Scotland Workplace Parking Licensing Consultation - ASLEF Response

The Transport (Scotland) Act 2019 introduced a discretionary power for local authorities to implement Workplace Parking Licensing schemes. ASLEF responded to the consultation on the regulations and guidance.
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The Scottish Government consultation on the Regulations and Guidance for Workplace Parking Licensing took place in August and September 2021. Below is ASLEF's response to the consultation:

  1. The Associated Society of Locomotive Engineers and Firemen (ASLEF) is the UK’s largest train drivers’ union representing over 21,000 members in train operating companies and freight companies as well as London Underground and light rail systems. We represent around 1900 members in Scotland.

  2. The union is pleased to be able to respond to this consultation. We are in favour of workplace parking levy provisions in principle. As a public transport union we are well aware of the need to reduce car use and encourage people onto public transport and active travel modes. ASLEF has campaigned on environmental issues for many years.

  3. In the case of a workplace parking levy, the union believes that consideration should be given to particular types of workplaces and workers to ensure that public transport is not compromised by the imposition of such a levy. The regulations allow for exemptions for specific types of NHS workplaces and care facilities but should also include named exemptions for public transport operators.

  4. While it is sometimes possible for public transport workers to get to their workplace using public transport, this is not always the case as someone needs to be able to take the first train of the morning out of the depot, or return the last service there at night. Obviously there would be no way for them to get home without a car at those times.

  5. We note the additional provision outlined for levies to apply only at certain times of day. Given the length of shifts typically worked by public transport workers, however, this would not mitigate the problem for rail and other transport operators as even if the start of a shift was outside the chargeable hours, the end would not necessarily be.

  6. While we appreciate that the proposed regulations allow for local authorities to make exemptions for specific types of workplaces - which could include public transport operators - the union believes that this specific exemption should be set out in the regulations at the national level.

  7. The number of public transport workplaces likely to be within areas covered by the scheme is small (assuming that schemes will only be applied in heavily congested urban areas) so the impact of such an exemption would not be significant.

  8. Public transport is undeniably one of the most important ways to tackle the climate crisis, and ASLEF believes that every effort should be made to improve public transport and its appeal to passengers and freight customers. We therefore believe that making public transport operators eligible for the workplace parking levy is in direct contradiction with this objective and is unnecessary.