I do not own a car. But I am strongly opposed to introduction of controls in any part of the consultation area.

Summary of response

1. I do not own a car.  But I am strongly opposed to introduction of controls in any part of the consultation area.   Introduction of controls simply creates a problem in streets where there is currently none.  The supposed problems perceived by residents of some streets are not so pressing as to justify the inevitable harm that controls would cause to neighbouring streets.  Instead the Council should attempt other measures to reduce car dependency throughout the locality.  Those include provision of additional car club spaces.  That would be preferable in policy terms to parking measures aimed at private cars.

Policy framework

2. Local Implementation Plan (2006): the ten overarching transport objectives include – as Lip 2 – “promote more sustainable modes of travel”.  The fact box on p. 2 defines “sustainable transport” as including “modes of transport that minimal [sic] impact on the environment, this includes walking, cycling and public transport and in some circumstances car clubs…” [emphasis added].  The Executive Summary shows “encourage use of… car clubs” in priority to “implement the parking and enforcement plan” (see below).  The Council’s transport hierarchy gives the lowest priority to private cars.  By implication, a higher priority is given to car clubs in satisfying travel demand.  
3. Parking and Enforcement Plan:

• The parking hierarchy prioritises “care share and car club bays” over resident and other parking.  That means measures to provide car club bays should take policy priority over measures that either provide or regulate parking of private vehicles. 
• Section 3.2 (“taking stock”) notes mixed reactions to recent consultations – “some of the reactions may reflect growing resistance by the public to CPZs” whereas “in some areas there remain localised conflicts between residents’ needs and parking by all day commuters…”.  “Analysis of supply and demand within existing CPZs indicates that pressures on available parking space vary significantly suggesting that a one size fits all approach to the CPZ regime may not be appropriate…”   [emphasis added]. 
• The “new strategic principles for parking control” (p. 8) begin with “The purpose of each CPZ and other parking controls should be defined in relation to local circumstances in the context of the council’s wider development and transport plans”.

4. Car clubs: The Council has recently adopted Borough-wide policy in favour of promoting provision of car club spaces.  That is also consistent with TfL policy of spreading availability of car club spaces.

The situation in North Dulwich

5. Frankfurt Road is typical of many of the streets in the area.  Parking congestion is at its greatest in the evenings and weekends when residents are at home.  There is no discernible commuter parking problem. Laying out a CPZ here would exacerbate congestion by reducing the parking capacity of the street for residents.   Some residents already park in neighbouring streets at the busiest times.  Introducing controls in streets like this would increase that pressure.
6. Introducing controls in a neighbouring street would, in the same way, displace resident parking to this street.  It also follows that if there is a commuter parking problem in a neighbouring street, introducing controls would also displace that problem here too.  So it would bring about pressure for a CPZ as “least worst option” to control commuter parking at the expense of creating additional problems for resident parking.  It is precisely because of this problem of “CPZ creep” that residents a large majority of residents opposed CPZ controls in the whole area at the last round of consultation.  The very fact that some residents of a street adjacent to the existing CPZ boundary are complaining of a commuter parking problem shows that we were right to anticipate this effect.  The problem is not the absence of controls but the controls themselves.

What the Council should do

7. The Council needs to get serious about reducing overall car use in the area.  Car club bays are an effective way of doing this.  I have not owned a car for over two years. I have been able to sustain this because I am a  member of a car club (Streetcar) which has a number of vehicles in bays in the immediate and wider area.   I know from dealing with planning applications around the Borough that there is powerful evidence that each new car club bay replaces several private cars.  The effect is particularly pronounced with second cars – a ratio of up to 1:20.  Households who get rid of a second car will be neither parking it nor commuting in it.   So the result of each new car club bay is to reduce overall car use and levels of ownership as habits change.  That reduces parking pressure from both residents and commuters.
8. But locally the scheme is becoming a victim of its own success.  There is now considerable pressure on the cars nearest Frankfurt Road (which are in Half Moon Lane and Kestrel Avenue).  The next nearest cars are more than a 10 minute walk away.  A 10-min walk is the outer limit in TfL policy.   So other local residents will be deterred from giving up their cars unless provision is increased.   So we need to increase provision sharply and see what happens.  If anything I would expect it to become possible to reduce rather than extend the existing CPZ.
9. The policy framework clearly prioritises car club measures over measures relating to private car parking.  Given that introduction of new CPZ controls in even one or two local streets would exacerbate parking problems in other streets, it makes sense to try providing a number of new car club bays first and monitor the effects.  There is no case for extending controls to any local street until this has been tried first.
10. A car club bay can be provided in streets without existing controls. 

Process

11. Under Southwark’s Constitution Part 3H para. 16 decisions on non-strategic parking restrictions are reserved to Community Councils, not to officers.  Given the small area involved, a decision on how to proceed in the light of this consultation cannot be considered strategic.  A binding decision should be taken by members of Dulwich CC. 
12. I would urge members to decline to introduce any new controls in any part of the area.  Instead Community Council should invite officers to return with proposals for an additional number of car club bays in the consultation area, with priority given to those streets where the consultation response reports the greatest pressure on parking.  The results should then be monitored for 6 to 12 months before any new proposals for CPZ controls are considered.
13. I could not find a link on the Southwark website to an electronic version of the consultation response form accompanying the proposals.  That is a matter of some concern.  I have e-mailed this document to parkingreview@southwark.gov.uk with a copy to the Village ward councillors.   I hope my views will be taken into account.

Gordon Nardell