Logged Responses Received on Or Before 23Rd June 2011 And

Appendix: 3

Addendum Table 2f – Logged responses received on or before 23 rd June 2011 and between 24 th June-28 th July 2011

RECEIVED ON OR BEFORE 23 JUNE 2011 Business/ Name Date Comments Response Organisation received BUSINESSES John Lewis Simon B - Against extending parking hours in West End Noted. Fowler E - Support increase loading bays ORGANISATIONS NWEC Richard 23/06/2011 As you know, New West End Company represents Noted. A number of responses from retailers Dickinson (letter some 600 retailers and major property owners in within the NWEC area have been received. dated) London’s West End. I am aware that you will already have received letters from many of our members The West End offers a unique mix of shops, expressing concern at the Council’s parking proposals. restaurants, museums, theatres, and other We agree with their concerns and would like to add our entertainment and cultural attractions which comments as the umbrella organisation for the area. shopping centres such as Westfield and Blue water will find very difficult to rival. In 2010 Economic impact Jones Land LaSalle conducted a study on ‘The As has been well documented in the media, domestic West End and The Westfield Factor – A brief consumers are undergoing a challenging in time with overview of London Retail’, which had the many additional demands on disposable income and following findings: this is likely to continue for a significant time. We also - the addition of Westfield has not stunted depend to a large extent on tourism spend which is still West End’s attraction to shoppers or fragile and is likely to reduce due to strengthening retailers. Westfield is actually Sterling. It is therefore important that no additional complementing the West End retail offer; obstacles are put in the way of our suburban and - Between January 2009 and September London shopper markets. Generally the impact of 2010, there was an average annual increased charges is to drive trade away, for example: increase of 6.5% in retail sales; - In Plymouth a 20% increase in parking - Tourism spend and rents have both risen charges has led to a significant reduction in with the West End outperforming the UK shopper numbers in the City Centre; average. The West End remains an - 200 of 800, or 25% of respondents to Mary attractive option for new retailers;

Portas’ website (in her new role as the especially international retailers with Government’s High Street Tzar) cite high demand for space outstripping supply and parking charges as the principal reason for the forcing up rents; deterioration in occupancy in their shopping - International consumer spending is up to streets. This is by far the most major issue 6 times higher than domestic, and identified; typically international consumers will not - A report by the British Retail Consortium be driving to the West End; published in November 2010 recognises that - Parking at Westfield is more expensive at ‘parking policy should be seen as a way to weekend than during the week which attract customers to the high street and keep reflects demand for spaces; the heart of communities beating’; - The 6% quoted in the NWEC response is - A survey by Park-up Com in 2010 revealed based on residential spend, rather than that 52% of drivers have been so put off by worker or tourist spend which represent parking issues that they now shop elsewhere. the biggest share of the overall spend. This problem is compounded when shoppers - Retailers will always want flagship stores who use their car tend to spend 2.5 times within the West End, which will always be more than those using other forms of one of the key retail centres in Europe. transport. Unlike most other urban centres across the UK, Competitive Threat in Westminster parking is a marginal influence Westfield Stratford, Europe’s largest retail mall, is due and dependence on the private vehicle is very to open in September 2011 and will become a low, i.e. 14% for combined car, motorcycle and destination in its own right, underpinned both by the powered two wheeler for trips as the main Olympic Games and the legacy of the Olympic Park. mode of transport in Westminster (based on an The following is relevant: average 7 day week between 2006 and 2009 – - Research from Jones Land La Salle estimates source TfL 2010). Whereas for those who walk a deflection in sales from the West End of it is currently 38% and those on public some 6% on the basis of the retail mix alone. transport it is 35%.There will be major public (Deflection to Westfield White City on the other transport schemes delivered over the next ten hand was negligible); years that includes the Crossrail scheme (with - Westfield is likely to offer free parking for an stations to be located at Tottenham Court Road opening period and after that, if they follow the and Bond Street) that will increase public pattern of the White City centre, it will only be transport capacity by 30%. Other major £2.50 an hour as proposed to Westminster’s improvements to the public transport network proposal of double that (£5 in Zone F). It is are also planned. Research for NWEC carried also easy to find spaces; out by KRC in 2004 on Opinions of Shopper

- The environment in Westfield will be better and Non shoppers towards shopping in the managed and the ‘public realm’ will be of a West End found that 0% of shoppers cited higher quality than Westminster’s streets expensive or inconvenient parking as a dislike which will mean some of the shoppers and 5% of non shoppers cited expensive or deflected from the West End will be lost for inconvenient parking as a dislike. Similarly, a good. Other impacts in the West End, such as 2006 West End Shopper Insights Profile and the Crossrail works and protest marches, are Positioning survey found that 89% use public already making the trading environment transport. NWEC figures say that 96% of particularly challenging and this should be visitors to the West End travel by public taken into account as they are also likely to be transport (Jones Lang Lasalle study, 2010). longer term issues. NWEC footfall counts from May 2011 indicated This competitive threat should no t be underestimated. that Fridays (3.6m) and Saturdays (3.8m) are While the West End is an international destination the the busiest days, followed by other weekdays, marginal impact of higher charges will undoubtedly with Sunday the lowest (2.5m), despite the erode competitiveness. The City Council has a wider currently free on street parking. responsibility for London to support the international retail centre as one of London’s economic drivers and Extended parking controls are necessary should not apply charges on the basis of a narrow because in parking Zones E, (F3 at weekends) financial interest. and G all currently exceed recognised parking stress indicators. It is therefore the duty of the Policy Effectiveness Council to introduce controls to mitigate this White the Council should not use charges to bolster reality. The Council’s comprehensive street by revenue we appreciate this need due to the current street 2011 Occupancy Survey identifies that financial climate. We would however question the overall in Zone E the weekday occupancy is theory that charging more can radically alter or reduce 73%, on Saturday evening it is 86% and on traffic volumes during weekdays given the number of Sunday afternoon it is 84%. In Zone F3 on through vehicles in Westminster and the experience Saturday evening it is 65% and on Sunday with the congestion charge bears this out. By the same afternoon it is 88%. In Zone G weekday token we would also question the need to levy charges evening occupancy is 71% on Saturday on Sundays as volumes are nowhere near weekday evening it is 81% and on Sunday afternoon it is levels. We recognise that there are hotspots which 92%. The standard parking stress levels the cause difficulties for local residents but we would think Council applies are if the recorded rate is >80% these could be controlled effectively with more 24/7 this means serious deficiency and if it is 70- resident parking bays. E.g. in some areas of 80% there is deficiency. Therefore in all three Marylebone. zones in question there are serious parking occupancy stress levels on all days including

While we are against both sets of proposals, the Sundays. Sunday charges are potentially the most damaging for retailers as they could significantly alter the shopping The proposed implementation of parking habits of a large number of people who regularly shop controls over this time would have the potential on Sunday by a car and often buy bulky items. The of increasing the turnover of parking stock on following is relevant: the street that would enable more visitors to - The lack of reliable public transport on park. Competing shopping centres such as Sundays is an issue, particularly the number of Westfield also charge visitors for parking in the underground liens which close for scheduled evenings and at weekends. engineering work – a programme which is due to continue for at least 8 years; The parking proposals of the PPR are therefore - The measures will also create problems for likely to represent a minor influence on other groups, such as local churches, (e.g. All people’s decision to visit the West End given Saints Margaret Street) and could also the range of attractions offered by the West threaten facilities useful for the local End, the availability of public transport, the community (e.g. the Marylebone Farmers availability of parking spaces for visitors in off Market); street car parks and on street paid for parking - Charges during the evening or on Sunday will bays, and the concessions offered to make it harder for people working the area late blue/white badge holders in the evenings and at night to use private transport to return at weekends. home. The City Council, with support from TfL, NWEC, the landowners and businesses continues to invest in improving the public realm of the West End, with a number of projects planned such as the Oxford Street East and South Molton Street schemes. This will to maintain the West End as an attractive place to visit. The Council is working with Crossrail to minimise the impacts from the works and this project will bring significant benefits to the area in the longer term, with public transport accessibility into Bond Street and Tottenham Court Road greatly enhanced. Associated public realm projects will also be delivered through Crossrail. There is a legal

4 obligation that any surplus income attained through DPP 1 and 2 should be re-invested back into the transportation and parking network of central London.

Regarding access to free parking for local churches, it should be noted that for other religions and faiths whose holy days fall on other days of the week when controls and charges apply, no exemptions are granted. The availability of public transport, the capacity of off street car parks during the evenings and on Sundays, the concessions offered to blue/white badge holders, the elderly and the disabled on London’s public transport network, including black cabs, all contribute to mitigating any adverse impacts on families with young children, the elderly and the disabled. Officers have also taken into account the provisions of the European Convention on Human Rights in this context and it is not considered that Article 9 rights would be infringed by these proposals, but any restriction there may be would be proportionate and justified in pursuit of a legitimate aim in any event.

Musicians Union Dave 21/06/2011 1. The Musicians’ Union (MU) represents over 30,000 1./2. Noted Webster musicians working in all genres of music. As well as negotiating on behalf of our members with all the major 3. There was a major public consultation Stage employers in the industry, we also offer a range of 1 between 22 November 2010 and 7 January services tailored for the self-employed by providing 2011. There has been media coverage, a assistance for professional and student musicians of printed item in the Westminster Reporter that all ages. reaches all householders and the proposals have been presented in 12 recent Westminster 2. We are responding to the proposed changes to Area Forums. Stage 2 began on 10th May parking charges in the West End of London in order to 2011 and was formally launched on 16th May protect the careers of our one thousand or so 2011, closing on 23rd June 2011 (6.5 weeks). members who regularly work in the West End. The Council’s Head of Research and Customer 3. The MU is also concerned that Westminster City Insight was asked to comment on the statistical Council (WCC) have not consulted broadly enough validity of the Parking Consultation Exercise. prior to these proposals being suggested. His conclusion was: “Overall the findings from the consultation provide a valuable and robust 4. The MU wrote to WCC in January 2010 setting out insight into the views of people towards the our concerns regarding the proposal to introduce Parking Policy Review, but in working through parking charges after 6.30pm in the West End. We the detail of the implementation there may be were assured that we would be kept informed and that some instances where opinion is finely discussions would be held with us. Unfortunately, this balanced. In these cases closer attention did not happen, and we hope that our comments in this should be brought to understanding the views document will be carefully considered. of individual sub-groups (e.g. under 45 year olds) as well as the overall figure.” 5. A – Should there be any concessions for certain road users? If the changes as proposed were to take 5/6/7. It is recognised that the many and varied effect, the MU would be seeking a concession for our music venues across central London contribute members that would allow them to park in the West much to its unique character and offer. Whilst a End without incurring any additional charges after select number of musicians have made a 6.30pm or at weekends. This is because our members, strong case for a workers permit scheme and as musicians, are often required to work unsociable their concerns have been clearly and hours and carry heavy and valuable instruments and professionally made by the Musicians Union on equipment that makes it difficult and risky to use public their behalf, like the casino workers who work transport. Some are women who use cars in order that within or near Parking Zones E, F3 and G it they do not have to make their way home alone late at would be inappropriate and potentially illegal to

6 night. Many of our members who work in the West End grant a workers permit concession to one are therefore, in many ways, essential car users. sector of the business community over and above all others. Even if the Council were to 6. Many of our members are self-employed and are not grant a worker permit to all eligible late night sufficiently well paid to be able to afford to pay the employees (under an equitable and transparent proposed extended parking charges. Rises in fuel duty, qualification criteria), there would be thousands congestion charge and existing parking charges are of viable applicants and the reality is that there already heavily affecting our members. is simply not enough kerbside space to accommodate all such vehicles in an already 7. B – At what time should extended hours in the West congested West End. Instead the Council End finish? Whilst most theatres close their doors by advises that the music industry en-bloc or 11pm, nightclubs, other gigs and operas finish well individual employees approach the secure off- after this time. MU members leave venues with their street car park providers who are very equipment long into the night, and, as stated above, interested to negotiate tailor made discount have difficulty in using public transport. We therefore schemes that suit the needs and lower do not believe that a specific end time would be easy incomes of such workers which would be to decide upon. significantly less than the cost of parking on- street. An example of such a concession 8. E –What are your views on increased loading scheme is already in place in Westminster activity on your streets? This question is directed at where a car park charges Casino employees residents, but MU members must also be considered. £5 per night to park. Our members often carry multiple, large instruments that are of significant value. MU members need to be 8. Noted. Vehicles are permitted to load/unload able to unload with ease and in safety. from yellow lines at any time of the day without cost (subject to local loading restrictions and 9. In order to provide some evidence for our views assuming loading activity is continuous). LGVs above, we conducted a survey of our members are permitted to load for up to 20 minutes and working in the West End: HGVs 40 minutes and private vehicles do not have a time limit. There are no proposals under Question 1: In what type of venue do you work? the PPR to change this. Indeed DPP 7 seeks to improve loading provision. Concert Hall 50% Club 39% 9. Noted. Pub 33% Note: some answers are multiple choice. 10. Noted. The Cabinet Member has met with Restaurant 26% the MU to discuss the proposals.

Theatre 66% Opera House 29% Hotel 29%

Question 2: How often do you work in the West End?

Every night 39%

Weekends 4% Once a week 9%

More than once a week 29% Once a month 8%

Less than once a month 11%

Question 3: How do you travel into the West End?

Tube 30%

Train (overground) 27%

Bus 6% Car 89%

Motorcycle 4% Bicycle 5%

Walk 2%

Question 4: If travelling by car/motorcycle do you have difficulty in finding a parking space?

Yes 61%

No 39%

Question 5: If travelling by car/motorcycle which of the following reasons influence your decision?

Size of instrument 66%

Value of instrument 40%

Distance from home to workplace 36% Lack of suitable public transport 32%

Cost of public transport 21% Personal safety 37% Disability 3%

Other 16%

Question 6: If the proposed parking charges were introduced, would they deter you from accepting work in the West End?

Yes 69%

No 31%

10. We believe that these proposals would have a serious impact on our members’ ability to work safely in the West End, and we urge WCC to review the situation as a matter of urgency. The MU would be happy to meet with WCC to discuss the points made in this submission in more detail. Pimlico FREDA Ian Maitland 10/06/2011 Edward Reeve has written to you on parking policy, Noted. There is no proposal to standardise and I write to add my support to his observations. I am parking controls across all zones of especially concerned by the following issues in the Westminster as it is recognised that demands Draft Parking Policy Proposals: placed on each parking zone vary across the I see no reason why a household in Westminster city. There are no proposals to change parking should require more than one car, bearing in mind the restrictions within Pimlico as part of the current high quality of public transport in the city. PPR. Similarly there is no proposal to limited I cannot support the proposal to standardise parking parking for residents to the 6 nearest streets to controls across all zones of Westminster. Parking their home. pressures vary widely around the city, and Pimlico is blessed with low parking demand by Westminster The PPR has identified that the City of standards, so the relatively short hours of control Westminster is a diverse settlement where should be retained in this area, and indeed in other parking controls in different areas need to be areas where there is no need for longer hours. different to meet the demands of communities. Pimlico has appreciably more parked cars in the DPP 5 seeks to introduce a mechanism to evening than during the day, so extension of hours of permit the review of individual parking zones. control to the evening would impose exceptional The mechanism includes the principle of local inconvenience without improving traffic flow which is consultation and careful evaluation of whether very low in the evening and at night. an amended zone is required or not. However, Any extension of local hours of control should be It will not be influenced by the position of a subject to prior approval of a majority of the residents minority of concerned individuals alone. (not those voting!!) A visitor’s parking scheme would be very welcome. Support for visitors parking scheme noted. Misuse and fraud risks could easily be controlled by a low limit on the issue of visitors’ permits – say 10 hours a month or 120 hours a year per household. Visitor’s parking schemes work well in many areas. Division of Zone A would be most unwelcome. I was surprised to learn that the proposals were omitted from

the papers circulated to the Cabinet members and ourselves. This is a most underhand way of conducting a consultation. I am equally shocked at the news that you proposed on 1st June that WCC parking policy should limit parking for residents to the 6 nearest streets to their home. This is totally unacceptable.

WORKERS Neela Bacoo B - Against extending parking hours in the West End There is a full range of late night workers who currently make use of unrestricted on-street Claims that casino workers have little option to use parking space across the West End and the their car to get to work as public transport at night is wider Central Activity Zone in Westminster. unsuitable The Council advises that the late night economy industry en-bloc or individual Says there is no problem finding parking employees should consider approaching the secure off-street car park providers who are very interested to negotiate tailor made discount schemes that suit the needs and lower incomes of such workers which would be significantly less than the cost of parking on- street. An example of such a concession scheme is already in place in Westminster where a car park charges Casino employees £5 per night to park.

weekends) and G all exceed recognised parking stress indicators. The Council’s comprehensive street by street 2011 Occupancy Survey identifies that overall in Zone E the weekday occupancy is 73%, on Saturday evening it is 86% and on Sunday afternoon it is 84%. In Zone F3 on Saturday evening it is 65% and on Sunday afternoon it is 88%. In Zone G weekday evening occupancy is 71% on Saturday evening it is 81% and on Sunday afternoon it is 92%. The standard parking stress levels the Council applies are if the recorded rate is >80% this means serious deficiency and if it is 70-80% there is deficiency. Therefore in all three zones in question there are serious parking occupancy stress levels on all days including Sundays.

Julie As above As above Henderson Pawel As above As above Spolnicki Glenn Miles As above As above Ross B - Against extending parking hours in the West End It is recognised that the many and varied music Anderson venues across central London contribute much Claims that extended hours would affect his livelihood to its unique character and offer. Whilst a as a musician as he needs to drive to work in order to select number of musicians have made a transport all his equipment but the cost of parking strong case for a workers permit scheme and would take a third of his wages their concerns have been clearly and professionally made by the Musicians Union on their behalf, like the casino workers who work within or near Parking Zones E, F3 and G it would be inappropriate and potentially illegal to grant a workers permit concession to one sector of the business community over and

above all others. Even if the Council were to grant a worker permit to all eligible late night employees (under an equitable and transparent qualification criteria), there would be thousands of viable applicants and the reality is that there is simply not enough kerbside space to accommodate all such vehicles in an already congested West End. Instead the Council advises that the music industry en-bloc or individual employees approach the secure off- street car park providers who are very interested to negotiate tailor made discount schemes that suit the needs and lower incomes of such workers which would be significantly less than the cost of parking on- street. An example of such a concession scheme is already in place in Westminster where a car park charges Casino employees £5 per night to park.

Darran Phillip B - Against extending parking hours in West End There is a full range of late night workers who currently make use of unrestricted on-street Claims that casino workers have little option to use parking space across the West End and the their car to get to work as public transport at night is wider Central Activity Zone in Westminster. unsuitable The Council advises that the late night economy industry en-bloc or individual Says there is no problem finding parking employees should consider approaching the secure off-street car park providers who are very interested to negotiate tailor made discount schemes that suit the needs and lower incomes of such workers which would be significantly less than the cost of parking on- street. An example of such a concession scheme is already in place in Westminster where a car park charges Casino employees

£5 per night to park.

It is unsustainable to expect that free unrestricted parking can be available for workers in the heart of the West End given the intense pressures on the kerb side and anticipated growth in the economy. Road traffic in the West End and Central Westminster area has reached high levels so it is the duty of the Council to introduce controls to mitigate this reality. The parking spaces in Zones E, (F3 at weekends) and G all exceed recognised parking stress indicators. The Council’s comprehensive street by street 2011 Occupancy Survey identifies that overall in Zone E the weekday occupancy is 73%, on Saturday evening it is 86% and on Sunday afternoon it is 84%. In Zone F3 on Saturday evening it is 65% and on Sunday afternoon it is 88%. In Zone G weekday evening occupancy is 71% on Saturday evening it is 81% and on Sunday afternoon it is 92%. The standard parking stress levels the Council applies are if the recorded rate is >80% this means serious deficiency and if it is 70-80% there is deficiency. Therefore in all three zones in question there are serious parking occupancy stress levels on all days including Sundays.

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Korjie Noel Labo As above As above Lamnet As above As above Bradley As above As above Gbasai Elsa Kirwan As above As above Shaun As above As above Barkus Robert As above As above Fairclough Joseph As above As above Rullan INDIVIDUALS Jonathun Wu B - Against extending parking hours Noted. However it is unsustainable to expect that free unrestricted parking can be available Is a resident and has not experienced problems with for visitors in the heart of the West End given parking occupancy the intense pressures on the kerb side and anticipated growth in the economy. Road traffic Concerned about how extending parking hours to the in the West End and Central Westminster area weekend will affect local small business as well as has reached high levels so it is the duty of the church congregations and residents' weekend social Council to introduce controls to mitigate this lives reality. The parking spaces in Zones E, (F3 at weekends) and G all exceed recognised parking stress indicators. The Council’s comprehensive street by street 2011 Occupancy Survey identifies that overall in Zone E the weekday occupancy is 73%, on Saturday evening it is 86% and on Sunday afternoon it is 84%. In Zone F3 on Saturday evening it is 65% and on Sunday afternoon it is 88%. In Zone G weekday evening occupancy is 71% on Saturday evening it is 81% and on Sunday afternoon it is 92%. The standard parking stress levels the Council applies are if the recorded rate is >80% this means serious

16 deficiency and if it is 70-80% there is deficiency. Therefore in all three zones in question there are serious parking occupancy stress levels on all days including Sundays.

There are many determinants that steer the performance of the capital’s economy such as variable exchange rates, levels of disposable income, employment levels, the weather, retail trends etc. Unlike most other urban centres across the UK, parking is a marginal influence and in Westminster dependence on the private vehicle to reach retail centres is very low, i.e. 14% for combined car, motorcycle and powered two wheeler for trips as the main mode of transport in Westminster (based on an average 7 day week between 2006 and 2009 – source TfL 2010). Whereas for those who walk it is currently 38% and those on public transport it is 35%. The parking proposals of the PPR therefore represent a minor influence on the West End economy.

holders, the elderly and the disabled on London’s public transport network, including black cabs, all contribute to mitigating any adverse impacts on families with young children, the elderly and the disabled. Officers have also taken into account the provisions of the European Convention on Human Rights in this context and it is not considered that Article 9 rights would be infringed by these proposals, but any restriction there may be would be proportionate and justified in pursuit of a legitimate aim in any event.

Colonel B - Against extending weekend parking hours For the reasons set out in the 9th May 2011 David M Cabinet report and within this Cabinet report, Tatlow TD. Concerned about how the extending parking hours will along with the extensive evidence base DL. affect his church congregation commissioned by the council, the introduction of controls and consequent charges during the proposed periods is considered justifiable. It should be noted that for other religions and faiths whose holy days fall on other days of the week when controls and charges apply, no exemptions are granted. The availability of public transport, the capacity of off street car parks during the evenings and on Sundays, the concessions offered to blue/white badge holders, the elderly and the disabled on London’s public transport network, including black cabs, all contribute to mitigating any adverse impacts on families with young children, the elderly and the disabled. Officers have also taken into account the provisions of the European Convention on Human Rights in this context and it is not considered that Article 9 rights would be infringed by these proposals,

18 but any restriction there may be would be proportionate and justified in pursuit of a legitimate aim in any event.

RESPONSES RECEIVED BETWEEN 24 JUN E – 28 JULY 2011 RESPONSES FROM BUSINESSES Business Name Date Comments Response received Caprice Jesus Adorno- 25/07/2011 I have been in this site for almost 30 years and I on There are many determinants that steer the Holdings S, Director hearing the news that Westminster City Council wants to performance of the capital’s economy such as start charging for parking on the streets after 6.30 on variable exchange rates, levels of disposable weekday evenings and also start charging on Sundays, I income, employment levels, the weather, retail OBJECT to this measure because clearly it will affect our trends etc. Unlike most other urban centres business overall. across the UK, parking is a marginal influence and in Westminster dependence on the private Would you kindly re-consider this measure and look for vehicle to reach retail centres is very low, i.e. other ways of saving money for Westminster City Council. 14% for combined car, motorcycle and powered two wheeler for trips as the main mode of transport in Westminster (based on an average 7 day week between 2006 and 2009 – source TfL 2010). Whereas for those who walk it is currently 38% and those on public transport it is 35%. Between 1996 and 2010 there has been a significant increase in the development of the core Central Activity Zone (CAZ) in Westminster that has led to a net increase of 792 thousand sqm of commercial and retail floor space and it is projected that this upward trend in the CAZ will continue. There will be major public transport schemes delivered over the next ten years including Crossrail scheme.

The parking proposals of the PPR therefore represent a minor influence on the West End economy given the availability of public

transport, the availability of parking spaces for visitors in off street car parks and on street paid for parking bays, and the concessions offered to blue/white badge holders in the evenings and at weekends. Extended parking controls are necessary because in parking Zones E, (F3 at weekends) and G all exceed recognised parking stress indicators. The proposed implementation of parking controls over this time would have the potential of increasing the turnover of parking stock on the street that would enable more visitors to park.

Staffords Stafford 22/07/2011 Please do not introduce parking charges on Sundays As a There are many determinants that steer the Gallery Crombie retailer in central London Staffords gallery 52 Charing performance of the capital’s economy such as cross road wc2h bob We have suffered since the variable exchange rates, levels of disposable congestion charge was introduced it would be a further income, employment levels, the weather, retail blow to small businesses if more people were put off trends etc. Unlike most other urban centres shopping in London. across the UK, parking is a marginal influence and in Westminster dependence on the private We are in a serious recession the council needs to focus vehicle to reach retail centres is very low, i.e. on supporting existing small businesses to prevent the 14% for combined car, motorcycle and loss to the capital of small independent shop keepers. powered two wheeler for trips as the main mode of transport in Westminster (based on an average 7 day week between 2006 and 2009 – source TfL 2010). Whereas for those who walk it is currently 38% and those on public transport it is 35%. Between 1996 and 2010 there has been a significant increase in the development of the core Central Activities Zone (CAZ) in Westminster that has led to a net increase of 792 thousand sqm of commercial and retail floorspace and it is projected that this upward trend in the CAZ will continue. There will be major public transport schemes

delivered over the next ten years that includes the Crossrail scheme (with stations to be located at Tottenham Court Road and Bond Street) that will increase public transport capacity by 30%. Other major improvements to the public transport network are also planned. The parking proposals of the PPR therefore represent a minor influence on the West End economy given the availability of public transport, the availability of parking spaces for visitors in off street car parks and on street paid for parking bays, and the concessions offered to blue/white badge holders in the evenings and at weekends. Extended parking controls are necessary because in parking Zones E, (F3 at weekends) and G all exceed recognised parking stress indicators. The proposed implementation of parking controls over this time would have the potential of increasing the turnover of parking stock on the street that would enable more visitors to park.

Montcalm Andrew de la 13/07/2011 I am the leasehold owner of The Montcalm Hotel, a Road traffic in the West End and Central Holdings Haye recently refurbished five star hotel which is situated in Westminster area has reached high levels so it Limited your ward. is the duty of the Council to introduce controls to mitigate this reality. The parking spaces in It has come to my attention that there are proposals to Zones E, (F3 at weekends) and G all exceed extend the parking restrictions in this area, both to recognised parking stress indicators. The Sundays and to later hours. Council’s comprehensive street by street 2011 Occupancy Survey identifies that overall in We wish to register objections to this proposal in the Zone E the weekday occupancy is 73%, on strongest terms as this will affect the operation of our Saturday evening it is 86% and on Sunday hotel. afternoon it is 84%. In Zone F3 on Saturday evening it is 65% and on Sunday afternoon it is Whilst we understand the need for parking restrictions 88%. In Zone G weekday evening occupancy

during the normal working week, the proposed extension is 71% on Saturday evening it is 81% and on of parking restrictions into the non-working week will have Sunday afternoon it is 92%. The standard a detrimental effect on our operational business and we parking stress levels the Council applies are if can see no advantages to the same, save the generation the recorded rate is >80% this means serious of additional parking fine revenues for the Council. deficiency and if it is 70-80% there is deficiency. Therefore in all three zones in Accordingly, I would strongly ask your Council to re- question there are serious parking occupancy consider the imposition of these charges. stress levels on all days including Sundays.

There is a legal obligation that any surplus income attained through DPP 1 and 2 should be re-invested back into the transportation and parking network of central London.

Addison Lee Selim 07/07/2011 Meeting held between Westminster Officer, the Deputy Noted. Choonara Cabinet Member for Parking and Transportation on 7 July 2011.

General support for draft policy proposals voiced and keen to work with the Council to develop these. RESPONSES FROM ORGANISATIONS

Organisation Name Date Comments Response received St James’s Brian 26/07/2011 1. The St James’s Conservation Trust was not informed 1. There was a major public consultation Stage Conservation Woodham by the City Council of either the first or second 1 between 22 November 2010 and 7 January Trust consultation on the proposed revised parking restrictions 2011. There has been media coverage, a in Zone E to extend Saturday parking charges up until printed item in the Westminster Reporter that midnight and to charge for parking on Sunday from mid- reaches all householders and the proposals day up until 18.30. It would have made its representation have been presented in 12 recent Westminster of this subject more completely and on time if it had been Area Forums. aware of the consultations but as it has only learnt of this proposal in the last few days, this is not possible. It is 2. If the proposals are agreed, residents will be also evident that a number of businesses and residents entitled to park free of charge in any paid for located within our Area of Benefit were unaware of these visitor parking bay during the extended hours

23 proposed changes as late as 25th July 2011. of control and also the last paid hour (5.30- 6.30pm). It is unsustainable to expect that free 2. It is of note that both the City Council’s and the Trust’s unrestricted parking can be available for policy is to encourage a larger residential population in St visitors to the heart of the West End given the James’s, drawing wealthier residents to the area. Inherent intense pressures on the kerb side and in this is the wish to be able to live a normal residential life anticipated growth in the economy. For those and to be able to invite visitors at weekends. Already, visitors who do not wish to use London’s public there are insufficient ‘free’ residents’ parking bays and transport system, parking will still be available charging for parking on Saturday evening and Sunday in paid for parking bays and in off street car afternoon will deter guests of residents from coming to St parks. Vehicles displaying a blue or white James’s. Having contacted several of our residents , this badge (for disabled people) will also be entitled is a very grave concern because they can only receive to park on the single yellow lines during the social visits at week -ends for the very reason that parking extended hours of control without charge. The is free. In addition, a number of art galleries will be Council is also considering introducing a visitor affected by these restrictions. Several owners of small scratch card scheme. However the feasibility of galleries make personal deliveries on Sundays because of introducing such a system is likely to depend the free parking and the bigger ones, such as Christies, on the availability of residents’ parking bays in have week-end events for the very reason that those that the area in question and this system will not be attend can readily find parking. suitable for all zones.

3. The Trust appreciates that the core area of St James’s 3. Noted. is a small part of Zone E and does not wish to comment on the effects of the proposal on areas outside its special 4. Road traffic in the West End and Central knowledge. However, the Trust is aware that numerous Westminster area has reached high levels so it businesses and residents are in Mayfair oppose the is the duty of the Council to introduce controls proposals. to mitigate this reality. The parking spaces in Zones E, (F3 at weekends) and G all exceed 4. The Trust has encountered no one, either a resident, or recognised parking stress indicators. The a business owner, either in St James’s or in Mayfair, who Council’s comprehensive street by street 2011 can see any reasons for these proposals. Indeed, the Occupancy Survey identifies that overall in Trust is left to assume that the impression given by the Zone E the weekday occupancy is 73%, on Council that these proposals are motivated to raise Saturday evening it is 86% and on Sunday money, is the correct one. If this is not, in fact, so, the afternoon it is 84%. In Zone F3 on Saturday Council should indicate what advantages are supposed to evening it is 65% and on Sunday afternoon it is ensue so that the argument can be tested in the trial 88%. In Zone G weekday evening occupancy period. If the motivation is, in fact, to raise funds for the is 71% on Saturday evening it is 81% and on

Council, then the Trust places on record that this is wrong Sunday afternoon it is 92%. The standard in principle and an abuse of the parking system which is parking stress levels the Council applies are if damaging to the areas concerned. the recorded rate is >80% this means serious deficiency and if it is 70-80% there is 5. Even if these proposals were to be given a trial period, deficiency. Therefore in all three zones in which, in the view of the Trust, they should not, 18 months question there are serious parking occupancy is too long for the area to endure this trial and the Trust stress levels on all days including Sundays. suggests that 6 months is long enough to prove the point. There is a legal obligation that any surplus income attained through DPP 1 and 2 should be re-invested back into the transportation and parking network of central London.

5. The Experimental Traffic Order (ETO) can run for up to 18 months. However, the Council could make this permanent after at least an uninterrupted 6 months, or end it sooner if necessary. Once the trial period has been completed, any representations received during this period must be collated, analysed & addressed and a report prepared for Cabinet upon which to make the appropriate decision(s).

London Roy Turner 20/07/2011 We do not have comments currently. However, we Noted. If the proposals are approved, Camden Borough of request that when you have developed specific proposals will be notified and kept informed of Camden we have the opportunity to comment on them and the developments. timescales that apply, especially in the context of our parking policy review that you may need to take into account. Chiltern Court Desmond Wall 20/07/2011 On 22nd June I wrote to the Parking Policy Review DPP 1 and 2 concern the experimental Resident’s Consultation - having attended the Summit meeting on 1st introduction of extended parking controls in Board June. zones E and G for weekdays, and additionally The key objection I registered was the proposed change at weekends in Zones F3 and F6, if approved in the time frame for the single yellow lines from the by Cabinet on 1 August 2011 and will have no

current 18.30 to much later possibly even midnight. direct consequence to the residents of Chiltern I drew attention to the Chiltern Court problem of our little 2 Court as the property is entirely within Zone minute set down and pick up box and how important the B10 that is outside of the boundary of the single yellow line free parking after hours is to us. zones that relate to the above proposed policies.

It is also advised that Mr Wall’s concern about proposed changes to nearby Zone F2 are allayed because again this zone is also outside of the boundary of the above proposed Parking Zones of DPP1 and 2.

With regard to Mr Wall’s concerns about the potential loss of the single yellow line provision in front of Chiltern Court it is advised that the complex highway authority and parking regulation in that part of Marylebone Road and Baker Street area indicates that those two roads in question are part of the Mayor’s Transport for London Road Network (TLRN) and that the ‘Station Approach’ forecourt area accessed from Marylebone Road that fronts the south side of Chiltern Court is private land and so outside of the Council’s responsibility for the enforcement of parking. It is presumed therefore that the private landowner has its own parking control on this particular stretch of kerbside. Regent Hall Major Ray 18/07/2011 As you will be aware, Regent Hall Salvation Army, along The council is aware of the concerns and Salvation Brown with other churches in Westminster, has recently found representations which various individuals, Army out about proposals to introduce parking charges on groups, businesses and institutions have made Sundays and weekday evenings. As currently proposed, in response to the parking policy consultation these changes will have an incredibly damaging impact on which we are currently embarked on. Whilst our church, as well as the other churches in Westminster, recognising that some bodies may only with the danger that some churches could be so hollowed recently have become aware of the proposals, I

26 out because of the change to parking policy, that they would urge that the consultation process has could cease to exist in their current form. This will affect been extensive and prolonged. We have tried not just the Sunday congregations at services but also the very hard to ensure the maximum awareness huge amount of social and community voluntary activity of the proposals across the city and I am glad undertaken by the churches across Westminster. that the churches and other faith groups have had the opportunity to take an active part – We want to put on record our profound disappointment at albeit in your view latterly - in the process. the consultation process undertaken by Westminster Council, which left the churches unaware of the proposed Thank you also for your comments on the changes until very recently. We feel, as an important matters of concern and your thoughts on their sector of the community, our concerns have not been potential resolution. considered adequately during this process. We have asked time and again that the Cabinet decision due for 1 The report to Cabinet on 1st August will August should be deferred to allow further discussions describe your concerns and your request for between the Council and the churches to reach a deferral will also be brought to the attention of satisfactory outcome for both parties. We understand the the Cabinet. The report will analyse and Council is unwilling to do this and therefore the churches evaluate the various concerns which we have have decided to mount a public campaign against the received. proposals, particularly as we have been offered no comfort that our concerns will be assessed fully and Your email is helpful in articulating some of the appropriate amendments made before the Cabinet options which you believe to be available. In decision is taken. If the Council’s proposals are regard to some of them, I would observe that implemented as they stand, there is a real danger that a) The essence of the scheme is to be hundreds of years of church activity in Westminster will be targeted, within administratively irrevocably damaged for the sake of a few months delay in defined parameters, and the policies the Council’s process. are not designed for city-wide application; We would ask that the request of the churches for a b) Timing will be considered; deferment is made known to the Cabinet on 1st August c) Church permit schemes in other parts and we are happy to provide formal representations to of the country are being looked at, explain our position. With just weeks to digest the although I would point out that the proposals, we have simply not had time to look fully at unique qualities of Westminster do alternative proposals. It is unclear to us whether the often render such schemes not Council has undertaken a thorough social, community and comparable to our context. economic impact assessment of the parking proposals. Indeed, if it had, we may well not have been in the To summarise:

27 situation we now find ourselves as these issues would • Your request for deferral will be have been discovered, and potential solutions developed, reported and we believe that the much earlier in the process. We think that it would be substance of the issues you raise will wrong for the Cabinet to make policy decisions when be covered in the report insufficient work has been done in looking at the impact of • We will undertake a thorough equalities them. impact assessment as we are legally required to do In our meeting on the 15th July, Councillor Rowley asked • Any mechanism for introduction of any us to suggest both alternative options and mitigating changes will be done under measures which could be taken to help the churches if the experimental orders which would allow parking proposals are pushed through against widespread for flexibility and assessment of impact concern from the community. We would, of course, like to before any permanent changes are have that conversation but would want to be able to do it made. (reply from CEX) before the Cabinet makes its decision on the wider policy. Anything else gives Westminster church members no confidence that our concerns are being taken seriously by the council. To date the only mitigation measure formally proposed by the Council to a number of church members who have written directly has been for them to park elsewhere and walk into church, which is both impractical and unsustainable. It also presupposes that the parking regulations will stay the same in various zones over the coming years which, given what has happened during this process, does not give us comfort.

While we remain unconvinced of the case for Sunday or evening parking restrictions, we do believe that, with the appropriate opportunity to work with you, there are options that can be developed that will both allow the Council to meet its statutory objectives whilst enabling the churches to continue to thrive in Westminster. However we will need some time to help you do this.

Other measures we would want to explore with the

Council include:

• Targeted application of parking restrictions in the evenings and Sundays only where there is actual congestion, rather than indiscriminate restrictions across areas E, F and G • Timing of when restrictions come into effect on Sundays to minimise impact on churches, if they were to be introduced at all • Development of a ‘church permit scheme’ – we are aware of other schemes in UK (e.g. Newcastle, Chatham, Hemel Hempstead etc.) where this has worked well and we would be keen to discuss this further • Imaginative exploration of other possibilities including wider use of underutilised resident parking areas on Sundays, bringing into use other off-street or private parking facilities.

As you can see from the above initial suggestions, we are trying to think creatively about alternative solutions to the Council’s issues that would still allow for a vibrant church community in Westminster. But given the time limitations on the time we have had available to help you explore these options as outlined above, we would ask that any decisions made at the Cabinet meeting on 1st August still leave open the opportunity to explore all options .

As we have told Councillor Rowley, we are currently taking legal advice on the consultation process undertaken by the Council, as well as engaging parking and transportation specialists to examine the actual policy case for the Sunday and evening restrictions. However, I am sure you will agree that it is in everyone’s best interests to find a solution to this problem collaboratively

and we are committed to that route if the Council will also commit to working with us in advance of making decisions that could close down options. So in summary, we ask that:

• Our request for a deferment is made known to the Cabinet on 1st August. • The Council undertakes a thorough social, community and economic impact assessment of the parking proposals, before decisions are taken by Cabinet. • Any decisions that are taken are framed to be sufficiently flexible to allow time for development of options to mitigate the effect on the churches.

Regent Hall Major Ray 10/07/2011 I wanted to write to you about a matter of some urgency to For the reasons set out in the 9th May 2011 Salvation Brown do with proposals to introduce parking charges in parts of Cabinet report and within this Cabinet report, Army Westminster on Sundays and in the evenings. I write on along with the extensive evidence base behalf of Regent Hall Salvation Army, a vibrant Christian commissioned by the council, the introduction Church on Oxford Street, with a strong ethos of serving of controls and consequent charges during the the local community, but the issue is important for all of proposed periods is considered justifiable. It the churches in the affected zones. I am seeking to should be noted that for other religions and engage our own ward councillors on this issue but know faiths whose holy days fall on other days of the that this has an impact across Westminster and given the week when controls and charges apply, no Council Cabinet has overall responsibility for this decision exemptions are granted. The availability of I wanted to make you aware of the situation. public transport, the capacity of off street car parks during the evenings and on Sundays, the Thousands of people travel from all over London each concessions offered to blue/white badge week, and many from outside the M25, to worship at holders, the elderly and the disabled on flagship churches in Westminster, such as Regent Hall London’s public transport network, including Salvation Army, including elderly people and young black cabs, all contribute to mitigating any families with children. Many of these people rely on their adverse impacts on families with young cars to get to the centre of London for early services, with children, the elderly and the disabled. Officers their family and meals for the day in tow. Many would have also taken into account the provisions of have great difficulty in accessing their church by public the European Convention on Human Rights in

30 transport. this context and it is not considered that Article 9 rights would be infringed by these proposals, For example, at Regent Hall Salvation Army, where we but any restriction there may be would be have a full day of activities on Sundays, families need to proportionate and justified in pursuit of a bring enough equipment and food to see them through up legitimate aim in any event. to eight hours , while many elderly members rely on lifts from other members to get to church. The structure of our There was a major public consultation Stage 1 Sunday, and the commitment required from members, between 22 November 2010 and 7 January especially those in the band or the choir, means that 2011. There has been media coverage, a parking on-street will just not be possible. Meters would printed item in the Westminster Reporter that not allow them to stay for 7+ hours, and even if they did reaches all householders and the proposals the cost would be prohibitive. We have worked out that have been presented in 12 recent Westminster the cost of parking for someone currently engaged in a Area Forums. Stage 2 had a ‘soft’ launch on number of activities at Regent Hall, in local car parks, 10th May 2011 and was formally launched on could top £100 per week, or nearly £4,000 per year for a 16th May 2011, closing on 23rd June 2011 heavily-involved family. (6.5 weeks). The council has accepted late responses. In order to ensure that a wide Like many Westminster churches, Regent Hall Salvation range of church, faith and religious groups Army has served the people of Westminster for more than were aware of the parking review the council’s 100 years, offering a place of spiritual and practical Faith Exchange (300+ members) contact respite. Regent Hall, in common with many of our fellow database was used to inform and disseminate churches, undertakes a significant amount of community information. On 20th May 2011 an e-bulletin and social work. At Regent Hall that is most clearly seen was sent to all members of the Exchange in 'Number 10', our drop-in centre for homeless people, informing them of the review and advising which offers advice and practical support to help people them that the deadline for responses was 23rd successfully move to a stable life off the streets. Our June 2011 (allowing five weeks to respond). church also offers a very low-cost cafe, subsidised by the At the request of the Cabinet Member for church membership, which caters for a wide range of Parking and Transportation on 14th June 2011 people but is particularly attractive to the elderly and low- a second e-bulletin reminder was sent to all paid because of its pricing. We also offer our rooms at 300+ members personally from the Cabinet very low cost to local community groups and organisations Member. This sought to ensure that all and contribute to the artistic health of the community by members of the faith Exchange had the running a series of musical concerts for the public on opportunity to comment on the draft policy Friday lunchtimes showcasing groups from London music proposals. colleges.

But the local outreach of Regent Hall Salvation Army church, as well as other churches in the City of Westminster, only exists because of the vibrancy of the worshipping community. A hollowing out of Regent Hall as a church would severely impact our ability to offer support to members of the public in Westminster, to the extent that we fear for our future.

Even though Regent Hall put forward a robust response to the last consultation on this issue in 2003, we were not contacted about the current proposals and only became aware of them following media coverage very late in the process. Indeed, it seems that none of the churches affected by these proposals were aware of them until the last 10 days. Given that, we do not believe that enough time has been given to groups materially affected by the decision to put forward their view to the Council, or for the Council to explain how they hope to mitigate the impact on such vital community organisations, and so we are calling for a halt in the process while this can be addressed.

Our position is not meant to be in any way directed at a particular person or political party. We just fear for our future as churches, with the inevitable knock on in reduced capacity to engage in our freely given, but personally costly, voluntary services to the community.

Religious Sr Amadeus 17/07/2011 We are greatly disturbed and ask you to reconsider the For the reasons set out in the 9th May 2011 Diocese of Bulger effect that Sunday Parking Charges will have on good Cabinet report and within this Cabinet report, Westminster citizens who value family life and lead lives of generous along with the extensive evidence base service to the community in so many ways. The lives of so commissioned by the council, the introduction many in Westminster who serve their community save of controls and consequent charges during the Westminster Council £thousands because of their proposed periods is considered justifiable. It voluntary care of their Christian communities. Thank you should be noted that for other religions and for your serious consideration of this. faiths whose holy days fall on other days of the

week when controls and charges apply, no exemptions are granted. The availability of public transport, the capacity of off street car parks during the evenings and on Sundays, the concessions offered to blue/white badge holders, the elderly and the disabled on London’s public transport network, including black cabs, all contribute to mitigating any adverse impacts on families with young children, the elderly and the disabled. Officers have also taken into account the provisions of the European Convention on Human Rights in this context and it is not considered that Article 9 rights would be infringed by these proposals, but any restriction there may be would be proportionate and justified in pursuit of a legitimate aim in any event. Churches Michael 12/07/2011 Covering Letter: a) There was a major public consultation Stage Together in Beckett a) I am writing on behalf of the thirteen churches present 1 between 22 November 2010 and 7 January Westminster this morning, with combined electoral rolls of just over 2011. There has been media coverage, a seven thousand worshippers. The public meeting last printed item in the Westminster Reporter that Thursday in St. George’s was attended by 253 people, reaches all householders and the proposals with representatives from twelve central London churches, have been presented in 12 recent Westminster many local residents and local businesses also present. Area Forums. Stage 2 began on 10th May The clear conclusion of the meeting was that none of the 2011 and was formally launched on 16th May churches, nor the business and residents had been aware 2011, closing on 23rd June 2011 (6.5 weeks). of the proposed Sunday charges until St George’s made The council has accepted late responses. In contact with them in early June, only a matter of a couple order to ensure that a wide range of church, of weeks before the consultation closed on the 23rd June, faith and religious groups were aware of the 2011. I accept and believe you sent out over fifty parking review the council’s Faith Exchange thousand e-mails as part of your consultation, but I would (300+ members) contact database was used to question to whom they were sent, and whether they inform and disseminate information. On 20th properly flagged up the potential changes. How user May 2011 an e-bulletin was sent to all friendly was the message in clearly identifying the members of the Exchange informing them of potential introduction of Sunday Charges? At St George’s the review and advising them that the deadline

33 we got a petition running (~2800 signatures so far), for responses was 23rd June 2011 (allowing involvement of the central London Churches, and the five weeks to respond). At the request of the public meeting set up; all by sending out about fifty e- Cabinet Member for Parking and mails in the first instance, and making a few telephone Transportation on 14th June 2011 a second e- calls. We believe the widespread public concern on this bulletin reminder was sent to all 300+ matter which we have uncovered has always been there, members personally from the Cabinet and a proper consultation would have brought these Member. This sought to ensure that all concerns to the fore. From this and other evidence we members of the faith Exchange had the consider the consultation process to have been flawed, opportunity to comment on the draft policy and that an extension of three months from the 1st proposals. August, to 1st November should be granted before any decision is made to allow for a wider and fuller The Council’s Head of Research and Customer consultation. The churches are willing to hold a local Insight was asked to comment on the statistical referendum in Mayfair, Soho and the southern part of validity of the Parking Consultation Exercise. Marylebone, to fully consult and measure the views of His conclusion was: “Overall the findings from residents, visitors and businesses. We would envisage the the consultation provide a valuable and robust Council being fully involved in this process, but at no cost insight into the views of people towards the to the Council. Parking Policy Review, but in working through the detail of the implementation there may be As a democratic council, and in the light of the recently some instances where opinion is finely published white paper on public services, such a balanced. In these cases closer attention referendum is exactly in line with David Cameron’s call for should be brought to understanding the views “localism” and to enable neighbourhoods to take control of of individual sub-groups (e.g. under 45 year planning and parking as detailed in the Open Public olds) as well as the overall figure.” Services White Paper section on Decentralisation. Representations are being made today to the Prime The Council has made a record of all late Minister’s office to see if we can gather their support for responses such as this, and the Cabinet such a measure. The Parking review is only undertaken Member for Parking and Transportation has every ten years or so, and a three month delay to ensure met with Churches Together in Westminster, so the right decisions are made is therefore not a lot to ask. is aware of its concerns, which will be taken As you are aware, the public meeting ended with a vote, into account in the decision making process. with 1 person in favour of the introduction of Sunday and An extension to the consultation period is extended evening controls, and 252 against. Although we therefore not considered to be necessary. would not claim the attendance to be a truly balanced representative audience, the 1 for, and 252 against, from b) Noted. See above. a sample of 253 is statistically significant out of a local

34 ward electorate of just over 5,000. I attach a summary of c) The churches’ voluntary and other the meeting that has been written for the Grosvenor community activities are acknowledged and Chapel magazine, although not the official minute of the welcomed. However, no parking exemptions meeting, it nevertheless gives a flavour of the meeting. are given to workers in other voluntary organisations across the City of Westminster b) Judicial Review : for the reasons outlined in the Cabinet Member The Churches do not wish to engage in legal proceedings report and below. unless it becomes absolutely necessary, but we believe so strongly in this matter, that should the council proceed 1) For the reasons set out in the 9th May 2011 with making a decision on the 1stAugust, and not grant a Cabinet report and within this Cabinet report, three month delay, we would have to seek Judicial review along with the extensive evidence base of any such decision on the basis that the consultation commissioned by the council, the introduction process was deficient. We understand the Council’s legal of controls and consequent charges during the right to take the decision, but only after due process and proposed periods is considered justifiable. It good practice have been followed, and we do not believe should be noted that for other religions and this has been the case to date. faiths whose holy days fall on other days of the week when controls and charges apply, no c) The Big Society exemptions are granted. The availability of The Church is the single largest channel of charitable public transport, the capacity of off street car giving and action in the UK. It has unparalleled experience parks during the evenings and on Sundays, the in volunteering activity and advocacy. It is very aware of concessions offered to blue/white badge needs in the society immediately around it, and also of the holders, the elderly and the disabled on needs of the wider world. It thinks locally and globally. London’s public transport network, including Every church in Westminster has its own volunteering black cabs, all contribute to mitigating any programme. So for instance, at a time when we are adverse impacts on families with young especially challenged as a society by the needs of our children, the elderly and the disabled. Officers elderly people, many churches are already actively have also taken into account the provisions of engaged on this front. This is an area – and there are the European Convention on Human Rights in many others – where we can and do work together with this context and it is not considered that Article Westminster Council on a common agenda, but this a 9 rights would be infringed by these proposals, demographic that would be hard hit by the loss of private but any restriction there may be would be transport. proportionate and justified in pursuit of a Taken together the Christian churches comprise the legitimate aim in any event. largest voluntary body in the UK. Their members come together, ultimately, to build a better society. Their Sunday The PPR has identified that the City of gatherings provide the spiritual formation that underpins Westminster is a diverse settlement where

35 their volunteering activities with an emphasis on love of parking controls in different areas need to be neighbour, self-sacrifice, and service to the poor and the different to meet the demands of communities. marginalised. In this way, the Church is of major benefit to DPP 5 seeks to introduce a mechanism to society and represents irreplaceable social capital. What permit the review of individual parking zones. society in today's world could afford not to support such a The mechanism includes the principle of local group? consultation and careful evaluation of whether In particular the Church goes out of its way in training an amended zone is required or not. However, young people in civic values, and in the practice of putting It will not be influenced by the position of a people first, ahead of other considerations. It strengthens minority of concerned individuals alone. This is the bonds of community and family life. It very actively in line with the localism bill. fosters good interfaith relations, and good relations generally with all people. The congregations themselves 1) Road traffic in the West End and Central are ethnically and socially highly diverse and Westminster area has reached high levels so it intergenerational. is the duty of the Council to introduce controls The cumulative social outreach of all the churches in to mitigate this reality. The parking spaces in Westminster must be amongst the largest (if not the Zones E, (F3 at weekends) and G all exceed largest) of any local authority within the UK. The Salvation recognised parking stress indicators. The Army in Regent Hall, Oxford Street does such good work Council’s comprehensive street by street 2011 with the homeless and disadvantaged around Oxford Occupancy Survey identifies that overall in Circus, but without their vibrant and supportive Zone E the weekday occupancy is 73%, on congregations on a Sunday this will all be put in jeopardy. Saturday evening it is 86% and on Sunday A similar case may be made for St Martin in the Field, afternoon it is 84%. In Zone F3 on Saturday Farm Street, All Soul’s, All Saint’s, St George’s Hanover evening it is 65% and on Sunday afternoon it is Square, and many, many more churches in the West End. 88%. In Zone G weekday evening occupancy We estimate the total social outreach of Westminster is 71% on Saturday evening it is 81% and on churches to be in excess of ten million pounds per annum. Sunday afternoon it is 92%. The standard Does the Council really wish to put at risk this contribution parking stress levels the Council applies are if to our city? the recorded rate is >80% this means serious deficiency and if it is 70-80% there is Conclusion deficiency. Therefore in all three zones in The Churches have not all come together just to be question there are serious parking occupancy difficult. We passionately believe that should Westminster stress levels on all days including Sundays. Council impose Sunday parking charges, it will be a death The proposed hours of control have been set to knell for some churches, and seriously reduce the ability coincide with these levels. of others to operate successfully and viably, and to continue their present levels of support within the city – 2/3) See response c) above.

36 something that is perhaps going to be even more necessary in these difficult times. 4) the council’s proposals do not prevent or take away an individual’s ‘freedom’ to visit friends and family and to support a church Position statement: community. Officers have taken into account the provisions of the European Convention on This note summarises concerns raised by churches Human Rights in this context. Under Article 9 across Westminster in response to Westminster Council’s of the Convention, which is enforceable in law current proposals for Sunday parking restrictions. We by virtue of the Human Rights Act 1998, would like to start by thanking the Council for all its work everyone has the right to freedom of thought, on behalf of the community, and by acknowledging the conscience and religion; this right includes the effort that has gone into Parking Review 2010/11. We freedom to manifest one’s religion, in public or wish to assist the Council in meeting its statutory private, alone or in community with others obligations regarding traffic and parking in the borough. These freedoms are subject only to such We hope the following comments will be seen as a restrictions as are prescribed by law and which constructive contribution to the discussion and that a way are necessary in a democratic society in the forward can be found that benefits all parties. interests of public safety, for the protection of public order, health or morals, or for the (1) Effects of Sunday parking charges on church protection of the rights and freedoms of others. communities It is not considered Article 9 rights would be For city-centre churches, because our congregations infringed by these proposals, but any come from outside, the effects of Sunday parking charges restriction there may be would be would be extremely serious. In order to build up and proportionate and justified in pursuit of a sustain our church communities we need freedom of legitimate aim in any event. movement. All our churches would be badly damaged by the current parking proposals, and some would be 5) Noted. See above. devastated. Church-goers who are particularly vulnerable include families with young children, the elderly and anyone who needs a lift. In particular, the proposal would 6) Noted. See response a) above. discriminate seriously against anyone on a low or even moderate income. 7) The Canterbury Worshippers Permit scheme is available to residents of Canterbury District (2) The community dimension: the social benefit of the and to Quakers resident in Swale District. It Church in the context of civil society. Taken together the allows them to park without charge when Christian churches comprise the largest voluntary body in attending, on a regular basis, a service of the UK. Their members come together, ultimately, to build worship on any day in an off street car park.

37 a better society. Their Sunday gatherings provide the Given that the vast majority of churchgoers in spiritual formation that underpins their volunteering Westminster are not Westminster residents’ activities with an emphasis on love of neighbour, self- they would not qualify for such a permit on sacrifice, and service to the poor and the marginalised. In these lines. Furthermore, the Worshippers this way, the Church is of major benefit to society and Scheme is an off-street scheme not on-street. represents irreplaceable social capital. What society in today’s world could afford not to support such a group? The purpose of the Experimental Traffic Order In particular the Church goes out of its way in training (ETO) is to allow those affected by the council’s young people in civic values, and in the practice of putting proposals to comment or object so that the people first, ahead of other considerations. It strengthens council can consider these prior to deciding the bonds of community and family life. It very actively whether to make the ETO permanent. Splitting fosters good interfaith relations, and good relations of the zones effected and the impact on traffic generally with all people. The congregations themselves flows and traffic numbers will all be considered are ethnically and socially highly diverse and as part of that process. intergenerational. 8) The Council will be developing a (3) The Church as a source of charitable giving and methodology for monitoring the impacts of any action. The Church is the single largest channel of proposals that are implemented. If DPP1 and 2 charitable giving and action in the UK. It has unparalleled are implemented, parking occupancy data will experience in volunteering activity and advocacy. It is very be key to this process. The Council is open to aware of needs in the society immediately around it, and ideas on how the church or others may be able also of the needs of the wider world. It thinks locally and to assist with additional data gathering. globally. Every church in Westminster has its own volunteering programme. So for instance, at a time when The ETO can run for up to 18 months. we are especially challenged as a society by the needs of However, the Council could make this our elderly people, many churches are already actively permanent after at least an uninterrupted 6 engaged on this front. This is an area – and there are months, or end it sooner if necessary. Once the many others – where we can and do work together with trial period has been completed, any Westminster Council on a common agenda, but this a representations received during this period demographic that would be hard hit by the loss of private must be collated, analysed & addressed and a transport. report prepared for Cabinet upon which to make the appropriate decision(s). (4) Sunday: a day of freedom and of rest Every culture has a day set aside for rest and for freedom from the claims of commerce and the state. This is a necessary space for any healthy society. For historic

38 reasons, Sunday is the day set aside in our country, and people consider this to be part of their way of life. On that day there is freedom to rest, to visit friends and family – and to support a church community. This is a freedom we have inherited and we should not destroy it. We are confident that other faiths would support us in defending this special day as we would defend the right of any society to such a day within their culture.

(5) Potential adverse effects on Westminster Council • a political backlash - thousands of voters would be alienated • negative publicity in press and media • an adverse effect on interfaith relationships – churches would feel they were being discriminated against • a public perception that the Council had acted unfairly – reinforced by the lack of proper communication and consultation with churches and also by the unfortunate timing of the proposal to coincide with summer holidays and the speed with which it is being rushed through the decision-making process • a public perception that the Council was unmindful of the human consequences of its pragmatic decisions • this proposal from a Conservative council would in particular be seen as a contradiction of the principles of the “Big Society” and also the recent White Paper proposals for a shift to localism, including parking issues - the churches of Westminster have many active and motivated Conservative voters

(6) An immediate proposal: A three-month extension of the consultation. We respect the integrity of Westminster Council and its professionalism but there is near- unanimous opinion among the churches that the notification process for this consultation was deficient.

(7) Practical suggestions for the experiment • flexibility regarding the hours for proposed restrictions • a “permit system” such as is available in other boroughs, e.g. Canterbury: http://www.canterbury.gov.uk/main.cfm?objectid=542i • a more reasonable and tailored sectioning of the zones, taking account of the reality of parking needs and the traffic flow in particular areas on Sundays – not a “one size fits all” approach.

(8) Monitoring the experiment: some issues • what part the churches will be playing in the monitoring of the results – how collaboratively is the Council prepared to work on that front? • how the Council will measure and assess the extent to which the parking measures meet their stated objectives; • the extent to which the measures lead to adverse social or other impacts, some of which may be unforeseen; • what criteria will be used in making recommendations to the Council at the end of the experimental period. Covent Andy Hicks 24/06/2011 Covent Garden London (CGL) welcome the opportunity to Support for extended hours of control noted. Garden comment on the City Council’s second draft Westminster London Parking Policy Review. We are committed to being a It is recognised that the many and varied late responsible landowner and as part of our stewardship of night leisure and entertainment venues across the Covent Garden district ensuring that car parking central London contribute much to its unique pressures are managed appropriately by the City Council. character and offer. The Council advises that the industry in question en-bloc or individual Covent Garden, more than other locations, is a hugely employees approach the secure off-street car complex area featuring a mix of commercial activities and park providers who are very interested to residential dwellings with different parking/ servicing negotiate tailor made discount schemes that demands on narrow congested streets during the daytime suit the needs and lower incomes of such and evenings. workers which would be significantly less than the cost of parking on-street. An example of The CGL Estate covers an area from Long Acre to the such a concession scheme is already in place north, Wellington Street to the east, Garrick Street to the in Westminster where a car park charges

40 west and Southampton Street to the south. The Central Casino employees £5 per night to park. Market Building and The Piazza are at the heart of the Estate. This area falls entirely within the City Council’s Unlike most other urban centres across the UK, Parking Zone G1 where the controlled parking within Zone parking is a marginal influence and in G are medium/longer term policies 1, 2 and 7. Westminster dependence on the private vehicle to reach retail centres is very low, i.e. Policies 1 and 2 seek to extend controls and charges in 14% for combined car, motorcycle and Zone G after 6.30pm on weekdays and on Saturdays and powered two wheeler for trips as the main Sundays in order to reduce the number of non-residents mode of transport in Westminster (based on an parking in the area. Demand for car parking provision in average 7 day week between 2006 and 2009 – the area is high due to the number of people living in the source TfL 2010). Whereas for those who walk area and Covent Garden’s role as an international it is currently 38% and those on public shopping and tourist centre which plays host to a transport it is 35%. There will be major public multitude of evening activities including the Royal Opera transport schemes delivered over the next ten House, several theatres and a host of other entertainment years that includes the Crossrail scheme (with uses. This particularly provides strain on spaces after stations to be located at Tottenham Court Road 6.30pm on weekdays and on weekends when parking is and Bond Street) that will increase public unrestricted. transport capacity by 30%. Other major improvements to the public transport network One of CGL’s objectives for the area includes increasing are also planned. The parking proposals of the housing provision on the upper floors of buildings across PPR therefore represent a minor influence on the Estate; therefore it is important that car parking is the West End economy given the availability of managed appropriately. Extending the control hours would public transport, the availability of parking mean that the car parking spaces could only be used by spaces for visitors in off street car parks and on residential permit holders for longer periods. CGL support street paid for parking bays, and the this change in certain ways as we consider that residential concessions offered to blue/white badge parking is important and that parking spaces for residents holders in the evenings and at weekends. should be protected. CGL do consider that concessions Extended parking controls are necessary should apply for Blue Badge holders. because in parking Zones E, (F3 at weekends) and G all exceed recognised parking stress However, one very important consideration is staff indicators. The proposed implementation of working in commercial and entertainment premises who parking controls over this time would have the park in the district because they leave work after midnight potential of increasing the turnover of parking at very unsociable hours. Penalizing these more low paid stock on the street that would enable more workers will be detrimental to their incomes, discourage visitors to park. flexible working arrangements and drive up prices in the

West End. This is not appropriate and any charging Policy 7 – noted, this will need to be assessed should be minimal. on a case by case basis depending on parking demands in the area. It is more likely that paid Although we support the principle of changing the control for parking bays would be shared with loading and charging hours within Zone G more information is areas, with loading permitted in the early needed on how this would be managed and enforced in morning when demand for visitor parking is practice. CGL are concerned that if there is to be charging lower. for non residential users that this is not at a high cost which could undermine the attractiveness of Covent The Council is happy to arrange a meeting to Garden to visitors compared to other areas. discuss transportation and parking matters further. Policy 7 intends to improve loading and servicing provision in Zone G by designating ‘shared use’ loading bays during out of hours periods. CGL acknowledge that there is a conflict between car parking spaces for residential occupiers and delivery vehicles with in the tight urban environment of Covent Garden and the surrounding area. However CGL consider that residential parking should take priority and as such these should not be compromised by the introduction of ‘shared use’ bays.

We are interested in the detail of how these new policies would work in practice and how they would be enforced, particularly give n CGL’s increased role in management of the Estate and would be very keen to arrange a meeting with both Councillors and Officers to discuss further.

Heart of Debra Karim 30/06/2011 Covering email received but no attachment London Business Alliance Grosvenor Rosalind 28/06/2011 I am Vice Chairman of Grosvenor Chapel and, as For the reasons set out in the 9th May 2011 Chapel Abrahams discussed with you and Councillor Burbridge, Lord Mayor Cabinet report and within this Cabinet report, of Westminster, the Grosvenor Chapel community is most along with the extensive evidence base concerned to learn about the proposals to charge for commissioned by the council, the introduction

Sunday parking in Mayfair. We have sent a petition signed of controls and consequent charges during the by members of the congregation of the Grosvenor Chapel proposed periods is considered justifiable. It requesting that the Council does not introduce parking should be noted that for other religions and restrictions and charges on Sundays. faiths whose holy days fall on other days of the week when controls and charges apply, no Although located in South Audley Street, only 10% of our exemptions are granted. The availability of congregation live in the immediate area and so the public transport, the capacity of off street car overwhelming majority have to travel to their chosen place parks during the evenings and on Sundays, the of worship. concessions offered to blue/white badge holders, the elderly and the disabled on With restricted public transport on Sundays there is no London’s public transport network, including option for most but to find their own transport, particularly black cabs, all contribute to mitigating any for the elderly. adverse impacts on families with young children, the elderly and the disabled. Officers As a result, the restriction of parking will obviously have a have also taken into account the provisions of detrimental impact and reduce the ability of people to their the European Convention on Human Rights in right of worship, a position that the original Act, The this context and it is not considered that Article Sunday Trading Act 1994, was at pains to ensure would 9 rights would be infringed by these proposals, not be compromised. but any restriction there may be would be proportionate and justified in pursuit of a To restrict the numbers able to attend the Grosvenor legitimate aim in any event. Chapel will reduce the quality of life of many Londoners, reducing their spiritual and social life at a time when we Easing congestion in the West End not only are all being encouraged to increase our social benefits those wishing to access the area by responsibility. This may also have a significant impact on car, but also by bus, bicycle and on foot. the finances for a self supporting church such as the Pedestrians and cyclists in particular suffer Grosvenor Chapel, if the result is reduced numbers able from poor air quality arising as a result of to attend Sunday service. congestion. Also, cars parking on single yellow lines sometimes obstruct cycle lanes. This seems a terrible price to pay just to allow a few from elsewhere to drive down South Audley Street a little more quickly.

RESPONSES FROM WORKER S

Name Date Comments Response received Luca Maurantonio 20/07/2011 I was just amazed at the proposal of introducing parking charges Road traffic in the West End and Central in Westminster on a Sunday. Sunday is all about celebrating the Westminster area has reached high levels so it is day of God. I do some volunteering jobs in central London helping the duty of the Council to introduce controls to old people with their shopping or helping the sick by doing home mitigate this reality. The parking spaces in Zones E, visits. Sunday is the day to catch up with friends, to go to Church, (F3 at weekends) and G all exceed recognised to go shopping, to have a roast out. What you are doing is simply parking stress indicators. The Council’s killing all of this and why??? Traffic in London on a Sunday is not comprehensive street by street 2011 Occupancy as bad as it is on a Saturday or weekdays when parking charges Survey identifies that overall in Zone E the weekday do apply. Meaning that traffic charges don’t necessarily stop occupancy is 73%, on Saturday evening it is 86% people especially rich people from driving. However it will affect and on Sunday afternoon it is 84%. In Zone F3 on like always the olds, and the poor. I find your proposal will not do Saturday evening it is 65% and on Sunday anything to traffic , destroy people’s networks, and affect local afternoon it is 88%. In Zone G weekday evening businesses. What you said about local residents is not true since occupancy is 71% on Saturday evening it is 81% a lot of areas in Westminster do have bays reserved for local and on Sunday afternoon it is 92%. The standard residents already. I am demanding as a British citizen to parking stress levels the Council applies are if the reconsider your proposal before making a final decision in August. recorded rate is >80% this means serious deficiency and if it is 70-80% there is deficiency. Therefore in all three zones in question there are serious parking occupancy stress levels on all days including Sundays.

other days of the week when controls and charges apply, no exemptions are granted. The availability of public transport, the capacity of off street car parks during the evenings and on Sundays, the concessions offered to blue/white badge holders, the elderly and the disabled on London’s public transport network, including black cabs, all contribute to mitigating any adverse impacts on families with young children, the elderly and the disabled. Officers have also taken into account the provisions of the European Convention on Human Rights in this context and it is not considered that Article 9 rights would be infringed by these proposals, but any restriction there may be would be proportionate and justified in pursuit of a legitimate aim in any event.

Florante Almoza 14/07/2011 I am an employee within the casino sector employed in There is a full range of late night workers who Westminster and wish to register my strong objection to any currently make use of unrestricted on-street parking extension of existing parking control hours, preferring instead that space across the West End and the wider Central parking charges and congestion charging in the evening remain Activity Zone in Westminster. For example, whilst synchronised within Westminster. the Council fully understands the concerns of the estimated 1,656 employees of the Casino industry The casino sector is an important part of the night time economy who work within or near Parking Zones E and G, it in Westminster and employs approximately 3000 staff. would be inappropriate and possibly illegal to grant a workers permit concession to one sector of the Via our trade association, the National Casino industry Forum business community over and above all others (NCiF), I understand that a staff survey and financial impact where public transport or some other sustainable assessment was undertaken in three different casinos within the transport solution is less viable. Even if the Council Westminster area. I understand that contrary to the limited survey were to grant a worker permit to all eligible late undertaken by Westminster City Council of 905 respondents, our night employees (under an equitable and own findings clearly indicated that staff had no difficulty in finding transparent qualification criteria), there would be parking spaces in the evening during their core business hours of thousands of viable applicants and the reality is 7pm to 4am. that there is simply not enough kerbside space to accommodate all such vehicles in an already

The NCiF survey also demonstrated that casino staff have little or congested West End. Instead the Council advises no option to use their personal car as a primary means of that the late night economy industry en-bloc or transport. The Westminster survey registered only a 25% car individual employees should consider approaching journey rate whereas the NCiF survey noted a 55% car journey the secure off-street car park providers who are rate. very interested to negotiate tailor made discount schemes that suit the needs and lower incomes of The NCiF survey noted the following other key points:- such workers which would be significantly less than - That staff would revert to public transport where available the cost of parking on-street. An example of such a but most found this unsuitable for the majority of their concession scheme is already in place in journey. Westminster where a car park charges Casino - Existing parking costs were already a major factor employees £5 per night to park. - Lack of night service public transport options for casino personnel, particularly those living long distances. - Safety concerns on public transport in the early hours, particularly for lone females. - Average return car journey distance was 53 miles, significantly higher than the Westminster survey. - Length of time that public transport takes compared to car travel, particularly relevant to night time working with childcare issues (23% of personnel).

It is our contention that these proposals by Westminster City Council could have a disastrous and irrecoverable impact on the financial viability of the night time economy in The West End. Furthermore that WCC have utterly failed to adequately consult those most negatively affected by these proposals; i.e. those working in the night time economy and finally that these proposals make absolutely no provision for those that have little choice but to drive in to the West End. Pauel Androuies 14/07/2011 Response identical to the above As above

Francis 14/07/2011 As above As above Akraninwan

Piero Ballarini 14/07/2011 As above As above

Justinas 14/07/2011 As above As above Banikonis

Anita Bobko- 14/07/2011 As above As above Bemett

Julio Butta Matos 14/07/2011 As above As above

Andrew 14/07/2011 As above As above Edinburgh

Mazek Friodez 14/07/2011 As above As above

Jo Hollis 14/07/2011 As above As above

Petr 14/07/2011 As above As above Honigschmied

Romas Klouee 14/07/2011 As above As above

Chris Kourtellaris 14/07/2011 As above As above

Titiomo Lenti 14/07/2011 As above As above

Ondrej Mensik 14/07/2011 As above As above

Sladeckova 14/07/2011 As above As above SImona

John Sinclair 14/07/2011 As above As above

Lalita Taoja 14/07/2011 As above As above

C Torrance 14/07/2011 As above As above

Michael Truka 14/07/2011 As above As above

Vaida Valionyte 14/07/2011 As above As above

Adrian Yang 14/07/2011 As above As above

RESPONSES FROM INDIVIDUAL S

Name Date Comments Response received The Rt Revd & Rt 06/07/2011 I do not wish to rehearse again the various arguments for and For the reasons set out in the 9th May 2011 Hon Richard against the proposal nor enter the public debate about supposed Cabinet report and within this Cabinet report, along Chartres motives of Westminster City Council. with the extensive evidence base commissioned by the council, the introduction of controls and Simply, I have a pastoral concern that whatever its intention, as it consequent charges during the proposed periods is is presently formulated, the legislation will be detrimental to the considered justifiable. It should be noted that for parishioners who have met Sunday by Sunday in our parish other religions and faiths whose holy days fall on churches for hundreds of years. As you know, the 1994 Sunday other days of the week when controls and charges Trading Act was formulated to protect those who wished to attend apply, no exemptions are granted. The availability worship, and the last figures I saw for Westminster showed that of public transport, the capacity of off street car about 15,000 attend churches of all denominations on a Sunday. parks during the evenings and on Sundays, the concessions offered to blue/white badge holders, I do hope that some imaginative compromise can be agreed with the elderly and the disabled on London’s public the local churches that will allay their very genuine feats that the transport network, including black cabs, all Council’s actions will be prove a strong disincentive for those contribute to mitigating any adverse impacts on wishing to attend their central London churches – those very families with young children, the elderly and the churches which contribute so much to the stability, sense of disabled. Officers have also taken into account the history and pastoral care of the community they serve. provisions of the European Convention on Human

Rights in this context and it is not considered that Article 9 rights would be infringed by these proposals, but any restriction there may be would be proportionate and justified in pursuit of a legitimate aim in any event.

The Sunday Trading Act 1994 was introduced to reform the law relating to Sunday trading, and to make provision for the rights of shop workers in relation to Sunday working. The Act repealed the Shops Act 1950, under which Sunday trading was generally prohibited. Under the 1994 Act shops are permitted to trade on Sunday, but larger stores may open only for a maximum of six hours, between 10am and 6pm. Save that the Act permitted shopping on a Sunday, which is a relevant part of the background to these policy proposals, it is not directly relevant to the question of whether or not Sunday parking controls should be introduced.

Howard Brecker 04/07/2011 We would like to add our voice to the President of the Western For the reasons set out in the 9th May 2011 Marble Arch Synagogue to register our objection to the proposals Cabinet report and within this Cabinet report, along to extend the parking restrictions in the area both to Sundays and with the extensive evidence base commissioned by later hours. the council, the introduction of controls and consequent charges during the proposed periods is There are many weddings and functions on a Sunday and even considered justifiable. It should be noted that for with four hour parking bays it is not always possible to leave other religions and faiths whose holy days fall on proceedings to move ones car. other days of the week when controls and charges apply, no exemptions are granted. The availability It is hard enough to park even without restrictions and this would of public transport, the capacity of off street car make it nigh impossible. parks during the evenings and on Sundays, the concessions offered to blue/white badge holders, I trust you will take these inconveniences into consideration when the elderly and the disabled on London’s public making your final decisions. transport network, including black cabs, all contribute to mitigating any adverse impacts on families with young children, the elderly and the

50 disabled. Officers have also taken into account the provisions of the European Convention on Human Rights in this context and it is not considered that Article 9 rights would be infringed by these proposals, but any restriction there may be would be proportionate and justified in pursuit of a legitimate aim in any event.

F J R Elton Letter dated I am writing to give you some views on the parking difficulties It is recognised that there are many households in 20/06/11, but around my house. There are eight houses WITHOUT a drive or Westminster that own more than one car, which not received parking area, one of which is mine. Most of the other residents puts significant pressure on residents parking bays. by Council seem to have at LEAST three cars and, as a result they park in Under DPP 4 the Council proposes to increase the until after the road as well. price for second and subsequent residents permits consultation by 100% to encourage households to give up their deadline had This makes it difficult for my wife (with our one car) to find additional vehicles in favour of using public closed. somewhere to park our car, which means that I have to stay transport or walking / cycling more. This is an propped up against a wall, while she collects the car. approach that is used in other boroughs.

Also, if we have visitors, they often have to park a long way away DPP 6 considers the potential for a scratch-card or are forced to come by other means to avoid any parking system to be introduced for those visiting problems. Westminster residents. This is successfully used in some other boroughs. However the feasibility of The parking situation is a nightmare. Anything that the Council such a system will vary from one parking zone to can do to alleviate the problem will be greatly appreciated, as well the next, and is likely to be dependent on the as a parking restricted slot outside our house, for our car. availability of residents and visitor parking bays. Where pressure on residents’ bays is already high, such as in Mr Elton’s area, it may not be feasible to permit visitors with a scratch-card to also use resident bays. Visitors should be encouraged to come by alternative modes to the car wherever possible.

ONLINE RESPONSES Name Date Comments Response received Ian Jeffery 27/07/2011 I am aware that on 1st August the Council will be voting on the For the reasons set out in the 9th May 2011 proposals to introduce car parking charges on a Sunday and week Cabinet report and within this Cabinet report, along day evenings. with the extensive evidence base commissioned by the council, the introduction of controls and I am a member of the Salvation Army and worship at our church consequent charges during the proposed periods is on Oxford Street. Clearly the implementation of Sunday parking considered justifiable. It should be noted that for charges will have a significant impact on the size of our other religions and faiths whose holy days fall on congregation. other days of the week when controls and charges apply, no exemptions are granted. The availability Our congregation covers all age ranges and is drawn from all of public transport, the capacity of off street car areas of London. Using public transport would not be a practical parks during the evenings and on Sundays, the alternative for many of these people, especially as there is concessions offered to blue/white badge holders, significant disruption most weekends because of engineering the elderly and the disabled on London’s public works on both main line routes and London Underground. Indeed transport network, including black cabs, all there should be no expectation of reliable public transport on a contribute to mitigating any adverse impacts on Sunday as it is my understanding that London Underground only families with young children, the elderly and the commits to provide a week day service in order to enable repair/ disabled. Officers have also taken into account the upgrade work to be carried out at weekends. provisions of the European Convention on Human Rights in this context and it is not considered that My main concern is that if the Sunday congregation reduces in Article 9 rights would be infringed by these size the Salvation Army will no longer be able to sustain a proposals, but any restriction there may be would presence in the West End. This would obviously have a direct be proportionate and justified in pursuit of a impact on the Council as the Salvation Army is active in the area legitimate aim in any event. seven days a week.

I understand that Mr Rowley has been talking to Salvation Army representatives about the impact on our work should the charges go through, so I am sure you are well briefed on the points under discussion.

Rather than reiterating these points I would like to draw your attention to the press release dated 7th September 2010 detailing

your speech ‘Turning the Big Society into Reality’

I would ask you to re-read your words in the context of the current proposals for car parking charges.

You will see that The Salvation Army and other City Centre churches and their congregations are the very organisations and people you want to mobilise to achieve the ‘Big Society’.

We are ahead of the game; we are the Big Society in action (and, in the case of The Salvation Army, have been for nearly 150 years). I would suggest, especially at this time of austerity, we are the type of organisation that you would wish to support as we try to enhance the life chances of those living and working in the West End.

I would ask you to re-think this proposal as it is going to generate outcomes which I don’t think have been foreseen by those proposing the parking charges.

1st August is going to be a crucial day as it will redefine what Westminster wants from its community; does it want to destroy organisations which bring a massive amount to the area or will it listen to the arguments being put forward by these organisations and revisit and refine the proposals?

Ian Douglas 21/07/2011 I read with interest about objections to the proposed introduction Noted. Many paid for parking bays within of paid Sunday parking in Westminster. The BBC report quoted Westminster already have time limits on the length Cllr Lee Rowley, who rightly wanted to make it easier to find of time a person is permitted to park there, with ‘no parking spaces in the evenings and on Sundays. return’ restrictions also in place.

Clearly imposing parking charges at those times is bound to A ban on all non residents is not something that is discourage many people from driving into Westminster. There are, felt to be necessary or desirable. Visitors may still however, other ways that would be just as effective, such as an park in paid for parking bays or in Council car equivalent to Stop and Shop? I.e. limiting the time that a vehicle parks. The Council has already explored all options

54 can be parked, and not allowing it to return within a set time. With and DPP 1 and 2 are considered to be the best suitable time limits, this should work well in the neighbourhood of proposals for the West End at the current time. most churches. Alternatively, imposing a total ban on non- residents? Cars for one hour on a Sunday afternoon would mean For the reasons set out in the 9th May 2011 that non residents could not park all day. Cabinet report and within this Cabinet report, along with the extensive evidence base commissioned by I am sure there are various other possibilities, and I would the council, the introduction of controls and encourage the Council to investigate them thoroughly before consequent charges during the proposed periods is imposing charges that are likely to have a negative effect on considered justifiable. It should be noted that for churches and their congregations, as well as on local shops. other religions and faiths whose holy days fall on other days of the week when controls and charges apply, no exemptions are granted. The availability of public transport, the capacity of off street car parks during the evenings and on Sundays, the concessions offered to blue/white badge holders, the elderly and the disabled on London’s public transport network, including black cabs, all contribute to mitigating any adverse impacts on families with young children, the elderly and the disabled. Officers have also taken into account the provisions of the European Convention on Human Rights in this context and it is not considered that Article 9 rights would be infringed by these proposals, but any restriction there may be would be proportionate and justified in pursuit of a legitimate aim in any event.

Steven Taylor 20/07/2011 I just saw you on the BBC London News, with regard to parking This is not the only reason for proposals DPP 1 and charges on Sunday. 2. Road traffic in the West End and Central Westminster area has reached high levels so it is You made an argument in relation to people parking, blocking the duty of the Council to introduce controls to spaces from Friday evening to Monday morning. mitigate this reality. The parking spaces in Zones E, (F3 at weekends) and G all exceed recognised If that is a problem, then might I suggest that you simply introduce parking stress indicators. The Council’s a maximum stay of 6 or 8 or 12 hours. There would be no need to comprehensive street by street 2011 Occupancy introduce charges for this. Survey identifies that overall in Zone E the weekday occupancy is 73%, on Saturday evening it is 86% I’d be grateful for a response to my suggestion, as I am struggling and on Sunday afternoon it is 84%. In Zone F3 on to believe that your motivation is not simply to raise revenue. Saturday evening it is 65% and on Sunday afternoon it is 88%. In Zone G weekday evening The fact there are no charges means that people without the occupancy is 71% on Saturday evening it is 81% means to pay can use their cars to visit Central London. and on Sunday afternoon it is 92%. The standard parking stress levels the Council applies are if the If there is a formal route for me to register my objection I would be recorded rate is >80% this means serious grateful if you would provide me with details. deficiency and if it is 70-80% there is deficiency. Therefore in all three zones in question there are serious parking occupancy stress levels on all days including Sundays.

Drivers are encouraged to use public transport, walk or cycle more to their destinations, as many already do.

Objection noted.

Simon Cole 20/07/2011 I think that your plan to introduce paid for parking and ban single Notting Hill is outside of the areas where it is yellow line parking on Sunday is the final straw in a long descent proposed to extend the hours of control under for Westminster City Council. proposals DPP1 and 2.

At some stage, when introducing parking restrictions and Road traffic in the West End and Central enforcing them with over enthusiastic wardens, you need to Westminster area has reached high levels so it is consider the effect this has on residents’ view of the Council itself the duty of the Council to introduce controls to and its part in society. mitigate this reality. The parking spaces in Zones E, (F3 at weekends) and G all exceed recognised You are elected to serve the community but you have to make parking stress indicators. The Council’s decisions which sometimes some of the community does not like. comprehensive street by street 2011 Occupancy It is a delicate balance. You need support for your mandate to Survey identifies that overall in Zone E the weekday operate properly but you also need to do your job. occupancy is 73%, on Saturday evening it is 86% and on Sunday afternoon it is 84%. In Zone F3 on I have been a resident in London for many years, I understand the Saturday evening it is 65% and on Sunday difference. afternoon it is 88%. In Zone G weekday evening occupancy is 71% on Saturday evening it is 81% The idea of the new Sunday parking restrictions will certainly turn and on Sunday afternoon it is 92%. The standard me, and I believe many others, against our Council. Local parking stress levels the Council applies are if the democracy will lose support in what will be seen by most people recorded rate is >80% this means serious as a cynical (and illegal) fundraising move. deficiency and if it is 70-80% there is deficiency. Therefore in all three zones in question there are I live in Notting Hill; it is busy, but there is no congestion on a serious parking occupancy stress levels on all days Sunday and no demonstrable need for any change in the parking including Sundays. regulations. There is a legal obligation that any surplus income attained through DPP 1 and 2 should be re-invested back into the transportation and parking network of central London.

Stephen 18/07/2011 Please register my strong opposition to the mooted introduction of There are many determinants that steer the Sutherland parking changes on Sundays, particularly in the Farm Street area. performance of the capital’s economy such as variable exchange rates, levels of disposable In short, the "direct" benefits of increased parking revenues seem income, employment levels, the weather, retail likely to be more than offset by the "indirect" impacts to trends etc. Unlike most other urban centres across businesses and charitable concerns in our borough. the UK, parking is a marginal influence and in Westminster dependence on the private vehicle to 1) The consequent impact on church congregations, and their reach retail centres is very low, i.e. 14% for donations (which are subsequently re-deployed substantially combined car, motorcycle and powered two within Westminster) could be catastrophic since most people wheeler for trips as the main mode of transport in come from out of borough to the fabulous churches of Westminster (based on an average 7 day week Westminster. between 2006 and 2009 – source TfL 2010). Whereas for those who walk it is currently 38% and 2) The retail sector is hardly in good shape more broadly and the those on public transport it is 35%. There will be impact of parking charges which reduce consumers incentive to major public transport schemes delivered over the travel from throughout the South East to Westminster to spend next ten years, including Crossrail which will some share of their pressurised retail wallet will not help the local increase capacity by 30%. The parking proposals of economy in this regard. the PPR therefore represent a minor influence on the West End economy given the availability of public transport, the availability of parking spaces for visitors in off street car parks and on street paid for parking bays, and the concessions offered to blue/white badge holders in the evenings and at weekends. Extended parking controls are necessary because in parking Zones E, (F3 at weekends) and G all exceed recognised parking stress indicators. The proposed implementation of parking controls over this time would have the potential of increasing the turnover of parking stock on the street that would enable more visitors to park.

For the reasons set out in the 9th May 2011 Cabinet report and within this Cabinet report, along with the extensive evidence base commissioned by the council, the introduction of controls and

58 consequent charges during the proposed periods is considered justifiable. It should be noted that for other religions and faiths whose holy days fall on other days of the week when controls and charges apply, no exemptions are granted. The availability of public transport, the capacity of off street car parks during the evenings and on Sundays, the concessions offered to blue/white badge holders, the elderly and the disabled on London’s public transport network, including black cabs, all contribute to mitigating any adverse impacts on families with young children, the elderly and the disabled. Officers have also taken into account the provisions of the European Convention on Human Rights in this context and it is not considered that Article 9 rights would be infringed by these proposals, but any restriction there may be would be proportionate and justified in pursuit of a legitimate aim in any event.

Warren Edwards 17/07/2011 I have just signed a petition via this link against Westminster's Noted. plan to introduce parking charges on Sundays. For the reasons set out in the 9th May 2011 http://goo.gl/wR0Gf Cabinet report and within this Cabinet report, along with the extensive evidence base commissioned by As a Westminster resident I walk to church but occasionally go by the council, the introduction of controls and Boris Bike. consequent charges during the proposed periods is considered justifiable. It should be noted that for But as I age I might find myself needing to go by car. other religions and faiths whose holy days fall on other days of the week when controls and charges Also as a Westminster resident I understand Westminster apply, no exemptions are granted. The availability Council's rationale though I do not fully agree with it. of public transport, the capacity of off street car parks during the evenings and on Sundays, the So I suggest a compromise: concessions offered to blue/white badge holders, the elderly and the disabled on London’s public Free parking until 13:00 on Sundays. transport network, including black cabs, all contribute to mitigating any adverse impacts on families with young children, the elderly and the disabled. Officers have also taken into account the provisions of the European Convention on Human Rights in this context and it is not considered that Article 9 rights would be infringed by these proposals, but any restriction there may be would be proportionate and justified in pursuit of a legitimate aim in any event.

Clare Higgins 17/07/2011 I am writing to express my extreme worry at the Council’s For the reasons set out in the 9th May 2011 proposals to introduce parking charges on Sundays Cabinet report and within this Cabinet report, along with the extensive evidence base commissioned by My young family and I travel into Westminster to attend the the council, the introduction of controls and Roman Catholic Church in Farm Street in Mayfair on Sunday consequent charges during the proposed periods is mornings. It is a church community which does much good work considered justifiable. It should be noted that for for the disadvantaged in the borough of Westminster. Like many other religions and faiths whose holy days fall on of our congregation with young families, it would be extremely other days of the week when controls and charges difficult for us to attend regularly without being able to come by apply, no exemptions are granted. The availability car. Our tube line is regularly closed or operating with a restricted of public transport, the capacity of off street car service on Sundays, and the journey takes more than twice the parks during the evenings and on Sundays, the time and is challenging with small children even when it is concessions offered to blue/white badge holders, working. The decline in congregation which the proposals would the elderly and the disabled on London’s public cause would significantly reduce central Westminster churches' - transport network, including black cabs, all including Farm Street's - ability to fund such activity which has contribute to mitigating any adverse impacts on provided clear and direct benefit to the borough and its citizens for families with young children, the elderly and the many centuries, from the time well before Westminster Council disabled. Officers have also taken into account the was set up in 1900. provisions of the European Convention on Human Rights in this context and it is not considered that The suggestion that introducing charging on Sundays would help Article 9 rights would be infringed by these residents is highly dubious. Residents will have access to the proposals, but any restriction there may be would same bays they do now, which are already controlled from be proportionate and justified in pursuit of a Sunday to Sunday. The proposal would actually reduce residents' legitimate aim in any event. parking as they would no longer be able to park on single yellow lines on Sundays as they can now If DPP 1 and 2 are approved by Cabinet and implemented, within Zones E, F and G, residents When the Sunday Trading Act 1994 was introduced, it was will be entitled to park free of charge in any paid for designed to limit the hours larger shops could trade on Sundays, visitor parking bay during the extended hours of while keeping Sunday different from other days to allow Church control and also the last paid hour (5.30-6.30pm). attendance. The regulation of Sunday trading was not at all intended to have an impact on church attendance - indeed the The Sunday Trading Act 1994 was introduced to opposite, but the parking restrictions and charges now being reform the law relating to Sunday trading, and to considered by Westminster Council will seriously affect the ability make provision for the rights of shop workers in of thousands of people to attend the church of their choice in the relation to Sunday working. The Act repealed the capital Shops Act 1950, under which Sunday trading was generally prohibited. Under the 1994 Act shops are

Please reject these proposals. permitted to trade on Sunday, but larger stores may open only for a maximum of six hours, between Much Sunday worship happens on Sunday mornings rather than 10am and 6pm. Save that the Act permitted in the afternoon, which is the main period when West End shops shopping on a Sunday, which is a relevant part of are open. If the Council felt there were no alternative but to the background to these policy proposals, it is not introduce Sunday charges and restrictions, putting them in place directly relevant to the question of whether or not from 1230-1800 would allow much of the churches' work to Sunday parking controls should be introduced. continue and their congregations largely to be maintained, while in practice having much of the restrictive effect on the bulk of the traffic

Peter Phillips 17/07/2011 I am writing to express my deep concern at the proposals to See above response. introduce parking charges on Sundays

My young children and I regularly travel into Westminster to attend Farm Street Roman Catholic Church in Mayfair on Sunday mornings. It is a wonderfully lively church which does much good work for the disadvantaged in the borough of Westminster. Like many of our congregation with young families, it would be extremely difficult for us to attend regularly without being able to come by car. Our tube line is regularly closed or operating with a restricted service on Sundays, and the journey takes more than twice the time and is challenging with small children even when it is working. The decline in congregation which the proposals would cause would significantly reduce central Westminster churches' - including Farm Street's - ability to fund such activity which has provided clear and direct benefit to the borough and its citizens for many centuries, from the time well before Westminster Council was set up in 1900.

The suggestion that introducing charging on Sundays would help residents is highly dubious. Residents will have access to the same bays they do now, which are already controlled from Sunday to Sunday. The proposal would actually reduce residents' parking as they would no longer be able to park on single yellow lines on Sundays as they can now

When the Sunday Trading Act 1994 was introduced, it was designed to limit the hours larger shops could trade on Sundays, while keeping Sunday different from other days to allow Church attendance. The regulation of Sunday trading was not at all intended to have an impact on church attendance - indeed the opposite, but the parking restrictions and charges now being considered by Westminster Council will seriously affect the ability of thousands of people to attend the church of their choice in the capital

I urge you to reject the proposals.

Much Sunday worship happens on Sunday mornings rather than in the afternoon, which is the main period when West End shops are open. If the Council felt there were no alternative but to introduce Sunday charges and restrictions, putting them in place from 1230-1800 would allow much of the churches' work to continue and their congregations largely to be maintained, while in practice having much of the restrictive effect on the bulk of the traffic

Guy 17/07/2011 I was very concerned to hear last week about Westminster City Response from Cllr Rowley on 17/07/2011: Featherstonhaugh Council's proposal to enforce weekday parking controls on Sundays in the area of Farm Street Church in Mayfair, as part of a Westminster Council began a full review of its wider proposal, as I understand it, to control congestion in Oxford existing parking policies - the first in ten years - last Street caused by Sunday shopping. year. As part of that, the Council has undertaken a significant amount research and analysis on parking I was surprised to hear that anyone might wish to drive to Oxford in the city. This has included two rounds of Street to shop, given the excellent public transport links along its consultation with the public, analysis of whole length. The same does not apply to Farm Street Church, demographic data, many meetings and both an which is some distance away from any tube or bus stop. That occupancy survey of our parking spaces and a consideration impacts upon the elderly and families who make up count of traffic to understand what is happening on the bulk of the Church congregation, all or most of whom drive to our streets. Church, and all or most of whom would be greatly affected by these proposals. One of the issues that all of this work highlighted was the increasing difficulty of parking in parts of Farm Street Church is a centre of excellence in the catholic the centre of the city. There are parts of the very community. It has always been associated with culture and centre of the city where parking occupancy exceeds learning, but it has painstakingly built up a reputation for the 90% at times on a Sunday. I have walked around excellence of its family masses and its pastoral care in the wider streets in these zones myself to see long tailbacks community over the last 15 years, which attracts worshippers from caused by bumper-to-bumper parking on single far and wide. It is no exaggeration to say that that would be yellow lines and not one space as far as the eye destroyed if the parking proposals are implemented. Put shortly, can see. given the pressures attendant already on those who go out of their way to do what they consider to be the right thing by their families, Faced with this information, the Council has come an extra imposition in the shape of a financial penalty would be forward with eight draft proposals to try to improve very likely to make them seek out a parish more sympathetic to parking in the City. Two of these involve changes their needs, if less good in its teaching. to controls in limited (central) parts of the Westminster, to try to address the problem Farm Street Church is some distance from Oxford Street. Those described above. The aim of these proposals is to who wish to drive to Oxford Street presumably do so for reasons ensure that traffic flows freely and there is a of convenience. I query whether anyone would find it convenient reasonable chance that those seeking to come into to park in Mount Street or Farm Street in order to walk up to Westminster would be able to find a parking space. Oxford Street. It seems to me that there may well be a good case The Council, which has a legal duty to ensure the for exempting the geographical area of the Church from your expeditious movement of traffic and providing proposals - something that I know the Council has power to do. suitable parking spaces, finds itself having to Can I ask you please to consider such an exemption? resolve a problem which it did not create - namely

65 the increase in the number of people entering London as a result of the changes in Sunday trading laws.

On the point regarding the area covered, the Council has already limited the proposals to a central area which seems most affected. The analysis has been undertaken on the basis of the existing parking zones. I shall ask officers to consider your comment regarding exemption of Farm Street although I think it might prove difficult to work properly.

The Council is now collating the responses provided to its second consultation before looking to make a decision on the proposals in the near future. The current timeframe is that this decision will be made in August.

Guy 17/07/2011 I think there is a fair amount of common ground between us. It 1. In the Mount Street scheme the number of Featherstonhaugh seems ironic that the easing of the Sunday trading laws - parking bays (residents and paid for parking) were something to which the catholic church at least was adamantly not reduced. Double yellow lines were introduced opposed - is now threatening the very viability of that church in on corners for safety reasons, at intervals along the Mayfair. street to facilitate larger vehicles to pass and at crossing points to aid pedestrians wishing to cross Can I however emphasise one or two points at the micro level the road. Vehicles are still permitted to load/unload which I suggest might usefully be taken into account in the from yellow lines at any time of the day without cost formulation of your macro plan. (subject to local loading restrictions and assuming loading activity is continuous). LGVs are permitted 1. Curiously, it used to be much easier to park in Mount Street to load for up to 20 minutes and HGVs 40 minutes before the recent WCC/Grosvenor street refurbishment. Single and private vehicles do not have a time limit. yellow lines in many places have been doubled, for no apparent reason. You will have noticed on your walking tour (and if not, I For the reasons set out in the 9th May 2011 invite you to look again) that Mount Street is now almost all Cabinet report and within this Cabinet report, along residents' parking in bays to the sides of the street - save for with the extensive evidence base commissioned by certain spaces which, mysteriously, are double-yellowed. This, I the council, the introduction of controls and emphasise, is not on the street, but in the bays. If you need a consequent charges during the proposed periods is refreshing reminder of how it used to be before the street works, considered justifiable. It should be noted that for have a look at Google street maps, which shows the position last other religions and faiths whose holy days fall on year, and compare that with the double yellow bonanza that other days of the week when controls and charges currently exists. This of course exacerbates the current parking apply, no exemptions are granted. The availability difficulties (although it is still possible to find single yellow lines in of public transport, the capacity of off street car more hazardous positions towards the eastern end of Mount parks during the evenings and on Sundays, the Street once one proceeds past the Connaught Hotel), but this will concessions offered to blue/white badge holders, be as nothing compared to the difficulty that will be experienced if the elderly and the disabled on London’s public you bring in your proposals to aid retailers at the expense of transport network, including black cabs, all churchgoers. contribute to mitigating any adverse impacts on families with young children, the elderly and the 2. I understand, and of course endorse, your aim of ensuring that disabled. Officers have also taken into account the traffic flows freely. I do not understand the point that follows provisions of the European Convention on Human below regarding the "reasonable chance that those seeking to Rights in this context and it is not considered that come into Westminster would be able to find a parking space". Is Article 9 rights would be infringed by these that a statutory responsibility? I had thought that the Council's proposals, but any restriction there may be would aim was to discourage, rather than encourage, drivers? Lest it be be proportionate and justified in pursuit of a thought that I may be arguing against myself here, let me make it legitimate aim in any event.

67 plain that I see a clear distinction between worshippers, on the one hand, who have been exercising their rights to attend church 2. The Council encourages those accessing the without restriction for many years, and who find that Farm Street West End to do so by walking, cycling or public Church is some distance (both for elderly and for very young transport wherever possible. However, it is limbs) from public transport, and shoppers, on the other hand, appreciated that this is very difficult for some people who apparently choose to drive despite an abundance of public to use alternative means for a number of reasons transport stops immediately outside the doors of shops they wish and may feel their only option is to drive. In these to visit. instances the Council aims to provide a reasonable supply of parking spaces for visitors to the West 3. I am not sure that I understand your point regarding the area End, albeit at a cost in order to manage demand. covered. Surely it is as easy as drawing lines on a map? Your officials will have conducted their surveys which will no doubt 3. Mount Street is only a 4-9 minute walk include studies of the extent to which drivers are prepared to walk (dependant on walking speed) from Oxford Street. from their parked cars. Is the Mount Street area seriously within Although no shopper surveys have been the casual Sunday shopper's radius? I would have thought not. conducted, it is anticipated that this distance is well within the threshold that most shoppers would be I understand that the Council is looking for extra sources of prepared to walk to/from their car. Westminster is revenue in these difficult times. I would not like to think that it has divided into a number of parking zones, and seen an easy target here under the guise of facilitating Sunday proposals DPP1 and 2 only affect zones E, F3 (on shopping. I have long looked up to the Council as a leading light Sundays) and G. The parking restrictions in these in the field of light regulation and big society initiatives. I very areas are enforced by Traffic Regulation Orders. much hope that you will not see fit to disappoint us. Having a series of smaller sub zones with different controls may be confusing for drivers, may result in drivers displacing to nearby zones where parking is still free and would also be more difficult for the Council to administer and enforce.

There is a legal obligation that any surplus income attained through DPP 1 and 2 should be re-invested back into the transportation and parking network of central London.

Brenda and John 17/07/2011 We are members of the Farm Street Church community and, like For the reasons set out in the 9th May 2011 Taylor many other members of churches in Westminster, we live outside Cabinet report and within this Cabinet report, along Westminster City Council area. This means that we travel into with the extensive evidence base commissioned by Mayfair to attend church services and other activities. We are the council, the introduction of controls and very concerned that the introduction of parking charges for consequent charges during the proposed periods is Sundays and evenings will place a significant burden on people considered justifiable. It should be noted that for who must rely on their cars for transport, particularly families with other religions and faiths whose holy days fall on children, the elderly and disabled, and the many volunteers who other days of the week when controls and charges provide their time and money to help support the social services in apply, no exemptions are granted. The availability Westminster City Council. We believe that many of these people of public transport, the capacity of off street car will simply decide it is too expensive to come into the Westminster parks during the evenings and on Sundays, the area and, not only will the churches suffer, but, perhaps more concessions offered to blue/white badge holders, importantly from your perspective, you will lose a very valuable the elderly and the disabled on London’s public social service resource that will turn its attention closer to where transport network, including black cabs, all those people live. contribute to mitigating any adverse impacts on families with young children, the elderly and the We strongly urge you to reconsider the introduction of parking disabled. Officers have also taken into account the charges for Sundays and evenings. If the intention of the Council provisions of the European Convention on Human is to relieve traffic congestion around the Oxford Street area, Rights in this context and it is not considered that could we suggest that you introduce parking fees only during Article 9 rights would be infringed by these Sunday afternoons, say from 1.30 p.m. onwards. There is not a proposals, but any restriction there may be would huge amount of traffic on Sunday mornings, and you should be proportionate and justified in pursuit of a balance the traffic in the evenings against the undoubted loss of legitimate aim in any event. volunteers for social services during that time.

Iain Bott 12/07/2011 As a recent recruit to the local conservative association in my It is recognised that parking stress levels vary from area, a resident, and a church goer. I have a few concerns over one zone to the next and therefore a visitors the parking proposals. parking scheme are likely to be difficult to accommodate in areas where residents parking Firstly, Sunday is the only day that friends and family are able to bays are already under significant pressure, as it visit residents by car without paying large parking charges. I am would allow visitors to park in residents’ bays at concerned that this will end. It sounded at the meeting that the certain times. The issue is that there is simply not introduction of a voucher scheme for residents is by no means enough kerbside space in many areas to allow all certain, and if it were that I would then end up having to buy books residents and visitors who wish to park to do so of vouchers for people to park near to my residence. This scheme freely. Visitors are encouraged to travel by could well be both costly and bureaucratic to introduce and alternative means i.e. walking, cycling or public oversee. Your thoughts on this would be appreciated. transport.

Secondly, the knock-on effect to local business may well be There are many determinants that steer the significant. With events like the Marylebone farmers market likely performance of the capital’s economy such as to take a direct hit, as well as other local shops and eateries. variable exchange rates, levels of disposable income, employment levels, the weather, retail Thirdly- I attend All Souls church on Langham Place. All Souls trends etc. Unlike most other urban centres across and its sister church are involved with regular children's activities the UK, parking is a marginal influence and in after school, elderly visitation, meals for the elderly, meals for the Westminster dependence on the private vehicle to homeless, plus much more. reach retail centres is very low, i.e. 14% for Many people helping in the above live outside of Westminster and combined car, motorcycle and powered two so have to commute in, charging them for Sunday parking is really wheeler for trips as the main mode of transport in going to be seen as a slap in the face to those who are greatly Westminster (based on an average 7 day week helping towards building the big society agenda. Of course this between 2006 and 2009 – source TfL 2010). work will most likely continue irrespective of charges, but the Whereas for those who walk it is currently 38% and message that Westminster sends out to these people is not surely those on public transport it is 35%. The parking a very positive message- which instead should be one of thanks proposals of the PPR therefore represent a minor and appreciation. influence on the West End economy given the availability of public transport, the availability of I understand there are areas of Marylebone where parking is very parking spaces for visitors in off street car parks busy on Sundays. Would you consider placing restrictions in only and on street paid for parking bays, and the certain areas on Sundays- main roads and intersections for concessions offered to blue/white badge holders in example while leaving the small roads and Mews free for parking? the evenings and at weekends. Extended parking controls are necessary because in parking Zones E, (F3 at weekends) and G all exceed recognised

70 parking stress indicators. The proposed implementation of parking controls over this time would have the potential of increasing the turnover of parking stock on the street that would enable more visitors to park.

For the reasons set out in the 9th May 2011 Cabinet report and within this Cabinet report, along with the extensive evidence base commissioned by the council, the introduction of controls and consequent charges during the proposed periods is considered justifiable. It should be noted that for other religions and faiths whose holy days fall on other days of the week when controls and charges apply, no exemptions are granted. The availability of public transport, the capacity of off street car parks during the evenings and on Sundays, the concessions offered to blue/white badge holders, the elderly and the disabled on London’s public transport network, including black cabs, all contribute to mitigating any adverse impacts on families with young children, the elderly and the disabled. Officers have also taken into account the provisions of the European Convention on Human Rights in this context and it is not considered that Article 9 rights would be infringed by these proposals, but any restriction there may be would be proportionate and justified in pursuit of a legitimate aim in any event.

Having a series of smaller sub zones with different controls may be confusing for drivers, may result in drivers displacing to nearby sub zones where parking is still free and would also be more difficult for the Council to administer and enforce.

Ann McKay 11/07/2011 I write to you as a member of Hinde Street Methodist Church in For the reasons set out in the 9th May 2011 Marylebone. Cabinet report and within this Cabinet report, along with the extensive evidence base commissioned by I understand that Westminster City Council is considering a the council, the introduction of controls and proposal to introduce parking restrictions on Sundays in consequent charges during the proposed periods is Marylebone, along with Mayfair and Soho, which could mean no considered justifiable. It should be noted that for parking on single yellow lines and charges at meters of more than other religions and faiths whose holy days fall on £4 an hour. other days of the week when controls and charges apply, no exemptions are granted. The availability of public transport, the capacity of off street car Naturally this could have a dramatic effect on the numbers of parks during the evenings and on Sundays, the people who could come to Sunday services at Hinde Street, and concessions offered to blue/white badge holders, many other churches in the centre. While some of us are able to the elderly and the disabled on London’s public get to church using public transport, there are many church transport network, including black cabs, all members for whom public transport is not an option, and they contribute to mitigating any adverse impacts on need to be able to drive and park near their church. families with young children, the elderly and the disabled. Officers have also taken into account the And it is the members of congregations that maintain these provisions of the European Convention on Human beautiful buildings for all to enjoy. If you lose the congregations, Rights in this context and it is not considered that the churches will close and the buildings fall into disrepair. And Article 9 rights would be infringed by these these congregations are responsible for much-needed social work proposals, but any restriction there may be would within the centre of the city. be proportionate and justified in pursuit of a legitimate aim in any event. I hope that Westminster City Council will listen to the voices of church members and reject the proposal.

Ron Whelan 08/07/2011 I may be in a small minority, judging from the responses of your Support noted. audience at St. Georges last night, but I thought that you presented a coherent case. As far as I could tell, only about 10% For the reasons set out in the 9th May 2011 or so of the audience actually lived in Mayfair . For the most past, Cabinet report and within this Cabinet report, along the strong emotional responses seemed to reflect a selfish with the extensive evidence base commissioned by concern about a perceived attack on their own personal interests, the council, the introduction of controls and and had little or nothing to do with the community. consequent charges during the proposed periods is As someone who has lived in the area for over 30 years, it is an considered justifiable. It should be noted that for observable fact (in spite of what Rev. Leece and others claimed) other religions and faiths whose holy days fall on that parking on the streets in this area on Saturday and Sunday is other days of the week when controls and charges excessive. As you know, this excess has been caused by the apply, no exemptions are granted. The availability changes in the shopping regulations, and people now pour into of public transport, the capacity of off street car the area on Saturday and Sunday afternoons, because of the free parks during the evenings and on Sundays, the parking. concessions offered to blue/white badge holders, the elderly and the disabled on London’s public But why shouldn’t these people pay? They inflict environmental transport network, including black cabs, all costs, they obviously have enough money, so why should they not contribute to mitigating any adverse impacts on make a contribution towards meeting these costs? families with young children, the elderly and the The Churches of course do have a particular problem, and I would disabled. Officers have also taken into account the argue that they should be given a special dispensation. As I provisions of the European Convention on Human suggested in a previous email to you, I can’t see why the local Rights in this context and it is not considered that churches should not be allowed to issue temporary parking Article 9 rights would be infringed by these permits to their congregations. This need not be a huge proposals, but any restriction there may be would administrative exercise, and the Mayfair Residents Group would be proportionate and justified in pursuit of a be quite willing to help organise such a scheme. legitimate aim in any event.

Caroline Cross 07/07/2011 I am writing regarding the parking review for Westminster. I For the reasons set out in the 9th May 2011 understand that restrictions will be imposed on Sunday parking. Cabinet report and within this Cabinet report, along As a resident of Westminster, I strongly oppose the restrictions. In with the extensive evidence base commissioned by particular, it would have a tremendous negative impact on the the council, the introduction of controls and churches in the area. Many families, elderly or invalided persons consequent charges during the proposed periods is drive to church, and imposing restrictions and increasing hourly considered justifiable. It should be noted that for rates would have affect them severely. It would also act as a other religions and faiths whose holy days fall on disincentive for people to come to church, where churches are other days of the week when controls and charges already struggling to retain their congregations. apply, no exemptions are granted. The availability of public transport, the capacity of off street car I would be grateful if you could take these matters into parks during the evenings and on Sundays, the consideration as part of your review. concessions offered to blue/white badge holders, the elderly and the disabled on London’s public transport network, including black cabs, all contribute to mitigating any adverse impacts on families with young children, the elderly and the disabled. Officers have also taken into account the provisions of the European Convention on Human Rights in this context and it is not considered that Article 9 rights would be infringed by these proposals, but any restriction there may be would be proportionate and justified in pursuit of a legitimate aim in any event.

Richard Shepley 07/07/2011 I am writing to object to the introduction of parking restrictions on For the reasons set out in the 9th May 2011 a Sunday in the Marylebone High St Area. We attend Hinde Street Cabinet report and within this Cabinet report, along Methodist Church and often transport a 76 year old lady who has with the extensive evidence base commissioned by great difficulty walking. This new proposal will cause her great the council, the introduction of controls and difficulties and seems completely unnecessary. I would ask the consequent charges during the proposed periods is Council to reconsider. considered justifiable. It should be noted that for other religions and faiths whose holy days fall on other days of the week when controls and charges apply, no exemptions are granted. The availability of public transport, the capacity of off street car parks during the evenings and on Sundays, the concessions offered to blue/white badge holders, the elderly and the disabled on London’s public transport network, including black cabs, all contribute to mitigating any adverse impacts on families with young children, the elderly and the disabled. Officers have also taken into account the provisions of the European Convention on Human Rights in this context and it is not considered that Article 9 rights would be infringed by these proposals, but any restriction there may be would be proportionate and justified in pursuit of a legitimate aim in any event.

S Frisken 07/07/2011 I understand that parking restrictions may be introduced in For the reasons set out in the 9th May 2011 Westminster for Sundays. I would like to protest against this Cabinet report and within this Cabinet report, along because it would affect the elderly members of our church with the extensive evidence base commissioned by congregation, who attend our Central London church and who the council, the introduction of controls and would find it difficult to take public transport, or else have to pay consequent charges during the proposed periods is up to £10-12 per week just to go to church. Sundays are meant to considered justifiable. It should be noted that for be a day set apart for rest, and every society needs this. People other religions and faiths whose holy days fall on need one day a week to get away from money making and to just other days of the week when controls and charges BE, and I think this would penalise people unfairly. Monday to apply, no exemptions are granted. The availability Friday, you are penalising corporations and working people to of public transport, the capacity of off street car drive in the area which is fair enough, but please don’t penalise parks during the evenings and on Sundays, the people who, on evenings and weekends, are simply trying to go concessions offered to blue/white badge holders, about their personal lives, just because it happens to be in a the elderly and the disabled on London’s public lucrative area. Historic churches do exist alongside the shopping transport network, including black cabs, all and they and their members should not be penalised for their contribute to mitigating any adverse impacts on location. families with young children, the elderly and the disabled. Officers have also taken into account the provisions of the European Convention on Human Rights in this context and it is not considered that Article 9 rights would be infringed by these proposals, but any restriction there may be would be proportionate and justified in pursuit of a legitimate aim in any event.

Paul Horrell 07/07/2011 I believe the proposed restrictions on Sunday parking would have For the reasons set out in the 9th May 2011 a high proportion of the relatively elderly and young families Cabinet report and within this Cabinet report, along among them, people who find it hard to use public transport. Many with the extensive evidence base commissioned by of these organisation do an enormous amount of good work within the council, the introduction of controls and the wider community, and their capacity would be reduced if their consequent charges during the proposed periods is Sunday numbers were damaged. I attend Hinde Street Methodist considered justifiable. It should be noted that for Church, which during the week supports a number of projects to other religions and faiths whose holy days fall on help move the homeless and vulnerably housed into more stable other days of the week when controls and charges lives, and among chronic drinkers and certain high-risk offenders. apply, no exemptions are granted. The availability of public transport, the capacity of off street car parks during the evenings and on Sundays, the concessions offered to blue/white badge holders, the elderly and the disabled on London’s public transport network, including black cabs, all contribute to mitigating any adverse impacts on families with young children, the elderly and the disabled. Officers have also taken into account the provisions of the European Convention on Human Rights in this context and it is not considered that Article 9 rights would be infringed by these proposals, but any restriction there may be would be proportionate and justified in pursuit of a legitimate aim in any event.

Gillian Brooks 07/07/2011 I am very concerned about the affect of further parking restrictions For the reasons set out in the 9th May 2011 in Marylebone High Street and surrounding area. I go to church at Cabinet report and within this Cabinet report, along HInde Street Methodist church which is on the corner of Hinde with the extensive evidence base commissioned by Street and Thayer Street in Marylebone. A very large proportion of the council, the introduction of controls and the congregation of our church travel in from many areas of consequent charges during the proposed periods is London. One of the reasons for his is the desire to support eh considered justifiable. It should be noted that for excellent social work that is managed from this church – aiming to other religions and faiths whose holy days fall on help those that need it most. If parking restrictions are put in place other days of the week when controls and charges our church community could be devastated as many, including us, apply, no exemptions are granted. The availability would find it too expensive to go into Marylebone for the church. of public transport, the capacity of off street car Public transport is not a reliable option on a Sunday especially for parks during the evenings and on Sundays, the a family with children – because of the poor service and cancelled concessions offered to blue/white badge holders, lines due to engineering works by TfL. the elderly and the disabled on London’s public transport network, including black cabs, all contribute to mitigating any adverse impacts on families with young children, the elderly and the disabled. Officers have also taken into account the provisions of the European Convention on Human Rights in this context and it is not considered that Article 9 rights would be infringed by these proposals, but any restriction there may be would be proportionate and justified in pursuit of a legitimate aim in any event.

Ann Cotterrell 06/07/2011 I am a member of Hinde Street Methodist Church in Marylebone For the reasons set out in the 9th May 2011 and I am very concerned to hear about the proposed parking Cabinet report and within this Cabinet report, along restrictions. Although my family walks to church whenever we can, with the extensive evidence base commissioned by we have had some family illness and injuries that have made the the council, the introduction of controls and use of public transport or walking impossible. My mother is 90 consequent charges during the proposed periods is years old and is not able to walk more than a few steps. We would considered justifiable. It should be noted that for not be able to attend church regularly if these parking restrictions other religions and faiths whose holy days fall on were introduced. Please reconsider them. other days of the week when controls and charges apply, no exemptions are granted. The availability of public transport, the capacity of off street car parks during the evenings and on Sundays, the concessions offered to blue/white badge holders, the elderly and the disabled on London’s public transport network, including black cabs, all contribute to mitigating any adverse impacts on families with young children, the elderly and the disabled. Officers have also taken into account the provisions of the European Convention on Human Rights in this context and it is not considered that Article 9 rights would be infringed by these proposals, but any restriction there may be would be proportionate and justified in pursuit of a legitimate aim in any event.

Jeremy Thorp 04/07/2011 I understand that there will be a meeting on 7 July to discuss For the reasons set out in the 9th May 2011 proposed changes to parking regulations, at which you will be Cabinet report and within this Cabinet report, along present. Unfortunately I shall be out of London that evening, but I with the extensive evidence base commissioned by wanted to let you know of my strong objections to the proposal, the council, the introduction of controls and which will make it impossible to attend a morning or evening consequent charges during the proposed periods is service at All Saints Church Margaret Street, or my wife's church considered justifiable. It should be noted that for in Farm Street, on Sundays without paying for parking. other religions and faiths whose holy days fall on other days of the week when controls and charges Due to their locations in the heart of the West End almost all the apply, no exemptions are granted. The availability congregations at these churches live outside the parish. For of public transport, the capacity of off street car many a car is the only practical way of getting to these churches parks during the evenings and on Sundays, the on Sundays. The proposal will charge people for worshipping at concessions offered to blue/white badge holders, their accustomed church. It is very likely that many of them will no the elderly and the disabled on London’s public longer worship there as a direct result of the change. This is transport network, including black cabs, all particularly the case at Margaret Street where there are no contribute to mitigating any adverse impacts on machines to pay locally and where payment would have to be families with young children, the elderly and the made by mobile phone at least an hour before the parking disabled. Officers have also taken into account the restrictions would come into force at noon. The effect would be to provisions of the European Convention on Human damage the ability of these churches to maintain themselves as a Rights in this context and it is not considered that part of the Westminster community, and as historic and beautiful Article 9 rights would be infringed by these buildings which are a tourist attraction in this city. proposals, but any restriction there may be would be proportionate and justified in pursuit of a When the Sunday Trading Act was enacted in 1994, great care legitimate aim in any event. was taken to ensure that the right to worship was not affected by the changes. This proposal would take away that right from the The Sunday Trading Act 1994 was introduced to people affected and for that reason I oppose it strongly. reform the law relating to Sunday trading, and to make provision for the rights of shop workers in relation to Sunday working. The Act repealed the Shops Act 1950, under which Sunday trading was generally prohibited. Under the 1994 Act shops are permitted to trade on Sunday, but larger stores may open only for a maximum of six hours, between 10am and 6pm. Save that the Act permitted shopping on a Sunday, which is a relevant part of the background to these policy proposals, it is not directly relevant to the question of whether or not

Sunday parking controls should be introduced.

Jacob Lyons 05/07/2011 I am a member of Marble Arch Synagogue and a resident of For the reasons set out in the 9th May 2011 Westminster. I would like to register my absolute objection to the Cabinet report and within this Cabinet report, along plan to extend the parking restrictions in the area, both to with the extensive evidence base commissioned by Sundays and to later hours. I would like to know why this plan is the council, the introduction of controls and up for consideration without any consultation with groups such as consequent charges during the proposed periods is ourselves and the churches who both reside and operate in the considered justifiable. It should be noted that for area. other religions and faiths whose holy days fall on other days of the week when controls and charges To impose charges punishes those members of the community apply, no exemptions are granted. The availability who wish to observe their religious traditions as well as Sunday of public transport, the capacity of off street car school attendants. parks during the evenings and on Sundays, the concessions offered to blue/white badge holders, As a resident and tax-payer I would like an explanation as well as the elderly and the disabled on London’s public an explanation as to why (I live near Regent's Park Mosque) those transport network, including black cabs, all same parking conditions and restrictions are not up for contribute to mitigating any adverse impacts on consideration near the mosque which as you will I am sure be families with young children, the elderly and the aware stands on a major arterial route and the congregation and disabled. Officers have also taken into account the parking around the site often leads to considerable congestion provisions of the European Convention on Human and inconvenience for the residents of St. John's Wood, Regent's Rights in this context and it is not considered that Park and others who wish to access adjacent areas. I would argue Article 9 rights would be infringed by these that the disruption caused by the mosque is far greater than proposals, but any restriction there may be would parking around the synagogue or local churches. be proportionate and justified in pursuit of a legitimate aim in any event.

Glossary of abbreviations:

PPR – City of Westminster Parking Policy Review (2010-11) DPP – City of Westminster Draft Policy Proposal number WCC – City of Westminster Council TfL – Transport for London EV – Electric Vehicles CC – Car Club CEO – Civil Enforcement Officer PbP – Pay by Phone visitor paid parking P&D – Pay and Display P2W – Powered Two Wheeler i.e. motorcycles, mopeds, Scooters etc LGV – Light Goods Vehicle – i.e. transit like van under 3.5 gross plated weight HGV – Heavy Goods Vehicles – i.e. lorry over 3.5 tonne gross plated weight