Decrim consult rep

1.a This Study was commissioned by the Isle of Wight Council to investigate the feasibility of creating a Special Parking Area (SPA) across the whole of the Council's administrative area, and the resulting financial viability of such a step. A SPA is an area, in which parking offences are decriminalised, using the powers of the Road Traffic Act 1991. Within a SPA, the responsibility for the enforcement for virtually all parking passes from the Police to the Highway and Traffic Authority. The income from the parking tickets issued is retained by the Highway Authority, to be used to fund the scheme, with on-street surpluses being ring-fenced under Section 55 of the Road Traffic Regulation Act 1984 for certain highway related matters. Being a unitary authority, the Isle of Wight Council would be responsible for all of these matters directly. The issue to be investigated in this Study is whether or not this is a viable power to be acquired, and the implications of doing so, were the Council to decide to proceed.

1.b The general conclusion is reached that the creation of a Special Parking Area is financially viable within a timescale of a few years, and is operationally desirable, given the declining involvement of Police resources on enforcement, and the level of current illegal parking activity. The Council is therefore recommended to decide how the powers will be adopted, to agree that local authority enforcement should be undertaken and the basis for this, and to instruct officers to proceed with implementation. The Special Parking Area should include the off-street car parks currently enforced by the Council, in order to provide a uniform enforcement capability in all Council parking areas, and to obtain full benefits of the economies of scale.

1.c The Hampshire and Isle of Wight Police will support the principle of a SPA that covers the whole of the Council's area, and have indicated that they will cooperate with the handover of the powers in an agreed manner. Their support is paramount to the success of an Application to the Department of Environment, Transport and the Regions (DETR) for the powers. Their traffic warden force has declined in recent years and this change is indicative of the reduced commitment that the Police can provide to traffic related matters.

1.d To acquire the powers, the Council will have to formally apply to the DETR for a Designation Order which decriminalises parking enforcement across the whole of the Isle of Wight. From the date set in this Order, the Police will be unable to enforce the majority of parking related offences, and the Council must be ready to undertake the responsibilities. This process is estimated to take around 8 months to complete, subject to any dissolution of Parliament for a General Election.

1.e If the Council adopts the responsibilities, the Council will then be in a position to enforce both on and off-street parking in a coordinated, comprehensive manner which for the first time will provide a single policy and responsibility for the control of public car parking on the Isle of Wight.

1.f This undertaking is in line with Government policies for restraint over the growth of traffic in urban areas, and it complements other Government measures such as the encouragement of the use of public transport, the restraint of commuter-based parking and the consideration of workplace charging. In this regard, the adoption of these power accords with the policies set out in the Council’s Local Transport Plan. The Government's view is that DPE is a positive contribution to traffic management, based upon research work carried out for the DETR by the Transport Research Laboratory.

· a coordinated parking enforcement service would be established, covering on and off-street parking;

· the service will eventually be self-financing, other than for the initial funding period;

· growth in demand for vehicular access to the town centres of the Island would be restrained;

· the design of future parking schemes such as resident permit schemes, for which there is demand, could be undertaken in the knowledge that parking controls would be enforced as the Council decided;

· overall environmental conditions, including safer traffic conditions, and less pollution would result from less illegal parking, fewer cars, and better circulation;

The question can be asked if there is not a simpler way of achieving these benefits. The 1984 Road Traffic Regulation Act allows authorities to enforce permitted on-street parking places; however, it does not allow them to enforce the adjacent waiting restrictions. Unless enforcement is applied in a uniform manner across a geographic area, there is a risk of displacement of parked vehicles, causing other, more serious problems. Consequently, the only way to achieve overall enforcement in an area is to establish a Special Parking Area, as defined in the Road Traffic Act of 1991, and for the Council to take responsibility for all non-endorsable parking contraventions in that area.

1.8 It is the view of the consultants that the project will be financially viable, assuming that the Authorities adopt a number of recommendations. A detailed financial model was created for the purposes of carrying out the financial assessment. This model also allowed the officers and consultants to test a range of possible outcomes for the project, and to arrive at conclusions regarding the range of circumstances which would result in financial viability. Financial viability is broadly considered to be recognised by a scheme design which results in the project recovering its set-up costs within a period of 3 to 4 years at the maximum, and thereafter, producing a surplus.

1.9 The project included the direct costs and income of the increased enforcement associated with decriminalisation; it also included in the financial assessment, the predicted impact of certain indirect consequences of DPE.

1.10 The projections are based on both the current levels of Penalty Charge Notice (PCN), which is set by Government at £40, and at an increased level of £60. The current level has now been set for about 10 years, and is widely recognised as being quite inadequate. As a part of a general review of fines and charges, the Government is expected to increase the £40 to £60 later this year, and has already announced increases in Police Fixed Penalty Notices. The £40 PCN makes it difficult to see how the Council could cover the basic costs of the scheme; however, the £60 level makes the scheme have a reasonable financial viability.

1.11 Additional parking-related income is important to help the project to achieve viability in the initial few years of operation; thereafter, the income surpluses will be available for the purposes decided by the Council, within the constraints of the law. The new on-street income from penalty charges is ring-fenced, as defined in Section 55 of the 1984 Road Traffic Regulation Act. However, use of off-street income is unaffected by this change.

1.12 The new decriminalised enforcement allows an Authority to enhance its ability to act against particular groups of offenders by the use of wheel clamping or vehicle removals. The conclusion is that at present these methods should be generally avoided, but considered for introduction if and when the new enforcement regime proves to be inadequate.

1.13 The modelling process tested a number of options, analysing issues such as:

1) The introduction of on-street enforcement, without any other major changes to the management of parking within the Council, and using current Penalty Charge levels as made available by Government (£40).

2) The impact of the probable increase in Penalty Charge levels to £60 expected within the next few months from Government.

· If the Penalty Charge (PCN) level is not raised from £40, the project is not viable, even if on-street charging is introduced;

· An active programme of enforcement is a basic requirement for a financially viable project; this applies to the issuing of parking tickets, and to the pursuit of debt.

On this basis, the view of the consultants is that progress should be based upon the above scenarios, with the £60 PCN level, which gives a strong probability of financial success.

1.14 To address the major change in responsibilities arising from decriminalisation, a coordinated internal parking management structure will be required. It should be responsible for all aspects of the operational management of parking on the Island, and should have a Parking Manager at its head. This must include all aspects of on-street parking, and should include all off-street parking operated by the Council as well. In the context of Best Value, consideration should be given, at an early stage after the decision to decriminalise, to tendering out the services associated with the revised parking enforcement, including on and off-street enforcement, the administration of parking tickets, and the management of resident permit schemes. It may be considered that it would be logical to include within such a contract, other aspects such as cash collection and banking from the car parks, and car park equipment maintenance. However, it should be borne in mind that there is already a viable in-house parking capability, and that in an authority of this scale, it would be questionable if tendering out and introducing decriminalisation are activities which could be successfully carried out at the same time. It is also far from certain that contracted out enforcement would offer financial savings over an in-house operation.

1.15 An enlarged parking administration section should be created, placing the responsibility for all aspects of the administration within the same overall day to day responsibility as the parking enforcement activities. As well as dealing with routine correspondence and payments, the administration team would have to incorporate the sensitive aspects of ticket processing, including the despatch of Notices, the consideration of formal representations from aggrieved drivers, the interface to the independent adjudication system provided for within the legislation, the registration of debt at the County Court, and dealing with cases passed to a bailiff.

1.16 The Council must participate in an independent appeals mechanism, known as the Adjudication Service. The new National Parking Adjudication Service (NPAS) is now established and functional. The Council should therefore apply to join this service, which will meet the need to have a source of hearings for appeals, when the Application for the powers is made to the DETR. The Adjudication Service functions as a Section 101 Committee so it will require an elected Member to formally represent the Council at the very infrequent Committee meetings that are held. The main costs of this service have been taken into consideration in making the assessment.

1.17 The Council's current IT system for the processing of parking tickets will need to be upgraded for the administration of Penalty Charge Notices. The experience of other authorities is that this is a significant undertaking, and should not be pursued without adequate resources being applied to the project. Due to larger volumes of work, the system should be re-configured to increase staff productivity through investment in technology. If other services are to be contracted out, consideration should be given to including within the contract; the provision of IT services for parking.

1.18 The next major stage of the project which would follow a decision to accept the principle recommendations of this report, is to prepare a SPA/PPA Application to the Secretary of State at the DETR. This aspect should be pursued over the next few months, accompanied by a programme of consultation with the Police, neighbouring mainland Authorities, and other interested parties. A review of the Council's parking policies in the light of forthcoming decriminalisation will form an important element of the Application. The objective should be to have an Application submitted for approval within a few months of a decision to proceed. Consultation with the public is not a statutory requirement, but the Council should decide how to consult with or inform the public, and the form such consultation should take.

1.19 In the meantime, a project to review the traffic regulations throughout the Island should be agreed and resourced. This will be a large undertaking, as there are a considerable number of kilometres of such regulations, and the views of the Police are that significant inaccuracies exist. It is the experience of the consultants that the process is easier to manage given that the TROs have been set up on a geographic information database system (GIS) from which maps can be produced for on-site checking, which can then be used to manage the amendment and schedule production processes. Subsequently, TRO accuracy and access improve greatly, both very important considerations when dealing with cases called for adjudication, as well as for routine correspondence management. The software system in use by the Council for a TRO database is the most appropriate one available on the market for this purpose.

1.20 Experience indicates that to introduce decriminalised enforcement will require a timetable of at least 18 months from the date of a decision to proceed. To manage this project, a Project Steering Group and Project Manager role should be established, to include not only officers from the various internal sections that are concerned, but also representatives from the Police. Such is the importance of the project, it is suggested that major policy direction for the project should come from a group of Members and senior officers within the Council, constituted and delegated with the responsibility for successful implementation of decriminalisation.

1.21 This report has confirmed what several other authorities have found; the Council can, by introducing decriminalised enforcement also introduce better parking enforcement at no overall cost to the Council, except for a short term deficit required to fund the start-up phase. The Isle of Wight Council will then join the other Authorities that have found that they can make the control over illegal parking a means of helping to achieve their overall transportation objectives.

2.a In responding to the requirements of the Study Brief, the consultants have carried out a detailed investigation into the feasibility of the Council taking on the powers available under the Road Traffic Act 1991 (RTA91) to transfer the responsibility for all non-endorsable parking contraventions from the Police to the Council. This power is usually described as the "decriminalisation of parking enforcement (DPE)".

2.b This would be an important step for the Council was the decision to be taken, it would have far-reaching impacts within the Council, but it would provide a major improvement to the overall traffic management capabilities of the Council. This report reviews a number of the key issues relating to the introduction of the powers. It should be read in conjunction with the financial summary (Appendix E) and versions of the financial assessment, which detail the range of possibilities and the likely outcomes. The versions of the model also provide the detail on staffing, associated costs, and a range of related issues.

2.c The 1991 Road Traffic Act (RTA'91) permits Highway Authorities to apply to the Secretary of State to become Special Parking Areas/Permitted Parking Areas (SPA/PPAs, usually referred to as a SPA). Once a SPA application is approved, the power to enforce on-street parking restrictions passes from the Police to the Highway Authority. The revenue collected from Penalty Charge Notices (PCNs) for contravention of parking restrictions goes to the Council rather than to the Government. The on-street income is ring-fenced under Section 55 of the Road Traffic Regulation Act 1984, and may only be used for certain designated highway matters.

2.d The main advantage of becoming a SPA would be the ability of the Council to determine the level of enforcement that was felt appropriate to satisfy transport policy objectives as they relate to parking. By employing Parking Attendants rather than relying on the Police to employ traffic wardens, the Council would have the ability to decide how many to employ, and in what ways they were to be deployed to address issues such as traffic capacity (through inhibiting obstructive parking) and traffic restraint (through reducing overstaying at time-limited spaces and parking on other restrictions imposed to limit on-street parking capacity). It would also enable the Council to enforce parking restrictions in support of other policies and development proposals in the Town Centres, and elsewhere on the Island. There is however, an overriding requirement in making a successful SPA application that the Police are satisfied that parking restrictions will be adequately enforced. In effect, this implies that the provision for enforcement is no less than it is currently.

2.e In a major study of the effectiveness of decriminalised enforcement in London, the Transport Research Laboratory (TRL) in their Research Report 279 (Sept. 1997) reported that one of the major achievements in the three areas studied was "an overall improvement in compliance with parking regulations". In the TRL Report 333 (March 1998) on the experience of the first year of decriminalised parking enforcement in Winchester, the first conclusion is:

"Compliance at all regulations monitored has improved, with reduced levels of occupancy, thereby increasing the likelihood that motorists will locate vacant parking spaces".

2.f There is now no doubt that DPE works, that it can be introduced at no long term cost if properly implemented, and that the traffic management benefits can be realised.

2.g The major benefits which the Council would experience as a consequence of the introduction of a SPA would be:

- An ability to design new parking controls in the light of Government pressures on traffic management policies, knowing that the Council has the ability to enforce the regulations;

- A more uniform level of enforcement applied across all parking regulations on the Island;

- Support for public transport initiatives through encouragement to consider alternatives to the private car;

- An ability to retain the income from the parking tickets issued, to re-invest this income in the provision of the service, and to develop a self-financing scheme with significant traffic management benefits;

- An ability to retain the VAT paid in respect of off-street Excess Charges when PCNs are issued in their place;

- An ability to respond to growing pressures on parking provision, for example, through the introduction of further resident parking schemes, in the light of having the ability to enforce them;

- Better use of the Council (and other) car parks, by encouraging drivers not to park illegally;

- Improved conditions for servicing, particularly through reduced competition for road space;

2.h There are few disadvantages of DPE; the main issue is that there is no opportunity to reverse the process once an Order is made. This implies that once decriminalised, the Council has to make the system work. This is not so large as issue as might be implied however. If the resulting financial equation is not appropriate, it is only a matter of adjusting the scale of the enforcement resource until a better balance is found.

2.i The scheme requires a significant amount of set-up money; if desired, much of this could be defrayed onto a contractor, but the Council will still have to find some set-up costs to invest before the main income stream is established.

3.a.i The most obvious internal impact of a DPE project would be that parking as a service would become much larger, with more staff involved, and more costs and revenue to manage. The current arrangement for the management of parking internally will therefore require review. DPE will not work unless there is a single responsibility to coordinate all aspects of parking service delivery, with service level agreements where necessary for aspects (eg cashiering) which cannot be managed by a single parking team. The Council is recommended to ensure that there is a single manager with the responsibility for all operational matters involved in on and off-street parking, including in particular, enforcement and administration. Strategic and design issues relating to parking should be kept under a responsibility separate from the service delivery issues.

3.b.i An important, but very simple, policy issue is the definition of the geographic extent of the SPA/PPA for the Council. The conclusion is that it should cover the entire Island, and that this coverage should be achieved in a single step. This conclusion is arrived at for a number of reasons:

* This is the simplest position to adopt for the DETR Application, and it is what the DETR wish to see; indeed, it is highly unlikely that DETR would agree to anything else.

* Excluding some areas of the Island, even initially, would mean that they would probably get no enforcement; a common Police view in such circumstances is that if the Council does not consider it important to enforce these areas, nor will the Police.

* From a practical aspect, there may be no traffic wardens to enforce these areas, should they all either transfer to the Council or their agent under TUPE, or be re-deployed by the Police, as is understood to be current Police policy.

3.b.ii However, certain exclusions may have to be made to this simple definition; the Police may have views on areas where they would wish to see the regulations remain under their control. This could apply for example in areas around the various prison establishments on the Island. However, initial discussions have not indicated a need for any such exclusions. This is an issue to be formally agreed with the Police as soon as possible.

3.b.iii The SPA/PPA must include the Council off-street locations where traffic orders apply, as DETR will not allow such areas to be excluded. This also means that the enforcement regime applied across the District is uniform from a public perspective, and has a single procedure from a parking administration point of view.

3.c.i As the introduction of DPE is about the transfer of certain responsibilities from the Police to the Council, it is important that good relationships are maintained between the two organisations throughout the project. The Police have to be formally consulted as an element of the Application preparation process, and although in theory, their agreement to the process is not required, it would clearly be a major failure if both parties were not to agree as to the nature and timing of the project.

3.c.ii One of the biggest issues to be determined by the Police is the future of the traffic wardens. The Police have to determine if they intend to retain some or all of the wardens, or if they wish to re-deploy them internally, or if they wish in effect, to make them redundant. In the latter circumstance, there may well be an issue of whether or not the wardens will be transferred to the Council and whether or not this would be under TUPE. It is understood that the Police have a current permanent establishment of 6 wardens in Isle of Wight, with 5 currently in post with another group recruited seasonally. Although this seasonal recruitment is normally about 6 wardens, this year, the complement was just 3 wardens. It has to be recognised however, that the overall number has declined significantly over recent years. What happens to these wardens will be determined by their local senior officers, with the preferred option at present being to re-deploy them internally. However this issue needs formal agreement as soon as possible within the project, as it could have a significant cost implication to the Council. The question of whether TUPE would apply is not clear; there are examples of TUPE transfers from Police to local authority, and there are examples of non-TUPE transfers. One issue which has arisen elsewhere is the contract terms for traffic wardens, and whether or not they are appropriate for the roles of Parking Attendants for the Council e.g. do they provide for routine Sunday or evening working? This whole TUPE issue needs resolution as it inevitably takes time to reach agreement.

3.c.iii The issue of physical violence after the start of DPE is also important to consider. In areas which have already adopted the powers, it has been found that Council PAs are more prone to physical abuse and even attack than are Traffic Wardens, so an excellent link to the police to request urgent assistance is essential. The most constructive attitude tends to be where the police recognise that having a larger number of uniformed people on the street can act as a benefit to their operations, acting as eyes and ears to assist them, as well as vice-versa.

3.c.iv Although they have no obligation to do so, a number of police forces in certain areas have agreed to hold a local Authority radio from the parking operation within their Control Room, in order to be in a position to respond to calls for assistance as quickly as possible.

3.c.v The issue of special events on the Island is of particular significance for discussions with the Police. With any such event occurring in this area e.g. Cowes Week, the nature of the responsibilities of both the police and the Council would change, with the Police losing aspects of their powers to enforce parking, yet the Council parking staff having no powers to get involved in the direction of traffic. This new relationship should be discussed, and the need for parking enforcement understood between the 2 organisations, with agreement reached as to how the resources would be best deployed in future, after DPE.

3.d.i The NPAS is now fully operational. The direct costs of the service have been fully accounted for within the financial assessment, with the minor exceptions of the costs of having Member involvement in the Section 101 Committee directing the service overall, and any costs of accommodating an adjudicator in neutral premises for their infrequent hearing sessions on the Island.

3.d.ii The Council should register their intentions with the NPAS as soon as they have decided to decriminalise, informing them of the probable start date, and the likely volume of PCNs that will be issued. This is primarily for the planning of the NPAS service, but it will presumably in due course, enable the Council to participate in the dissemination of knowledge and experience which is important in understanding the appeal mechanism.

3.d.iii In time, it will be necessary to establish and operate local premises for the adjudication cases that are to be heard in person and locally. These premises are likely to have to be provided and organised by the local authority. They will have to be such that appellants can perceive the process to be independent of the Council, and other authorities who have already gone down this path have found that public service premises, such as courts and even Guild Halls are acceptable as being suitably divorced from the pressures of the Council.

3.d.iv It is also to be expected that the Council will have to provide the staff to support the adjudicator in administering the hearing sessions. This would include reception duties, dealing with enquiries; ensuring adjudicator decisions are given to appellants, and perhaps even providing a degree of security back up for the hearings.

3.d.v The volume of cases that will be referred to the NPAS is likely to be quite small. The propensity for appellants to go to independent review is strongly influenced by the care and effort invested by the Council in dealing with the early stage of an appeal. Winchester gets less than 0.5% of the PCNs issued going to appeal, and the average overall for London is still below 1%.

3.e.i Many Council have chosen to tender out the services associated with DPE, as they are frequently either new services, or considerable extensions of existing services. Whereas 10 years ago, there was no commercial market for the provision of such services, there is a now a fiercely competitive marketplace, with tenderers vying for what are often 5 year, multi-million pound contracts.

3.e.ii New companies are continuing to try to break into this marketplace, which makes it particularly important that contracts are well specified, and carefully evaluated. The range of assessed quality between the companies is quite marked, as is evident just from their tender submissions.

3.e.iii The issue of whether or not to contract out is fundamental to the project scope; it is decision which has to be taken at an early stage, as it has a major impact on just about every other aspect of the project. It is not possible at this juncture to advise as to whether it would be appropriate for the IoWC to contract out all or part of the enforcement services. It is possible to say that if the Council wanted to contract out; there is ample evidence that such an approach in general can work, but that it will not necessarily result in a better service, or in a financial saving.

3.e.iv There are several benefits of contracting out parking enforcement services, in general. The principle ones are considered to be:

· the contractor will provide the capital required; this can cover the main capital items required for DPE, as well as related items such as the renewal costs of signs and lines;

· Good contractors have a wealth of experience of this service now; this means that they can get up the learning curve locally must faster than an authority can do on its own; this could translate into better enforcement in the early stages, and better cash flow to the authority.

· Contractors mostly have good links to the IT system suppliers, and can provide a comprehensive IT service instead of the authority having to upgrade their system separately, then re-implement it and manage it.

· Contractor parking attendants tend to be more effective in terms of issuing tickets than Council employees.

· The provision of seasonal labour may be easier for a contractor than for the Council.

· The provision of short-term resources for special events is much easier for a contractor; eg to provide a vehicle removal service for Cowes Week.

3.5.5 The negative aspects of contracting out a service is that unless the specification is well designed and then managed, an authority can end up with an inflexible and unresponsive service. However, to be fair to contractors, the good ones, of which there are about four, will fight to provide a good service, and to establish a reputation, particularly if an individual contract is seen in some way as providing a precedent for an area.

3.5.6 If contracting out is to be established, a client side has to be defined, and resourced; for a contract on the Island, for contract management alone, this would be probably a task taking up a ½ time post, depending upon the scope of the contract.

3.5.7 To contract out for such a service will take the best part of a year, allowing for EC procurement and three months for the contract set-up period after award. It is one of the larger sub-projects within the overall project, requiring specialist skills and experience to progress the preparation through to award.

3.5.8 An early decision has therefore to be made if the services are to be tendered, and if so, in which combination, and how the contract is to be designed and structured.

· Labour supply, where a contractor provides an initial number of skilled, trained parking attendants to be deployed in accordance with the varying wishes of the Council.

· Frequency based, where the Council defines in advance the initial level of enforcement, with the ability to alter that to cope with experience and changing circumstances, and the contractor tenders a resource to meet this demand.

3.5.10 Outside of the main duties of enforcement and possibly of routine administration, the contractor could be asked to undertake many other duties, as noted above; thus for example, a ticket issuing contract could also involve the contractor providing all the hand-held ticket issuing equipment, checking the car parks daily, checking pay and display machines on each visit, reporting missing signs and so on.

3.5.11 Best Value has to be considered as part of this process. How and when it should be accommodated is a matter for the Council policy on Best Value, but the growth in scale of this service can either be seen as the trigger for tendering out under BV principles, or it can be argued that tendering out should be avoided until after the service has been operated internally for a period of time. Experience has shown that is not practical to decriminalise and conduct a full Best Value service review at the same time.

3.6.1 The issue of the levels of charges applied in off-street areas is not directly affected by DPE; indirectly however, the question can be raised about the opportunity to ensure that charges are in line with the market, as recommended by the Audit Commission. There is also the issue of the ramp effect on charges, and whether the strategy for long-stay charging in car parks reflects the Council's policies for such parking acts.

3.6.2 The off-street places will receive a higher level of demand after DPE is introduced; this effect has been noted in every area where it has been introduced. It is understood from discussions that certain car parks, at certain times are already at or close to capacity. DPE will increase the demand for these places, so differential charges between car parks in fairly close proximity will help to avoid the consequences of an excess of demand for certain car parks.

3.6.3 The relative volume of the off-street market that is in private operation is an issue worth considering, and the extent to which the Council can alter prices, in relation to demand. It is noted that the Council dominates the off-street market on the Island. It is also worth noting that in other areas where DPE has been introduced, the major private operators have recognised the opportunity to increase prices to reflect the increased demand brought about by displaced on-street parking.

3.6.4 A review of the application of charging for both on and off-street areas indicates that there is scope to review the provision of free car parking in the context of DPE.

3.7.1 The Police on the Isle of Wight do not currently have the powers to clamp vehicles, and they carry out no parking offence related removals, except for a few cases of obstructive or dangerous parking, powers that they would retain under DPE.

3.7.2 There is no doubt that the parking problems of the Isle of Wight are not such as to warrant the need for these techniques, and in any event, it would be sensible to let the new enforcement regime settle for perhaps 18 months before any serious consideration was given to this topic. This is particularly appropriate given the new regime of more active on-street enforcement. The powers to undertake clamping and removals should however, be sought in the Application; they can then be brought into use at any time in the future, should the policy on the use of clamping or removals change.

3.7.3 Both clamping and removals, but the latter in particular, require a great deal of initial investment and operational costs to make them pay their way. There is a need for a 24 hour operation to release vehicles, there has to be a pound and a payment centre for drivers whose vehicles are restrained, and different procedures exist in several aspects of the processing of the PCNs attached to such vehicles. Because of these characteristics, the Council would find such services extremely expensive, and contractors would take a very sceptical view of the possible profitability of such a contract.

3.7.4 During detailed discussions on the SPA Application, the Police should be asked to agree that they would act on cases of obstruction using their network of contractors, where the local authority notifies such cases to them. Such agreement has been reached without any trouble by several other authorities across a number of Police Forces, such as Oxford and Winchester. If they intervene in this way, the case then effectively becomes a police matter, and is of no further interest to the District, unless a PCN has been issued.

3.7.5 In the case of clamping, the District should formulate a policy for the use of this technique when it is considered necessary. Initially, for at least the initial period of DPE enforcement, the use of clamping should not be considered, as it is excessively heavy handed, and will cost more to operate than the income it will produce. However, it may emerge that there are cases for which clamping is the most appropriate solution, despite the additional work and procedures required by the Council, and where a very low cost, low volume operation could be considered.

* Persistent offenders - ie those who regularly flout the regulations, but pay the PCNs, regarding the cost perhaps as a legitimate aspect of their behaviour; depending upon local attitudes, such drivers could be regarded as a special problem. To get the message across to them, targeting them via the PAs for special attention by clamping could ensure that their anti-social behaviour is changed.

* Persistent evaders - ie those who regularly flout the regulations, and who do not pay the PCNs. Targeting them for clamping will be partially successful, and when and if the law changes such that the District can restrain the vehicle until all outstanding PCNs have been paid, it will be much more successful. However, under such circumstances, the District would almost certainly have to remove the vehicle from the streets, in order to effect its policy. Vehicles in this category are often those for which it is not possible to obtain a keeper name and address via the DVLA. Whilst the Council cannot ensure the availability of a correct name and address by clamping the vehicle, it is certainly one way of ensuring that the keeper becomes aware that the vehicle is being targeted for illegal parking.

* Foreign vehicles - if there are particular problems with such vehicles in tourist destinations such as Cowes, and where these are issued with a PCN, the chance of the PCN being paid is relatively low. By being able to clamp the vehicle, the probability of the monies being received increases greatly. This approach is used by a number of central London Boroughs, where such vehicles pose a constant problem, many being owned and used locally on foreign plates, rather than owned by visitors.

3.8.1 There are several departments within the Council, plus the Police, which would be involved in some way in the implementation of decriminalisation. The experience of other Authorities is that the best way to coordinate the involvement of these various groups is via an RTA Project Team or Steering Group, which is chaired by a senior officer from the Department responsible within the Council, and which includes other representatives such as:

• Hampshire Police, including a representative of their local traffic officers, and perhaps the policy officer from Headquarters

3.8.2 It is recommended that such a group should meet on a regular basis, probably bi-monthly, in order to coordinate the programme for implementation, and to ensure that all functions that are affected by this implementation are kept informed of the development of the project.

3.8.3 The Council is already well structured to handle the change to DPE. The change to undertake enforcement of all TROs on the Island is not nearly as great here as it is in many other authorities in the country. The responsibilities for parking are already within one section, and the move to DPE will only extend the existing responsibilities, rather than make fundamental changes. However, the scope will clearly grow, both geographically and in terms of the volumes of transactions to be handled. Certain processes will have to change and the amount of expenditure and income being handled will increase significantly.

3.8.4 Consideration should be given to the organisation of the staffing required to handle DPE, when that change is brought about. As the numbers of client side staff will increase, and the scale of enforcement and administration will increase, it will be important to define roles more clearly, with more division of duties, and greater separation of functions particularly in the areas of appeals management. The issue of the management structure has been made elsewhere, but it will be essential to have a single post with operational responsibilities for the parking service overall.

3.8.5 The functions which will be necessary for a coordinated and comprehensive parking operation will be:

· consideration of Representations(formal appeals to the Authority against a Notice to Owner)

· preparation of case files for adjudication(external appeals after rejection of Representations)

3.8.6 The timescale for implementation is also important to consider. The DPE project will consist of several main sub-projects, such as TRO reviews, possibly tendering out, IT enhancements etc. Each of these is a significant task, and each will require many months to achieve successfully. If the correct project resources are applied, the overall project can be accomplished within a period of not less than about 15 months, and it could easily run to over 24 months. Experience has shown that an average of around 18 months is realistic, from the time that a positive decision is taken to adopt the powers, the resources are applied, and funding is clear. The attached project plan has been based on an 18-month implementation period.

3.8.7 The issue of a suitable start date must be fully considered. In the context of the Island, it would seem that a start date in the spring would apply the resources at the time when they are most required. However, as it takes some time to get this new enforcement settled as a service, a date later than early April might reduce the effectiveness of the operation for that summer. A target of April 2002 would seem therefore, to make a practical target.

3.8.8 Lastly, the role of Project Manager is crucial. The project demands the commitment of a capable officer who is either full-time or close to full-time on the project. His or her role will be to coordinate the activities leading to DPE, and to ensure that the others within the various other sections and organisations are playing their part. Clearly, this calls for an experienced person, with the capability to make the implementation possible.

3.9.1 The need for consultation falls into two main sections; there is a need for formal consultation as an aspect of the preparation of the SPA/PPA Application, and there is need for less formal consultation with interest groups and the public at large over the introduction of the measures. The former requirement has to be completed in time for the submission of the Application, and should include the Police as described above, the neighbouring mainland authorities, the Highway Agency, Fire Service and other such bodies who may be considered to have an interest in the possible change in enforcement. There is clearly no issue about TROs on the boundary to other Councils, but there could just be an interest from mainland authorities if there was a belief that better enforcement on the Island could have an impact on those who chose to travel regularly between the Island and the mainland.

3.9.2 The consultation with other organisations, such as resident groups, Chamber of Commerce, Town Councils etc will be determined by the style of the IoWC in involving other groups in such matters. In several cases, authorities have proceeded with little or no consultation at this level, while others have gone to considerable lengths to inform and involve the community. The general experience is that DPE on its own is not a topic that engenders a lot of public interest. However, where such interest does exist, it is usually either a strong view that "more enforcement" is required, or it stems from particular sections of the community who perceive it as a threat eg retail operators who think more enforcement will damage trade. It is often difficult to differentiate DPE from other parking related matters, such as increased charges.

3.9.3 The other aspect of the less formal consultation is the need to inform people more generally what the implementation of DPE means to them, and to warn them about what is going to happen and when. This can often be achieved by quite low cost measures such as leafleting households, articles in Council magazines, and putting warning notices on illegally parked vehicles in the 2 weeks prior to commencement. It is also very helpful to try to get information releases out to the local media, but to do so in a manner that explains the changes, and attempts to gain a degree of understanding, if not accord, with such organisations. Ensuring that Members and senior officers are fully briefed, and understand the issues and Council policy are also simple but effective measures which can be taken.

3.9.4 It is recommended that a complete PR campaign should be designed at an early stage, and then implemented particularly in the last few months before the start date.

3.10.1 A major milestone which has to be achieved within the project is the submission of a formal SPA/PPA Application by the Council, as Traffic and Highway Authority, to the DETR. There is no set structure for such an Application, but Guidance identifies a large number of issues that have to be addressed. This task of writing an Application is really the culmination of the planning for the project implementation, and once submitted and approved; it marks the threshold between initial planning and the actual implementation. As this is such a significant milestone, it is referred to frequently in the following paragraphs, and is termed simply the "Application".

3.10.2 To submit an Application which will be successful, the Council has to confirm that policies in relation to parking have been reviewed. Authorities are encouraged by DETR to consult widely on these, particularly with the Police, and to publish the agreed outcome of such a review.

3.10.3 The timing of the submission of the formal Application is quite important, as it commits the Council to a start date, from which variation is not easily possible. This date is also the date when the Police lose the power to enforce parking on the Island. The Council must therefore be confident it can achieve the date. On the other hand, the Application has to be submitted in good time to get the necessary Order prepared, laid before Parliament, and approved. This process can take up to 8 months before the start date. If contracting out is to occur, thought needs to be given to the availability of confirmation of the Application before any contract is signed, which can lengthen the overall timescale by perhaps about 3 months. The possibility of a General Election during 2001 cannot be disregarded; if this were to occur, the process of laying the Statutory Instrument before Parliament would be stopped, and could only re-start when a new Parliament met. It is unlikely that this would affect the overall process for the IoWC, but it does emphasise that the timing of the Application has to be considered.

3.10.4 The content of the Application itself is not specified in detail by DETR, but it should cover all aspects of the planning by the Council for DPE. An outline is contained within Guidance. In this respect, it really forms the boundary between the planning stage of the project, and the implementation processes.

3.10.5 It is necessary within the Application for clear statements to be made regarding the policy framework for the provision and enforcement of parking on the Island, and thus, the circumstances within which this review is taking place.

· consultation with neighbouring mainland authorities etc using the draft as the basis;

4.a.i The DETR expect to see evidence within the Application that a review has been (or is being...) carried out on the TROs. This has to review and remedy the accuracy of the implementation of the TROs on the ground in the first place, but also should review the appropriateness of the TROs. This would include for example, ensuring that TRO's that were implemented when circumstances were quite different eg a factory subsequently demolished, have been suitably modified. The review should also consider the accessibility of the TROs. The DPE debt pursuit process is quite different from the current criminal system; adjudicators taking appeals will routinely require detailed presentations of the TROs that apply at a location. They therefore must have some form of accessible extract of the relevant TRO. The easiest way is to do this is by using the existing Parkmap database, and for appeals staff to be able to prepare an extract map, and details of the Order, and enclose these with the adjudicator case file.

4.a.ii In reality, it is the accuracy check that is absolutely paramount prior to commencement of DPE in an area. Enforcing inaccurate TROs will run the risk of being identified by adjudicators, and they will not hesitate to accept such appeals. They have also been known to criticise Council heavily where TROs are considered to be in such a state that enforcement in general, is questionable. The appropriateness check can be carried out up to and after the start of the enforcement, and in effect, this is the on-going TRO maintenance work that should occur in any event. The accessibility is required for the Council, not really for the DETR; it will save the Council significant amounts of manpower once the appeals process gets under way.

4.a.iii It is also worth noting that DPE allows authorities to take a different view of the need for certain TROs, in the knowledge of their ability to provide enforcement resources. Thus, where a double yellow line has been determined as appropriate in the knowledge that the police may not be able to provide much if any enforcement, if the Council is able to provide more resources resulting in more vigourous enforcement, a different regulation may be considered appropriate.

4.a.iv One common objective of such a review is the production of consolidated TROs; the DETR understands the benefits of such an approach, giving a clearer, simpler, more standardised basis for the DPE operations. Many authorities in their preparations for DPE, are aiming to have one or just a small number of on street Orders for their whole SPA. This certainly makes it easier for the NPAS to be given a set of Orders for their reference, instead of having to provide details for most cases that go to appeal.

4.a.v This review will have to be carefully planned and resourced; the costs are built into the overall financial assessment, and the project plan identifies a typical timescale for such a project.

5.a.i In order to assess the financial consequences of the introduction of decriminalised enforcement, a spreadsheet model was used. This model was based heavily on similar work carried out for other Authorities, including those where the consultants have had the opportunity to return to verify the principle of the use of such a tool in an exercise such as this. One of the advantages of this approach is that it allows the testing of the predicted combination of circumstances that the consultants believe will most accurately reflect the situation on the Isle of Wight after decriminalisation. It also encourages the testing of possible alternative scenarios, to the point where it is possible to identify the limits of financial viability of the project.

5.a.ii At all stages, the principle adopted has been to err on the side of conservatism; thus for example, a full year is allowed for ticket issuing operations to get to the predicted level of activity.

5.a.iii The model predicts the start-up costs of the new operation, the expenses to be incurred, the revenue stream that will result, and the cash flow over the initial years. The issue of financial viability is addressed by looking at a combination of these issues, and in particular, by identifying when the total cumulative expenditure by the Council is exceeded by the total cumulative amount of revenue. This is considered to show a "break-even" date when the total income exceeds the total expenditure by the Authority, and is used generally as the measure of viability.

5.a.iv The model makes no allowance for inflation over the term. While inflation will clearly occur in the costs, price rises will also occur on the income side, but as the latter in particular are difficult to predict, being largely dependent upon Government action, the changes on both sides are excluded, for clarity.

5.a.v It should be understood that the model operates by predicting not the whole Parking Revenue Account, but the changes that will occur to the Account as a result of decriminalisation and other related activities. It is therefore a marginal assessment, and not a total assessment.

5.a.vi The model has been found to be quite insensitive to a number of issues, but is very sensitive in other aspects. The major variable issues which are important, and have been focused upon are:

5.1.7 The issue of the value of a PCN is a critical one. The current level of £40 was set some 10 years ago, and has not been reviewed until recently. In the meantime, the costs of an enforcement regime have risen in just about every respect. It is understood that DETR are consulting on revised PCN levels at present, along with the amount of other fines and charges. An announcement for the change to the Police FPN level has already been made. The best information the consultants have to date is that the PCN value will increase shortly, and that this will probably be to £60, and will occur towards the end of 2000.

5.1.8 In predicting these issues, the consultants based the requirement for enforcement upon information regarding the Council's current extent of regulations. A database of streets, the types of regulation implemented in each street and the overall length of each regulation on each street was established, using data collected from the Council’s database of TROs. This approach is detailed but simplistic, and experience elsewhere has shown that it is sufficiently reliable to determine with reasonable accuracy the amount of resource that is required for enforcement patrol. Factors were then applied for the average speed of Parking Attendants in each type of regulation, using measurements derived from similar work in other Authorities.

5.1.9 We have specified in the model, a level of patrol that is considered to be appropriate for the local circumstances. We have not assumed the use of fully mobile patrols, but we have assumed the use of a degree of mechanisation (scooters and small cars), to move PAs around within the Island at the start and end of their duties, and between sites.

5.1.10 A similar approach was used in the case of the car parks in Council ownership, using information about their size, and need for patrolling. This required resource is then carried forward into the totals.

5.1.11 Using information about the actual deployed availability of PAs from other Authorities, allowing for sickness, holidays, shift working etc, we were then able to calculate the number of PAs which would be required for the given level of patrol.

5.1.12 The number of PAs (including supervisory staff) is thus estimated at an average of 28 for on-street areas, and about 7 for the off-street areas. This is to allow for 7 day operations, covering the required hours, and a full 7 day operation in the summer in particular. The base version of the model uses these numbers within the overall financial predictions. This number compares to the levels of up to 12 to 15 Police traffic wardens (seasonal peak in past years) and 7 Council car park Inspectors, plus a Senior Inspector. It would be recommended that a new operation for on- and off-street enforcement should gradually build up from the current level over a period of perhaps as much as a year to give the opportunity for the effectiveness and impact of the enforcement to be monitored. This would give the chance to modify the plan as proposed here, were it to prove to be either inadequate and excessive in terms of the impact.

5.1.13 The number of PCNs which are likely to be issued have been extrapolated by taking an average number of PCNs which will be issued by each PA when deployed, in the various areas of the Island. This approach assumes that there are many more contraventions than there are PCNs issued; the norm is for only about 3% to 5% of all contraventions to be actually issued with a PCN, and thus this method is quite reliable.

5.1.14 We have used different rates of issue for the PAs operating in off-street areas and on-street areas, and for different on-street areas, given the differing opportunity to issue PCNs. The rates of issue have been based upon our experience of broadly similar areas, although with what is considered to be a conservative view being taken of the projected numbers. Thus, the rate of issue is predicted for on street of 25 to 40 PCNs per f.t.e. PA, per week, depending upon the area of operation and the season. In the off-street areas, the rate is based upon the current c.34 PCNs per week, per PA. These numbers compare for example, to averages of about 25 to 30 per day in central London, to about 15 to 20 in outer London, and about 11 per day over both on and off-street in Winchester. They are therefore considered to be reasonably conservative.

5.1.15 We also studied the numbers of FPNs issued by the Police for non-endorsable offences in Isle of Wight. The number of non-endorsable parking related FPNs issued in the last 12 months was around 8,000. The volumes of FPNS have declined over the past decade, although not to anything like the extent noted in other Forces.

5.1.16 The projections are therefore based upon around 42,000 PCNs being issued annually by the Council PAs in all locations, in a full year. The model assumes it will take about a year to get up to this run-rate. This compares to about 12,000 parking tickets currently issued by the Council in a comparable period, and the 8,000 issued by the Police, giving a total by both agencies of around 20,000 tickets.

5.1.17 The basis on which the versions of the model have been prepared is to establish a base model, which is the best projection of what the consultants think is most likely to be the outcome. This is the "Base Model", which is included in full. We have then prepared a series of differing versions of the Base Model by considering the main issues which are either likely to vary significantly, or have a significant impact on the financial outcome of the project.

5.2.1 The financial viability has thus been assessed in detail, and on a number of different bases. These bases were:

5.2.2 Each option assumed that as a consequence of better on-street enforcement, there would be a modest increase of 5% in off-street income, and 3% of on-street income. Similar effects have been noted in all of the other authorities that have adopted DPE.

5.2.3 The model assumes that all operations are carried out in-house, as this is the only reasonable basis for financial evaluation. The analysis produces a marginal impact of DPE, which means that it predicts the change to the parking account, and not the revised total of the account.

Test	PCN Level	Collection rate	Off-street car parks displacement impact	On-street increased payment impact	Number of PCNs		Annual surplus (deficit) in year 3	Deficit pre-commencement, including capital	Maximum Deficit, including capital
1	£40	70%	5%	3%	42,400	N/a	(£98,650)	(£333,511)	infinite
2	£60	70%	5%	3%	42,400	3	£316,650	(£333,511)	(£508,235)
3	£60	70%	5%	3%	Increased by 10% over Base	2	£429,787	(£334,206)	(£449,605)
4	£60	70%	5%	3%	Decreased by 10% from Base	3	£203,514	(£332,817)	(£566,865)
5	£60	65%	5%	3%	42,400	3	£245,005	(£333,374)	(£551,410)
6	£60	55%	5%	3%	42,400	6	£101,713	(£333,100)	(£637,761)

5.2.4 In summary, in test 1, the assumptions have been made that only the take-over of parking enforcement from the Police would occur, and that there would be no further changes to any of the car park operations. From this Base, tests were carried which altered in turn, the value of each PCN to £60, and the impact of 10% more or fewer PCNs being issued, and of lowering the debt recovery rate from 70% to 65%, then to 55%.

5.2.5 The assumption is made that one further parking management post would be required, and that 28 f.t.e. Parking Attendants would be recruited to add to the current off-street staff, to provide a single team to enforce all on-street and off-street locations. The Attendants would all be fully equipped with electronic ticket writing machines, and radios. Additional transport would be procured, incorporating the use of scooters and vehicles to ensure the staff are fully mobile. A conservative estimate is made of the numbers of parking tickets which an Attendant would issue, of around 1 per on-shift hour. This compares to the 11 per day, per Attendant issued in Winchester. In reality, the number of Attendants should be built up over a period of a few months, to allow for assimilation and training, and to gauge the impact of the new enforcement on the behaviour of drivers.

5.2.6 Levels of enforcement are taken as the frequency of visits by Attendants to the various key areas on the Island, and the varying types of restrictions in these areas. This option assumes a low level of enforcement on Sundays in winter, and during the week, about 1 or 2 visits per day to the restrictions, except for the time limited, permitted parking spaces in the town centres, which are visited 4 times per day. This higher level is necessitated by the requirement to visit a limited waiting area at least twice to identify an offence.

5.2.7 A team of 8 administrative staff (currently 5) would be required to deal with correspondence, telephone calls, payments, formal representations to the Council, and appeals to the external adjudicator, in relation to the parking tickets issued. They would require an upgraded IT system to support them in this work, as detailed later.

5.2.8 The major assumptions for each Option are summarised as an Appendix to this report.

5.3.1 The introduction of DPE on its own at the present time is not financially attractive; if the Council were to proceed with the Base Model scenario, the project would require significant financing from other income sources, such as off-street income.

5.3.2 The new PCN charge levels are reported as being due for introduction towards the end of this year, as a part of the wider Government review of such measures. When this happens, the financial viability is transformed, and the project, without other significant sources of revenue, is financially viable. This is expected to occur later this year.

5.3.3 The Council will have to recognise the need for an active approach to enforcement to ensure the financial balance is achieved.

6.a.i The question of the provision of I.T. facilities is one that has dominated many DPE projects. Computer systems are fundamental to a procedure that processes thousands of parking tickets, permits, payments, letters, and formal notices. The systems required are complex and increasingly sophisticated. There are also relatively few suppliers in the market for such systems. The processes involved for PCNs are substantially different from those for ECNs, to the extent that existing systems will have to be replaced or significantly re-written to reach a successful operational level.

6.a.ii It has been established that it takes between 3 and 6 man-months of work to tailor a system, once installed, to suit a particular method of DPE working by an authority. This work requires a capable person with good IT skills, and a full understanding of the processing which will be required. It should not be tackled by just keeping a stage ahead of the PCNs being processed, but should be undertaken as a major step in the project, with the goal of having the system fully implemented for PCN processing before the first PCN is issued in a real situation.

6.a.iii The result of this is that when the Council intends to upgrade the existing system used for parking tickets, it has to allocate resources (human and financial) and equipment to reach a successful conclusion in good time. Alternatively, the authority should rely on others to provide a working IT service to meet their needs. In this context, the contract discussed above could be defined to provide the IT solution, to manage it on behalf of the Council, and to provide a service to Council officers for those aspects of the processing for which they are responsible.

6.a.iv It is therefore recommended that the Council should address the question of whether to tender out the enforcement services, and if so, whether or not to include the IT aspects, at an early point after the decision to adopt the powers. If the decision is to handle the work in-house, resources must be allocated to address the issue of a replacement system in good time. The current system is understood to be a locally developed package using Compex hand-helds for the issuing of tickets. A fundamental decision will then have to be taken as to whether to go back to the use of a proprietary package or to upgrade the existing system. The processing and procedural changes for PCN processing are quite extensive, and in addition, the volumes of data to be handled are about 3 times what they are at present. It will be essential to have a considerably more sophisticated system in use, in order to keep the extra numbers of staff to a minimum, and to keep track of the extra data. There are also a number of areas where increased investment in technology will repay the cost. Automating the DVLA interface will be essential, and introducing document image processing, to allow all letters, in particular, to be scanned for subsequent retrieval will offer considerable savings.

6.a.v All of the systems on the commercial market handle both ECNs and PCNs. This implies that if this were the chosen path, it would be beneficial to replace the present system for progressing parking ticket collection with a new one sooner than rather later, and definitely not at the same time as implementing DPE. It should be in place and fully operational in good time for the anticipated peak of correspondence expected as a consequence of the introduction of DPE.

6.a.vi The attached project plan includes the necessary activities to procure a new system through open competition; it would be wise to resolve how such a system should be procured, and to progress this in the near future.

6.b.i Training of all staff, but in particular the Parking Attendants, is crucial to the success of the project. The Council should adopt a training plan, whether it is for their staff or for contractor staff, and ensure it is adhered to. The developments in training in recent months in this industry have put a great deal of emphasis on the assessment of competence, and reduced the attention on the means of achieving this competence. Thus, while it is entirely sensible to want to have the majority of staff qualified at a parking NVQ level, it is not realistic to expect this to occur without a good training plan to get them there, nor without recognising that this will take a long time. It is also important to recognise that staff turnover in the parking enforcement business is quite high, and that as a result, many staff will not stay long enough in the job to achieve something as long term as an NVQ.

6.b.ii Experience has shown that training is an issue where the Council should develop a relationship with a competent supplier of training courses. Other Councils in Hampshire are working together to coordinate the demand for and provision of, training, and it is suggested that IoWC should join in on this development, and profit from it. The development of such a service could be achieved by the establishment of a contract for such services on a shared and call-off basis. This would equate with selecting a franchise supplier for training, and giving that company a preferred right to organise and present courses for a period of time. If this occurs, there are now two or three competent companies, plus several of the contractors who are prepared to offer training courses for on-site staff. If the Council chooses to go down the path of contracting out the services, this issue will change, as all of the contractors provide their own training. However, the Council should have a means within the contract of monitoring the presentation and content of the training to ensure it meets with defined needs.

6.b.iii Before deployment on street, there should be compulsory attendance for all staff at a PA training course, which will teach the basics of a PA's job under DPE. Experienced staff will only require about a week to reach a suitable stage while new staff will require 2 weeks. Local content from the police and the client should be made welcome during these courses. If possible, these courses and the trainers should be approved to a recognised standard, such as by the TCfL.

6.b.iv During the first month of deployment, a new PA should be closely monitored by one of the supervisory staff. This monitoring should initially include patrolling with the PA to ensure that the training about dealing with people, recognition of offences etc have been absorbed. It should also include observing the results of independent patrolling including PCNs issued rejects, complaints, notebook entries and such visible and tangible evidence of performance.

6.b.v PAs should be encouraged to progress to NVQ certification, through on the job training, further formal training sessions, and on the job counselling. This NVQ process will take several months in every case, and it would be unrealistic to expect to have a team of NVQ qualified PAs for a period of approaching two years from the start of operations.

6.b.vi For the administrative staff, training should be provided for all aspects, including the PA’s job. They will also need training in the processes, including the IT aspects of the workflow. Experience has shown that they will require documented procedures to help them to standardise the formalities of PCN processing, and then training in these procedures. It is therefore recommended that as a part of the set-up of the administration, documented procedures should be developed, probably using external sources of assistance, such as other authorities or specialist advisors and authors.

6.c.i The following issues are those to which the Council will have to give attention if a decision is taken to adopt the powers:

• How extensive a review of the TROs is required, and how that should be organised

b) There are no changes to car park charging from the current regime to consider;

c) Use of off-street car parks would increase by an average 5% as a consequence of displacement from on-street, and on-street income would increase by 3% for related reasons;

d) No charging is to be introduced into car parks which are currently without charges

e) All set-up costs would include a full month's expenses prior to commencement;

f) All events would occur at the same time ie there would be no consideration for phasing any part of the project;

h) 70% of all PCNs would be paid, and of these, 75% would be paid at discount, 20% at face value and 5% at the incremented value;

k) £10,000 to be spent on PR before DPE starts, £10,000 on work to establish the project, and £45,000 to remedy defects in signs and lines; £30,000 to be spent annually on signs and lines maintenance.

l) All Attendants to be equipped with hand-held electronic ticket issuing machines, as well as radios;

r) Approximately 1.25 hours per day per Attendant to be lost in travel and administration;

s) On-street, Attendants issuing between 25 and 40 PCNs per person, per week, depending upon the area and the season;

t) PCNs to be paid between 1 month and 6 months from date of issue, depending upon level of payment;

v) All regulations to be enforced, the frequency to depend on type and location;