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NPPG 17 ADDENDUM AND REGULATORY IMPACT ASSESSMENT:
TRANSPORT AND PLANNING MAXIMUM PARKING STANDARDS
OVERVIEW OF CONSULTATION RESPONSES

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INTRODUCTION

Background

1. On 1 February 2002 the Scottish Executive issued a draft NPPG17 Addendum and Regulatory Impact Statement on transport and planning maximum parking standards. The draft Addendum set out the Executive's proposals which develop policy in NPPG17 and, inter alia, proposed a set of national maximum car parking standards.

2. This report provides an overview of the findings from the consultation responses.

Responses

3. Approximately 600 copies of the Addendum were distributed to all local Councils in Scotland, a wide range of public bodies and non governmental organisations, industry, business and professional interests, plus a number of other groups and individuals. The consultation period closed on 30 April 2002.

4. In total there were 45 responses from a wide range of interests which can be broken down into the following categories:

5. A full list of respondents can be found in Annex A. Only one respondent requested that their response be kept confidential, and copies of all other responses are available for public inspection at the Scottish Executive Library, Saughton House, Broomhouse Drive, Edinburgh EH11 3XD. For an appointment, please contact Mr Alan Gold (0131 - 244 4552). Additionally a fuller digest of comments relating to each issue is available on the Scottish Executive Planning Homepage http://www.scotland.gov.uk/planning /.

ISSUES EMERGING FROM RESPONSES

General Comments

6. The Executive has analysed the comments and, where appropriate, made amendments to the policy guidance. There was a clear majority of respondents who supported the guidance, albeit many had constructive comments intended to improve policy implementation. Some mainly rural Councils were opposed to the application of maximum standards, and opposition also came from parts of the private sector, including major food retailers.

Options

7. The majority of responses supported the principle of maximum standards and identified Local Council standards coupled with a national ceiling as their preferred option. The majority of Local Councils welcomed the flexibility to set their own maximum standards. This sat well with the principle of subsidiarity and was necessary to reflect local circumstances and to take account of local factors. Those opposed to maximum standards were most likely to favour the status quo and retention of minimum standards, and only two responses supported complete non-regulation.

An Integrated Approach

8. The point was made that maximum standards form part of an integrated approach to transport. It was generally felt that the proposals would encourage sustainable development and sustainable transport choices, although some felt the NPPG could have described these benefits more fully. Clarification was also sought on how the proposed standards were derived.

Minimum standards

9. Many Councils stressed the need to impose minimum standards in addition to maxima. Without a minimum standard developers would be tempted to provide little or no parking. Developer contributions would be difficult to secure without a minimum standard, and minimum standards would be required in some instances to prevent on street parking. In defence of the developer, a small number argued that market forces, and demand for spaces, would always ensure a minimum level of provision.

Land Use Classification

10. There was some confusion regarding the land use classifications used by the NPPG. There was a clear desire for the development types to be more tightly defined.

Exceptions

11. Several groups felt that national standards should allow for exceptions on such grounds as poor accessibility by public transport, operational need and to support economic regeneration.

Accessibility

12. A number of responses were concerned about the role of accessibility. It was suggested that the level of accessibility by public transport should be a determinant of parking standards. There was concern that strict standards would make areas of poor accessibility even less accessible.

Structure Plans

13. Several responses considered that standards should be implemented through the Structure Plan, as opposed to Local Plans or Local Transport Strategies. This would improve consistency and reduce competition between local Councils.

Location

14. There were mixed views on the relationship of parking standards and location policy. Most Councils expressed support for directing development to, and implementing stricter parking standards at, key nodes and town centres with existing transport links. Higher density development should be allowed where developer contributions support public transport, though doubts were raised about the ability to secure developer contributions under the new proposals.

15. One response considered that some businesses depend on their location on the road network and the availability of car-parking, and some felt the guidance could have done more to recognise that development will still be required in out of centre sites with limited transport provision. One response suggested that the standards would place the attractiveness and viability of new developments at a disadvantage in comparison with existing developments in terms of car parking.

16. One Council stressed that brownfield development in built up areas should not be undermined by more generous standards on greenfield sites. However many rural Councils believed businesses would relocate from rural areas to more accessible urban locations. One Council argued that parking standards would in some instances prevent development from proceeding at all.

Economic Impact

17. A number of responses suggested that the proposals could have a detrimental impact on the economy, particularly on town centres and food retailing outlets. Businesses in rural areas are often more dependent on car use, and therefore the introduction of maximum standards poses a greater potential risk to the rural economy, including risks to car borne tourism.

Local Council Competition

18. It was widely, though not universally, recognised that the introduction of national parking standards would, to an extent, constrain Councils from adopting unsustainable standards. Standards would also be effective at reducing competition between urban Councils that can presently lure developers with less strict standards. Some suggested that competition would be reduced if standards were applied through structure rather than local plans.

Retailing and Town Centres

19. Parking restrictions for quantity food and bulky goods retailing were regarded by some as inappropriate, notably by the supermarket chains themselves, but also by some Local Councils. Restricting parking provision will do little to encourage the use of alternative modes of transport. Tesco and the Scottish Retail Forum did not accept that car parks are under-utilised, and Tesco suggested that the food retail standard should be 1:10 and not 1:14. The application of any standard should recognise that supermarket parking in town centres is often also used by town centre users. Viability and vitality of town centres were important objectives which parking standards should not compromise.

Residential Development

20. The exclusion of residential developments from maximum standards was widely welcomed. There were exceptions, and a number of bodies argued that residential areas in urban centres or in close proximity to transport nodes should have reduced levels of parking to help encourage lower car ownership, while others suggested the application of minimum standards to residential developments. A housing association suggested that a market solution to residential parking would be preferable to minimum standards.

Urban/Rural Split

21. Some felt that the NPPG failed to recognise levels of public transport provision outside of urban areas and Scotland's central belt. In remote and less populated areas services are often variable and public transport accessibility is poor. However criticism of public transport provision was also levelled at urban areas.

22. After public transport concerns the most commonly raised issue was that of urban and rural split. A number of Councils with significant rural populations considered that the proposals would have an adverse impact on rural areas, and suggested that the proposals be re-examined.

23. Issues identified included lower population densities, longer travel distances, higher car ownership, basic public transport provision, and an often narrower economic base. It was felt that a nation-wide policy, which covers large high density cities with high levels of public transport and relatively short journeys, bore no relationship to the experience of rural areas with low levels of public transport and large journey distances. It would be unreasonable in rural areas to reduce parking places and expect the existing public transport network to cope.

24. It was also suggested that while strict standards are appropriate in areas with buoyant economies, economic development could be thwarted in less prosperous areas. Traffic growth was sometimes necessary for economic development, and businesses will relocate from rural areas to more accessible urban locations to the detriment of the rural economy.

25. A number of Councils recommended that further consideration should be given to variations for rural areas, and that to reflect geographical and economic diversity maximum levels should differ in cities, towns and other areas.

Social Justice

26. The proposals were generally considered equitable. One Council suggested that parking restrictions would socially exclude those with no access to public transport while others suggested that economic impacts resulting from the proposals could have consequences for employment and therefore lead to social exclusion.

Mode Shift

27. Some doubts were expressed as to whether the proposals would achieve mode shift. Journeys would continue to be made by car regardless of the parking available at the journey's end. Others stated that some trips could not reasonably be undertaken by any mode other than the car, the two most common examples being quantity food and bulky goods shopping. Several responses sought greater emphasis on public transport, walking and cycling, and one party suggested that maximum standards should also be applied to cycle parking.

Public Transport

28. It was recognised that the introduction of maximum standards would have to be linked with improvements and investment in public transport, to improve levels of provision, quality and attractiveness. Alternative travel choices and public transport provision should be in place before parking is introduced. There was some concern over how this would be achieved.

Parking Overspill

29. A significant proportion of responses raised the issue of on street parking in areas surrounding a development. There was a strong risk of developers providing insufficient car parking to keep costs down and maximise floorspace on site. The impact on residential areas was of particular concern. Some argued that minimum standards could be used to prevent uncontrolled parking in some instances, and would be appropriate for smaller developments in residential areas. Two responses believed that sharing parking across developments would be difficult to achieve.

Disabled Parking

30. A number of responses suggested that the guidance could be clearer in stating that maximum standards do not apply to disabled parking. Various responses suggested specific wording.

Benefits

31. Although there was a generally positive reaction to the proposals, few responses referred specifically to 'benefits'. One Council stated explicitly that the benefits had been described adequately and comprehensively while two others stated that they considered the benefits to be overstated. A number of responses stated that the proposals would enhance sustainable development.

Compliance Costs

32. Two responses stated explicitly that the compliance costs are comprehensive, adequately described and weighted. There was very little detailed information on costs in any of the responses.

33. There were mixed responses on development effects. Less parking would bring construction costs down, and cost savings for large developments may be significant. Savings must however be set against possible lower rents if the occupier perceives there to be too little parking. This would affect a scheme's viability. One response recognised that car park areas will become available for development.

34. There was no consensus on the impact on small business. Some thought standards would be detrimental for small businesses, others that they would have little impact, and others again that they would lead to the growth of small businesses.

35. A number of groups believed there would be extra administration costs connected with the proposals. One company stated that delays from appeals and referrals could lead to increased operational costs.

36. A number of responses concerned the burden that enforcement of restricted parking might place on the police. The introduction of PCZs would have considerable resource implications, both in establishing a PCZ, and in enforcing it. The procedures for establishing PCZs could be simplified.

37. Eleven Councils raised the issue of developer contributions. Several were concerned that without a minimum standard there would be little leverage with which to obtain commuted sums and that developers may provide no parking at all.

38. Several Councils were concerned with the implications of providing additional public transport, and many Councils were anxious about the possible loss of revenue currently received from commuted payments (these two issues are addressed previously in this report). The prospect of introducing parking restrictions was a cause of concern for many, and it was also suggested that there could be implications for development planning and development control. The issue of transport assessments and transport plans was also raised. Several Councils requested further guidance on the implementation of the proposals.

39. A significant number of Councils believed the introduction of parking control zones could have considerable resource implications for themselves and for the police. The procedures for establishing Traffic Regulations are lengthy and time consuming and of particular concern to smaller Councils with less experience of parking controls. It was also noted that there would be additional costs in surveying and providing additional infrastructure associated with restricted parking.

40. A third of Councils responded specifically on issues of development control. The development control process would become more complicated, more discussion with developers would be required and local Councils would become more involved in delivering the transport requirements of new developments.

41. A number of Councils believed the proposals would lead to additional demand for section 75 planning agreements. It was felt this would result in an additional administrative burden.

42. Two responses were concerned about the practicalities of reducing parking provision in the event of an extension to an existing development.

43. A number of responses considered that the proposals would lead to increased use of Transport Assessments and Travel Plans particularly to justify exceptions from standards. A small number of responses were concerned that this could have additional resource implications.

44. Several responses addressed the issue of referral to Scottish Ministers. Additional referrals might cause delay, which in turn could lead to increased costs to local Councils, developers and business. Some felt that the referral mechanism introduced further complication to the planning process, and would lead to delays.

45. One Council was concerned that council parking standards would perform badly at planning appeal should fewer spaces be required than the national standard. Another Council believed it would be difficult for them to refuse applications that brought employment if there was doubt over maximum standards being backed at appeal. Any additional appeal proceedings resulting from the proposals would incur additional burdens on the resources and finances of the local Councils.

Annex A: List of Respondents