Harringay, Haringey - So Good they Spelt it Twice!
Council abolition of daily parking based on information so vague it is not held in council records
A few weeks back cabinet member Seema Chandawani explained that the Council is "abolishing" daily visitor parking permits on the basis of evidence of their abuse. A proposal to this effect was part of measures approved by the council cabinet last month.
I was contacted this morning by Haringey journalist Gabriella Jozwiak with a copy of her Freedom of Information request about the decision and Haringey's response to that request.
Haringey Council's email to Gabriella shows that apparently the basis on which the daily parking decision was made was hearsay so vague that, as their answer clearly states, it is not even held in formal council records. The email is reproduced below.
Should our council be making decisions on our behalf on the basis of information so anecdotal that the Council feel it unworthy to even be included in its records? This sounds like a slippery slope.
Sent on behalf of Ann Cunningham – Head of Highways & Parking
Dear Ms Gabriella Jozwiak,
Re: Freedom of Information Act Request ref: LBH/15659824
Thank you for your request for information received on 7th August 2024, in which you asked for the following:
Please can the council provide the full "circumstantial evidence" upon which it has based its recommendation to discontinue the option for daily visitor parking permits in the borough. This is referred to in the council's recent Parking Strategy and Policy/Changes Review, Appendix D, section 4.3.
Please give all the evidence you have collected that proves: "daily visitor permits are open to being used for purposes other than intended - typically by commuters using permits to park for the day, or by those residing in properties without entitlements to resident permits".
The Cabinet report stated circumstantial evidence for the proposal, and this is in the form of anecdotal information which has been brought forward from a range of sources over a number of years. While various sections of the council may hold information, it is not held in a format, nor was it intended to be documented, in manner to be used to supply for such a response. The Freedom of Information Act gives people the right to access records held by public authorities, but it does not extend to a right to have records created in order to provide information that is of interest to members of the public. We do not hold this information and are therefore not able to provide it to you.
If you are unhappy with how we have responded to your request you can ask us to conduct an Internal Review. If so, please contact the Feedback & Resolutions Team. (Please note you should do so within two months of this response.)
Yours sincerely,
Ann Cunningham
Head of Service, Highways & Parking
Tags for Forum Posts: daily parking permits, parking, visitor parking, visitor parking permits
Replies to This Discussion
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Permalink Reply by Niall
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Oops, this just gets worse!
Add this to the data collected and presented by Caitlin here on the disproportionate impact this will have on the more deprived areas of Haringey and it is clear that the Cabinet were very badly advised. It strikes me that it would be a huge own goal for the Council to now 'rubber stamp' this decision, especially given the widespread criticisms and the atention given to it by the BBC and local press (well done Gabriella Jozwiak btw)
Equally, does anyone know the cost of a statutory consultation? It would seem pretty pointless to go through with it when it is clear the original decision was so flawed.
Far better for Cabinet to reflect on this, accept they were not fully advidsed and refer it back for more detailed advice. I have already suggested to our local councillors in Harringay (Zena, Anna and Gina) the following be considered- Re-run the Equality Impact Assessment given the glaring failure in the original report. That also should be shared
- Data on misuse of one day passes and benchmarked against comparable boroughs and how they tackle the issue
- Alternative proposals/solutions to address the revenue shortfall and misuse.For example:
- weekly passes for local traders/builders and registered family members?
- limit number of day passes per household (why 999 passes??)
- Increasing charges elsewhere eg second vehicle use
- monitoring of app data on misuse of passes - easily done now that it is electronic
There are plenty of points others have raised here also.
Far better for Cabinet to refer this back and make a properly informed decision than to let this run on for months in the media and amongst residents, given these glaring failings - it makes sense practically and politically
Hugh, do you know when the next Cabinet meeting is? And can we ask our councillors to make representation to that meeting?
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Permalink Reply by Hugh
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I'm not sure what a consultation would cost, but Michael Anderson may.
If people aren't sure what you're referring to when you raise the issue of the Equality Impact Assessment. see towards the bottom of my original post on all this where it was first raised and is explained. See also Caitlin's very useful graphic which expanded my data pool and very clearly illustrated the issue that I pointed up.
Yes, I agree about calling the decision in. I set on the grounds on which this could be done here.
Next cabinet meetings 17 Sept at 6:30. There should be a public gallery.
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Permalink Reply by AndrewAW1
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It was pretty obvious that no real data had been looked at for this and it was a policy that was based on anecdotes as this confirms.
The cost of the consultation for this element will be minimal as it is part of a raft of parking charge amendments which will all be consulted on.
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Permalink Reply by Shar
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Clearly someone at the Council (not taking any names here) thought it would be a great idea to raise more revenues this way, but at least some pretense of due process would have been nice...
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Thanks for this Hugh, do we know whether Gabriella plans to publish on this at all?
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I get the impression not, but I didn't ask. She seems to have approached the BBC first who told that they're not planning on revisiting the story until the 'consultation' in the Autumn. So it came into HoL
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Looking for something else just now, I saw mention of an April 2023 "Parking Schemes – Resident Engagement Policy".
It apparently has weight since an element of a Crouch End scheme consulted on at the end of last year couldn’t be adopted because it was not in line with this policy.
How odd that no one has drawn our attention to it.
So what does the poklicy say?
At the end of the intro blurb it states,
This document outlines the co-design process for residential parking schemes, identifies the types of schemes that can assist with reducing parking pressures and provides a framework for future residential parking scheme design and review to work within ...
... It provides a framework for how the schemes can be co-produced to ensure they are fit for the local communities that benefit from them. ...
...This policy intends to provide clear guidance on how residents and businesses can request to have parking in their streets managed and protected. It provides a framework for how the schemes can be co-produced to ensure they are fit for the local communities that benefit from them.
It then goes on the define what Stautaory consultation is - this is the stage the daily parking issue is at.
Statutory consultation
Statutory consultation forms part of the legal process set out in Road Traffic Regulation Act 1984 2 (RTRA 1984), for controlling vehicular movements by introducing measures such as parking places and waiting and loading restrictions. It is, therefore, not consultation or engagement with the community on the need for controls. It provides for objections to proposals to be made by anyone, not just those in the area subject to proposals. The nature of response therefore tends to be objections that must be considered by the Council alongside any mitigations.
In other words, it seems to be saying, statutory consultation isn't concerned with finding out what people want: it's following a legally required route to check if people object to decisions already made by the Council. To be clear, contrary to what Cllr Chandawani is claiming, and I quote the policy here, "It is ... not consultation or engagement with the community".
Elsewhere in the document the statutory consultation is further defined:
As this is a legal process and the results of this consultation including objections must be formally considered by the Council. This decision report will take account of the following:
- Ensuring the council has fulfilled its legal duties set out in RTRA 1984
- That no substantial objections are received in relation to the wording, content or errors present within the legal Notice of Proposal.
- That due consideration is given to objections and submissions and if required amend proposals to settle objections raised.
- That recommendations contribute to Council’s wider Policy, strategy, and other key areas of local authority governance.
- That recommendations consider decisions set out in the public engagement decision report.
There's then a helpful section of how decisions are made
The policy says,
The Council will need a minimum response rate of 10% to the public engagement, before any decision can be considered ... ‘calculating the percentage’ from the total number of properties responding, against the total number of registered properties within the engagement area.
So this is when I started wondering if this policy is supposed to apply to a borough-wide change like the one about daily parking permits. But looking at the ground the polcy claims to cover, I think it's hard to argue that the daily parking permit change is not covered. Even if not, it clearly sets out principles of engagement and I can't see how a collection of unrecorded anecdotes goes anywhere near community engagement or is anything like a 10% response rate.
At least this offers more clarity on exactly what a statutory consultation is and according to its introduction, it covers daily visitor parking type issues and so points out the process that should have been followed and plainly hasn't been.
Full document attached below.
- Attachments:
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