Following a recent meeting of the Rye Business Forum, where the main topic of the meeting was the recently-announced implementation plan for civil parking enforcement (CPE), the forum chairman Cllr. Rebekah Gilbert wrote to East Sussex County Council, who are controlling CPE and has received the following letter in return.
“Dear Dr Gilbert
The comments and suggestions you make on behalf of the Rye Business Forum have been added to the consultation feedback already received. For ease of reference I will answer each of the points you have raised in turn.
Last night we held a Business Forum meeting and, of those who attended, there was universal disapproval of the scheme.
It would be helpful to know how many members were at the meeting and voiced their disapproval so we can add your members concerns to the consultation.
In short, businesses in the town felt that both East Sussex Country Council (ESCC) and Rother District Council (RDC) were trying to find a solution but did not understand the root cause of the problem, namely lack of parking for the town. What is currently proposed is not fit for purpose and is considered by many something that will break our town if implemented.
CPE only applies to on street parking and the number of spaces are limited by the available kerb space. A lack of parking in the town cannot be considered as part of this process. The proposed restrictions have been based on what is already in place and where issues have been previously highlighted.
Furthermore, the presentation time, over the busiest retail period of the year – the run up to Christmas, and the finite closing of the consultation – mid January, when retail and hospitality businesses are only just winding down after Christmas and New year, was the wrong time to be consulting in a town dominated by independent retail and hospitality outlets.
The requirement for consultation is just 21 days and this has already been extended to 56 days to allow for the Christmas period. Therefore we do not propose to extend this further.
1 It is important to understand that Rye is a unique town. Over 95% of retail is run by independent traders, which makes it an unusual visitor attraction, and something that we are proud of as residents. Its medieval streets were obviously not designed for cars, so it makes driving and parking in the citadel area very difficult. Throughout the UK, however, High Streets are suffering, and we need to do all we can to help businesses and sustain a thriving town, especially given the fact that Rye is highly dependent on tourist trade. Added to the mix of Rye is residential access, parking and usage of our small streets. Greater thought needs to be given to the application of residents’ parking permits. Therefore, rather than looking in isolation at a few streets, the bigger picture needs to be addressed first.
As above the proposals are based on what is already in place. When introducing or extending permit schemes we would expect there to be a demand for it from at least 40% of the residents in the area. This has not been demonstrated in any of the correspondence we have received about parking in Rye and so a large extension of the residents permit area was not included in the proposals we are consulting on. However, if you or your members have suggestions about changes to the proposed residents permit area, I would encourage you and your members to give this detailed feedback in your responses to the consultation. Furthermore, once CPE is in place regular reviews will be undertaken and if requested, extending the permit schemes will be considered.
2 Of great importance is the matter of displacement. Without investment in more parking, displacement of cars from the High Street will go to the likes of Military Road (which has seen unprecedented growth in parking in the last year already), Love Lane and other out of town roads where residents can no longer park outside their houses. Displacement is not factored into this proposal, which we feel is a grave error.
We are only proposing minor changes to the current restrictions and do not believe there will be any significant displacement. Again investment in more parking for the town cannot be addressed in this process.
3 Businesses understand that tender contracts are currently out for CPE in Hastings and Battle, with the suggested revenue take into the millions. Any company bidding for this tender is only going to be interested in one thing, profit, and not the wellbeing of a small, rural, coastal town completely dependent on small, self-sustaining, independent, family-run businesses. No consideration is seen in the proposals regarding safety nor protecting our environment, but purely revenue-related.
We currently have an enforcement contract with NSL and there will be no tender for extending this to cover Rother district. The contract takes into consideration much more than revenue; key performance indicators are in place to monitor health and safety, customer care and compliance. In our experience we have found that the introduction of CPE helps with traffic flow and the turnover of spaces to the benefit of local businesses.
4 Neither residents nor businesses are happy that revenue raised from Rye will not be ring fenced for the town but shared across Rother. As a highly attractive visitor town, we will be subsiding other towns.
I appreciate your views, however, when implementing CPE into a district we must ensure that the income generated is sufficient to cover the cost of enforcement across the whole of the district. With the proposed scheme, we estimate that the majority of the income will come from Bexhill, Rye and Battle; however, these towns will undoubtedly also require the majority of the enforcement.
5 Information as to what will happen on a Sunday (still a busy day in a tourist town) is lacking.
The current proposal is Monday to Saturday, if you feel Sundays should be included you can request this by responding to the consultation either on our website or by emailing the consultation team, details are below.
6 Given that we have an above national average number of older residents in this area, little has appeared in the consultation regarding disabled parking, nor the monitoring of blue badge use.
Disabled bays will be formalised in the town centre area, so misuse can be enforced. In addition to the national concessions blue badge holders will also be able to park in pay and display bays without charge.
7 Provision needs to be considered for short term deliveries and long term work vans in the citadel area.
Along with loading bays, loading and unloading is permitted in permit bays and on yellow lines where there is no loading ban in place. More information on loading and unloading concession is available in our parking guide which can be viewed on our website at https://www.eastsussex.gov.uk/roadsandtransport/parking/policies/policy/
8 Regarding the consultation exhibition, disabled access to the Town Hall was not advertised, so some visitors did not attend as they did not know it was available. Notes on the stands about parking were generic according to your colleagues, which gave the impression to some visitors that ESCC had taken a blanket and simplistic view to Rye’s unique situation.
Access information was available from the Town Hall. Much of the information about CPE and permits was generic as it applies to all CPE areas. The maps and proposals were specific to Rye.
9 The proposed parking meters on display at the exhibition are large and unsuitable for Rye, which rightly has considerable restrictions on planning alterations to buildings (eg changing the colour of a windowsill needs planning consent) and these machines are unsightly, too big and not appropriate for the town. Furthermore, the pavements are narrow at best, not wheelchair or buggy-friendly so adding large machines to the public realm adds further congestion and difficulty for pedestrians. Modern technology could be better used to alleviate this problem.
The machine on display was an example of one that is currently in use in other areas of the county and they are using the most modern technology. In our experience residents and visitors want to be able to pay for parking using cash as well as more modern technology such as pay by phone. This is why pay and display machine have been proposed. If the proposals are approved, we will look to site the machines in locations where they cause the least inconvenience. If you have comments on the machines please feed these into the consultation and they will be noted.
10 Better, clearer and less ambiguous signage needs to be considered all around the town.
Under CPE signs have to comply with the Traffic Signs Regulations and General Directions which details the size of the sign and wording which can be used, so this should improve the parking signage.
11 In order to progress, data needs to be available to discern the number of visitors, residents, and businesses using vehicles/parking in the town to best address their needs. This does not appear to have been disseminated to the town. What little research on parking in the south east that has been done has focused on bigger towns that do not have the make up of Rye.
This consultation is being carried out as part of the introduction of CPE process; it is not a comprehensive traffic management study. The proposals are based on the restrictions already in place and proposed changes to address concerns previously brought to our attention.
In response to the suggestions you have made, as explained above a lack of parking in the town cannot be considered as part of this process. For the introduction of CPE only on-street kerb space is being looked at in this consultation. We can only consider comments on the proposed restrictions, not your other suggestions such as park and ride or offering incentives to use existing car parks.
Whilst I appreciate my response may not be the one you were hoping for, I hope you understand that we must follow the consultation process and consider all views fairly and consistently. As most of the issues you raise fall outside of the remit of this consultation, we do not feel a meeting is necessary.
I would urge you and your members to feedback any comments you have on the proposals by contributing to the consultation. This can be done by completing the form on our website at https://consultation.eastsussex.gov.uk/economy-transport-environment/parkingrother2018/ or by email to firstname.lastname@example.org
Thank you for your interest in the matter.
Team Manager Parking
Parking Team, Communities Economy and Transport”
Mr Clarke points out, correctly, that the scheme only deals with on-street parking and does not cover additional parking provision. Readers may, however, feel that other answers do not address the specific problems of Rye and which do not necessarily apply to the larger towns in our area, such as Bexhill.
For example, no concession is indicated on the placement of very large parking meters on narrow pavement or on residents parking permits for residential areas other than Watchbell Street. This could perhaps be accounted for by the fact that ESCC have been working of an old and out of date street map of the town which still shows commercial use in streets, such as Market Street, where the use is now primarily residential. It is apparent, therefore, that no on-site survey has been carried out prior to the production of the parking plan.
The overall tone of the letter is dismissive of genuine concerns that the manner of implementation needs to be specific to Rye and not just follow a generic plan that is unlikely to be a success here.
ESCC is currently conducting a consultation period for the plan and this ends on January 14. It is important, therefore, that if you have any comments on the proposed CPE scheme, you should write and make your views heard. This can be done by completing a form on the ESCC website of by email to: email@example.com.
Image Credits: RTC.