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Parking Consultation – another brilliant response

Mr Hudson spells out what the Department of Transport says “controlled parking” is for, and compares it with CCC’s approach.


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7th December 2012

Ref:- Canterbury City Council (Off-Street Parking Places) 0rder 20l3

Dear Mr. Carmichael,

I wish to OBJECT to the above Order concerning proposed raising of car
parking charges. I believe that Canterbury City Council (CCC) made a profit of around
£2.5 million in the last financial year from an overall turnover of
approximately £7 million in car parking charges.

I would like to quote you a few passages from the Department of
Transport Operational Guidance
manual on parking and have enclosed a copy of
the front page for identification.

From page 14:

“But raising revenue should not be an objective of CPE
(Controlled Parking Enforcement) nor should authorities set targets for revenue
or the number of Penalty Charge Notices (PCNs) they issue.”

Also:

“The judgement in R v LB Camden (ex parte Cran) made clear that the Road Traffic Regulation Act 1984
is not a revenue raising Act”.

Also:

“The objective of CPE should be for 100 per cent
compliance, with no penalty charges”

As you are aware CCC issued 25,275 PCNs in 2009/10 and this obviously
accounts for considerable income.

From page 24, when talking about parking objectives it states:

“keep traffic moving, rather than raising
revenue”.

Page 112, once again it repeats:

“Authorities should never use parking charges just to
raise revenue or as a local tax”

and goes on to state what should happen with any surplus income:

“In such cases local authorities must ensure that any
on-street revenue not used for enforcement is used for legitimate purposes only
and its main use is to improve, by whatever means, transport provision in the
area so that road users benefit”.

Page 135, it repeats again when talking about surpluses

“They can use any surplus to improve off-street, or,
where this is unnecessary or undesirable, for certain other transport-related
purpose and environmental schemes”.

To sum up, Canterbury City Council is already making a hefty profit
from its parking regime and any further increases seem to more of about general
revenue raising, which this manual seems to clearly indicate is not the
stated aim of parking regulations.

What benefits have drivers gained from previous years’ profits?

I would like a written response to my objection letter concerning the
issues raised.

Thanking you for your time.

Yours sincerely,

Mr. Terry Hudson

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