Unnecessary

30th November 2009

Dear Mr Tim Walker, Mr Eckersley, Ms Crookshank and Mr Vineall

Re: North Dulwich Parking Review - 1st Stage Consultation

I am writing in regard to the proposal to extend controlled parking (CPZ) into North Dulwich area. I believe this proposal is misguided and that the current consultation process is biased and flawed.

I object to the proposal for the following reasons:

1. Unnecessary

As a resident within this area I have never experienced significant parking problems for me, my family or my visitors within the North Dulwich Area. Parking has been ample and convenient. I can easily park close to my home on all days and at all times. I have also never experienced difficulties parking close to business and other residents' homes within the North Dulwich Area. 
 
Of course there maybe a few roads within the area that at times have pressure on their parking spaces. However, to impose a controlled parking on all or most of the proposed area is an excessive and draconian response.

2. Expense
 
I do not want the additional expense and administration burden of having to buy a residents parking permit. At £100 per year this is a significant cost. A significant part of this expense will go to Southwark's favoured private sector parking management and enforcement company as business revenue. Another part will go to Southwark Council to be spent at the discretion of council officials on projects and administration costs across Southwark. The CPZ proposal means taking money from the budgets of residents and families of the North Dulwich area and put it into the accounts of parking companies and into the budgets of Council officials.

I also do not want my visitors to have to pay for parking when then come to visit my young family. Often we have other parents come to visit (sometimes to enjoy and use the facilities of Sunray Gardens). Having to pay for parking would discourage our friends from coming to visit. As such the CPZ proposals will result in a social cost to my family, as well as a financial one.

3. Unfair

How will resident parking permits be allocated and how many residents’ parking permits would a household be able to have? These questions are not addressed in the consultation document.

Are parking permits limited to a certain number per household? If so then the allocation of permits would be unfair. It would favour those that live in individual small flats rather than adults who live collectively in larger houses.

I live with my partner and our young daughter. I require a car for my work which involves visiting different sites through the week. My partner also requires a car to transport our daughter and for her own independence. This means we need two cars. Will our household be entitled to have two residents parking permits? What then happens if we took in a lodger and he or she owned a car. Would the lodger living in our house also be eligible for an additional residents parking permit?

4. Ugly

North Dulwich is an attractive part of Southwark. The area has pretty gardens and parks, attractive period housing, and impressive tree lined streets. The beauty of the area would be harmed by the introduction of controlled parking. Lines and bays painted on the roads, parking meters and parking notices on metal poles are all unattractive.

If any individual or resident stuck an ugly metal pole into the pavement they would be arrested for criminal damage. However, Southwark Council is willing under these proposals to plant many meters and poles into the pavement and paint lines over quiet residential roads. Yet the detrimental effect of this ugly CPZ infrastructure is not even mentioned in the consultation document. Why does Southwark Council have such little regard for the aesthetics of the streets where we live and work?

5. Confrontational

The introduction of controlled parking means new controls, new rules and new penalties. Drivers that break or misinterpret these rules, or are perceived to have done so, will be punished. This new regime of rules, control, enforcement and punishment will generate disputes and confrontations within the North Dulwich area.

Currently the North Dulwich area is relatively peaceful and harmonious community. I do not believe that the community wants uniformed Civil Enforcement Officers (C.E.O.s) patrolling our residential streets searching for motorists to fine. This enforcement activity will result in instances of public aggression and abuse. This likelihood is reflected in the training given to C.E.O.s which focuses on how to deal with anger and possible violence from members of the public.

A recent television documentary filmed Civil Enforcement Officers in Westminster. This programme showed the frequent outbreaks of aggression and abuse that is associated with their work. Unlike the center of Westminster, the North Dulwich area does not need to be a CPZ and it certainly does not need the stress and confrontations that stem from CPZ enforcement.

6. Biased Consultation

Southwark are obliged to fairly consult with local residents and businesses before imposing controlled parking on an area. Your department has failed to fulfill this obligation. The "consultation" document that you have posted out is so overtly biased that it reads simply as a pro-CPZ pamphlet. It has a whole specially highlighted page listing the "many benefits" that "a CPZ provides for the surrounding community". It does not anywhere mention the disadvantages of controlled parking (such as those I have listed above).

Is such a biased document considered acceptable as the basis of a fair consultation process? Can Southwark Council not trust local people to be able to give their opinions and indicate their preference without first trying to influence them with propaganda?

As well as being overly biased your consultation document is also disingenuous. It states that the CPZ proposal is not about revenue generation. This is cannot be not true. Revenue generation is of upmost importance to Southwark Council. All bureaucracies have an inherent drive to seek to maximise their budgets and economic influence. Southwark Council has many departments and projects all clamoring for additional funding. Parking is recognised as major source of revenue. According to an article in the Evening Standard article last week, Southwark council in the financial year 2008/09 issued parking fines totaling £6,234,001. This is on top of the huge sums collected from parking meters and from the sale of parking permits. Southwark Council is motivated (at least partially) to extend existing CPZs and impose new ones by the opportunity to generate more revenue and fund more activities and projects. Your consultation should be honest about this and admit that CPZs results in a direct transfer of purchasing power from local residents, families and business to Southwark Council officials. Furthermore, money generation and profits will be primary motivation for the private sector company that Southwark will nominate to administer and enforce the CPZ.

7. Flawed Questionnaire

The basis of the consultation process is a questionnaire for residents to complete and return. Two, out of a total of eight questions, make no sense. Basic errors in the wording of these questions mean the whole questionnaire is misleading. Question 6 states that if you tick the "no" box in response to the question "Do you want controlled parking to be introduced in your street?" then you should ignore question 7 and go to question 8. However, question 7 is only of relevance to those “no” voting respondents that oppose controlled parking. This means that the very people that should be considering question 7 are being told to skip it.

Question 7 also makes limited sense as it refers the respondent to question 3. However, question 3 has nothing to do with question 7.

Was this short questionnaire not proof read?

Given these basic errors, will the questionnaire be corrected and reissued? I believe it should be. Fair consultation cannot require respondents to re-interpret your questionnaire and ignore instructions to skip over specific questions.

Summary

I am against Southwark Council's proposal to make North Dulwich a CPZ. A CPZ will be unnecessary; costly for residents and visitors; and likely to negatively impact the area both visually and socially.

Despite this Southwark Council seems determined to actively seek new areas to impose and expand controlled parking. The Council says they are acting in response to residents’ concerns about localised pressures on parking. Yet neither evidence nor statistics are given to support this claim. The local residents that I have spoken with have all said that they would prefer parking in North Dulwich to remain free and unrestricted. Whilst it must be possible to find some local residents with parking complaints, the fact that Southwark Council is so eager to consider parking controls for the entire area suggests to me that the true motivation is about increasing their revenues and influence.

Local residents and businesses that oppose Southwark Council's plan to impose controlled parking on our community are reliant on their legal right to be consulted. The consultation process is of upmost importance. It should be conducted diligently, accurately and fairly.  The current consultation process fails on all of these criteria. It is biased, misleading and inaccurate. I therefore request that Southwark Council either abandon the CPZ proposal for North Dulwich or restart the whole consultation process. A new consultation should be based on a balanced, impartial consultation document and a questionnaire that makes sense. I would also like to know how transparency in the consultation process will be ensured and how the results of the consultation will be collated and how these results will be used to determine policy.

I would be grateful if you could consider my reasons for opposing the CPZ proposal and also examine the flaws in the current consultation process.


Yours sincerely

Martin Bayntun 
Elmwood Road