Written evidence submitted by AppyWay (EVP0054)
There are a number of key issues to be considered when proposing road usage pricing models as AppyWay have learned from consulting with cities globally, these are:
● Clear communication on the use of funds generated and how these will be re deployed to the benefit of those who have paid. Existing Road Tax must not be forgotten and how these new schemes differ from the national acceptance for highways maintenance.
● Measurable evidence based communication of the benefit schemes are having on the environment / social well being of the city they serve
● An integration of road pricing within a wider pricing framework to cater for all use cases and trip types. This includes parking and kerbside charging to capture end of trips, trip purpose and offers the potential to charge different rates to different users, for example through traffic versus those that stopped.
● Contextualise the road pricing strategy against existing measures including schemes that manage noise pollution, traffic calming and proximity to other amenities such as schools and workplaces and be sensitive to trading hours.
● Quality assurance in the way billing, fines and enforcement are managed to ensure transparency and trust
● Further Digitisation and Standardisation of existing road regulations, accessible for all.
It is well recognised that road usage based pricing is one method enabling control, incentivise and generate revenues for Local Authorities and Governments. We must however ensure that new measures are not recognised as an additional tax, as seen recently in the press concerning changes to the ULEZ London charge (https://www.telegraph.co.uk/business/2021/01/15/sadiq-khan-unveils-inflation-busting-hike-tube-bus-fares/#:~:text=Drivers%20could%20be%20charged%20%C2%A3,to%20a%20halt%20next%20year.), and instead ensure these schemes are recognised as enabling, positive schemes that deliver on key climate goals. This is achieved via an integration between road based charging and parking.
Parking is a contentious ((https://uk.movies.yahoo.com/councils-raked-in-millions-via-parking-fines-in-2020-164109581.html) topic due to the impact it creates directly on users, the existing flow of money that it unlocks and the public perception around the negative way in which it is enforced. Given that all persons accessing a city are already subject to parking payments and restrictions, it is our view that there is evidence enough to consider the consumer experience of parking and improve upon that at the benefit to road users but while also achieving the key goals of additional charges such as road usages based charging.
It is key to consider the consumer at all times within such proposals as users are varied and have a large complexity of habitual and business driven needs they are looking to achieve. Consider an EV vehicle choosing to drive through a town but contributing to congestion, where a trades person in a non EV may stop in the town, deliver services, purchase services and generate the local economy. At present it would appear the EV driver would be rewarded but without any positive impact on the local area while the trades person would be penalised for generating local jobs and growth.
Any strategy that may be proposed must demonstrate how it will evolve over time and respond to market forces. EV vans for example are currently priced out of reach of many small businesses and sole traders and we expect these persons to remain within their combustion engine vehicles for far longer than the larger, capital primed fleets capable of adopting EV strategies far faster. Is it right therefore to further fuel large monopolistic fleets who can electrify faster than smaller, local brands who may not have access to the capital, or their business simply cannot afford such new technology. This scenario is true of the current market (2021) but by 2031 we expect the price of EV’s and EV vans in particular to be far reduced, therefore enabling pricing today may migrate to a blocking, enforcing strategy for the future. Designing the messaging for that adjustment will be complex.
In 2019 we co authored a report (https://www.centreforlondon.org/publication/parking-kerbside-management/) with the respected think tank, Centre for London to study parking across the capital and consider a fresh approach to move to positive parking and it’s inclusion in such schemes such as road pricing. The report focuses on a state of the nation by Local authority, deep insight into the strategy employed by each local authority, a comprehensive review of kerbside use by use case and goes as far to make a series of recommendations to both central and local government:
Many London boroughs are already proactively using parking and kerbside policies to achieve wider transport objectives, but different boroughs are at different stages of this journey.
This report presents a menu of interventions that councils can use to encourage residents to think differently about car ownership and use, and to create a greener and safer city, to the benefit of everyone, including:
● Develop kerbside strategies that allocate road and kerb space in accordance with clear user hierarchies;
● Reallocate road space gradually through introducing a cap on the number of permits issued, and using waiting lists or limited eligibility for new residents;
● Set residential permit charges at a level that fully covers operating costs;
● Regularly review the coverage, size and operating hours of Controlled Parking Zones;
● Move towards an emission-based charging structure for resident permits, and escalating charges for additional vehicles.
The content is included within this reply to illustrate the need for a consumer focus, a sensitivity to existing measures, and a clear delineation between the price paid the benefit gained by user, operator, local authority and wider city population.
On from understanding, supporting and enabling the user to go about their business without recognising road pricing as “just another tax,” there is added complexity regarding the accurate management and potentially enforcement of such schemes. Multi occupancy vehicles for example may be on a lower tariff for road pricing but such schemes are subject to abuse from home made camera beating schemes to imitate multiple occupancy, the use of multiple phones to appear digitally as multi occupancy and a complex plea process to avoid detection (I was lying down / I was obscured by sunshine). The USA has adopted multiple solutions to try and mitigate these issues but few work with great accuracy creating frustration. The implementation therefore of such schemes could depend on the need for expenditure on expensive, total road network sensing capability to avoid and mitigate for abuse and poor execution. By comparison, kerbside and parking sensing via IoT devices are relatively cheap to supply, monitor the same network, provide a great level of accuracy and when combined with a range of sensing capabilities can be used in multiple sectors and business models to derive additional benefits and insights. Insights vital for use in our future cities. Such agnostic sensing capability is extremely powerful when overlaid to the existing directives seen within the UK and backed by key departments, such as the Department for Transport, to digitise our existing traffic regulation orders. (http://transportdatainitiative.com/webinar-4-digital-tros-dft/tdi-webinar-4-department-for-transport-digital-tros/
https://www.gov.uk/government/publications/traffic-regulation-orders-identifying-improvements-to-the-legislative-process-in-england) This is a key initiative to be addressed in the context of road pricing as it forms a digital back bone of Britain, empowering local authorities and ensures a homogenised approach is taken, preventing from complex, fragmentation of the UK traffic and road management strategy being proposed.
Finally we recognise that any scheme, its implementation, its change management and billing must all be accessible digitally in a standardised, transparent format. This will ensure strategies put in place today are capable to evolve with the ever changing demand of our people and can be adapted at short notice to deliver on a cities key performance indicators such as the “Ten Point Plan for a Green Industrial Revolution.” Parking can be considered today as static road pricing. When digitised within wider schemes, parking becomes a huge enabler to local authorities and diffuses any misconception on further charges and their need to deliver prosperity and cleaner streets in our cities. We propose a re-purposing, a rebranding, of parking toward the positive messaging that Kerbside Management affords. Kerbside management which provides access to our cities, access to education, access to healthcare and access to employment.
February 2021