This is our response to the Transport (Scotland) Bill – Workplace Parking Levy Amendments, submitted May 2019.
Sustrans Scotland support the amendment in the name of John Finnie MSP to permit local authorities discretionary powers to introduce Workplace Parking Levies (WPLs).
There is clear evidence WPLs reduce congestion and encourage modal shift to sustainable and active travel.
They have the capacity to reduce carbon emissions and improve air quality. Importantly, WPLs raise valuable revenue for local authorities to invest in sustainable and active transport options.
Nottingham City Council is the only UK local authority to have introduced a WPL. The bulk of evidence in this submission is drawn from its success.
WPLs have significant capacity to reduce congestion.
The mechanism of a levy on workplace parking means that for the most part it will target journeys undertaken at peak times. It will act as an inducement for people with alternative transport options to use those instead of a car – which is often the product of free work parking .
Evidence from Nottingham City Council’s evaluation indicates a 9% reduction in congestion during rush hour, with a proven link to the WPL . It also reduced average journey times. In 2009, the Department for Transport agreed the proposals for Nottingham’s WPL to be implemented in 2012. Subsequently, 17.5% of parking as removed from Nottingham City Centre before it came into effect in 2012. This means congestion reduction started in 2009 when employers and the public knew what the terms were to be, prior to charging
Objective data from SatNav records indicates that from 2009 to 2012, extra journey time reduced from 35% to 23%, and despite slight regression remains 8% lower than the 2009 peak .
This potentially explains why there is no evidence of negative economic impact. In fact, 2,000 jobs were created in the period since implementation – faster job creation than other UK cities of a comparable size .
Evidence suggests business values reduced congestion and investment in public transport.
Congestion already costs Scottish cities billions of pounds each year . Alarmingly, the Scottish Government estimates that by 2032 traffic levels will have risen by more than a quarter  and the cost of congestion to Edinburgh and Glasgow by 2025 is estimated at £2.8bn and £2.3bn respectively .
Scotland must tackle congestion to unlock economic growth, and we cannot build more roads in congested space. We cannot let cities become choked by cars and air pollution and the WPL forms part of the solution.
Modal shift to active travel and sustainable transport
A WPL acts an incentive to leave the car at home and travel by alternative means.
The social cost of driving is vastly under-priced, as current costs do not include the impact of congestion, road casualties, carbon emissions, air pollution, noise, and physical inactivity. It has been estimated that the cost of these motoring externalities is as much as
£56 billion in the UK .
A WPL is a relatively minor, but highly effective, way to better balance people’s travel choices.
The impact of Nottingham’s WPL crystallises the major impact the measure can have on mode choice. Public transport usage has grown 15% since the introduction of the measure  which has led to modal share over 40% . In addition, the number of trips by bike in the city is up by 1/3 since 2010 . This could be attributable to both the investment in cycling infrastructure and the lower number of cars in the city centre. The Committee should note the associated health impacts of increased physical activity.
There is, therefore, strong evidence that WPLs directly achieve their specified aims.
There exists a dynamic between revenue-raising and encouraging modal shift to walking, cycling and public transport. WPLs have the capacity to do both, and give local authorities the freedom to set or alter the cost of the levy at a rate that suits local priorities.
Transport is responsible for nearly a third of Scotland’s annual carbon emissions (28% or 13 MtCO2e) and the sector has reduced emissions the least .
Though steps have been taken to promote the use of electric vehicles to reduce the carbon impact of transport, modal shift from cars to walking and cycling has the potential to cut carbon emissions faster than transition to electric vehicles.
Research indicates that a 12% reduction in carbon emissions is possible through modal shift by 2030; a rate only matched by transition to electric vehicles by around 2050 .
Furthermore, policies centred on electric vehicle promotion alone will not be sufficient for Scotland to meet emission reduction targets for the transport sector .
Increases in active travel mean lower demand for motor vehicle travel, and a transition of vehicle fleets to electric becomes easier to achieve. Combining behavioural change with promotion of electric vehicles leads to transport sector emissions 43% lower than expected with current policies, with no extraordinary assumptions about uptake of active travel .
A WPL has the capacity to catalyse this vital behavioural change and provide revenue to support the transition to low carbon transport systems.
WPLs can help Scotland to tackle air pollution and achieve the aims of Cleaner Air for Scotland.
Cleaner Air for Scotland acknowledges that transport is responsible for the emission of 1/6 of particulate matter and 1/3 of nitrous oxides . However, road transport is responsible for 80% of NOx pollution where legal limits are being broken, most commonly in cities .
Reducing car use will reduce air pollution. Evidence from Nottingham City Council indicates that the WPL will allow Nottingham to achieve its air quality objectives by 2024 without a Clean Air Zone  (though this is being implemented anyway).
With Aberdeen, Dundee, Edinburgh and Glasgow planning low emission zones by 2020, a WPL is a strong complementary policy.
Sustrans Scotland note that Cleaner Air for Scotland is currently being reviewed. Our submission to this has centred on a need to reduce the number of vehicles in cities, an aim that WPLs can have a significant impact on accomplishing.
WPLs have the capacity to provide much-needed revenue for local authorities.
The Nottingham WPL raises more than £9 million per year that has helped to fund tram infrastructure, a smart card scheme, electric buses, cycling facilities and match-funding for national funding programmes. The cost of administering the scheme is a mere 5% of the revenue raised in Nottingham .
Sustrans Scotland would like to draw attention to the provision to hypothecate any revenue for sustainable transport investment. This has been a key criticism of WPL proposals in Scotland that has been overcome through the amendment.
The Scottish Government should be lauded for doubling the active travel budget to £80 million. The majority of this funding requires match-funding from local authorities.
Sustrans Scotland note the desire from local authorities to fundamentally alter how they prioritise mobility in cities and that a WPL has the capacity to raise revenue that can contribute to match-funding. This will help to achieve the shared goals of local authorities and the Scottish Government to prioritise walking and cycling infrastructure.
A WPL can help local authorities to encourage better use of in-demand city space.
Space in our cities is increasingly at a premium and a side-effect of a WPL is that more land is available for more valuable uses than parking. Nottingham City Council’s WPL led to a 25% reduction in land used for parking .
The Glasgow Connectivity Commission recently noted that the city only uses approximately half of the 12,000+ parking spaces in the city centre . This is ‘dormant’ land that could be put to better use and the Commission endorsed the potential of a WPL to help Glasgow
meet this and other priorities.
Inclusivity and fairness
WPL is a progressive policy that is likely to be of greatest benefit to people on lower incomes.
The Scottish Parliament Information Centre briefing on WPLs notes that it is difficult to assess the impact on people on lower incomes without knowing the details of a particular local scheme .
This implies, and Sustrans Scotland concur, that a local authority is best placed to assess and design a WPL in order to ensure that it protects and benefits people on low incomes.
However, WPLs are likely to have a positive impact on social inclusivity at a population level. The likelihood of owning a car and driving to work increases depending on household income. The majority of people living in households with incomes of less than £15,000 do
not drive to work .
Many do not have the option of doing so, and Sustrans Scotland research into transport poverty indicates that many do not have adequate, affordable public transport or walking and cycling infrastructure to access essential services that most people take for granted .
WPLs can be of benefit to social inclusivity by ensuring that revenue raised supports better public transport and active travel options in deprived communities.
People on the highest incomes are most likely to drive. There are externalities to this choice that all people, regardless of income, are paying the cost of, through poor air quality and increased road danger, among other factors.
A reduction in vehicle traffic is of greatest
benefit to deprived communities, where people are more likely to suffer from higher levels of local air pollution from vehicles  and increased road danger .
A WPL is a step to redress this inequality, to help people suffering the impacts of transport poverty to access essential services, and start to correct the social cost of motoring.
Comment on exemptions
Sustrans Scotland support the exemption for blue badge holders, though it may prove easier to administer if exemptions are instead applied to disabled parking bays.
A system that exempts blue badge holders, rather than the parking bay, may also lead to an excess of unoccupied bays if the bay has to be designated to one person for administrative reasons.
The bill gives significant leeway for local authorities to exempt based on various factors.
This should give comfort to critics of WPLs that they are not a blunt tool. The provisions to ensure assessment and review of a WPL will ensure inclusive schemes that delivers on the benefits discussed above. In order to ensure the success of WPLs, we would advise local authorities to limit the number of exemptions and keep these simple.
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