TRAFFIC REGULATION ORDERS AND PARKING

Transcription

1 11 PARKING PRACTICE NOTES OCTOBER 2005 GORDON BELL CONTENTS WHAT ARE ORDERS USED FOR... 2 MAIN TYPES OF ORDER... 2 Permanent Orders... 2 Experimental Orders... 2 Temporary Traffic Orders...3 Notice Procedure for Amending Parking Charges...4 ORDER MAKING PROCEDURES... 4 Permanent Orders... 4 Publication of Proposals... 4 Consideration of Objections... 4 Public Inquiries...5 Making an Order... 5 Corrigenda...5 Experimental Orders... 5 Minor Orders... 6 Consolidation Orders... 6 Temporary Traffic Orders... 7 Documenting Orders...7 CONSULTATION... 7 Consultation with the Police...7 Other Statutory Consultees... 7 Costs... 8 Charging for Making Orders...8 REFERENCES AND FURTHER READING...8 APPENDIX...9 Table 1 - Notice of Proposals... 9 Table 2 - Notice of Making...9 Table 3 - Deposited Documents...10 TRAFFIC REGULATION ORDERS AND PARKING INTRODUCTION Most parking controls operate under Traffic Regulation Orders (TROs) made under the provisions of the Road Traffic Regulation Act 1984 ( the 1984 Act) as amended. Enforcement of the controls relies on the provisions of this Act and, for decriminalised parking operations, the Road Traffic Act 1991 ( the 1991 Act ), as amended. [NB.The provisions of the 1991 Act will be replaced, for authorities in England and Wales, by those in the Traffic Management Act 2004 when these are brought into force.] TROs are sometimes referred to as Traffic Management Orders. It is believed the latter term was developed for use in London, where S.6 of the 1984 Act applies as compared with S.1 elsewhere. This note is designed to offer an introduction to traffic regulation orders as they affect the parking or stopping of vehicles. It is not concerned with other orders, nor does it cover all aspects of the legislation. It does not, for example, deal with exceptional actions that can be taken with the consent of or under powers accorded to the Secretary of State. Nor does it deal with powers available to introduce orders to prohibit parking or carry out suspensions of parking places in relation to terrorist activities, as provided for in the Civil Contingencies Act 2004 and the Prevention of Terrorism (Additional Powers) Act (See References 8 and 9). Some restrictions and controls rely on national or local primary legislation - eg stopping in bus stop clearways, stopping within the controlled areas of pedestrian crossings or parking in contravention of the London-wide footway parking ban. Some authorities may control some aspects of parking through local bye-laws. 1

2 TROs are made by order making authorities. Powers vary according to type of local authority. Further explanation on this is beyond the scope of this note, but authorities need to determine for themselves the scope of their powers and any specific requirements for consultation with and/or approval by other authorities. A good, although slightly out-of-date, summary of powers is given in Appendix A of Colin Chick s On-Street Parking: A Guide to Practice (Reference 11). This note refers to the situation in England and Wales. Some references are made to the situation in Scotland, where known to be different. However, Scottish authorities should consult with Iain Gardiner at the Scottish Executive (iain.gardiner@scotland.gsi.gov.uk or tel ) on powers and procedures. The legislation can be complex and reference should always be made to the statutory provisions. WHAT ARE ORDERS USED FOR? Typical controls that can be introduced under the 1984 Act, which are relevant to the parking industry include: Waiting restrictions - which can be general or related to certain classes of vehicle e.g. commercial vehicles - and can apply at any time or at specified times e.g. Mon-Fri, Mon-Sat, the peak hours, the working day or overnight. Stopping prohibitions, e.g. at bus stops, outside schools, on footways/verges Loading/unloading prohibitions On-street parking places for: visitors - with or without a charge or time limit, controllable by parking meter, ticket machine, parking voucher, parking disc or simply by sign. permit holders - which can be for residents, businesses, traders, doctors, market traders, street traders, etc. blue badge holders. loading/unloading operations. police or ambulance vehicles. Taxis. motor-cycles [NB.These can also be provided by exemption to waiting and loading restriction orders.] pedal-cycles. Off-street parking places (i.e. car parks). TROs must be supported on the street by lines, markings and signs as prescribed by the Traffic Signs Regulations and General Directions 2002 (TSRGD 2002) (Reference 4), or as specially authorised by the Secretary of State for Transport or, in Scotland, the Scottish Ministers.There are no regulations for signs and lines in car parks. MAIN TYPES OF ORDER PERMANENT ORDERS The normal powers for introducing or changing parking controls are those provided in the following sections of the 1984 Act: Section 1 and, in London, Section 6 for on-street controls (except parking places with a charge). Typically, for parking, these sections of the Act allow authorities to introduce or amend waiting restrictions and loading/unloading prohibitions, free on-street parking places for particular classes of vehicle (e.g. disabled persons vehicles) or with a time limit, or loading places. Section 32 for free on-street parking places outside London (without charges) Section 35 for off-street parking places (car parks) Section 45 for on-street parking places (with or without a charge) Section 61 for off-street loading areas. Other sections of the Act provide supplementary provisions to these powers. Under these powers authorities need to advertise proposals, consider unresolved objections and then make an order before it can be brought into operation. [See under Order Making Procedures chapter.] EXPERIMENTAL ORDERS Instead of introducing changes under permanent powers, authorities may wish to consider using experimental powers to make traffic orders under the provisions of Sections 9 and 10 of the 1984 Act.These powers allow authorities to do everything allowed 2

3 under Ss 1, 6, 45, 46 or 49 of the 1984 Act, but restrict any controls imposed to a period of 18 months. The advantages of using experimental powers are: Authorities can make amendments to schemes quickly.this can be beneficial if a scheme produces unexpected effects. [For more on this see under Order Making Procedures below]. Residents and others affected by the order can consider their responses to a scheme under practical conditions, with up to six months of the making of the order (or six months after any changes are made) to make a formal objection. More speedy implementation. However, as paragraph 30 in the Department of Transport Local Authority Circular 5/96 (Welsh Office Circular 50/96), says:- Experimental orders should not be seen as a way of quickly making an order without going through the normal procedures for permanent orders of consultation, consideration of objections and, where required, the holding of a public inquiry before the order can be made.to avoid the possibility of a successful challenge in the High Court, an authority must be able to demonstrate where the element of experiment or uncertainty lies as an experimental order can only be made for the purposes of carrying out an experimental scheme of traffic control. The authority must provide a statement explaining why experimental powers are being used, and it is recommended by the author that any committee or similar report should incorporate and seek approval for such a statement. As noted above, experimental schemes can last for up to 18 months. An experimental order made for a shorter period (and which has been in continuous operation) can be extended to 18 months. Within that period: 6 months is allowed for formal objections to be made 12 months is allowed for changes to be made 18 months is allowed before the order must either be made permanent or revoked. If the 18-month period expires, the order becomes invalid. This 18-month period should be long enough to evaluate any experimental parking scheme. To overcome a possible legal challenge, one local authority officer recommends that no action should be taken on implementing an experimental scheme, particularly a parking scheme that can involve considerable expenditure, until the six-week High Court challenge period expires. Experimental orders cannot be used to introduce controls in off-street parking places (car parks) or amend those controls.the author asks whether provision for this should be made. In at least one case known to him, this would have been helpful. TEMPORARY TRAFFIC ORDERS Under the powers of S.14 of the 1984 Act, authorities can introduce temporary restrictions on parking by order to facilitate works on or near a road, cleansing operations, or as a consequence of the likelihood of danger to the public or damage to a road.these powers allow restrictions to be in place for up to 18 months. There are also powers to introduce temporary restrictions by notice where these are needed without delay. In this case, there are maximum periods of 5 or 21 days, depending on the reason for the restrictions. Authorities can also introduce restrictions by order under S.16A of the 1984 Act in order to facilitate a sporting, social or entertainment event held on a road. In London, S.9 of the London Local Authorities Act 1995 provides similar powers for off-road events. There are restrictions on the length of time of such restrictions and, for S.16A orders, the number of times in a year they can be imposed. For more information, readers are referred to the relevant legislation and procedure regulations. The above-mentioned powers are normally used, in relation to parking, to prevent parking on yellow lines, as temporary suspensions of parking places can normally be arranged by local authorities under the terms of their parking places orders (assuming those orders have a suitable clause providing the local authority with such powers). The police also have powers to suspend parking places, as well as temporarily suspend provisions of any order made under S.6 or S.9 of the 1984 Act, for up to 7 days in order to prevent or mitigate congestion or obstruction to traffic or danger to or from traffic in consequence of extraordinary circumstances. 3

4 NOTICE PROCEDURE FOR AMENDING PARKING CHARGES Increases in parking charges introduced by order can be made either by Amendment Order or, under section 35C or 46A of the 1984 Act (as appropriate), by a Notice of Variation. Making changes by notice means that objections to the changes need not be entertained, as would be the case if an amendment order were advertised. Changes can thus be made more quickly. [For more details see Reference 10]. There has been uncertainty as to whether this procedure also applies in the case of permit prices, but the general view of practitioners is that this is the case. ORDER MAKING PROCEDURES Procedures for making orders are prescribed in statutory instruments. For England and Wales, these are the Local Authorities Traffic Orders (Procedure) (England and Wales) Regulations 1996 and, in Scotland, the provisions of the Local Authorities Traffic Order (Procedure) (Scotland) Regulations 1999 apply. The regulations are detailed (covering for England and Wales, some 19 pages), but a summary of the main aspects follows. PERMANENT ORDERS PUBLICATION OF PROPOSALS The order making authority must: Publish in a local newspaper a notice of proposals. The information to be provided in this notice is detailed in Table 1 in the Appendix to this note. In London, publication of notices of proposals are also required in the London Gazette, but only in the case of an order under S.6 of the 1984 Act. Not later than the date of publication, send a copy of the notice of proposals to consultees. [For details on consultees, see section below on Consultation.] Place documents relating to the proposal on deposit from the date of publication until six weeks after the order is made, or the date the authority decide not to make the order.the deposited documents must be available for public inspection and must include the documents specified in Table 3. Authorities are required to take such steps as it may consider appropriate for ensuring that adequate publicity about the order is given to persons likely to be affected by its provisions.they may therefore wish to consider the provision of on-street notices and/or deliver letters or leaflets to households and other properties in the area likely to be affected.they might also want to provide details on their website. Authorities might also want to provide more than the statutory minimum details of the proposals to the statutory consultees. CONSIDERATION OF OBJECTIONS Objections can be made during a period of 21 days from the date of publication of the order or (if later) the date given in the notice of proposals or the date the authority has complied with the other statutory requirements for giving publicity to the order. Objections must be in writing and state the grounds of objection. There is a statutory requirement for authorities to consider objections. In the past, this has typically been a committee decision, but now with revised local government administration, alternative arrangements may have been put in place. In one authority, for example, decisions are delegated to a named officer, with reference to the Cabinet Member required in certain cases. In another, the decision is delegated to a Cabinet Member either in liaison with a specified officer or, for more complicated situations, following review by a panel or group constituted for the purpose. Different approaches could be taken for different types of order, or for substantial and nonsubstantial objections. Whatever the procedure, case law [ the Camden judgement - see reference 12] advocates that authorities should produce a written report on objections for consideration by the relevant decision maker. Authorities should consider and, wherever possible, include in these written reports any relevant objections received after the stated end of the objection period. Within 14 days of making an order, where there are unwithdrawn objections which have not wholly or partly been acceded to, an authority must write to objectors notifying them of the decision in relation to the objection and the reasons therefore. 4

5 PUBLIC INQUIRIES Although authorities can hold public inquiries before making any order, they are required to do so only where the proposal relates to prohibitions on loading and unloading before 7am, between 10am and 4pm, after 7pm or at all times and there are unwithdrawn objections (excluding frivolous and irrelevant objections which can be ignored). An inquiry is not required where the proposals relate to a prohibition on loading and unloading during the above-mentioned times: Within 15 metres of a junction, unless the effect would be to prevent loading/unloading for a total distance of 30 metres out of 50 metres on one side of any length of road. Where the installation of a disabled person s parking place is proposed. A public inquiry is not required where an experimental order is proposed, but will be required if relevant objections are made and it is proposed to make the order permanent. Where a public inquiry is held, an authority must consider the inspector s report and any recommendations made before making an order. MAKING AN ORDER Before bringing the provisions of an order into force, an authority must make the order (in effect having the order signed by the proper officer on a specified day), and within 14 days publish a notice (the notice of making ) in a local newspaper. London authorities are also required to publish the notice of making of all orders under S. 6 of the 1984 Act in the London Gazette. The notice of making must include the information outlined in Table 2, which includes a statement that anybody may apply to the High Court within a period of 6 weeks if they wish to question the validity of the order or procedures used. An order cannot be made until after the last day by which anybody may object. No order or any part of an order can be implemented before the date that an authority intends to publish the notice of making, or more than two years after the advertisement of the notice of proposals. There are provisions to make an order in part, with other parts abandoned, deferred or made at a later date. An authority can also make modifications, as long as the modifications do not (in its view) constitute a substantial change. Generally, this is interpreted as increasing the lengths of area under control, increasing the proposed times of control or increasing charges. If such changes are proposed, further consultation and consideration of representations is required. Orders are sometimes made with different commencement dates for different parts of the order, eg to allow equipment including signs and lines to be installed before the operational date for enforcement, although there does not appear to be specific provision for this. There are also provisions for remaking an order in cases where there has been or will be a delay in publishing the notice of making as a result, for example, of a newspaper strike. To save space, some authorities abridge their published notice of making by referring to details previously published in the notice of proposals (where unchanged). On making the order the authority must, as soon as possible, add the made order to the deposited documents, including the date on which it is to come into force. CORRIGENDA Where minor errors have been made in a notice or in an order, authorities have been known to produce and advertise Corrigenda, describing the errors and the corrections thereto.there is, however, no legal provision for such procedures. EXPERIMENTAL ORDERS There are a number of differences in the procedures for experimental orders. Most importantly, there is no need to advertise a notice of proposals, nor a requirement to consider objections (other than any from the police - see under Consultation below) before or on the making of the order. A notice of making is still required but here only 7 days must elapse between the date of publication and 5

6 implementation.the order and supporting documents need to be placed on deposit and made publicly available from the date of advertisement to the day the order ceases to have effect. The information to be published in the notice of making (in a local newspaper and, for London Authorities, the London Gazette) is generally similar to that required for permanent orders, but with some additions. See Table 2 for details. The notice of making must also include statements that the authority will be considering in due course whether the order will be made permanent, and that within the first six months of the operation of the order (or within six months of any variation or modification) any person may object in writing and with reasons to the indefinite continuation of the order. With regard to the deposited documents, these should include a statement of the reasons for proceeding by way of experimental order and a statement as to whether the authority intends to consider making a permanent order with the same effect.table 3 details the documentation requirements. S. 10 (2) of the 1984 Act provides for an experimental order to include a provision empowering a specified officer, in set circumstances, to modify or suspend the operation of the order or any provision of it. Such modifications cannot, however, extend to making additions to the order or to designating additional onstreet parking places for which charges are made. Any such changes must be preceded by consultation with the chief officer of police, and once made need to be properly documented and placed with the deposited documents. MAKING AN EXPERIMENTAL ORDER PERMANENT Where it is desired that an experimental order should continue in force indefinitely, either unchanged or as varied or modified in accordance with the 1984 Act and where all of the provisions of the procedure regulations have been complied with, an authority may make a permanent order having the same effect.this requires a notice of making similar to that needed for a permanent order. Before making the order, however, any objections made in the first six months of the operation of the experimental order must be considered by the authority in the same way that objections to a permanent order are dealt with. MINOR ORDERS The procedure regulations provide for some orders or changes to be made without the need to advertise the proposals or consult.these provisions include: Postponing the coming into force of any provision of an order for up to 6 months Substituting any references in an order to vehicles adapted to carry 12 passengers or more than 12 passengers to more than 8 passengers Changes to parking places (or waiting or loading restrictions/prohibitions) to accommodate the zigzag marking associated with pedestrian crossings Changes to an order consequential to the setting up of a permitted or special parking area Changes to an order authorising a person to remove or arrange for the removal of a vehicle from a parking place Changes to an order allowing payment to be made in a parking place by an alternative method of payment Making an off-street loading places order under S. 61 of the 1984 Act Provision in roads or elsewhere of stands and racks for bicycles In order to bring a minor order into effect, an authority must publish a notice in a local newspaper within 14 days of the order being made.table 2 details the information to be shown in the notice of making. The order cannot be brought into effect until 14 days after the date of publication of the notice. Documents relating to the order must be placed on deposit for a period of 6 weeks after the date of publication of the notice.table 3 details the requirements for deposited documents. CONSOLIDATION ORDERS Consolidation orders revoke the provisions of existing orders and re-enact them with no substantive change, 6

7 other than those provided for under the minor orders procedure (as described above).these can also be made without the need to advertise the proposals or consult. The procedures are similar to those required for minor orders, except that the notice must include a list of the orders consolidated by the order, and there should be a statement of the effect of any (allowable) minor changes made. The order cannot be brought into effect until after the date of publication of the notice. It is desirable to make consolidation orders on a regular basis. Even with a few amendment orders, interpreting TROs can be difficult and time consuming. Adjudicators have drawn attention to the need to carry out regular consolidation of orders.there can be no hard and fast rule on the frequency of this, but the author would recommend that orders subject to frequent and substantial amendment such as Waiting and Loading orders and Disabled Persons Parking Places orders should be consolidated every 3-4 years. A number of authorities keep ghost orders incorporating all amendments into an electronic copy of the original order.this can significantly ease the interpreting of orders and the making of amendment orders, and at the same time, makes consolidation when it is done, an easy task. TEMPORARY TRAFFIC ORDERS For the procedures dealing with temporary traffic orders and notices under S. 14 of the 1984 Act please refer to Reference 7. There are no procedure regulations for making orders under S. 16A of the 1984 Act or S. 9 of 1995 London Local Authorities Act. Authorities are advised when using these powers to act as they would for S. 14 orders. DOCUMENTING ORDERS It used to be common practice to seal orders, but nowadays most authorities simply have the orders signed by a proper officer. It is essential that rugged office procedures are adopted for the recording of all aspects of the order making procedure.there is a danger that without such procedures, it can be difficult or impossible to prove what constitutes the original order.there is perhaps always the danger that an order might be electronically altered in order to support a particular standpoint. The strict procedures needed for the hard copies of orders need to be similarly applied to the electronic files holding the orders. It is not unknown for the electronic versions of orders to be lost, over-written or corrupted, so that they have to be copy-typed, with the consequent danger of introducing errors which can easily go unnoticed. Changes in word-processing systems can also cause problems. Authorities should remember to file with their orders any relevant notices of variation made under S35C and 45A of the 1984 Act, and any other relevant amending orders. Not doing this has been known to introduce errors when consolidating orders. CONSULTATION CONSULTATION WITH THE POLICE Paragraph 20 of Schedule 9 to the 1984 Act requires consultation with the chief officer of police of the area before any order is made or modified. OTHER STATUTORY CONSULTEES In England and Wales, except for minor and consolidation orders, authorities must in all cases consult: Freight Transport Association (FTA) Road Haulage Association (RHA) Organisations representing persons likely to be affected by the proposals.this is likely to include groups or organisations representing local residents and businesses, pedestrians, cyclists, motorists, and disabled persons. [NB.The importance of this requirement is illustrated by the Camden case (Reference 12) referred to above. In this case the judge ruled that the Council had failed to consult with an open mind and that there had been inadequate consultation with and consideration of representations by a local group. As a result the appeal to the High Court was upheld and the designation order quashed. Further comment on this judgement is beyond the scope of 7

8 this note. However, it is essential reading for those consulting on CPZ or other designated parking schemes.] In addition, where the proposed order relates to or is likely to affect traffic on a road or, in the case of emergency vehicles the passage of their vehicles, the authority must consult: On a road managed by another traffic or highway authority, a Crown road or a road subject to a concession, that other authority, the Crown authority or the concessionaire On a road served by bus, trolley or tramcar routes, the service operator and (in London) Transport for London On a road where the passage of ambulances or fire-fighting vehicles might be affected, the ambulance or fire authority. All consultation should be in writing. In Scotland, the list of statutory consultees is contained in regulation 4 of the Local Authorities Traffic Orders (Procedure) (Scotland) Regulations COSTS The costs associated with TROs comprise of advertising, publicity and staff costs.the latter can include costs of order-making officers and technical officers promoting and dealing with objections to orders. CHARGING FOR MAKING ORDERS REFERENCES AND FURTHER READING 1. Road Traffic Regulation Act 1984 (Chapter 27) 2. Road Traffic Act 1991 (Chapter 40) 3. The Traffic Management Act 2004 (Chapter 18) 4. The Traffic Signs Regulations and General Directions 2002, [SI 2002 No. 3113] 5. The Local Authorities Traffic Orders (Procedure) (England and Wales) Regulations 1996, [SI 1996 No. 2489], and the Local Authorities Traffic Order (Procedure) (Scotland) Regulations 1999, [SI 1999 No. 614 (S.38)] 6. New procedures for traffic orders: guidance on the Local Authorities Traffic Orders (Procedure) (England and Wales) Regulations 1996, Department of Transport, Local Authority Circular 5/96 (Welsh Office Circular 50/96), October The Road Traffic (Temporary Restrictions) Procedure Regulations 1992, [SI 1992 No. 1215] 8. The Prevention of Terrorism (Additional Powers) Act 1996 (Chapter 7) 9. The Civil Contingencies Act 2004 (Chapter 36) 10. Parking Practice Note No 1, Charging for Parking, British Parking Association 11. On-Street Parking: A Guide to Practice, Colin Chick, Landor Publishing, Regina v Camden London Borough Council. Ex Parte Cran and Others (1995) (RTR 346) Local authorities may recover their charges for making orders in certain circumstances. For more details see Reference 10. Gordon Bell is a parking engineer with the London Borough of Richmond upon Thames. He is also a Council member of the BPA. He would welcome comments or suggestions on this paper for incorporation into any future revision. Please send any comments to the BPA, kelvin.r@britishparking.co.uk, putting feedback on PPN11 in the subject field. 8

9 APPENDIX - DETAILS TO BE PROVIDED IN NOTICES AND DOCUMENTS TO BE PLACED ON DEPOSIT TABLE 1 - NOTICE OF PROPOSALS TYPE OF ORDER Details to be included (shown by *) Permanent Experimental Minor Consolidation The name of the authority The title of the order A statement of the general nature and effect of the order The name or description of any road or roads affected by the order, and where appropriate the lengths of road affected For an off-street parking place or loading area, a description of the place or area and location For a parking place where charges or restrictions on times of use or classes of vehicle are proposed, a description of those aspects A statement that more detailed particulars are available, and where and when these documents can be inspected. A statement that objections and other representations must be made in writing and that objections must state the grounds of objection The date by which such objections or representations should be received, and the address to which they must be sent Where appropriate, details concerning any public inquiry that is proposed TABLE 2 - NOTICE OF MAKING TYPE OF ORDER Details to be included (shown by *) Permanent Experimental Minor Consolidation The name of the authority * * * * The title of the order * * * * A statement of the general nature and effect of the order * * * * The name or description of any road or roads affected by the order, and where appropriate the lengths of road affected * * For an off-street parking place or loading area, a description of the place or area and location * N/A For a parking place where charges or restrictions on times of use or classes of vehicle are proposed, a description of those aspects * * A statement that more detailed particulars are available, and where and when these documents can be inspected * * * A statement that the authority will be considering in due course whether the order will be made permanent N/A * A statement that within the first six months of the operation of the order (or within six months of any variation or modification) any person may object in writing and with reasons to the indefinite N/A * continuation of the order The date the order comes into force * * A statement that anybody may apply to the High Court within a period of 6 weeks if they wish to question the validity of the order or procedures used * * A list of the orders consolidated by the order * A statement of the effect of any changes made under the Minor Orders provisions * 9

10 TABLE 3 - DEPOSITED DOCUMENTS TYPE OF ORDER Documents to be included (shown by *) Permanent # Experimental Minor Consolidation A copy of the notice of proposals * A copy of the notice of making * * * * A copy of the proposed order # # * * * * The date the order is to come into force * * A copy of the orders to be amended * * * * A map showing the location and effect of the order # # * * * * A statement why the authority proposed to make the order * * * * A statement of the reasons for proceeding by way of experimental order A statement as to whether the authority intends to consider making a permanent order with the same effect Where an experimental order has been modified, details of such changes Where a public inquiry has been held, a copy of the inspector's report and recommendations * * * * # With the exception of the reference to the notice of proposals, these requirements also apply to making permanent an experimental order. # # Not required where the order - - simply revokes another order - changes the charges, time limits or other conditions relating to the use of a parking place. 10

11 These Parking Practice Notes are believed to contain accurate and current information and are published by the BPA in good faith. They are, however, intended for guidance and not as a substitute for appropriate specialist advice. Neither the BPA nor the author can accept any responsibility or liability for any omissions or errors that these Notes may contain. Any views expressed in this paper are those of the author. Price: 10 Non-Members 5 Members British Parking Association Stuart House Perrymount Road Haywards Heath West Sussex RH16 3BN Tel: +44 (0) Fax: +44 (0) info@britishparking.co.uk British Parking Association, Gordon Bell, 2005