bus lanes (under the London Local
Authorities Act 1996)
 setting penalty levels in respect of moving traffic contraventions, one way streets,
banned turns and yellow box junctions etc (under the London Local Authorities and
Transport for London Act 2003)
 setting penalty levels in respect of the London Lorry Control Scheme (under the London
Local Authorities and Transport for London Act 2003)
 setting the rate of discount which applies to the early payment of all penalties.
TfL has similar responsibilities for setting additional parking charges on the Transport for London
Road Network (TLRN), which it exercises with the approval of the Mayor of London and the
agreement of the Secretary of State, following consultation with the London local authorities.
The need for a review
There is no doubt that the level of resources devoted by London boroughs and TfL to parking
and traffic enforcement, based on the application of existing penalty charge levels, has resulted
in better compliance with the regulations. However, continued residual illegal parking results in
traffic congestion, causes delays to buses and raises concerns for the safety of cyclists and
pedestrians.
London boroughs and TfL are committed to ensuring drivers understand the parking regulations
as a deterrent to being issued a Penalty Charge Notice (PCN). Each authority seeks to deliver a
fair and common sense approach to traffic enforcement. It is essential for keeping London
2
moving, with enforcement focused on safety and the smooth running of London’s road network.
London Councils and TfL believe that holding a review of the level of charges at regular intervals
is consistent with the intent to deliver a fair and appropriate approach to enforcement.
A review does not necessarily mean an increase in the level of charges set but provides an
opportunity for reflection and to address the success of the measures currently employed.
Consultation results
For each question, we have presented the statistical results in a series of at-a-glance charts. We
then give a broad overview of the responses to that question, followed by a series of quotes
that typify the general ‘mood’ of all the submissions. Finally, conclusions are drawn based on
our analysis of the data.
Public opinion survey
Given the technical nature of the consultation document, we felt it important to ask some of the
‘bigger’ questions to a wider audience. Also, consultations tend to attract people with strong
views on the subject matter. As such, we wanted to get views from average Londoners, who
could be affected by changes, but might not feel strong enough to go to the trouble of
responding to a consultation.
London Councils commissioned TNS to conduct a public opinion survey to supplement the
http://wellstuffed.wordpress.com/results of this consultation. They asked 1,007 Londoners for
their views on the current penalty level, and whether the system of differential penalties should
be continued. The results of these questions are included at the relevant points in the document
(Questions D and F respectively).
The questions we posed were part of their twice-weekly face-to-face omnibus survey. Data was
collected over four waves in order to achieve a representative sample (in terms of age, gender
and socio-economic status). Respondents were interviewed face-to-face in their own homes
using the latest computer-assisted personal interviewing technology. ‘Londoners’ refers to
people living within the M25.
Next steps
The conclusions contained in this report, together with results of the public opinion survey, will
be distilled into a set of recommendations for TEC. They will decide on those recommendations
at their meeting in December 2010. These decisions will then be forwarded to the Mayor for
consideration and approval in January 2011. The Mayor will then outline the proposals to the
Secretary of State for Transport soon after. Assuming no rejections are received, any changes to
the existing regime will come into effect from 1 April 2011.
Responses to the consultation
We received a total of 97 responses to the consultation. These responses are broken down by
type, as follows:
3
London Borough
Other public sector
Road user group
Other
representative
body
Individual business
Individual person
Response
Count
31
5
8
2
10
41
In the ‘other public sector’ category, we received submissions from NHS Kensington & Chelsea,
the Olympic Delivery Authority, Transport for London and the Metropolitan Police. In the ‘road
user group’ category, we received responses from the Association of British Drivers, the
Automobile Association (AA), PenaltyChargeNotice.co.uk, the RAC Foundation, the Freight
Transport Association, the Road Haulage Association, the Brewery Logistics Group and the
British Motorcyclists’ Federation. The ‘other representative bodies’ were the British Parking
Association and the British Vehicle Rental and Leasing Association.
It is important to remember that individual businesses and people are self-selecting, and do not
constitute a representative sample. While the analysis will not be mathematical, a greater
‘weight’ will be given to those responses from London Boroughs, road user groups and other
representative bodies, given the number of people these organisations represent.
Publicity
The number of responses has decreased slightly since the last time we ran this consultation (in
2006, 113 responses were received). This is despite a great effort to encourage as many
responses as possible. The consultation document was sent by post to over 130 organisations,
including all London Boroughs and Primary Care Trusts, as well as a number of road user groups
and other representative bodies. It was also sent by email to 173 recipients, of which 64 actually
opened it.
Following a thorough and sustained media campaign, the consultation received 55 press
mentions between July and September 2010. These included three bulletins of BBC London
television news, BBC London Radio, BBC news website, LBC Radio, Evening Standard, Daily
Telegraph, Local Transport Today, Parking Review, Coach and Bus Week, and the British Parking
Association’s magazine Parking News.
A note on the respondents
A number of the responses (mostly from individuals) either did not address any of the questions
asked, and/or were unrealistic in nature (‘all parking charges should be abolished’). Some gave
views on subjects outside the scope of this review (and indeed outside the control of London
Councils or TfL).
In the interests of transparency, all responses received have been included. For respondents
who did not answer any / all of the questions posed, ‘no response’ was recorded for each of
4
those questions. We have endeavoured to include their comments under question W (‘any
other comments’). However, a summary of the written submissions which did not address any
of the questions asked is as follows:






One respondent complained that the Congestion Charge was unfair (she was directed to
the appropriate TfL consultation)
Two sent blank or unreadable forms (replies were sent asking for resubmission, but
none were received)
Two made complaints about their respective boroughs (they were referred to the
Parking and Traffic Appeals Service)
One suggested that motorists’ costs should be reimbursed if their appeal is successful
(at present, costs may be paid, but at the adjudicator’s discretion)
One felt the consultation document was too complicated, would discourage open
responses and was ‘designed to achieve specific changes’ (the respondent was assured
of the open and transparent nature of the consultation, and that no conclusions would
be drawn until all responses had been analysed)
One asked whether she could park near the station in Redbridge at the weekend (she
was referred to the London Borough of Redbridge).
We also received seven telephone enquiries. Some of these were voicemails with feedback, and
others gave their views ‘as dictation’. One requested a consultation pack to be sent. Again, ‘no
response’ was recorded where relevant (i.e. a specific question was not addressed), and the
comments are summarised below:






‘There should be a tear-off slip on each parking ticket that tells you what time your
ticket expires’
Parking penalties are unfair and ‘you should get a five-minute grace period’ (on pay-anddisplay)
‘Hearses should be exempt from all restrictions’
‘£60 penalty for brief spell in a bus lane is using a sledgehammer to crack a nut'
‘Your mind is already made up - the consultation is just a publicity stunt. You should fine
the cyclists who ride on the pavement and leave the motorist alone.’
Motoring fines are too expensive; enforcement activity is disproportionate and heavyhanded; a shortage of parking compels people to park illegally.
Where quotations have been used in the ‘headline responses’ for each question, they will be a
typical cross-section of those who submitted free text responses. Quotations may be edited for
readability, context and grammar, although every effort has been taken to preserve the
meaning of the original.
5
Question A: Do you think that the current banding system for parking penalties should be
retained? If not, what would you change and why?
Statistics
London
Borough
Yes
No
Other
No response
20
10
1
0
Other
public
sector
3
0
0
2
Road
Other
user representative
group
body
5
2
2
0
0
0
1
0
Individual
business
Individual
3
6
0
1
7
15
2
17
Overview
The majority of respondents favoured keeping the existing regime, except for individuals and
businesses where opinion was more divided. The free text responses for many of these showed
that a number of respondents had confused parking bands with differential parking penalties;
by saying no to this question, they thought they were voting to abolish differential penalties.
Others chose ‘no’ on the basis they wanted banding to continue, but to remove band C.
Headline responses





“The banding system should be retained as it fairly reflects the difference in demand at
different locations.” (London Borough)
“It is logical and can be easily explained to the general public that the two Bands, which
largely correspond with inner and outer London, are linked to the availability of and
pressure on parking.” (London Borough)
“The system [is] too complex for the average road user to understand (in terms of
differing penalties for different offences in different locations).” (Road user group)
“Banding is pointless as most people are unaware of the bands and in any case they
don’t want to get a ticket in any band.” (individual)
“Up until now, I did not know there was a banding system – [I] just thought individual
boroughs set their own fees. The current system is very complicated.” (individual)
Conclusions
The system of parking bands should remain, subject to amendment to make it simpler.
6
Question B: Should we dispense with Band C?
Statistics
London
Borough
Yes
No
Other
No response
24
6
0
1
Other
public
sector
1
2
0
2
Road
Other
user representative
group
body
4
2
3
0
0
0
1
0
Individual
business
Individual
3
5
1
1
9
13
0
19
Overview
As for Question A, there seemed to be a certain amount of confusion over what Band C refers
to. This question was more divisive, with fewer clear trends among respondents, other than that
the majority of boroughs voted to remove Band C. For many respondents who opted not to
retain the current banding system, their response to this question made it clear that they
wanted the system of bands to be retained, but reduced to two: A and B.
Headline responses






“There is no point in retaining it as there are now no London Authorities in which it
applies.” (London Borough)
“Band C is not in use and it is therefore misleading to retain it.” (London Borough)
“Yes - the current system is unnecessarily complicated.” (individual)
“The arguments for dispensing with Band C are fraudulent. Once again this proposal is
about raising taxation and not securing compliance with the law and regulations.”
(individual)
“Guidance should be issued to councils to restore Band C penalties. … there are areas
which can reasonably fall into each of the three bands.” (individual business)
“It would be helpful if this review could lead to Band C being re-instated and
encouraged as it has merit and should be used more widely.” (road user group)
Conclusions
In light of general comments regarding keeping things as simple as possible, and given that it is
not used by any local authority in London, we feel band C should be removed.
7
Question C: Do you think it is more important for the level of the penalty to reflect the severity
of the contravention, or would it be better to have the simplest possible penalty regime?
Statistics
25
Other
public
sector
4
4
0
0
0
3
8
2
0
0
1
1
1
0
0
2
1
2
18
London
Borough
Level of penalty
should reflect
severity of
contravention
Simplest possible
regime
Other
No response
Road
Other
user representative
group
body
6
2
Individual
business
Individual
4
13
Overview
Comments on this question were overwhelmingly in favour of ‘the punishment fitting the
crime’. Free text responses from businesses and individuals asked for revisions to what
constitutes a ‘more’ or ‘less’ serious contravention. A number of these called for councils to
make their policy on this area clearer. Two key criteria for more serious offences were
consistently mentioned by all respondents: dangerous manoeuvres and causing an obstruction.
Headline responses






“The penalty should reflect the offence – dangerous and obstructive parking should be
punished more severely.” (individual)
“I think that the way you define "severity" needs to be revisited … if a car is parked in a
way to cause DANGER then they should be faced with a higher penalty” (individual
business)
“As the most dangerous and obstructive contraventions attract a higher penalty, this
helps to demonstrate that parking enforcement is being undertaken to improve
compliance and not to raise revenue.” (London Borough)
“It is widely accepted that proportionate penalties are a morally acceptable response to
contravention of regulations, and so likely to be less resented and to generate better
compliance.” (Road user group)
“It is … certain that almost no drivers decide to break the rules on the basis of the level
of the penalty. Instead they gamble on not being caught, or more often get caught out
unaware that they are breaking the rules.” (individual business)
“No system is perfect.” (London Borough)
Conclusions
It is more important that the level of penalty should reflect the severity of the offence. However,
the Committee should consider reviewing which contraventions are at the higher or lower level.
8
Question D: Do you think we should continue with the current system of differential parking
charges, or revert back to the original system of a single parking charge?
Statistics – consultation
29
Other
public
sector
3
1
1
0
London
Borough
Continue with
current system
(differential
parking charges)
Revert back to
original (single
parking charge)
Other
No response
5
Other
represent
ative body
2
0
0
0
2
7
212
1
1
2
1
0
0
2
1
5
18
100
0
Road User
Group
Individual
business
Individual
5
11
Public
Opinion
Survey
695
Overview
Similarly to Question C, the significant majority of all types of respondents favoured continuing
with the current system. However, free text responses indicated a need to ‘tweak’ the system to
make it fairer on those who tried, but failed, to comply with the regulations. The public opinion
survey also showed a large majority of Londoners were in favour of keeping differential parking
penalties.
Headline responses




“London should retain the current successful system of differential parking charges.”
(London Borough)
“The differential penalties regime appears to be working and should be kept. It may be a
factor in compliance increasing across London. …Differential penalties … help motorists
understand the reasons behind parking enforcement and it is more likely to be accepted
as "fair" than a single-level regime...” (London Borough)
“differential parking charges are fine if the system is patently fair” (individual business)
“On the simple principle that the "punishment should fit the crime" I believe that the
more serious contraventions … should attract higher penalties than simple overstaying.
For me, there is also a moral issue – can it be right to penalise someone who has paid
for parking (made an effort), to the same extent as the person who pays nothing and
parks in a place … considered unsafe or obstructive to the flow of traffic.” (individual)
Conclusions
The current system of differential parking penalties should be retained. However, the
Committee should revisit why some contraventions are charged at the higher rate.
9
Question E: If we should keep differential parking charges, should there be an increase or
decrease in the gap between more and less severe penalties? How big should the gap be?
Statistics
Increase (more
severe)
Decreased (less
severe)
Stay the same
Other
No response
London
Borough
7
Other
public
sector
2
Other
Road user representative
group
body
0
1
0
0
0
17
6
1
1
0
2
6
1
1
Individual
business
1
Individual
0
0
2
0
0
1
2
5
2
5
5
24
Overview
The majority of people who responded to this question were in favour of keeping the gap the
same. Some called for an increase, and virtually none suggested a decrease. Several responses
said that the gap itself is irrelevant, and that the higher and lower level of penalties should be
set independently of each other. Free text responses to other questions indicated a desire to
increase the higher penalty, and/or decrease the lower one – although this was not necessarily
reflected in answers to this question.
Headline responses





“The existing gap of £40 between the more and less serious contraventions is about
right.” (London Borough)
“We do not have any evidence to suggest a need for either an increase or a decrease in
the gap between the two penalty levels.” (London Borough)
“Over staying in a parking place, or even parking without payment, is not the callous act
that, say, parking on zigzag lines near to a pedestrian crossing is. The first may result in
inconvenience for other drivers whereas the latter may result in physical injury. These
possible outcomes should be reflected in differential extra parking charges.“ (Road user
group)
“the gap … is a function of the appropriate levels for these penalties, which should vary
independently of each other… the gap itself is irrelevant, it is the levels of the penalties
that are important” (London Borough)
“The gap should be at a level that reflects the difference in severity between the
contraventions, while the lower level penalty is high enough to be a deterrent and the
higher level is not disproportionately high.” (London Borough)
Conclusions
Analysis of this question in isolation suggests the gap should remain the same. However,
considering it in the context of responses to other questions – particularly free text responses –
means there may be merit in widening the gap.
10
5
Double-page spread
Question F: Do you think there should be an increase or decrease in the penalty? If so, what
should the penalty be? Should it be linked to inflation and/or another index?
Statistics
London
Borough
Increase
Decrease
Stay the same
Other
No response
15
0
9
7
0
Other
public
sector
3
0
1
0
1
Road User
Group
0
2
3
2
1
Other
representa
tive body
1
0
0
1
0
Individual
business
Individual
2
3
1
3
1
1
12
3
9
16
Overview
It was clear from the language used that this is an emotive and divisive topic. Responses from
individuals are weighted towards a decrease. Many people answered only this question; of
those that did, most said they wanted a decrease on the basis they did not like paying higher
penalties, rather than for any reason relating to compliance.
Many boroughs erred on the side of caution here; those who suggested an increase said it
should be very modest, and/or linked to inflation. Others felt further work needed to be done to
quantify what an effective deterrent should be. This sentiment was echoed by a number of
respondents of all types – it was felt by many that we do not know what level would constitute
adequate compliance, or exactly what level of fine is needed to achieve this.
The majority of individuals who chose to answer this question felt the penalties should
decrease, although it could be argued that these were ‘self-selecting’ – free text responses
indicated many of these had received one or more tickets. Overall, most proposals to increase
penalties recommended using inflationary figures to do so. Expressions like ‘a tax on the
motorist’ and ‘daylight robbery’ were not uncommon. No responses recognised that these
penalties are entirely avoidable simply by driving legally.
Headline responses





“Parking illegally is antisocial and the penalties should reflect society's distain.”
(individual)
“A substantial increase. It should be set at say £200 and linked to inflation rounded up
to the nearest £10.” (individual)
“The penalty parking charge level should be set to ensure compliance. Without sight of
figures to indicate levels of compliance, it is difficult to say whether they should be
increased or decreased.” (Road user group)
“Penalties should be inflation linked” (London Borough)
“Penalties are high enough already. Some offences should be re-categorised as less
severe and therefore attract a lower penalty - especially when no obstruction to traffic
has taken place.” (individual business)
11
Public
Opinion
Survey
82
554
289
82
0









“We do know that the number of PCNs [issued] fell by 11% over the prior year, and 22%
in the past two years. Surely this tends to indicate improved compliance, and that the
current level of charges is clearly adequate” (Road user group)
“This increase should be limited to inflation.” (London Borough)
“Charges should not be linked to inflation per se. The issue is always whether or not it is
a sufficient deterrent.” (London Borough)
“We believe that parking penalties should be increased in line with inflation to maintain
a deterence effect and to ensure that the penalty level remains higher than all-day pay
and display parking in areas where tariffs are high.” (London Borough)
“The penalty for overstaying at a meter is already the same as the fixed penalty for
shoplifting and the higher penalty of £120 is 50% more than if caught shoplifting and
double that for speeding. These penalties already act as a deterrent as issued penalties
have fallen by 22% in two years. Nick Lester has always said that they must be set at the
minimum to ensure compliance so what possible reason could there be for increasing
them at this stage. Penalties should surely be decreased as compliance is up. However
as London Councils is looking for the best deal for local authorities and as TFL have a
vested interest in seeing penalties rise I think it highly unlikely that there would ever be
a decrease. Why not think of the motorist for a change.” (Road user group)
“Keep in mind that not everyone's pay is linked to inflation.” (individual)
“If prices are not increased at this opportunity, they will not be reviewed again until
2014. This would mean that the prices would have been [unchanged] for seven [sic]
years. This is a risk as they may no longer be seen as a deterrent.” (London Borough)
“Given the current financial climate and the downward trend in PCNs, the overall
charging amount … is probably at the correct rate.” (London Borough)
“Whilst inflation has resulted in some reduction in the face value of PCN amounts, the …
recession means that the financial penalties still have an impact on people and this may
be a reason for the better compliance recently.” (Road user group)
Conclusions
In drawing conclusions to this question, we have considered responses to other questions, and
also the self-selecting nature of the respondents. In particular, we have considered the need for
proportionality, and for the desire for penalties to reflect severity. We therefore conclude that
there may be merit in maintaining or decreasing the lower level of penalty, and maintaining or
increasing the higher level penalty. In addition, there may be benefit in London Councils
commissioning some research to establish a consistent methodology for measuring compliance,
and establishing what constitutes ‘acceptable’ compliance.
12
Question G: Should the differential parking penalty for contravention codes 12, 16 and 19
remain as they are? If not, should there be a single level of penalty charge for each of the
contravention codes? Should it be set at the higher or lower level? Should we dispense with the
previous Mayor’s caveat on visitors receiving a lower penalty if they were able to prove they
were visiting a resident at the time of the contravention?
Statistics
10
6
Other
public
sector
0
0
5
10
0
London
Borough
Remain as they are
Single level of penalty - higher
level
Single level of penalty - lower
level
Other
No response
4
0
Other
representat
ive body
1
0
3
2
0
4
10
0
2
1
1
0
1
5
1
10
18
Road user
group
Individual
business
Individual
0
0
3
0
Overview
This is a confusing issue for motorists and authorities alike, and this is perhaps manifested in the
varied responses received to this question. The general consensus seems to be that the penalty
should be at one level for ease of understanding. Whether this should be at the higher level
depends on whether or not parking in a resident’s bay without permission is a ‘more serious’
offence. Not everyone commented on the Mayor’s caveat but, of those that did, the majority
favoured removing it.
Headline responses






“All the above are NOT severe and therefore should receive a lower penalty without the
bureaucratic need of proof that the current system entails.” (individual business)
“I see no difference in who parks there, so don't see why visitors should be charged
less.” (individual)
“They should be removed and a single level of penalty be made. The Mayor's caveat on
visitors receiving a lower penalty should be removed.” (London Borough)
“…these three contraventions should all be subject to the lower-level penalty as they
are not likely to result in road dangers nor increased traffic congestion and are therefore
less serious matters. It would also mean that proving "visitor status" would be
irrelevant.” (London Borough)
“Protection of resident parking is a priority for most boroughs / residents, and these
contraventions should sit with other higher rate contraventions.” (London Borough)
“[The Mayor’s caveat] is something of an operational complication that is unnecessarily
burdensome on motorist, resident and enforcement authority alike. It is also open to
abuse.” (London Borough)
Conclusions
13
There is support for contraventions 12, 16 and 19 all being at a single level. Given earlier views
that the higher level of penalty should be reserved for serious obstructions and dangerous
manoeuvres, these offences should all be at the lower level. This may need to form part of a
broader discussion on whether taking up residents’ parking is as serious as causing an
obstruction or driving dangerously.
The Mayor’s caveat would no longer be necessary if all offences were at the lower level. In any
case (even if they were higher level) the caveat should still be removed due to the uncertainty it
causes, and the possibility for confusion and abuse.
14
Question H: Should the penalties on the TLRN be subject to differential parking charges?
Statistics
London
Borough
Yes
No
Other
No response
18
11
0
2
Other
public
sector
1
3
0
1
Road
Other
user representative
group
body
5
0
1
1
0
0
2
1
Individual
business
Individual
4
5
0
1
8
13
1
19
Overview
Views were very mixed; it seemed clear that many respondents thought there already are
differential parking charges on the TLRN (all parking penalties on the TLRN at present attract the
higher level of penalty). Of those individuals choosing ‘no’, it appeared from the context that
they were voting against the general concept of regulation and enforcement, rather than on the
specifics of this question. Very few respondents acknowledged the strategic nature of the
Transport for London Road Network.
Headline responses





“The differential parking charges system should be uniform across London as this
makes it easier for the public to understand and accept.” (London Borough)
“The TLRN has a variety of parking restrictions, as do borough roads. Therefore the
principle of some contraventions being of more nuisance … than others still applies.”
(London Borough)
“The TLRN applies to roads that must be kept clear as a priority to enable free flow of
traffic. They should therefore attract the highest band of penalty.” (London Borough)
“As the TLRN runs through a variety of London Authorities, it is considered that it should
be subject to the same differential charging which current applies to all London
Boroughs.” (London Borough)
“…all penalty charges issued on the TLRN should remain at the higher level as these
roads have been identified as priority arterial routes in and around London by the
Department of Transport. The strategic road network is critical to London and the
Mayor’s transport policy; penalty charge levels need to reflect the importance across
London of this network.” (other public sector)
Conclusions
There is support for the TLRN being subject to differential charges.
15
Question I: Do you agree with the discount level for early payment being 50 per cent? If not,
what level would you propose?
Statistics
London
Borough
Yes
No
Other
No response
30
1
0
0
Other
public
sector
4
0
0
1
Other
Road user
representative
group
body
6
2
1
0
0
0
1
0
Individual
business
Individual
4
3
1
2
13
7
2
19
Overview
The overwhelming majority of respondents, of all types, favoured keeping the current discount
level of 50%. Of those who advocated changing the percentage, suggestions ranged from a
discount of 15% to 90%. A small minority questioned the purpose of the discount, and felt it was
to discourage people from appealing unfair tickets (as opposed to paying promptly tickets they
acknowledge were lawfully issued).
Headline responses




“The current 50% discount provides a good incentive for the motorist to pay at this rate
as well as avoiding further recovery costs for the Council.” (London Borough)
“50 per cent is easily understandable by motorists and is easy to administer.” (London
Borough)
“A fine should be a fine and not discounted.” (individual)
“Encouraging early payment is wrong as it discourages people from disputing penalties
that should not have been imposed.” (individual)
Conclusions
The current 50% discount level should continue.
16
Question J: Should there be the same clamping, removal, storage and disposal charges across
London?
Statistics
London
Borough
Yes
No
Other
No response
22
7
1
1
Other
public
sector
4
0
0
1
Road
Other
user representative
group
body
6
1
0
0
0
0
2
1
Individual
business
Individual
5
2
1
2
19
3
2
17
Overview
As for Question F, the subject of clamping and removal is very emotive. A lot of respondents,
particularly individuals, discussed their negative feelings about the concept of clamping, rather
than their thoughts on the specific issues of how much it should cost. In general, there was a
clear majority in favour of these charges being the same across London. A handful of boroughs
suggested there should be a banding system which would recognise the differing costs incurred
by different boroughs.
Headline responses








“consistent levels reduce complaints” (London Borough)
“I can see no reason for some areas to be able to charge extortionate fees” (individual
business)
“Clamping is a horrid system and should not be used.” (individual)
“A standardised charge across London is easier for motorists to understand.” (London
Borough)
“Differential charges for removal and storage should be introduced which better reflect
the differing cost of land across London.” (London Borough)
“They should reflect the true cost of this type of action.” (London Borough)
“…charges should reflect authorities' actual costs; the current system of a single London
charge involves some authorities making a profit, which is inappropriate, and other
authorities making a loss, which is also inappropriate.” (London Borough)
“Costs of operating and managing these functions are likely to vary significantly across
London and therefore it is not appropriate to have a fixed/London-wide charge...”
(London Borough)
Conclusions
There should be one set of clamping, removal, storage and disposal charges across London.
Councils should review their policies on clamping and removal.
17
Question K: Do you agree that the clamping, removal, storage and disposal charges should be
set on the basis of cost recovery?
Statistics
London
Borough
Yes
No
Other
No response
23
4
2
2
Other
public
sector
3
0
0
2
Other
Road user
representative
group
body
4
2
2
0
0
0
2
0
Individual
business
Individual
4
3
0
3
13
7
3
18
Overview
Again, a number of respondents shared their thoughts on the concept of clamping and removal,
rather than the costs. Of those who addressed the question, the clear majority was in favour of
the charge being on the basis of cost recovery. A small number addressed the deterrent factor –
saying costs should be lower as the inconvenience factor is penalty enough, or that the costs
should incorporate a deterrent aspect in addition to the cost element. Many respondents
questioned the need for these practices, particularly clamping, and many boroughs were very
clear that they only clamp or tow in very limited circumstances, if at all. Only a tiny number of
respondents recognised that it is very unlikely charges could be on the basis of cost recovery if
they were also standardised across London (as per the previous question). In other words, if the
charges are at the same level, but borough costs differ, some boroughs will make a loss and
others a profit (although this may not be a large amount).
Headline responses





“No profit should be made out of the removal and storage of the vehicle.” (individual)
“…charges for clamp release, release from car pounds and storage charges should be
much reduced as the inconvenience is sufficient incentive to ensure drivers do not risk
such penalties.” (Road user group)
“There appears to be no justification for any other basis on which these charges can be
set.” (London Borough)
“These charges should be set to cover the cost of service provision but not to make a
profit. However, the question of compliance with parking regulations will also influence
the charges set and should be a consideration.” (Road user group)
“To drivers, the true cost of removal and clamping punishments are actually greatly in
excess of their monetary value - there is loss of time and general inconvenience... So
perhaps these other factors may be more of an influence in deterring offences than the
financial cost...” (Road user group)
Conclusions
Clamping, removal, storage and disposal charges should be set on the basis of cost recovery.
18
Question L: Do you think the charges are set at the right level for clamping, removal, storage
and disposal? If not, at what rate should the charges be set?
Statistics
London
Borough
Yes
No - too high
No - too low
Other
No response
19
0
7
4
1
Other
public
sector
3
0
0
1
1
Road
Other
user representative
group
body
2
1
2
0
0
0
1
0
3
1
Individual
business
Individual
1
5
0
1
3
5
15
0
2
19
Overview
There was a wide variety of views expressed in response to this question. As may be expected,
no-one advocated increasing the charges, except for seven boroughs. However, it must be
borne in mind that only the boroughs are in a position to comment on whether the current
charge adequately covers their costs. Of the eight boroughs who said clamping fees were too
low, only one actually clamps (Kensington & Chelsea). Their per vehicle costs for clamping
release are £96. In terms of removal, two of these eight boroughs do not remove, and one
contracts out to another borough. Of the remaining five, four had per vehicle costs ranging from
£212 to £284. The City of London currently has costs of £864 per vehicle, although these are
likely to decrease considerably in the near future as a result of changing contractors and
enforcement methods. No borough commented specifically on their storage and disposal costs.
Headline responses





“[Clamping] should only be undertaken in cases of persistent fine evaders or where
recovery of a fine is not possible because the vehicle is registered abroad.” (individual)
“Providing the current charges are covering costs, there should not be any increases.”
(London Borough)
“…charges do not meet the cost of the service.” (London Borough)
“…inner London Pounds have higher charges and this should be reflected…” (London
Borough)
“[We] do not carry out clamping as we feel that it is counter productive.” (London
Borough)
Conclusions
Only a handful of boroughs currently clamp vehicles, of which just one has costs in excess of the
current fee payable (or would want fees to be increased to cover their costs). Around half the
boroughs remove vehicles, of which only five have costs which are not covered by the fee
payable. Again, boroughs are the only respondents who actually know what their costs are, and
none felt the charges were too high. We therefore conclude there should be no increase to the
clamping, removal, storage and disposal charges.
19
Question M: Should there be a separate charge for the relocation of vehicles to neighbouring
roads that do not warrant the need for vehicle impounding? If so, how would you expect the
penalty for the relocation of the vehicle to be collected?
Statistics
London
Borough
Yes
No
Other
No response
17
12
1
1
Other
public
sector
2
0
1
2
Other
Road user
representative
group
body
4
1
1
0
1
0
2
1
Individual
business
Individual
1
5
1
3
9
6
6
20
Overview
Moving a vehicle to a nearby road was seen by some as a much fairer alternative to impounding,
although others felt it to be fraught with difficulty. The main problems were seen to be in
relation to recovering the cost of removal, as well as informing the motorist of their car’s
location. Of those who made recommendations, the majority suggested issuing a PCN and
collecting in the usual way. No-one mentioned the duty of care implications of moving a vehicle,
or the legislative difficulties with doing so. A council cannot issue two PCNs for the same
offence, and you could not issue a PCN to move it without first issuing it with a PCN for the
original contravention.
Headline responses






“[We] would support a scheme where a car could be relocated to another location in
the area to avoid it being impounded.” (Road user group)
“Moving vehicles on different roads would cause chaos, and the owner would not know
where his vehicle is” (individual)
“It will be difficult to explain to the owners of the vehicle, where their vehicles have
been taken” (individual business)
“If a car is causing obstruction it should be removed to a pound not placed elsewhere …
placing a vehicle elsewhere that is not secure may leave the authority open to legal
challenges if anything should happen to the vehicle.” (individual business)
“When it is deemed necessary to move a vehicle as it is causing an obstruction or is
compromising safety, it should be impounded. In circumstances where such drastic
action is not considered necessary, a penalty charge is sufficient.” (London Borough)
“The problems surrounding the enforcement and collection of this charge are such that
it would be impractical [to do so].” (London Borough)
Conclusions
There is clearly appetite for councils to be able to charge for moving a vehicle. However, in the
absence of any proposals to facilitate this legally, we conclude the system should remain
unchanged.
20
Question N: Should the same level of penalty apply to both bus lane and other minor moving
traffic contraventions, such as infringement of box junctions or contraventions of one-way
streets?
Statistics
London
Borough
Yes
No
Other
No response
28
2
1
0
Other
public
sector
3
0
1
1
Road
Other
user representative
group
body
5
2
1
0
0
0
2
0
Individual
business
Individual
2
5
0
3
11
10
3
17
Overview
The majority favoured the same level of penalty applying to both types of contravention.
Opinion was somewhat divided over whether blocking a box junction was more or less serious
than contravening a one-way street, although the statistics show a preference for a standard
level of penalty. A number of respondents advocated cars being allowed to drive in bus lanes
during quiet periods or ‘when empty’. Two separate respondents suggested fitting every bus
with an enforcement camera to record motorists using bus lanes.
Headline responses






“All moving traffic contraventions should attract the same level of charge.” (London
Borough)
“These contraventions are substantial breaches of the Highway Code that impede traffic
flow or create a hazard, and therefore should be discouraged as a priority. Decreasing
the penalty level would send out the message that these contraventions are tolerated
and risk decreasing compliance.” (London Borough)
“Bus lane infringements should be treated more leniently - these typically cause no
problems to anybody and are often hard to avoid.” (individual)
“All these contraventions impact the flow of traffic, and therefore lead to congestion.”
(London Borough)
“The application of the same charging level for both types of contravention has proved
very effective across London, with compliance levels increasing year on year. For this
reason [we] support the current charging policy.” (London Borough)
“Bus lane penalties should be lower, because they rarely involve road safety, and also
rarely impede bus operations.” (individual business)
Conclusions
The same level of penalty should apply to both bus lane and other minor moving traffic
contraventions.
21
Question O: Do you agree that there should be the same penalty for bus lane and minor moving
traffic contraventions throughout London?
Statistics
London
Borough
Yes
No
Other
No response
30
0
0
1
Other
public
sector
4
0
0
1
Other
Road user
representative
group
body
5
0
1
1
0
0
2
1
Individual
business
Individual
4
3
0
3
17
6
1
17
Overview
Again, there was a clear majority in favour of bus lane and minor moving traffic contraventions
being the same across London. It was generally felt that this was the fairest way of doing things,
and the simplest for motorists to understand. There was a general sense of dissatisfaction
expressed about bus lanes by a number of individuals.
Headline responses





“The danger posed, or inconvenience caused, to other road users is the same no matter
where in London the contravention occurs and therefore the penalty should be the
same wherever it occurs in London.” (London Borough)
“We need to have a radical review of bus lanes and their timings. I have seen countless
examples where the time varies along the same road which is not only misleading but
amounts to an injustice.” (individual)
“…these are more serious contraventions that potentially have road safety implications
wherever they occur… the penalties should be consistent across London.” (individual)
“Uniform charging is more easily understood by the public and should continue.”
(London Borough)
“Nearly all drivers do not know what the penalties are until they get a payment demand,
and do not decide where to break the rules on the basis of what the penalty is.”
(individual business)
Conclusions
There should be the same penalty for bus lane and minor moving traffic contraventions
throughout London.
22
Question P: Do you agree that this penalty should be the same as the higher differential parking
penalty in band A? If not, what do you think the penalty for these contraventions should be and
why?
Statistics
London
Borough
Yes
No
Other
No response
28
3
0
0
Other
public
sector
4
0
0
1
Other
Road user
representative
group
body
1
2
3
0
1
0
3
0
Individual
business
Individual
1
6
0
3
5
17
1
18
Overview
Similarly to Question O, many respondents expressed dissatisfaction with bus lanes as a
concept, rather than commenting on whether these contraventions should be charged at the
higher rate. The majority of boroughs and public sector respondents favoured the higher level,
explaining the strategic nature of bus lanes and the serious impact these contraventions have on
traffic flow. Individuals and businesses, on the other hand, generally felt the lower level was
more appropriate, given how easy they felt it was to contravene such measures by accident.
Headline responses



“Bus lane infringements are commonly accidental and … we can only see any
justification for a higher level of penalty where road safety is an issue.” (Road user
group)
“It should remain as it is so as not to compromise road safety and the reliability of bus
services.” (London Borough)
“The goal … is increased compliance, and the policy of linking bus [lane] and moving
traffic contraventions to the higher Band A charging level has proved very effective.”
(London Borough)
Conclusions
Penalties for bus lane and other minor moving traffic contraventions should remain at the
higher penalty in Band A.
23
Question Q: Should the penalty for drivers contravening the London Lorry Control Scheme
(LLCS) continue to be set at the higher differential parking penalty level in band A? If not, what
do you think this penalty should be and why?
Statistics
London
Borough
Yes
No
Other
No response
22
3
1
5
Other
public
sector
2
1
0
2
Road
Other
user representative
group
body
4
2
1
0
1
0
2
0
Individual
business
Individual
3
3
0
4
9
9
3
20
Overview
It was clear from the context that many responses (particularly individuals) felt this question
concerned the London Low Emissions Zone, rather than the London Lorry Control Scheme. The
majority of boroughs and public sector organisations sought to maintain the current level.
Businesses and individuals were fairly evenly split on whether to keep the penalty at the current
level or reduce it, although most individuals did not seem to realise they are not eligible to
receive the penalty if they do not drive an 18t vehicle.
Headline responses




“If contraventions are increasing, the penalties should increase to try to ensure that this
trend is addressed and reverses, whereas if contraventions are not increasing, the
penalties should be kept as they are (or even decrease).” (London Borough)
“Decreasing the penalty level would send out the message that these contraventions
are acceptable and risk decreasing compliance.” (London Borough)
“For consistency, [we] support the existing policy of linking the charging levels for
contraventions of the London Lorry Control Scheme to the Band A higher level.”
(London Borough)
“We oppose… this scheme. It leads to more congestion and pollution … by concentrating
lorry movements into busier times, and causes a serious loss of efficiency. It also
necessitates a complicated and expensive bureaucratic permit system, and enforcement
action.” (individual business)
Conclusions
The penalty for drivers contravening the LLCS should continue to be set at the higher differential
parking penalty level in band A.
24
Question R: Should the penalty for operators/companies contravening the LLCS continue to be
set at £550? If not, what should the penalty level be and why?
Statistics
London
Borough
Yes
No
Other
No response
20
4
2
5
Other
public
sector
3
0
0
2
Other
Road user
representative
group
body
2
2
2
0
1
0
3
0
Individual
business
Individual
2
4
0
4
10
6
3
22
Overview
As per Question Q, it was clear from the free text responses that many respondents had
confused the London Lorry Control Scheme with the London Low Emissions Zone. Again, most
boroughs and public sector organisations sought to maintain the current level. Businesses were
in favour of reducing the penalty (perhaps unsurprisingly, as it applies only to businesses, not
individual drivers), and individuals were divided on the issue, although most favoured
maintaining the current level.
Headline responses




“Any reduction in charge is likely to result in a reduction in compliance.” (London
Borough)
“Decreasing the penalty level would send out the message that these contraventions
are acceptable and risk decreasing compliance.” (London Borough)
“This seems excessive when the small margins of road hauliers and small businesses
relying on lorries … are considered.” (individual)
“That's far too much….cripling small businesses” (individual business)
Conclusions
The penalty for operators/companies contravening the LLCS should continue to be set at £550.
While intentionally set considerably higher than the penalty for drivers, to act as an added
deterrent, this is an easily avoidable penalty. There is also an independent appeals process in
place.
25
Question S: Should the level of bond remain at £250? If not, what should the level of bond be
and why?
Statistics
London
Borough
Yes
No
Other
No response
17
8
2
4
Other
public
sector
2
0
0
3
Other
Road user
representative
group
body
5
2
0
0
0
0
3
0
Individual
business
Individual
3
2
0
5
9
6
2
24
Overview
This question received some of the lowest volumes of free text responses. The majority of all
respondents favoured keeping the level of bond at £250, particularly as it has only recently been
set (2009) and has yet to be used by boroughs. A handful of boroughs advocated an increase in
line with inflation.
Headline responses



“It needs to be retained at a level sufficiently high to encourage the vehicle owner to
make representations against outstanding penalty charges. An increase in the bond
would be necessary should the penalty charge be increased.” (London Borough)
“The bond should be reviewed following the pilot of the legislation, not at this stage.
Depending on the behaviour of persistent evaders over the pilot, the bond may need to
be increased (or even decreased) outside of the usual four-year cycle for reviewing
parking and traffic charges.” (London Borough)
“The level of bond should be set at £250 plus any outstanding PCNs.” (London Borough)
Conclusions
The level of bond should remain at £250.
26
Question T: Should the penalty for contraventions on those parts of the Olympic Route Network
(ORN) where traffic and parking restrictions are unchanged be matched to the penalty set by
Olympic Delivery Authority (ODA)? In other words, should there be a single fixed penalty level
for all contraventions on the ORN, or should there be different penalties at different points
along the ORN, including the differential parking penalties that apply elsewhere in London?
Statistics
Yes - there should be a
single fixed penalty for the
whole ORN
No - there should be
different penalties at
different points along the
ORN
Other
No response
London
Borough
23
Other public
sector
4
Road user
group
4
Other representative Individual
Individual
body business
2
1
10
5
0
2
0
4
6
1
2
0
1
1
1
0
0
1
4
5
20
Overview
For all three questions regarding the Olympic Route Network, many respondents expressed
general dissatisfaction with the concept of the network, or even the Games themselves, rather
than answering the questions about level of penalties. While it is outside the scope of London
Councils’ / TfL’s remit to do away with the network, it is important to consider how emotive this
issue is.
The majority of all respondents to this question felt the same level of penalty should apply
across the whole ORN.
Headline responses





“Different penalties will just cause confusion” (London Borough)
“There simply should not be a penalty. Why can't police escort athletes? The traffic isn't
bad enough in london to warrant the ORN” (individual business)
“There should be a single level of penalty for all ORN offences.” (individual business)
“We can see no justification for any differentiation … there should be the same charges
applied as for any other PCN … We can see no reason why additional penalties should
be imposed for the Olympic routes.” (Road user group)
“To have a two tier system would be nonsensical and a recipe for confusion.” (London
Borough)
Conclusions
The penalty for contraventions on those parts of the ORN where traffic and parking restrictions
are unchanged should be matched to the penalty set by the ODA.
27
Question U: Do you think that in areas off the ORN, where Games-related restrictions apply, the
penalties for contraventions of unchanged regulations should be matched to the penalty set by
ODA, so that a single penalty level applies?
Statistics
19
Other
public
sector
4
10
0
5
0
5
11
0
2
0
1
0
1
0
0
0
4
4
20
London
Borough
Yes - a single
penalty should
apply
No - different
penalties should
apply
Other
No response
Road
Other
user Representative
group
body
2
2
Individual
business
Individual
1
6
Overview
As per Question T, this was a contentious issue, although the majority here was not as clear. This
is also has the potential to be very complicated, and many respondents called for the system to
be as simple and easy to understand as possible.
Headline responses




“There is no need for anything special for the Olympics. London has paid for these
games and should not be penalised in addition.” (individual)
“If the higher penalties agreed by the ODA only apply to the ORN, this will be to the
detriment of non-ORN roads in areas in close proximity to events.” (London Borough)
“it would be confusing and inappropriate to have penalties for non-ODA regulations, off
the ORN, changed during the Games; if the regulation and/or area is not Games-related,
it should not be affected by the Games – [they] are likely to cause disruption enough
without deliberately multiplying their adverse effects.” (London Borough)
“Yes there should be a single fixed penalty for all contraventions on and off the ORN,
where games related restrictions apply. However, this should be linked to the PCN
charging levels which result from this consultation.” (London Borough)
Conclusions
There should be a consistent penalty in each area away from the ORN.
28
Question V: Should different criteria be applied for different circumstances?
Statistics
London
Borough
Yes
No
Other
No response
7
18
0
6
Other
public
sector
0
3
1
1
Other
Road user
representative
group
body
2
0
4
1
1
1
1
0
Individual
business
Individual
3
1
0
6
10
9
4
18
Overview
Again, simplicity and ease of understanding were the most common themes in respondents’
answers to this question. Most respondents felt different criteria should not be applied in
different circumstances, although the majority was not as clear as it has been for other
questions. Individuals had varied views on this question.
Headline responses




“The boroughs need the flexibility to determine those areas most at risk during the
actual Olympic Period. For some it will be the area around an event/venue for others it
will relate to access to public transport.” (London Borough)
“For simplicity and to reduce implementation costs, one charging system should apply whether the ORN's charges or the standard borough charges.” (London Borough)
“Athletes should allow sufficient time for their journeys, as everybody else has to.”
(individual)
“Too many variables and too vague. Ajudication cases would be challenging to say the
least.” (London Borough)
Conclusions
Any changes over the Games period should be as simple as possible. Dates of operation should
be kept simple and consistent, so it is easy for the motorist to understand when different
penalties apply.
29
Double-page spread
Question W: Do you have any other comments?
Overview
As previously discussed, many people used this consultation as an opportunity to express their
dissatisfaction with the current regime of parking enforcement. In particular, the current level of
penalties, the concept of clamping and removal, and the need for an Olympic Route Network,
were all extremely unpopular. There were also a number of comments that ‘the system’
(ranging from the number of contravention codes through to the appeals process) is extremely
complicated, and excessively punitive.
Headline responses








“the current charges which are covered by this consultation are generally excessive, and
the system too complex for the average road user to understand” (Road user group)
“Westminster and other councils have introduced pay by phone/text which is a great
improvement on the ‘no change given’ approach that has been taken up until now. This
should be extended across the entire capital with one central number and registration
centre.” (individual)
“Petty rules that stipulate which way up the ticket must face, not having multiple
(expired) tickets on the dash board and not transferring an unexpired ticket to another
vehicle are grossly unfair and bring the whole parking system into disrepute.”
(individual)
“In general there needs to be a sense of fair play and common sense introduced. At the
moment the motorist is just seen as a soft target and a cash cow by local authorities.
Motorists see the local authorities as modern-day Dick Turpins.” (individual)
“Whilst there is a contravention code for issuing a PCN to a lorry entering a lorry ban
area, there is currently no such code for a PSV doing so. This needs to be remedied.”
(London Borough)
“It is stated clearly in the consultation document that “It is not the boroughs’ or TfL’s
intention to seek to raise revenue through the issue of PCNs” and that traffic
enforcement is “essential for keeping London moving”. It is difficult to reconcile these
statements with daily practice. There are two specifics here:
o Current practice focuses all too often on side streets rather than main traffic
routes as this provides easier income and less confrontation.
o We have a major problem with repeat offenders, often deliveries for shops, who
are content to pay the parking fines and the councils who see the revenue
stream from this as more important than protecting traffic flows.” (individual
business)
“Traffic delays on Sundays are a problem yet to be addressed: the absence of parking
restrictions in many areas on Sundays means that delays on Sundays can be worse than
the rest of the week.” (individual business)
“If existing policies are continued I would not be surprised to see a widespread revolt by
London residents many of whom are entirely capable of recognising the difference
between reasonable, fair, and well managed traffic and parking rules and enforcement;
and the flat-rate stealth taxes now levied.” (individual)
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“There should be a separation of powers between authorities that remove the provision
of parking space (or set conditions upon its use) and authorities that enforce parking
offences (and, it may be noted, collect revenues from doing so). The existing conflict of
interests is a recipe for exceedingly poor corporate governance. Councils have shown
repeatedly that they cannot be trusted to act responsibly in the regulation of
parking.”(individual)
“There should be a generous grace period (say 15 minutes) because there are many
circumstances where well intentioned people get delayed through no fault of their
own.” (individual)
“There is a strong and justified belief widespread across London that regulations are
imposed in order to generate income from penalties, and the way that London councils
are allowed to retain income is wrong. We say that councils should lose the ability to
retain revenue from enforcement, and this should instead be passed to the general
taxpayer.” (individual business)
“There is also a need to review the number of contraventions that exist. Currently there
are over 200 possible contraventions although … 96% of the PCNs issued fall into only 20
of the possible contraventions.” (London Borough)
“What is, or is not, complex, with parking penalties, is somewhat academic. With nearly
100 offence codes and many more suffixes, the system is not simple. What the system
should achieve is fairness and transparency. The offence code descriptors are clear in
themselves and one trusts that the signage on street is of a similar quality.” (London
Borough)
“Each local authority should be free to set its charges as it chooses according to local
conditions. The days of centralist control by London-wide commissars should end.”
(individual)
Conclusions
When considering levels of penalty, local authorities should make their decisions in the context
of calls to make the system fairer and simpler.
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