Workplace Parking Levy Response

Claudia Webbe MP Member of Parliament for Leicester East House of Commons, London SW1A 0AA Tel: 07973816885

Response to Leicester City Council’s Workplace Parking Levy Consultation – Claudia Webbe MP Introduction Councils are facing considerable financial pressure while meeting their commitments to improve and protect the local environment and investing in improvements to public transport; in addition,Leicester faces its own unique challenges. Leicester was one of the areas of the UK worst affected by the COVID-19 pandemic, to the detriment of local businesses. The City’s workers are also paid less than the median average income.

Leicester’s air quality has improved significantly over time. Air pollution levels at the monitoring station at Melton Road in Leicester East fell below the World Health Organisation’s (WHO) specified maximum threshold of toxicity (40ugm3) in 2017 and have since continued to fall. However, monitoring stations at Vaughan Way and Glenhills Way/Soar Valley Way show pollution levels persisting above the WHO standard. To ensure that air quality continues to improve, Leicester City Council plans to introduce a local charging scheme modelled on the Workplace Parking Levy already introduced by Nottingham City Council. Under the Workplace Parking Levy scheme, businesses will need to register for car parking licenses from Leicester City Council and will be charged a levy according to the number of spaces they maintain if the number exceeds 10.

The constituency of Leicester East suffers from narrow and congested streets, parking pressures on existing residential roads and a lack of resident only parking facilities, which has led to front gardens being converted into parking spaces. This means that congestion is a problem for those residents, who have complained about other residents’ cars blocking their driveways. If a Workplace Parking Levy (WPL) is successful in reducing traffic, it may help ease these pressures.

To be worthwhile, a Workplace Parking Levy (WPL) will need to strike a balance between its positive impacts on the environment on the one hand and, on the other, potentially detrimental outcomes on the financial welfare of local workers and businesses.

Would a workplace levy work for Leicester?

In terms of revenue raising, it is possible that Leicester’s Workplace Parking Levy scheme, may be less successful than Nottingham’s scheme because Leicester has fewer medium sized and large businesses (enterprises with more than 50 employees): 255 compared with 300.i Businesses that employ more people are more likely to provide higher numbers of parking spaces, so Leicester City Council can expect to raise less revenue than Nottingham. Leicester’s population of 441,984 is also higher than Nottingham’s figure of 337,100, which means that the revenues generated by the scheme may have to stretch further.

Leicester’s demography also carries greater risk than the scheme pursued by Nottingham City Council. The UK is experiencing a cost-of-living crisis, with energy and food prices rising. According to the 2019 Indices of Deprivation, Leicester ranked 32nd out of 317, which places the City in the 20% most deprived areas of England. The biggest driver of deprivation in Leicester is low income.

In the country as a whole, the median household income is £29,000. In Leicester, it is £23,000: £6,000 below the median.ii This places Leicester amongst the 10% most deprived of local authorities for income deprivation, leaving the City’s residents particularly vulnerable to cost-of-living increases.

Additionally, Leicester’s council tax is set to rise by 3% this year following a 5% rise in the financial year 2021/22. There is therefore a real risk that the impact of a Workplace Parking Levy could worsen one of Leicester’s key drivers of deprivation if charges are passed on to workers.

For casework please email: claudia.webbe.mp@parliament.uk Twitter: @claudiawebbe www.facebook.com/claudiaforLE www.claudiawebbe.org

Claudia Webbe MP Member of Parliament for Leicester East House of Commons, London SW1A 0AA Tel: 07973816885

By contrast, the median income in Nottingham is £29,000, suggesting that its workers are likely better able to absorb any additional costs that employers pass on to them as a result of the scheme.

It is important to note that Nottingham’s workplace Levy has come under criticism for placing additional financial burdens on the city’s residents. Some employers choose to foot the bill themselves but, according to the BBC, 8 out of 10 companies affected have passed the cost on to their employees.iii The value of Leicester’s Workplace Parking Levy will be judged not just on the modest improvement it is likely to contribute to Leicester’s air quality but also the finance it raises for investment in public transport infrastructure, which will, in turn, help to incentivise sustainable travel.

The Nottingham model currently sees employers who provide more than 10 parking spaces for their staff pay £428 every year to the city council for each space, with the charge increasing each year in line with inflation.

Leicester City Council claims its Levy will raise between £9.5million and £14.3 million. However, Nottingham’s Workplace Parking Levy reportedly raised approximately £9 million and,iv as outlined above, conditions are likely more favourable for this type of scheme in Nottingham than Leicester. It is therefore likely that Leicester City Council’s projections overestimate the amount of income that the scheme will raise. A factor that may increase the revenue raised by Leicester’s scheme is that, in contrast to Nottingham City Council, Leicester City Council is controversially planning to include NHS organisations in the levy, which could raise additional income but risks being unsustainable due to its likely unpopularity.

The impact of any Workplace Parking Levy on the finances of people in Leicester should therefore be a significant consideration in the Council’s decision to move forward with the scheme. If the Council is able to find other sources for transport infrastructure funding, it may want to reconsider whether a Workplace Parking Levy or any local charging scheme is appropriate for the city.

The Workplace Parking Levy compared to other charging schemes?

Following the 2008 Local Transport Act, three local charging scheme options have been available to councils. These are Road User Charging (RUC), Parking Controls and Charges (PCC) and Workplace Parking Levy. These schemes are intended to reduce traffic in urban areas, while using the revenue accumulated in charges to fund transport infrastructure projects that provide alternatives to car use.v Road user Charging ➢ Road pricing involves direct charges levied on motorists for driving on public roads. It has two purposes: first, to generate revenue; and, secondly, to manage the costs of motoring such as pollution, emissions and congestion. They include schemes targeting cars powered by diesel engines. Local road pricing schemes currently operate across the UK. They include toll roads, charges to enter bridges and tunnels, zonal charging schemes such as the London congestion charge, where drivers pay a fee to enter a certain area with a certain vehicle, and the HGV Road User levy, all of which means an authority can effectively deliver wider transport strategies and objectives.

For casework please email: claudia.webbe.mp@parliament.uk Twitter: @claudiawebbe www.facebook.com/claudiaforLE www.claudiawebbe.org

Claudia Webbe MP Member of Parliament for Leicester East House of Commons, London SW1A 0AA Tel: 07973816885

Parking controls and charges ➢ Civil parking enforcement should contribute to the authority’s transport objectives. A good civil parking enforcement regime is one that uses quality-based standards that the public understands, and which are enforced fairly, accurately and expeditiously. ➢ Enforcement authorities should aim to increase compliance with parking restrictions through clear, well designed, legal and enforced parking controls. Civil parking enforcement provides a means by which an authority can effectively deliver wider transport strategies and objectives. Enforcement authorities should not view it in isolation or as a way of raising revenue. ➢ Local authorities should ensure that parking in town centres and other shopping areas is convenient, safe and secure, including appropriate provision for motorcycles and deliveries.

Parking policies, including enforcement, should be proportionate and should not undermine the vitality of town centres.vi Workplace Parking Levy: ➢ A Workplace Parking Levy (WPL) is a charge on employers who provide workplace parking, a type of congestion charging scheme that has been introduced in Nottingham. ➢ Nottingham City Council has introduced a WPL to tackle problems associated with traffic congestion, by both providing fundings for major transport infrastructure initiatives and by acting as an incentive for employers to manage their workplace parking provision. ➢ Employers, rather than employees, are responsible for paying any WPL charge, although employers can choose to reclaim part or all of the cost of the WPL from their employees.

Why these schemes would not be suitable in a city that lacks transport and travel alternatives.

All of the available schemes are designed to disincentivise car use and improve the environment, including tackling poor air quality and pollution. However, introducing different schemes at once is inadvisable because they all reproduce existing taxation; the Transport Select Committee has identified that locally implemented charging schemes risk forcing motorists to pay a double tax on emissions. As the Committee has suggested, “the introduction of a range of more-or-less-generous local road pricing schemes would risk engendering regional inequality and driving economic disadvantage”.vii Any local charging scheme premised on directly charging drivers, including Parking Controls and Charges increases these risks. Increased city centre parking fees could also hurt local businesses. It is likely that the negative impact of such a scheme would be felt particularly acutely in a city whose residents earn below the median national income and direct charges to drivers could therefore disincentivise travel into the city centre, thereby hurting business and putting jobs at risk.

The potentially discriminatory impact of Road User charges on people with low incomes was identified by Birmingham City Council’s risk register and Equality Assessment, conducted in the consultation for its own Clean Air Zone. This led to the Council introducing exemptions on grounds of income, hours of work, residency and disability status. However, these exemptions are considered temporary, and it is unclear if they will be sustained.viii In the event a Road User Charge avoids targeting ordinary motorists and targets just heavy goods vehicles, this could also hurt local businesses. This risk has been demonstrated by Manchester RUC, For casework please email: claudia.webbe.mp@parliament.uk Twitter: @claudiawebbe www.facebook.com/claudiaforLE www.claudiawebbe.org

Claudia Webbe MP Member of Parliament for Leicester East House of Commons, London SW1A 0AA Tel: 07973816885

which has reportedly been unpopular with businesses. Leicester was among the areas of the UK worst affected by the COVID-19 pandemic and its businesses may not welcome any additional financial challenges introduced by local charging schemes.ix There is a false assumption that Workplace Parking Levy is preferable to the alternative local charging schemes because it does not pass the cost directly on to drivers. Furthermore, there are those who argue that the Workplace Parking Levy model would be directed to larger businesses (those with the most parking spaces) and is therefore less likely to negatively impact on smaller businesses that have suffered from the pandemic than the other schemes, which are arguably less compatible with a targeted approach. Additionally, they argue that mitigations can be introduced to offset equality impacts (for instance, removing disabled parking spaces from inclusion in the levy).

Exemptions and discounts?

Government legislation allows local authorities a considerable amount of discretion regarding the implementation of Workplace Parking Levy schemes. Local authorities can choose the level of charge, the scheme’s boundaries, operating times, as well as exemptions and discounts.x These exemptions include: ➢ ➢ ➢ ➢ ➢ ➢ ➢ ➢ ➢

Small business (<10 parking places) Blue Badge Emergency Services Qualifying NHS premises Motorcycles Fleet vehicles Delivery vehicles Business customers Occasional business visitors

Leicester City Council has proposed the following exemptions to its scheme: ➢ Providing a 100% discount for workplaces with 10 or fewer workplace parking places ➢ Providing a three-year 50% discount for NHS including University Hospitals Leicester (UHL) ➢ Exempting operationally necessary vehicles including suppliers, business customers and occasional business visitors ➢ 100% discount for emergency services ➢ 100% discount for blue badge holders ➢ Exemption for voluntary workers ➢ Exempting personal mobility vehicles, such as motorbikes The proposals do not appear to include any positive incentives, such as discounts for companies that introduce car sharing policies or choose not to pass costs on to staff.

Sustainable transport infrastructure- how well connected is Leicester in terms of sustainable transport alternatives?

Leicester East suffers from narrow streets and congestion, as well as a lack 20mph speed limits, which, if imposed would make it safer for people to travel on foot or by bicycle. While these issues could be addressed through investment from funds raised by the Workplace Parking Levy scheme, at present it seems unlikely that they will. In its Workplace Parking Levy business case, Leicester City Council outlined that it would use funds generated by the scheme to invest in: For casework please email: claudia.webbe.mp@parliament.uk Twitter: @claudiawebbe www.facebook.com/claudiaforLE www.claudiawebbe.org

Claudia Webbe MP Member of Parliament for Leicester East House of Commons, London SW1A 0AA Tel: 07973816885

➢ ➢ ➢ ➢

cycling and walking infrastructure, focussed in and around the city centre the city’s public realm through revitalised streets and public squares improvements in bus services and introducing affordable bus fares with discounts the refurbishment and improvement of Leicester Train Station

Improvements in bus services and potential reductions in fares may encourage residents of Leicester East to leave their cars at home. It is therefore unfortunate that the Council intends to focus the additional cycling and walking infrastructure in and around the City Centre, which may not improve green transport connectivity between residents of Leicester East and other parts of the City. Without more investment in Leicester’s East’s green transport infrastructure there is a risk that residents impacted by the Workplace Parking Levy will not feel the benefit of the improvements it finances.

It is also unfortunate that the funds will not be used to invest in electric charging points, which would allow those who need to drive a personal car to transition to a less polluting form of transport.

Communication, buy-in and fallout.

The Nottingham Workplace Parking Levy has been criticised by trade unions in light of the worsening cost of living crisis, following Nottingham City Council’s decision to increase the levy.

As employers are able to pass on the cost to employees, a major concern is that Leicester City Council’s scheme will have a detrimental impact on the income and finances of Leicester’s workers, who are already amongst the least well renumerated in the country. It is therefore imperative that Leicester City Council ensures that its own scheme addresses this concern.

A representative from GMB said: "Nottingham and the entire country is facing a cost of living crisis, and all employers should be doing their upmost to protect employees from the impact of this" "Local government workers have already faced a real terms pay cut this year and many Council employees will be facing sky rocketing energy and fuel costs.

"Parking price hikes for loyal staff, many of whom kept Nottingham running through the pandemic, is outright unfair."xi A representative from Unite said: “Many council workers are already struggling as the cost of living rockets and wages stagnate and the increase in parking charges will make things worse. This is an opportunistic money-grab by the council on its own workers and it needs to be reversed.”xii Leicester City Council’s scheme would be even more controversial because of the proposed charge for NHS providers, albeit at a 50% discount. This levy could be diverted from essential services or staff pay.

NHS staff pay has been a major political issue during the pandemic, with unions criticising the Governments appalling offer of just 3% pay rise.

Unite the Union said: “The government’s 3% pay rise for NHS (AfC) staff falls well short of what we know our NHS heroes our worth.”xiii For casework please email: claudia.webbe.mp@parliament.uk Twitter: @claudiawebbe www.facebook.com/claudiaforLE www.claudiawebbe.org

Claudia Webbe MP Member of Parliament for Leicester East House of Commons, London SW1A 0AA Tel: 07973816885

Leicester City Council risks angering council and NHS workers and receiving negative publicity if it goes ahead with its Workplace Parking Levy as currently proposed. Furthermore, the De Montfort University Report, “Workplace Parking Levy: An evidence-based review of policy and prospects for Leicester”, makes clear that a Workplace Parking Levy scheme would, on its own, only be expected to provide “moderate” reductions to the City’s levels of traffic and pollution. If stakeholder expectations are not carefully managed, and Leicester City Council’s strategy not clearly communicated, there is a risk that the Workplace Parking Levy will be perceived as primarily a revenue generating scheme for the Council, even though the money generated will be ring-fenced for other local transport projects.

To be well received, the Workplace Parking Levy will have to be demonstrated as playing a key role in funding improvements to public transport infrastructure, which will encourage more people to leave their cars behind.

The proposals indicate that the scheme will fund infrastructure projects that are also receiving finance from elsewhere – such as the redevelopment of Leicester Train Station, to which the Levy will contribute 19.5% of the overall funding, with the rest provided by non-local sources. This also presents a risk because, without clear explanation, members of the public and business owners may not be aware of the difference that their money is making with regards to improving Leicester’s transport infrastructure.

Whilst this potential problem can be mitigated by a clear communications strategy and stakeholder engagement, the Council is a long way from convincing the trade unions, employees and the general public of the benefit of introducing a Workplace Parking Levy scheme. i

https://www.ons.gov.uk/businessindustryandtrade/business https://www.ons.gov.uk/peoplepopulationandcommunity/personalandhouseholdfinances/incomeandwealth /bulletins/householddisposableincomeandinequality/financialyear2020 iii https://www.bbc.co.uk/news/uk-scotland-scotland-politics47089134?at_medium=RSS&at_campaign=KARANGA iv https://www.wwf.org.uk/sites/default/files/2016-12/nottingham%20case%20study%20%20Workplace%20parking%20levy.pdf v https://committees.parliament.uk/publications/8754/documents/88692/default/ vi https://www.gov.uk/government/publications/civil-enforcement-of-parking-contraventions/guidance-forlocal-authorities-on-enforcing-parking-restrictions vii https://publications.parliament.uk/pa/cm5802/cmselect/cmtrans/789/report.html#heading-1 ii

viii

https://birmingham.cmis.uk.com/Birmingham/Document.ashx?czJKcaeAi5tUFL1DTL2UE4zNRBcoShgo=A0FDqj ptvbRSuOsDgkefOBEsWE1OA99mlUncaPA%2brDXiLvRLZ6lSzQ%3d%3d&rUzwRPf%2bZ3zd4E7Ikn8Lyw%3d%3d =pwRE6AGJFLDNlh225F5QMaQWCtPHwdhUfCZ%2fLUQzgA2uL5jNRG4jdQ%3d%3d&mCTIbCubSFfXsDGW9IXnl g%3d%3d=hFflUdN3100%3d&kCx1AnS9%2fpWZQ40DXFvdEw%3d%3d=hFflUdN3100%3d&uJovDxwdjMPoYv% 2bAJvYtyA%3d%3d=ctNJFf55vVA%3d&FgPlIEJYlotS%2bYGoBi5olA%3d%3d=NHdURQburHA%3d&d9Qjj0ag1Pd9 93jsyOJqFvmyB7X0CSQK=ctNJFf55vVA%3d&WGewmoAfeNR9xqBux0r1Q8Za60lavYmz=ctNJFf55vVA%3d&WGe wmoAfeNQ16B2MHuCpMRKZMwaG1PaO=ctNJFf55vVA%3d ix https://www.manchestereveningnews.co.uk/news/greater-manchester-news/burnham-clean-air-zoneradio-22666712 x https://www.nottinghamcity.gov.uk/wpl xi https://www.nottinghampost.com/news/nottingham-news/parking-charge-rise-nottingham-city-6782389 xii https://www.nottinghampost.com/news/nottingham-news/parking-charge-rise-nottingham-city-6782389 xiii https://www.unitetheunion.org/campaigns/fair-pay-for-nhs/

For casework please email: claudia.webbe.mp@parliament.uk Twitter: @claudiawebbe www.facebook.com/claudiaforLE www.claudiawebbe.org