Written evidence submitted by the British Parking Association (SDV0028)

Call for evidence: self-driving vehicles

This response relates to the most relevant points to our members that the Committee seeks views on. As the voice of the parking sector in the UK, the British Parking Association (BPA) works to ensure that its 270 local authority members and 480 commercial members are prepared for the digital revolution in transport and parking. The significant advances in parking technology and the creation of a parking data standard will assist the introduction of driverless vehicles which rely on the kerbside being able to be read digitally.

Between 2018 - 2021, we responded to all three of the Law Commission’s consultations on connected and autonomous vehicles.  The Law Commission was grateful to the BPA and its members for helping to shape its final recommendations. We welcome the opportunity to respond to this call for evidence whilst the UK, Welsh and Scottish governments consider the report’s recommendations and we support its main one; to introduce a new Autonomous Vehicles Act to regulate driverless vehicles.

Our response includes views on the following:

Likely uses, including private cars, public transport and commercial vehicles
No comment.

Progress of research and trials in the UK and abroad
No comment.

Potential implications for infrastructure, both physical and digital

Traffic Regulation Orders (TROs)
TROs are key to informing drivers of all the on-street restrictions including where a vehicle can and can’t park, for how long and under what circumstances. A loading bay only restricted to 8-10am, a taxi or disabled parking bay.  They are constantly maintained and adjusted to meet traffic management needs including changes to road layouts.

Currently TROs, managed by local authorities who make up the majority of our members, but also other bodies, are mostly not digitised. They are cumbersome and expensive to create. We recommend the government prioritises streamlining the TRO process and supports our local authority members to transition to digitising TROs which was one of the options the government’s pavement parking consultation made in 2020. We call on the government to urgently publish the response to this consultation. TRO analogue data is no use to driverless vehicles, they need to be available digitally in real time.

The creators of TROs will need to ensure that they:

This will require significant additional resource for those maintaining TROs and signage, and in a far more mission-critical way than is currently needed for human interpretation.

So, the processes for making and amending TROs will be much more responsive than is currently the case. At present the regulations mean that it takes a significant amount of time and money for even minor TRO defects and adjustments to be made, which will not be acceptable if driverless vehicles rely on this data to move around.

Data standards and interoperability
Creating data standards assists data sharing and the interoperability of the transport network as a whole, including driverless vehicles. The work we and our members are doing in this field is important. The National Parking Platform (NPP), a DfT funded, local authority owned (Manchester City Council) and DfT funded pilot project is a good example of how the parking customer experience can be brought into the 21st century and could enable driverless vehicles to park safely. The NPP facilitates parking data exchange and digital payments. It’s a whole new way of delivering better parking and mobility services.

The NPP pilots in Manchester and Oxfordshire, and in Chester, Camden and Coventry soon are a good foundation for a nationwide implementation of the NPP. We are currently recommending to government it pushes for all local government to adopt this public service nationally.  A truly ‘national’ NPP will help:

This data could usefully be aligned with other data including the public EV chargepoint availability data.  Access to EV chargepoints for driverless vehicles is not something that the Law Commissions consultations considers.  Dynamic wireless charging and vehicle to grid charging may not be commonplace now but having this data available on the NPP would be logical. Data and technology is moving fast and this is a key opportunity to ensure the building blocks are in place for a consistent and seamless customer experience that facilitates, mobility as a service, driverless vehicles and transport hubs etc.

The BPA together with the European Parking Association and the International Parking & Mobility (US equivalent) have created the ISO approved Alliance for Parking Data Standards, a global parking data standard which will help to speed up data-enabled innovation including the introduction of driverless vehicles. It is important that local authorities and other bodies involved in parking also adopt this data standard and is another recommendation we are making to government currently. 

The regulatory framework, including legal status and approval and authorisation processes

We support the introduction of a new Autonomous Vehicles Act to regulate driverless vehicles. However to achieve consistency between driverless and human driven vehicles we recommend the regulatory framework for human driven vehicles is reviewed simultaneously.  Last year we submitted an application for the Law Commission to consider reviewing parking and traffic management legislation in its 14th Programme of Law Reform and await to hear if this has been successful.

Our main reason for submitting the application is that parking and traffic management law is fundamentally structurally flawed and complex. It is inappropriate for today's modern world of connected autonomous vehicles and digital transactions, predating the internet. As you know and experience, the management of parking is regularly discussed in Parliament and reported by the media. Much of this arises from the confusion and misunderstanding about the way parking is managed and the way the law works. It is therefore important that driverless vehicle regulation does not simply take existing enforcement law and transpose or reference it an Autonomous Vehicles Act. This is an opportunity to bring existing law up to date. 

Safety and perceptions of safety, including the relationship with other road users such as pedestrians, cyclists and conventionally driven vehicles
Safety and perception of safety is key. The driverless vehicle sector needs to work more closely with the parking and traffic management sector and society in general, to test the many real-world physical issues that need to be overcome. For example, camera technology records the road signs and road lines so that driverless vehicles can ‘read’ what it is ahead but what if the road lines are worn away and therefore ‘unreadable’ or the road signs do not match the digital TRO? The evidence is road lines are not in good order currently and this needs to be addressed with additional funding in place. The experience of the introduction of smart motorways is a good illustration of how safety needs to be taken more seriously, tested more rigorously and sufficiently resourced to ensure new measures are safe so that pedestrians, cyclists, non-driverless vehicles can coexist. 

Rightly pedestrians and cyclists are given greater regard in the latest revision of the highway code and yet the approach to pavement parking enforcement is yet to be decided on by government. This is another safety issue that needs to taken into account when introducing driverless vehicles.

Parking enforcement
Parking enforcement is nearly all civil enforcement carried out by local authorities, not the police.  How will this work with driverless vehicles? There will need to be consistency of enforcement between driverless vehicles and those with drivers. Local authorities will need a uniform way to enforce any civil parking and traffic management contraventions arising from the use of driverless vehicles. Recently, twelve local authorities have taken up the opportunity to enforce moving traffic contraventions and potentially all local authorities in England could apply in future. How will driverless vehicle enforcement work in practice? Local authorities are only allowed to issue penalty charge notices for parking infringements on a windscreen not through the post.  A driverless vehicle will not ‘see’ the PCN a motorist does. Consideration should be given to local government being able to issue PCNs through the post (notice to keeper) to enforce parking.

Paying for the parking service
Parking charges are decided by the landowner or car park operator and currently there are no charges for moving vehicles other than clean air zones, ULEZ etc. If the cost of parking were to remain higher than the cost of cruising this could unintentionally incentivise driverless vehicles to continually cruise between bookings and add to congestion, to avoid paying for parking.

Stopping, waiting and parking
The distinctions between stopping, waiting and parking are often not clearcut so this needs consideration.

The role of Government and other responsible bodies, such as National Highways and local authorities; and potential effects on patterns of car ownership, vehicle taxation and decarbonisation in the car market.

Vehicle registration
Driverless vehicle registration is an opportunity to review the DVLA vehicle registration process.  Currently DVLA’s ability to spot vehicles that are registered incorrectly or un-registered is limited and needs proper resourcing.

Who we are
The British Parking Association represents the UK parking and traffic management profession. Our 750 plus corporate members includes mostly local government and also commercial providers and parking system operators, as well as consultants and academics. In addition, we represent over 500 individuals and have a separate membership structure to support their professional development. 

We are a not-for-profit membership association representing the UK parking and traffic management profession. Most of our 750 members are local government, in addition to technology providers, parking system operators, consultants, hospitals, and universities.