New Parking Code of Practice Enforcement Framework - Consultation

DoaM

UPDATE:
This thread is to discuss the  government consultation regarding enforcing the CoP:
https://www.gov.uk/government/consultations/parking-code-enforcement-framework

The thread started by Umkomaas should be used to discuss the CoP itself.
https://forums.moneysavingexpert.com/discussion/6185781/the-draft-private-parking-code-of-practice-now-out-for-consultation

KeithP

Looks to be the same as Umkomaas' earlier thread. 

BrownTrout

Document here no login needed 

Le_Kirk

You only need the log in if you want to comment I think.

DoaM

KeithP said:

Looks to be the same as Umkomaas' earlier thread. 

That must have slipped off the 1st page as I didn't see a thread.

DoaM

Le_Kirk said:

You only need the log in if you want to comment I think.

Click on either Download button (for the letter or the CoP) and I get the following:

You are trying to access a protected resource and it seems your login session has expired.

Please Login here and try to access this page again.

I get exactly the same for the Read draft and comment button too.

Coupon-mad

We need to use a thread to discuss the specification and the 'wider framework' and avoid putting in knee-jerk comments.

Needs careful reading and these are two separate consultations. 

Both need careful study and separate, considered comment...but we have over a month.

The 'wider framework' is equally important if we want to remove ''Dracula from being in charge at the bloodbank'', or at least clip his batwings.  Need to get the level of parking charge right and because the MHCLG are proposing a tiered system, that needs consideration:

- what would be a fair tier for a higher breach, like parking in an accessible bay 'without reasonable excuse' (i.e. being disabled)? 
- what about a lower tier for a lesser breach such as an overstay?
- how long should the discount be offered for on the parking charge, IMHO and I've said before, this should be 21 days because the direction of travel is towards postal NTKs (over 80% of private ones are already issued that way, as 'remote' charges) and 21 days discount period matches a LA Reg 10 postal PCN.  Seems fairer to give lease firms longer and registered keepers longer to make decisions - especially if it arrives when they are on holiday and they weren't driving so it;s not something they know about.

Which thread shall we use to share ideas?

DoaM

Shall we use this for the Enforcement Framework and Umkomaas' earlier thread for the CoP? I've updated my OP and thread title accordingly.

Coupon-mad

Yes let's use this for discussing the 'wider enforcement framework'.  People need to know that comments are needed about BOTH.

IMHO, there are some good things about the specification but the wider framework is too weak.  Discuss!

This part of the framework (below) needs to change.  IMHO it fails, and effectively it is saying ''let's set a cap on parking charges then let the Trade Bodies increase it at will''!  Oh dear, then later we'll realise this was an ill-advised and over-trusting idea...why didn't we make the Scrutiny Panel responsible for authorising any change in the cap?  Or, make the cap a cap...

32. If an operator wishes to set a parking charge higher than that cap, the Certification Scheme could detail a robust procedure for how the APA would weigh up that evidence before deciding whether a higher level of parking charges is permitted. Factors to consider would include the effectiveness of the deterrent and proportionality to the tariff (in the case of permitted paid-for parking). These procedures would, in turn, be monitored by UKAS and the Scrutiny and Standards Board

APA is the new acronym for Trade Bodies, I think to follow how they were described in the 2019 Act.

And why is one of the 'factors to consider' when increasing the cap at a site, NOT ''the interests of those persons wishing to use the facility''?  The Act was set up with that intention and the Act uses that phrase!

And why not also ''the detrimental effect and risk of charges upon service users at busy times?''  e.g. if they move the cap for a retail park overstay up to £100, what happens at Christmas and New Year and during pandemic queues when everyone is held up, yet are genuine patrons? 

They all still get £100 fines, then, do they?   Just like they do now...

e.g. if it's a Hospital or a residential car park or other sensitive site (or even a retail park) why the heck would the APA be allowed to increase the cap without considering the interests of the consumers who are the 'sitting duck' victims at that site?  

Coupon-mad

HAVE YOUR SAY .... PLEASE READ THIS!

September 2020 brings your chance to comment on the new (Government Draft) 'proper' Code of Practice to rein in the worst PPC conduct and that of their scam debt collectors - please please can NEWBIES do this and in particular, comment on

(a) the AMOUNT OF THE PARKING CHARGE, WHICH WE ALL AGREE MUST BE LOWER THAN £100, and also

(b) the use of unregulated debt collector firms and the fact that they add a false layer of an extra £60 or £70 to a £100 PCN.  This must stop but you can bet your bottom dollar that the ATAs will have misled the Government if they got a chance and most likely will have spun the same misinformation the BPA did, in 2012, when they gave false figures to Government about the number of court claims and promised that keeper liability would reduce the burden on the courts.   

The BPA said there were up to 90.000 court claims per annum on 2011.  There were 845.  They said that keeper liability would reduce the '90.000 court claims'.

In fact, the 845 (in fact just 600 in 2012!) increased to 37000 within two years and is now around 110,000 per year.

This time, I suspect PPCs will prey on the concerns of Government and predict dire consequences again, if the charges are too low and if debt collector scams are brought to an end.

THAT IS WHAT WE MUST CLEARLY ADDRESS AND TELL THE GOVT THERE ARE NO SUCH CONCERNS AND THAT COURT CLAIMS WILL NOT INCREASE.

ONE OF THE TASKS OF A CONSUMER RESPONSE WILL BE TO POINT OUT THESE LIES AND WARN THE GOVERNMENT THAT IN FACT, REMOVING THE DEBT COLLECTORS ALTOGETHER AND BRINGING IN A ROBUST APPEALS SERVICE WILL REDUCE COURT CLAIMS!

Code of Practice consultation thread:
https://forums.moneysavingexpert.com/discussion/6185781/the-draft-private-parking-code-of-practice-pas-232-now-out-for-consultation/p1