The Executive (or which (Sub-) Committee)

Officer delegated decision Date June 2007

Introduction of a vehicle emission based charging regime for residents parking permits

Item XX

All Wards

Report authorised by: Robert Overall, Executive Director-Environment, Culture & Community Safety

Executive summary

On 21 May 2007 the Executive Director approved the undertaking of appropriate consultation and to the advertising of Traffic Orders in the association with the introduction of new charges and a new charging regime, based on vehicle emissions, for residents parking permits.

This report outlines the representations received to the consultation, including the statutory consultation in association with the Traffic Order process.

The report considers those representations in the context of the proposals and recommends that the Executive Director approves the introduction of the new charges and charging regime.

Summary of financial implications

The financial implications arising from this report are as set out in detail within section 4 of the delegated report agreed by the Executive Director on 21^st May 2007. It is estimated the introduction of the regime described would result in an estimated additional (net) income of £957,000 in a full year.

Accordingly it is estimated that introduction of the proposal would result in additional (net) income of £675,000 in 2007/08 and £281,000 in 2008/09.

Recommendations

That, having given consideration to the representations received and discussed in this report, the Executive Director for Environment, Culture and Community Safety agrees to the introduction of the charges and regime as described within this report on or shortly after 1^st July 2007.

I agree the above recommendations:

Signature _____________________________ Date ______________________

Post ___________________________________________________________

Any declarations of interest (or exemptions granted):

Issue	Interest declared

Consultation

Name of consultee

Directorate or Organisation

Date sent to consultee

Date response received from consultee

Comments appear in report para:

Internal

Mike Dickens	Head of Legal Services	21.06.07	21.06.07	5.1
Bev Winter	Divisional Director (Resources) - Environment, Culture & Community Safety	21.06.07
Cllr Lib Peck	Cabinet Member - Environment, Culture & Community Safety	21.06.07
Cllr Nigel Haselden	Deputy Cabinet Member (Highways & Traffic)	21.06.07

Entered in Consultation and Events Diary?

If yes, date

N/A

Report history

Decision type:

Urgency item?

Key decision

Entered in Forward Plan: February 2007

Authorised by Cabinet member:

Date report drafted:

Report deadline:

Date report sent:

Dec 2006

20.06.07

N/A

Report author and contact for queries:

Tim Jackson, Assistant Director - Street Management

020 7926 1236 [email address]

Background documents

Delegated officer decision report: Introduction of a vehicle emission-based charging regime for residents parking permits: May 2007 (approved 21 May 2007) and documents listed in that report.

Appendices

Appendix A - Proposal Charges.

Appendix B - Summary of all representations received.

Introduction of a vehicle emission-based charging regime for residents parking permits

Context

The proposed (emission based resident parking permit) regime and charges that form the subject of this report were included within appendices which were approved by Cabinet on 8 January and 8 February 2007 and subsequently by Council on 27 February 2007 as part of the 2007/08 budget setting process.
The proposals were subject to scrutiny at the meeting of the Environment, Culture and Community Safety Scrutiny Committee on 2 February 2007.
Consistent with the Scheme of Delegation, a report was subsequently made to, and approved by, the Executive Director for Environment, Culture & Community Safety on 21 May 2007.

That report provided approval to the undertaking of appropriate consultation and the advertising of Traffic Orders in association with the proposed introduction of new charges and a new (vehicle emission based) charging regime for residents parking permits.

The proposed charging regime is detailed at Appendix A.

Consequent to the decision made on 21 May 2007, the necessary statutory consultation associated with the making of the appropriate Traffic Orders, necessary to effect the proposed regime, has been undertaken.

The statutory consultation comprised the displaying of street notices on every road within existing controlled parking zones, the publication of notices in the press and consultation with statutory consultees (principally the emergency services).

The statutory consultation period commenced on 29 May 2007 and closed on 19 June 2007.

In addition to the statutory process, arrangements have been made to allow interested parties to consider the proposal and make representations regarding them.

These arrangements effectively commenced when the proposals were put in the public domain by means of the initial reports to Cabinet and Council. However, this engagement was supplemented by a letter to all businesses and residents in controlled parking zones (distributed early May 2007), an article in Lambeth Life (February edition), details in the “Parking Newsletter” (distributed to all existing permit holders May 2007) and information on the Council's website.

Arrangements were made for representations to be received by post and e-mail at addresses identified within the information provided.

The delegated officer decision report of 21 May 2007 agreed that the Executive Director would consider all representations received in relation to the proposal prior to deciding whether or not to introduce the proposed regime.

This report details the representations received and provides that consideration.

Results of consultation

A total of 95 representations were received in response to the proposals.

12 representations were received in direct response to the statutory consultation associated with the Traffic Orders.

83 representations were received in response to details of the proposals provided through the other consultation/engagement mechanisms described in 1.5.

One of the responses stated unreserved support for the proposals and hence the remainder can be construed as objections. Sixteen (17%) of the responses stated that they were generally supportive of the concept. Three (3%) of responses stated that they were wholly supportive but that the structure should be revised.

Details of the representations are summarised in Appendix B.

All of the representations received were from current permit holding residents.

No feedback was received from businesses or residents without access to a vehicle.

There are approximately 21,300 (full year equivalent) resident parking permit holders in the Borough. Thus objections have been received from approximately 0.4% of permit holders.

There are approximately 64,000 households within that part of Lambeth covered by controlled parking zones. Thus objections have been received from approximately 0.14% of households.

Of those representations received in the form of objections to the proposals, there were a number of recurring grounds for the objections. These were:

that the proposals are disingenuous (i.e. that they purport to be part of a strategy to combat climate change but are actually not so);
that the proposals are (wholly) revenue driven;
that it is perverse to seek to reduce emissions by imposing a regime of charges around parked cars;
that the regime penalises residents who act responsibly (limiting their car use) and should be related to actual car usage (mileage covered);
that the proposed charges are too high;
that the regime disproportionately impacts on large families, those on fixed incomes and/or the less well off (who tend to have older/larger cars);
that the regime discriminates against residents in controlled parking zones;
that the consultation on the proposals has been inadequate;
that the proposal will encourage car change and increase the overall carbon footprint;
that the proposals are unlawful in that they are a retrospective tax.

Of those representations received in the form of support for the proposals, the recurring theme was that the charging structure provides insufficient incentive to influence residents' decisions.

A number of supportive respondents were concerned that the lowest “standard” low emission vehicles available (other than electric cars) will not fall within the lowest charging band.

A number of supportive respondents were concerned about the lack of physical infrastructure (charging points etc) to subject electric cars.

3. Consideration of objections

3.1 “Proposal is disingenuous”.

The report to the Executive Director (May 2007) and appendices to the Council decision (27 February 2007) clearly set out the transport and environmental context within which the proposals are framed. In particular all previous documentation has stated that “the current charges fail to provided sufficient encouragement for residents to own vehicles that cause less environmental damage through CO₂emissions or to discourage those residents who use less environmentally friendly vehicles”.

The proposals sit within a wider framework of combating climate change through the support of sustainable transport use, car clubs etc.

3.2 “Proposals are (wholly) revenue driven”.

It is not lawful for a Council to use the Road Traffic Act 1984 to impose charges simply to raise revenue. The report to the Executive Director (May 2007) and the appendices to the Council decision (February 2007) refer to that being the case and clearly outline the transport and environment policy objectives behind the proposals.

3.3 “It is perverse to charge for parking”.

The cost of parking is part of the overall cost of motoring and, as a consequence, parking charges are a factor in ownership decisions. The situation is similar to the vehicle excise licence differential charges (a licence is required to place the vehicle on the public highway regardless of whether or not it is driven).

“The regime should be designed around car usage”.

In the longer term, it may be possible to develop a regime that influences behaviour by considering both car use and type of vehicle. However, such a regime would be complex to devise and require increased administration. A regime based around car usage only would not necessarily encourage consideration of the CO₂emissions

“The proposed charges are too high”.

The charges are reasonable when considered in the context of the overall cost of motoring (they equate to between 60p and £3.85 per week). They bring charges in Lambeth more broadly in line with other boroughs with similar parking conditions and practices. At the same time the proposals provide sufficient financial incentive for residents to consider emissions when considering replacement or a new purchase of a car.

“The regime disproportionately impacts on larger families, those on fixed incomes and the less well off.”

Precise information about the car ownership profile amongst existing permit holders is not available, but it is estimated that around 7.5% of permit holders will fall into the highest payment bands (6 and 9).

Car owner ownership levels amongst those on fixed incomes and the less well off in Lambeth is relatively low (car ownership in Lambeth is typically below the London average) and consequently the proposals will not affect a significant proportion of residents in that category. The cost of parking is an integral part of the cost of motoring and a factor in lifestyle decisions for all residents - including large families. There is often a range of vehicles that could accommodate the lifestyle of larger families and some cars have lower emissions than others.

“The regime discriminates against residents in controlled parking zones”.

The Council is currently not in a position to apply the charges outside of controlled parking zones. Controlled parking zones are introduced after extensive consultation and with the support of residents who currently benefit from the advantage of controlled parking, albeit whilst being charged for permits. In the longer term, the Council will seek to use any powers it is given to influence emissions and car ownership across the borough.

“Consultation has been inadequate”

The consultation arrangements employed are described in Section 1 of this report.

The statutory consultation procedure required in relation to the necessary Traffic Order has been fully complied with and included in the displaying of a notice on every street within controlled parking zones.

The proposals have been in the public domain, initially in outline and then in detail, for a number of months. A mechanism is available to receive any representations and Appendix B illustrates that it has been successfully used.

The purpose of this report is to give proper consideration to all representations received. The Head of Legal Services has previously advised that the arrangements put in place have been adequate.

3.9 “The proposal will encourage car change and increase the overall carbon footprint”.

Parking charges are a relatively small proportion in the cost of a car purchase. Whilst the aim of the proposed regime is to influence decisions about the type of car purchased (or whether to own a car at all), it is considered most unlikely that the charges alone would precipitate car changing on a significant scale and consequently increase the overall carbon footprint due to an increase in the number of vehicles. Similarly it is considered unlikely that residents would increase car usage to get “value for money” from their permits.

The proposals are unlawful in that they are a retrospective tax”.

Richmond Council introduced a similar scheme earlier this year and this was not challenged subsequently. Counsel for Richmond advised, prior to implementation of the Richmond scheme, that there was no reason, in principle, why the changes should not, as a matter of law, be implemented. The advice provided by the Head of Legal Services with regard to the Lambeth proposal was consistent with that view and was summarised in the report to the Executive Director (May 2007).

4. Consideration of supportive representations

“Structure of regime provides too little incentive for change”.

The structure incorporates a range of charges (from £30 to £200), which sends a clear message to residents around car emissions. The introduction of emission based charging regimes represents new ground for all councils and the effectiveness will have to be monitored over time. The council will need to review the outcome of the regime against the stated policy objectives and consider adjusting the structure if those policy objectives are not being achieved.

4.2 “The most commonly accepted low emission car (other than an electric car) is not in the lowest charging band”.

The charging structure has been based on the DVLA “VED” banding structure for general consistency with Central Government and other boroughs' regimes. It is anticipated that, in time, more vehicles will be available in Band A.

4.3 “Too few electric car charging points.”

The council is working with TfL to introduce additional charging points in the borough and will support residents seeking to install charging points as part of their car ownership decisions.

Legal Powers

The Council is empowered by the Road Traffic Regulation Act 1984 (as amended) and the Road Traffic Act 1991 to provide parking places on and off the highway and to charge for their use.

Section 45 (!) of the Road Traffic Regulation Act 1984 (RTRA) provides the power to designate by order, on-street parking places. Sections 45 (2) (b) and 46 (2) (i) of the RTRA extend the means to charge for such parking places.

The proposed emission-based residents' parking permit regime would be introduced by making a Traffic Regulation Order (TRO) under the RTRA. The procedure for doing this is set out in the Local Authorities Traffic Orders (Procedure) (England and Wales) Regulations 1996.

This requires:

consultation with organisations representing persons who use any road to which the Order relates, or are likely to be otherwise affected;
publication of proposals and providing documents for inspection;
inviting written objections to proposals following publication;
consideration of objections made.

Section 122 (1) of the RTRA specifies that an Authority has a duty “…to exercise the functions conferred on them by this Act as (so far as practicable having regard to the matters specified in subsection (2) below to secure the expeditious, convenient and safe movement of vehicular and other traffic (including pedestrians) and the provision of suitable and adequate parking facilities on and off the highway”.

Some of the matters specified at Section 122 (2) include:

the effect on amenities of any locality;

the strategy prepared under Section 80 of the Environment Act 1995 (Air Quality Strategy) and

(d) any other matters appearing to the local authority to be relevant.

Sections 122 (2) (bb) and (d) therefore permit the Authority to consider Air Quality and Environmental matters when determining the parameters of a new parking scheme.

Sections 45 of the RTRA permits differential charging based on vehicular emissions and that regard may be had to environmental considerations in creating a parking regime under the RTRA.

Furthermore, local authorities have well-being powers under the Local Government Act 2000. These are wide-ranging powers which allow authorities to do anything which they consider is likely to achieve objectives listed and which include the promotion or improvement of the environmental well-being of their area.

The Scheme of Delegation to Officers, as approved by Council at its Annual Meeting on 24^th May 2007, empowers Executive Directors to approve fees and charges for departmental services (unless otherwise reserved to Cabinet) in consultation with the relevant Cabinet Member and with the agreement of the Executive Director of Finance & Resources.

The proposed (emission based resident parking permit) regime and charges that form the subject of this report were included within the appendices which were approved by Cabinet on the 8^th January and 8^th February 2007 and Council on 27^th February 2007 and have therefore been authorised. They were also the subject of scrutiny at the meeting of the Environment & Community Safety Scrutiny Sub-Committee on 2^nd February 2007.

The powers to advertise and subsequently make the Traffic Orders (subject to proper consideration of all objections received) that are required to introduce the charges set out in his report are expressly delegated to officers in Environment, Culture & Community Safety, as set out in the Scheme of Delegation The legal powers associated with this proposal are as detailed in the report to the Executive Director (May 2007).

6. Recommendations

The Executive Director for Environment, Culture & Community Safety is recommended, after proper consideration of the matters raised by way of objections and representations and summarised in Section 2.3 and Appendix B and discussed in detail in Sections 3.0 and 4.0 above and in the context of the policy and other reasons for the proposal as set out in early reports, to agree to the introduction of the charges and regime (described in this report and shown in Appendix A) on or shortly after 1 July 2007.

APPENDIX A

Proposal charges - annual residents' parking permit

For vehicles registered on or after 1^st March 2001:

Lambeth charging band	1	2	3	4	5	6
DVLA “VED” band	A	B	C & D	E	F	G
CO₂ emission figure	Up to 100	101-120	121-165	166-185	186-225	225+
Permit charge (per annum)	£30	£100	£115	£130	£160	£200

For vehicles registered before 1^st March 2001:

Lambeth charging band	7	8	9
Engine size	Less than 1550 cc	1550-3000 cc	Greater than 3000 cc
Permit charge (per annum)	£115	£130	£200

For vehicles owned by residents living within the central London Congestion Charging Zone:

As (i) and (ii) above less £10.00

For vehicles retro-converted to dual (petrol/LPG) fuel

Charged one band lower than the standard non-converted band.

(v) Proposed residents' parking permit charges - for periods less than 1 year

The charge shall be pro rata the annual charge shown in Appendix D. rounded up to the nearest £ with the addition of an administrative fee as follows:

	Additional fee (£)
For permits of 1 month	4.60
For permits of 3 months	3.75
For permits of 6 months	2.50

APPENDIX B: SUMMARY OF REPRESENTATIONS RECEIVED

No	Address	Resident or business or other	Response to	Representation
1	Poynders Rd	R	S	Fully supportive but fees for higher emission vehicles should be higher.
2	Roupell Street	R	S	Supportive but structure provides too little incentive for change. Regime should be related to car use.
3	Not provided	R	S	Charges disproportionate.
4	Hannington Road	R	S	Disingenuous tax. Regime should relate to car use.
5	Brixton Road	R	S	Disingenuous tax. Regime should relate to car use. Not appropriate to charge for parking.
6	Railton Road	R	S	Increases too high. Charges do not provide guarantee safe parking spaces
7	Not provided	R	S	Increases too high. Revenue driven. Disingenuous proposal.
8	Gilbert Road	R	S	Inadequate analysis of impact undertaken: charges not aligned (cf Wandsworth). Will adversely affect poorer residents with older vehicles.
9	Grantham Rd	R	S	Increases too high for average vehicle. Disingenuous proposal. Council's duty is to provide statutory services.
10	Haverhill Road	R	S	Climate change not proven. Revenue driven. Regime unfair - does not impact on residents with off road parking. Insufficient alternatives to car use available. Not appropriate to charge for parked vehicles. Will adversely affect larger families. Inadequate consultation.
11	Dulwich Road	R	S	Disproportionate effect on drivers with low car use. Consultation should have been via direct mail.
12	Elms Crescent	R	S	Supportive of concept. Appears revenue driven. Regime provides too little incentive. Regime does not relate to car use.
13	Arlingford Road	R	S	Inadequate consultation Disingenuous proposal Alternative mechanisms (mileage or fuel use related or cheaper public transport) should be utilised.
14	Tradescant Rd	R	S	General queries.
15	Dulwich Road	R	S	Insufficient consultation (should have notified residents by letter). Disproportionately impacts on residents with low car use.
16	Dulwich Road	R	S	As 15.
17	Methley Street	R	G	Supportive but regime does not encourage low emission vehicles sufficiently. Banding appears arbitrary.
18	Not provided	R	G	Proposal fails to support increased use of motorcycles (by providing adequate parking facilities).
19	Thornton resident	R	G	Disingenuous and unjustified. Controls in Thornton imposed without support.
20	Not provided	R	G	Disingenuous proposal. Additional revenue should go into climate changing initiatives not the transport related schemes quoted.
21	Fitzwilliam Rd	R	G	Supportive of measures to reduce emissions but proposals unfair, disproportionate and discriminatory. Inappropriate for local government to tax. Retrospective and fails to recognise car use. Revenue driven. Not appropriate to charge for parking.
22	Thornton Ward resident	R	G	Disingenuous proposal. Revenue driven.
23	Thornton Ward resident	R	G	Supportive but structure flawed. Facilities for electric cars not available. Will be seen as revenue driven.
24	Edgeley Road	R	G	Increases too high. Increased revenue should be met by improved enforcement.
25	SE11	R	G	Not appropriate to charge for parked vehicles. Disproportionately affects those with no off street parking.
26	-	R	G	Not appropriate to charge for parked vehicles. Revenue driven.
27	-	R	G	Will different colours be used to identify different payment bands?
28	Not provided	R	G	Proposal serves no purpose. Not appropriate to charge for parked vehicles. Discriminates against residents in CPZ areas. Increases too high.
29	Not provided.	R	G	Generally supportive but increases for middle band too high. Proposal should be revenue neutral.
30	Grantham Road	R	G	Increases too high - unfair.
31	Brixton resident	R	G	Query about operation
32	Grimsworth Road	R	G	Increased charges disproportionate (compared to elsewhere).
33	Not provided.	R	G	Increases too high. Not appropriate to charge for parked vehicles. Legality questioned.
34	Not provided	R	G	Inadequate consultation. Flawed logic - won't work. Penalises those with low mileage. Revenue driven.
35	Haverhill Road	R	G	Recognise need to reduce emissions. Not appropriate to charge for parked vehicles. Increases too high.
36	Not provided	R	G	Increases too high considering too little parking space in my vicinity.
37	Not provided.	R	G	Supportive of concept. Charging structure will not affect change. Proposal should relate to mileage.
38	Crescent Lane	R	G	Disingenuous proposal. Proposal should relate to mileage.
39	SW8	R	G	Proposal should relate to mileage.
40	Not provided.	R	G	Insufficient encouragement for lower emission vehicles. Inadequate provision for electric vehicles.
41	Not provided.	R	G	Revenue driven/disingenuous. Proposal should relate to mileage.
42	Not provided.	R	G	Disingenuous proposal. Proposal should relate to mileage.
43	Thorne Road	R	G	Proposal should relate to mileage. Proposal doesn't consider overall carbon footprint associated with changing vehicles.
44	Elm Park (CPZ) resident	R	G	Supportive of concept but increases too high.
45	Baytree Road	R	G	Increases preposterous and concept disingenuous.
46	Clapham Common North Side	R	G	Proposal should relate to mileage. Inappropriate to charge for parked vehicles.
47	Sancroft Street	R	G	Inappropriate to charge for parked vehicles. Increases to high - cannot afford it. Proposal should relate to mileage.
48	St Marys Gardens	R	G	Flawed proposal. Inappropriate to charge for parked vehicles. Discriminates against residents in CPZ areas. Increases too high.
49	Not provided.			Disingenuous proposal.
50	Not provided.	R	G	Flawed proposal. Proposal doesn't consider overall carbon footprint associated with changing vehicles.
51	Not provided.	R	G	Disingenuous proposal - stealth tax.
52	Not provided.	R	G	Disingenuous proposal. Irrelevant to compare with others. Flawed charging structure. Increases not justified.
53	Queensville Road	R	G	Too expensive - especially in CPZs with two hour controls.
54	Not provided.	R	G	Will disproportionately affect the less wealthy. Inadequate consultation.
55	Arodene Road	R	G	Increases too high. Penalises those who rely on cars and unable to change vehicles.
56	Not provided.	R	G	Support concept but: Inadequate consultation. Discriminates against those residents in CPZs. Not practical to charge. Increases too high.
57	Not provided.	R	G	Supportive of concept but structure flawed. Fails to consider car use mileage. Open to challenge. Appears revenue driven.
58	Trinity Gardens	R	G	Increase excessive. Revenue driven.
59	Not provided.	R	G	Supportive of concept but: Inadequate consultation
60	Not provided.	R	G	Imperfect proposal fails to recognise new car spiral. Disingenuous proposal. Revenue driven.
61	Not provided.	R	G	Disingenuous proposal. Revenue driven. Affects drivers with low mileage.
62	Bromfelde Road	R	S	Proposal is unlawful in that it is a retrospective tax. Proposal will disproportionately affect larger families. Inappropriate to charge parked cars. Revenue driven.
63	Not provided.	R	G	Flawed logic - should make it easier to park where public transport is good.
64	Jeffreys Road	R	G	Fails to sufficiently encourage ownership of lower emission vehicles. Disingenuous proposal.
65	Not provided.	R	G	Not justified. Proposals should relate to car use/mileage.
66	Not provided	R	G	Unfair increase.
67	Pentney Road	R	G	Disproportionately impacts on responsible, low car use residents
68	Fitzwilliam Road			Inadequate consultation. Supportive of concept but “ultra vires”
69	Not provided.			Unreasonable to increase without staging. Disproportionately affects those with low car usage.
70	Not provided	R	G	Disingenuous proposal. Penalises families who use cars infrequently. Revenue driven.
71	Not provided.	R	G	Disproportionately affects the average resident. Flawed concept.
72	Pentney Road	R	S	Supportive of concept but: Disproportionately affects larger families with low car use. Should address multiple car ownership.
73	Ferndale Road	R	G	Inadequate consultation. Not appropriate to charge for parked vehicles Disproportionately affects residents with low, essential car use.
74	Not provided.	R	G	Disingenuous proposal. Not appropriate to charge for parked vehicles. Discriminates against poorer residents without ability to change vehicles or park off street. Traffic management activity inconsistent with stated aim.
75	Not provided.	R	G	Revenue driven. Disingenuous proposal.
76	Not provided.	R	G	Proposal not justified and hurriedly - should have been introduced incrementally. Standard of service does not justify increases.
77	Mayall Road	R	G	Disingenuous proposal. Revenue driven.
78	Not provided.	R	G	Increases not justified. Disproportionately affects residents with low car use. Will encourage new car purchase.
79	Hyde Farm Area	R	G	Disproportionate affect on families with need for cars. Not appropriate to charge for parked vehicles. Disproportionately impacts on residents in CPZs.
80	Hydethorpe Road	R	G	Inadequate publicity/consultation. Revenue driven.
81	Hazelbourne Road	R	S	Disproportionate impact on residents with low car usage. Concept flawed. Charges not broadly in line with neighbouring Boroughs (Wandsworth).
82	Not provided.	R	G	Disingenuous proposal. Revenue driven. Pollution in Lambeth not caused solely by residents - by all road users. Issue should be addressed by Government.
83	Regent Road	R	G	Increases not justified. Disproportionate effect on larger families. Proposals should relate to car use.
84	Walcott Square	R	G	Flawed banding structure, particularly in relation to older vehicles.
85	Concanon Road	R	G	Flawed proposal which will impact on low car use residents and drive up usage. Disproportionate impact on older vehicles and hence elderly and low income residents. Proposals should relate to car usage.
86	Helix Road	R	S	Previously advised that permit charges would not increase for 7 years. Proposals should relate to car usage.
87	Tasman Road	R	S	Disingenuous proposal. Revenue driven.
88	Haverhill Road	R	S	Unacceptable increase. Disproportionately impacts on residents in CPZs and families requiring larger vehicles but have low mileage. Revenue driven. Should increase charges for multiple car owning residents.
89	Not provided.	R	G	Supportive of concept but should be revenue neutral. Disproportionately impacts on residents in CPZs.
90	Not provided	R	G	Regime should be related to car use. Should apply only as car is replaced.
91	Not provided	R	G	Should have exemption for historic vehicles.
92	Robertson Street	R	G	Supportive of concept but increases too high.
93	Not provided.	R	G	Supportive.
94	Burnbury Road	R	G	Disproportionately impacts on the elderly.
95	Kimberley Road	R	G	Increases not justified. Disproportionately impacts on the elderly.

Notes

Column 4: S - response to statutory consultation

G - response to other engagement mechanism

Representations have been summarised and paraphrased for brevity

Introduction of a vehicle emission-based charging regime for residents parking permits 20

Report title here in Arial 8pitch