The Liberal Democrats believe that the consultation on changes to parking charges for 2024 misses several opportunities for positive change for both Merton residents and the environment. The Labour political administration advances two broad justifications for the latest round of increases to parking charges: 1) Increased costs in the management of on-street parking, 2) Efforts to tackle the climate crisis. Whilst the objectives are legitimate, we remain unconvinced that either is being approached properly or effectively. It’s unclear how or if the administration’s proposals complement the Walking and Cycling Strategy currently being developed (which presumably will look at the management of on-street and pavement parking and accessible travel).

Our recommended additions and changes to the options recommended in the consultation:

• The removal of the costs differential brought in with the price structure adopted in January 2020. It is an in-built unfairness that residents parking in the west of the borough pay nearly double the charge as elsewhere. This acts to undermine the legitimacy of the scheme in the eyes of many.
• The consideration of whether other variables would be appropriate when determining charges (for example, new discounts) such as vehicle weight and length. This could incentivise residents to use vehicles that are safer in a dense urban environment.
• The introduction of discounts to incentivise certain behaviours, for example for smaller vehicles as described above, a “low mileage” discount for those using their vehicles less (as previously proposed), and/or the introduction of discounts or other benefits for multi-occupancy use, such as carpooling and/or ride sharing.
• The ringfencing of monies from any additional charges to support air quality measures in the Borough to improve the legitimacy and public acceptance.
• The automatic index linking of permit charge increases (to an appropriate measure – not CPI) to depoliticise future changes in parking charges.
• The alignment of the diesel levy to ULEZ principles, so as to remove a level of confusion in the application of two different measures intended to improve air quality.
• The implementation of realistic lead-in times to allow people the time needed to change. This again is an important measure in improving the legitimacy and public acceptance of the measures.

Our concerns with the content of the consultation are detailed below.

The costs of running parking services

The proposals in the consultation rely on highlighting both the failure to reach budgeted income and general measures of inflation.

We disagree that references to general measures of inflation such as CPI in the section “inflation” in the detailed proposals is the correct measure, given many of the costs of managing parking are managed ‘under contract’ (for example, issue of PCNs by CEOs). As such, any increased costs of parking should be able to be specifically calculated. Certainly no evidence is offered in the consultation document to suggest that CPI is a relevant measure reflecting increased costs in running parking services.

Reference to pre-pandemic levels of parking (and thus parking income) is not relevant. The “income gap” identified appears to be the gap between the income levels expected and those now achieved, rather than between the costs of the service and the income generated. The Council administration has itself recognised this and has made “growth bids” in the latest business plan. Unless and until the direct costs of the management of parking fall below the amounts raised, it is not clear that significant increases can be justified.

Labour Council bosses take a confused approach to the cost-of-living crisis. For example, railing against proposed levy increases by the Commons’ Conservators, calling plans amounting to £1 or £2 a month “wholly unacceptable” in a cost-of-living crisis. Even ignoring the fact that the real objection is that it reduces the amount of Council tax increase Merton can levy, it is also dwarfed by these proposals to increase parking charges.

We could support automatic index-linking of permit charge increases to depoliticise future changes in parking charges, but that must be in the light of our comments above about the appropriateness of CPI - general measures of inflation might not be the appropriate indexing.

We strongly disagree with the introduction of a £30 charge for a carer permit, as mentioned in Question 5 of the consultation survey/as outlined in ‘Appendix 2: Summary - Carer and Visitor Permits’ of the detailed proposals especially in a cost of living crisis. We do not consider that the appropriate factor in this decision is the “utility of the carer permit to residents who need daily care visits”, rather it should be the additional needs of the individuals in question resulting in extra costs to them and their families and friends.

The Climate Emergency

Our view is that the political administration’s approach since 2017 has completely undermined the idea that parking charges can be used legitimately to support climate emergency objectives.

We wish to highlight that we continue to oppose the “tiers” brought with the price structure adopted in January 2020, which undermines the Council’s approach to the climate emergency generally.

Many members of the public view the doubling of residents parking charges for the western and central parts of the borough with effect from January 2020 had more to do with the borough’s political geography than anything else. This fundamental unfairness has permeated proposed revisions since then, including the administration’s proposals for additional emissions-based charges in 2020/21 – as well as these current proposals. In our view, maintaining this distinction where parts of the borough pays much higher charges (Tier 1 being £175 according to the new proposals, compared to £105 in Tier 3, according to Appendices 3a and 3c) is not acceptable. Neighbouring Kingston-upon-Thames has a borough-wide flat rate of £97 (soon rising to £103), which is significantly less than Tier 1 parking charges in Merton.

The root of the 2020/21 emissions-based charges proposals were cabinet decisions in late 2016. Despite having argued that the changes would mean that around half of residents would see reductions in residents parking charges for less environmentally damaging vehicles, the then leader of the Council dumped these proposals in April 2022 in advance of the election, claiming that he was saving people from higher parking charges suggested by others.

This embarrassing and cynical approach previously taken by the political administration means that it is almost impossible to justify further changes in parking charges. Even recent activities have reinforced this. ULEZ mitigation measures such as the local scrappage scheme exclude huge parts of the borough even though the justification given is to reduce carbon emissions. Such carbon-reducing programmes and initiatives should be spread equitably and fairly across the Borough – carbon emissions and air pollution do not respect ward boundaries.

Subject to the above, we would require the January 2020 ‘tiered’ pricing structure to be removed before we could properly consider any move towards emissions-based charges. This would also likely reduce the costs of administering the scheme. Further, we therefore support the proposal (set out in Question 5 of the consultation survey) to standardise visitor permits charges borough-wide.

As part of building support for changes we would encourage ringfencing of any additional monies raised to support air quality measures. We have proposed this multiple times and the political administration has always rejected it, again undermining the suggestion that changes to parking charges are legitimately about improving air quality.

One of these changes Merton council is proposing is the introduction of a surcharge on high carbon-emission petrol vehicles. According to the consultation document, this approach will result in a switch to lower carbon-emission petrol vehicles. This assumption is based on another assumption – that the switch by some motorists to less-polluting vehicles is down to previous increases in Merton’s parking charges. However, no evidence is provided within the consultation documents as to how this claim was measured. New proposals to extend surcharges on parking permits should not be put forward in the absence of evidence demonstrating causation. The basis for this new proposal appears to be on correlation alone, which we believe is insufficient. We also question whether a flat rate carbon surcharge of £150 mentioned under Question 3 of the consultation survey is appropriate.

Our approach is that the administration should focus on the ‘carrot’ not the ‘stick’, and so we would expect to see longer lead in times and appropriate exemptions. This should not be problematic if the objective is not to raise money but to change behaviour and reduce carbon emissions and pollution.

An example of a ‘carrot’ approach would be the introduction of discounts to incentivise certain behaviours. These behaviours could be things such as the use of smaller vehicles (both length and weight), using a vehicle less and therefore getting a “low mileage” discount, and/or the introduction of discounts or other benefits for multi-occupancy use, such as carpooling and/or ride sharing.

If the Council wants to help motorists to switch towards cleaner modes of transport, it would be better achieved by allowing all residents of Merton to access the ULEZ scrappage scheme. The £1000 grant would be a much better tool to reach the Council’s climate aims.

The opportunity should be taken to rationalise the diesel levy with ULEZ principles. It makes little sense for Merton to penalise newer diesels that are encouraged by the Mayor’s ULEZ scheme. It acts to further undermine the legitimacy of measures adopted by Merton.

We do not agree with the premise of Question 6 in the consultation survey, where it suggests choosing an essentially random period of time to move the price of parking permits for Electric Vehicles closer to the price for petrol vehicles is a helpful choice to make. The relevant factors should be the rate of the switch to less environmentally damaging vehicles and the costs of the parking service.

The consultation fails to acknowledge the potential environmental damage which can be caused as a result of increasing resident permit parking charges. The increase in charges will lead to more residents paving over their front gardens - resulting in biodiversity loss and increased risk of flooding.

As a final note, there has been some confusion around the nature of this consultation.

At its budget meeting in March 2023, the administration passed a budget including 16% increase in parking charges, and as such the decision on the broad thrust of these proposals already seems to have been made.

However, the consultation document sets out that it is to gauge opinion and that a report will go to Cabinet for a decision on which proposals to carry forward. After that, there will be a statutory consultation.

Therefore we would encourage the political administration to engage in a genuine consultation on these measures.