Dear Mr Bond
I have a
number of comments and concerns I wish to make regarding the three proposed
TROs currently being consulted on. I trust it is acceptable to address each TRO
within this single letter.
The council’s
stated aim, to increase the availability of short-stay parking spaces in Yarm, is
laudable and long overdue. However, the
council has failed to provide any compelling evidence that this aim can, or
will, be met by way of the current proposals. In fact, there is potential for
the situation in Yarm to deteriorate gravely as a direct consequence of these
proposals.
As has
already been highlighted in the representation made by Michael Kitching of SK
Transport Planning Ltd, the council first needs to fully understand the current
use of the existing car-parking facilities in Yarm before it can assess the
impact of any changes to the current arrangements and make any informed decisions.
To achieve this the council needs to undertake a comprehensive study of the
current usage, and good practice is for this to be done by way of a parking
beat survey.
Neither a
parking beat survey nor anything comparable has been undertaken by the council.
To bring forward the proposed TROs without having taken this necessary first
step is negligent and leaves residents and traders alike vulnerable to unseen
(by the council at least) consequences.
The only
survey relating to parking undertaken to date and made available to residents
is the market research undertaken by NEMS in 2011. This is wholly inadequate
for the purpose of making any informed decisions on changing the existing
arrangements in Yarm. NEMS Market Research is not, nor do they profess to,
professional parking or travel planning consultants. They did not undertake any
meaningful parking study, their data mainly being extrapolated from small
sample surveys undertaken. Their report is not a meaningful parking study and
it is wrong of the council to contrive to treat it as such.
This absence
of any detailed study or baseline data makes it impossible to make any evidence
based decisions, or to assess the likely impact of the proposed changes. On this
basis alone it is reckless of the council to proceed with the proposed TROs.
I am extremely concerned about the impact of removing the
current maximum stay of 2 hours on the High Street; you will be aware that the
proposed TRO imposes no maximum length of stay other than what the visitor is
prepared to pay for. In effect this will
convert every short-stay parking space within the disc controlled zone into a
medium- or long-stay parking space, contrary to the council’s stated aims.
Common sense dictates this will result in an unquantified
number of visitors staying in excess of the current maximum of two hours. How
this will lead to an increase in the availability of short-stay spaces is
unexplained and is indeed counter-intuitive.
This will be to the detriment of Yarm traders in two
profound ways. Firstly, the reduced availability of parking spaces, as longer
stays can only result in a reduced turnover of vehicles and therefore visitors
/ shoppers. Secondly, NEMS’ report illustrates that the average spend of
visitors reduces as the length of stay increases – the average spend of
visitors (excluding workers) staying for more than 2 hours is 34% less than
visitors staying for 1 to 2 hours. The average spend of visitors staying for
more than three hours falls off a cliff edge.
I would therefore request that urgent consideration is
given to amending the TRO to limit the maximum length of stay on the High
Street to 3 hours. This would lessen the detrimental impact on traders whilst accommodating
those visitors wishing to stay for more than two hours.
I am also concerned that the proposed residents’ permit
scheme will also impact detrimentally on traders, and that this impact has not been
(and cannot be, given the lack of a proper parking survey) properly considered
assessed and quantified.
The requirements of those residents who live on or off
the High Street must be of primary concern to the council before proposing any
changes to the existing arrangements, and it is pleasing that the council
appears to have taken this on board. However, that can be no excuse for
proposing a scheme which presents a real and present danger to traders.
The council has failed to quantify the number of
residents’ permits it expects to issue. Nor has it qualified how frequently and
at what times of which days it expects these permits to be used. The same
failures apply equally, and perhaps more worryingly, to the visitors permits
residents will be permitted to buy. These failures are entirely understandable,
given the lack of any parking study having been done, but are nevertheless
inexcusable.
The current proposals will see approximately 150
properties eligible to apply for up to two parking permits and to buy the
visitors permits. We will therefore see
anywhere between 0 and 300 residents’ permits, plus an unknown number of
visitors’ permits, used on any given day. As the High Street currently has only
80 unrestricted parking spaces available to residents, the risk that we will
see an reduction in the number of available short-stay spaces (as the permits
will allow residents and visitors to park in a short-stay space at no cost for
an unlimited period of time) is great.
This risk is undoubtedly at its greatest on Saturdays, the busiest day
for High Street traders.
Once again, as the council is unable to quantify this
risk it would be reckless to proceed with the proposed TROs at this time.
I am equally concerned at the absence of any measures to
minimise or mitigate the inevitable displacement of vehicles from Yarm High
Street to peripheral areas.
Given the change from a free parking arrangement to a
charged parking arrangement, and given the incontrovertible and widespread opposition
to such a change, it is inevitable there will be considerable resistance to the
proposed changes which will result in displaced vehicles. The number of displaced vehicles will only
increase when we see a reduced availability of short-stay parking spaces on the
High Street (as I have already explained), and given the reduced number of
off-street parking spaces as a consequence of another of the proposed TROs.
Once again, the council has failed to quantify the
anticipated level of displacement (understandably in the absence of any parking
study having been undertaken), failed to identify to where these vehicles may
be displaced, and has failed to propose a single measure to mitigate or combat
any issues which will ensue in neighbouring streets and communities from this
displacement. This is unacceptable. When this matter has been raised verbally
with officers, their response has been to say that they would reactively
address any issues that arise due to such displacement. To adopt this approach,
in favour of proactively dealing with this issue, is wholly unacceptable. Once again, it would be reckless of the
council to proceed with the proposed TROs until this issue has been
satisfactorily addressed.
Finally, and this point almost seems too obvious too
mention, given the risks of a reduced availability of parking spaces and the
risk of a substantial number of vehicles being displaced, it would be reckless
to implement any of the proposed changes prior to additional off-street parking
provision having been brought in to use.
The council’s website states “encouraging process on
securing suitable sites in the vicinity of Yarm High Street is being made”.
Whilst this comment needs to be taken with a healthy pinch of salt, given how
many years we have heard this line, it must be a prerequisite for these sites
to be brought to fruition and delivered before any other of the proposed
changes could be tolerated.
With regards to the taxi rank element of the plans, I
wish to consult with both residents and taxi drivers some more and will write
separately to you on this matters before the closing date of Friday 26th
July 2013.
In summary, there is a real – though, sadly,
unquantifiable – risk that the proposed TRO would bring about consequences
contrary to the council’s stated aim, namely to increase the availability of
short-stay parking spaces. Until such
time as a comprehensive parking study has been undertaken, and the risks of any
proposed changes identified, quantified and mitigated as far as is possible, it
would be reckless and negligent of the council to proceed with the proposed changes.
It is extremely disappointing that the council has
decided to implement parking charges at the two existing off-street car parks.
It is also extremely disappointing that the justification for this change (as
referred to in the notice)
has not been made available to residents on the council’s website.
It is pleasing that the charges have been set at such a
relatively modest level. However, this in itself seems to put the lie to any
argument that such charges are necessary to contribute to the provision of any
additional off-street parking. Such a
contribution, even over a number of years, would appear to be minimal,
particularly in light of the contributions to meet this end which have recently
been secured as a condition in the approval of a number of major housing
applications which have been approved.
It has also been argued that it is only equitable to
charge for on- and off-street parking in Yarm as this is currently the case
within Stockton. There is very little merit in this argument whatsoever. The
differing nature and needs of the two towns are obvious, and require very
different solutions. The ‘one size fits all’ approach is rarely an appropriate
solution, let alone the best, to any problem. Furthermore, there is an iniquity
in the amount of works currently being undertaken in Stockton Town centre at a
cost of tens of millions of pounds without visitors to Stockton being asked to
subsidise these, and the council’s stance that any additional works in Yarm
(i.e. the provision of additional off-street parking provision) require the
subsidy of residents / visitors.
Furthermore, given the wide scale opposition to the
introduction of parking charges in Yarm, there will undoubtedly be resistance
and a resultant level of vehicle displacement from the off-street car parks. I
have already explained in some detail my concerns about displacement earlier in
this letter and they apply equally to the implementation of charging in Yarm’s
off-street car parks.
Whilst not universally popular, I broadly welcome the
majority of the proposed new restrictions.
I am concerned at the proposed new restrictions on High
Church Wynd. I recognise that the
proposed lines on the north side of the wynd will, for the most part, reinforce
current custom and practice where the majority of residents park on the south
side of the wynd. However, given there
is insufficient on-street parking to accommodate all of the residents who live
on the wynd and I must insist those affected residents are able to apply for
residents’ permits permitting them to park on the High Street.
I am also disappointed that no additional restrictions
have been proposed for West End Gardens.
I understand additional restrictions have previously been considered on
the west side corner, where West Street meets West End Gardens, but were
rejected following complaints from residents. However, as the pressure on
parking has increased in recent years, we are seeing more obstructive parking
in West End Gardens than was previously the case and I, along with many
residents, consider additional restrictions to be necessary. If it is not possible to include these in the
proposed TRO, I would ask that urgent consideration is given to bringing
forward and additional TRO to address these concerns.
Finally, I wish to comment on Bridge Street. I must point
out from the outset that I currently live at the east end of Bridge Street,
although none of the proposed new restrictions are planned for outside or near
my home.
I am in favour of the proposed new restrictions on both
north and south sides of the street underneath the viaduct and flanking the
entrance to Bridge Court. I am also broadly in favour of the new restrictions
on the south side of the western end of Bridge Street, to replace the current
keep clear markings. I have however been
contacted by residents who have asked whether the restrictions need to extend
as far east as is proposed and whether these could be reduced in order to
create one or two additional parking spaces. I should be grateful if this
request could be considered and a response issued.
Finally, I approve of the proposed new restrictions on
Atlas Wynd and would thank officers for including these at the eleventh hour in
response to requests from residents of Atlas Wynd, myself and Councillor Andrew
Sherris.
Yours sincerely,
Cllr Mark Chatburn
