The Department for Transport's consultation on local authority parking has the stated intention of enhancing 'the attractiveness of our high streets and town centres'. We are concerned, however, that the consultation misdiagnoses both the problem of high street decline, and its potential solutions.

The central assumption seems to be that the vitality of urban areas is inextricably tied to cheaper car access, and the ability to park for free at locations most convenient to the individual. Yet there is no evidence of any connection between the availability of extensive and cheap (or even free) on-street parking, and high street vitality . If there is any relationship, it is often entirely masked by other (much more important) variables. There is no clear relationship between footfall (what matters) and the cost and availability of parking .

The consultation states

There are concerns about over-zealous parking enforcement and high parking charges driving people out of town centres, pushing up the cost of living and making it harder for people to park responsibly and go about their everyday lives.

'Over-zealous' in this context appears to refer to the legitimate issuing of parking fines to motorists who have stayed beyond the time limit of their tickets, or who have parked illegally.

We would argue that the viability of high streets actually depends on this kind of enforcement. Drivers who overstay in parking bays, beyond the length of time they were legitimately allowed to park there, are effectively blocking access by other potential customers, and reducing the amount of potential trade for shops and businesses. The same applies for free parking. Long periods of free parking suppress turnover.

While this consultation argues that

Town centres should be welcoming, attractive and designed to meet the needs of a variety of visitors and employees.

it should obviously be appreciated that an excess of car parking on streets - and cars circulating to find parking - can greatly reduce how welcoming and attractive they are, in turn making them less likely to be visited. This is something the consultation seems to recognise -

poorly designed parking can create safety problems and reduce the visual quality of a street

and

Town centres should be the most walkable part of the transport network… As centres of public life, they must actively enable access by all in society, and they must also support efficient access by delivery, service and emergency vehicles. At the same time, they should be attractive places to shop, eat, drink, work, play, do business, meet, study and look at.

It must be noted, in this context, that the places most often cited as direct competitors for the high street - out of town shopping centres - ensure that motor vehicles are kept well away from the environments in which people are shopping, meeting, working or eating. These malls are designed to make shopping a relaxing and stress-free experience, without the danger, noise and pollution posed by motor traffic. Naturally this means that people are expected to convey themselves from shop-to-shop in these centres without their car.

We see no reason why this strategy should not to be transferred to the high street. While the government seems keen to apply the out-of-town approach of free parking to town centres, it should also learn from this other element of out-of-town success, and appreciate that town centres need to be places where people walking (and cycling) are put first. That will often mean expecting people to travel (on foot, or by other means) from their motor vehicles to the places they intend to visit, rather than simply attempting to enable parking directly outside. Parking spaces for those with blue badges should be provided, and sited appropriately.

This kind of strategy need not diminish the economic viability of the high street. Indeed, all the evidence suggests it will enhance it. Transport for London research has shown that those who arrive on foot, or by public transport, on the high street spend more (much more) over the long-term than those who arrive by car . These results are mirrored by similar studies in other areas, including Germany . More revenue is generated on the high street in Denmark by people who arrive by bike, than those who arrive by car .

We are not arguing that town centres should be inaccessible by car. Parking should be available, at a reasonable price. However, that parking must not come at the expense of the quality of the street environment, nor must it impinge upon the ease with which people - all people - can access town centres on foot, and by bike. That means that at street level we should be allocating space for walking and cycling, over car parking. What parking space that is available should be prioritised for loading, and for disabled access.

Specific responses

Q2.The Government intends to abolish the use of CCTV cameras for parking enforcement. Do you have any views or comments on this proposal?

Abolishing the use of CCTV cameras for parking enforcement would prevent councils from using this technology appropriately, to deal with dangerous, obstructive or anti-social parking that could be occurring at multiple locations simultaneously, particularly at peak times, and during the school run. Traffic wardens cannot be everywhere at the same time - CCTV cameras therefore represent a useful method of ensuring that important parts of the road and street network are kept clear of obstructions that affect every road user. For these reason we do not feel that abolishing their use for parking enforcement is sensible or wise.

More broadly we feel that the government's attitude on this, and other aspects of parking, conflicts with its own 'localism' agenda. The government summary of the 2011 Localism Act states

The Government is committed to passing new powers and freedoms to town halls. We think that power should be exercised at the lowest practical level - close to the people who are affected by decisions, rather than distant from them. Local authorities can do their job best when they have genuine freedom to respond to what local people want, not what they are told to do by central government

The implication of this is clearly that local authorities should have the 'powers and freedoms' to do as they see fit, rather than being dictated to by central government.

Q6. Do you think local residents and firms should be able to require councils to review yellow lines, parking provision, charges etc in their area? If so, what should the reviews cover and what should be the threshold for triggering a review?

Allowing anyone to be able to force the council to conduct parking reviews is additional bureaucracy. If a council already has a statutory duty to try to provide a town centre space for all users, how can it help to require it to consider parking and yellow lines as a special case?

Q7. Do you think that authorities should be required by regulation to allow a grace period at the end of paid for parking?

No, grace periods are foolish. The rules are simple, and adding grace periods simply makes them more complex for all involved. It is also farcical to suggest that a grace period can be provided in legislation or regulation.

Q10. Do you think the Government should be considering any further measures to tackle genuinely anti-social parking or driving? If so, what?

Councils should be able to levy higher fines or choose other enforcement options for anti-social parking or driving. This is an area specifically requiring more, and more robust enforcement.

We also feel that much greater clarity is needed about where people are legitimately allowed to park. Legislation regarding parking on footways, and in cycle lanes and tracks, is ambiguously worded and open to misinterpretation. We need explicit rules outlawing parking on footways and in cycle lanes and tracks, and their enforcement, particularly as these forms of parking make walking and cycling more unpleasant and hazardous.