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| 'Spurs Trust's Official Objection to Parking Ban' posted by Bernie Kingsley on 10/11/2005 | We reproduce below the full content of the Spurs Trust's official objections to the proposed Controlled Parking Zone
You can find out more about the proposed ban on parking near the White Hart Lane stadium on matchdays here.
8th November 2005
President – Steve Perryman MBE
Tottenham Hotspur Supporters’ Trust
www.tottenhamtrust.com
Alex Constantinides
Head of Highways
River Park House
1st Floor (South)
225 High Road
Wood Green
London N22 8HQ
Dear Mr Constantinides,
Re: Tottenham Matchday CPZ
The Tottenham Hotspur Supporters’ Trust (‘the Trust’), which is officially recognised by Tottenham Hotspur FC (‘THFC’) to represent its supporters, wishes to place on record its opposition to the proposed controlled parking zone (‘CPZ’) around Tottenham Hotspur’s stadium on matchdays. We are opposed to the scheme in principle and further believe that the manner of consultation has been seriously inadequate and designed to conceal the true facts from the people most affected by the scheme and thus contrary to the requirements of the Local Authorities’ Traffic Orders (Procedure) (England and Wales) Regulations 1996. I will go into further detail about the objections to the scheme and the consultation issues below.
It is also the case that incorrect information was given by officers of London Borough of Haringey (’the council’) to representatives of the Trust, supporters and others at a meeting on 13th October 2005. Again, I will go into further detail below.
You will no doubt be aware that I have been in e-mail correspondence with your officer Vincent Valerio about some of these matters and I have also lodged a separate objection as a private individual.
Objections to the CPZ in principle
The Trust objects to the introduction of a CPZ around THFC on matchdays for the following reasons:
1. For many of our members and other supporters, who travel from a wide range of destinations both near and far by car, public transport is not a viable option. With the exception of the W3 bus route, all train and most bus services follow north-south lines and serve very limited areas. These services are already over-crowded, particularly after matches, when it can take up to an hour to get on a bus. Currently, bus services that normally operate along Tottenham High Road are actually diverted away from the area after matches, making the problem worse, and there have been instances of further limitations or even cancellations to the train services on the lines running either side of the stadium.
2. You are not currently proposing any additional assistance in getting from where supporters will have to park in the form of improved and/or subsidised public transport.
3. Senior citizens and those suffering from poor health (which may not amount to a registered disability) will have difficulty in walking longer distances from where they will be forced to park to the stadium.
4. Women, particularly single women, and familes with children will be at considerably increased risk returning to their cars after night games.
5. You are not currently proposing any additional off-street parking provision available at low or no cost to supporters.
6. Supporters have been travelling to Tottenham matches by car for many years – the ground has been in its current location since 1899 - and the parking situation has always been the same: supporters have parked on the street near the ground. There is no evidence the situation has got worse for residents.
7. Supporters of THFC bring a considerable amount of revenue into the area on matchdays, through spending in local shops, restaurants, pubs and other businesses. Having to park further away will mean less time spent in the immediate area and therefore less opportunity to contribute to the local economy.
8. Everyone living in the area will have moved into their house or flat, or grown up in the area, in the knowledge that Tottenham football ground was there and that crowds and cars would arrive on matchdays. Nothing has been imposed unexpectedly on them.
9. People lead busy lives. Supporters have families and other things to do before and after games and their ability to attend games or participate in these other things would be diminished by the CPZ.
10. That latter point leads on to the most important - the balance of convenience or inconvenience. A CPZ would definitely inconvenience the several thousand Tottenham supporters who travel to the ground by car. That weighs against what is a potential inconvenience for residents who may have some difficulty finding an on-street parking space near their residence within certain very defined periods surrounding THFC matches.
11. A survey of the area on any non-matchday shows that there is significant on-street parking capacity not taken up by residents and local business use. There is no reason to presume this capacity will therefore be used by anyone other than Tottenham supporters on matchdays.
12. The council has already reduced parking capacity by increased use of yellow lines (beyond areas where it is legitimate to reduce hazards at junctions), other ‘traffic calming’ measures and the controlled parking introduced earlier this year immediately east of White Hart Lane station. It has also contributed to residential occupancy increasing by allowing high density development on sites previously used, for example, for schools.
13. It is acknowledged that there is traffic congestion on matchdays but introducing a CPZ will solve neither that or any ‘parking problem’. There is congestion in the area on most days of the week and the ‘parking problem’ (and some of the congestion) will simply move to the areas immediately outside the proposed CPZ.
Consultation issues
Background
The Trust has attended regular, planned meetings with Tottenham Police and THFC safety personnel for a number of years. Other supporters’ groups (Spurs’ Supporters Club and, formerly, TISA) and independent supporters attend as do, on occasions, representatives of the council. Minutes of these meetings show that the Trust referred to “reports in the paper about CPZs and asked what the current position was” in September 2003. The council officer present replied “that this matter is in the early stages of discussion”.
The Trust requested an update at the January 2004 meeting when the council confirmed “Talks had taken place between the Club and Council, in particular last week. The target is to get the CPZ up and running by next season [2004/05]. All parties must have their say in the matter. [The council] stated that this matter should be out in public forum in due course.”
The Trust requested a further update at the June 2004 meeting. The council responded that they were “awaiting the results of traffic flow surveys … these results should be known b y August [2004]. Supporters will be given sufficient information when more news is known.” It was also stated that the scheme was likely to be delayed due to financing for surveys, consultation would take place by August [2004] but implementation was unlikely before January [2005]. At the September 2004 meeting the council said “it was still going to programme and the results of the survey were now with councillors. The survey would be published in October”.
The council failed to attend the January 2005 meeting when the police reported “the CPZ is ongoing and will probably start at the beginning of next season [2005/06]”. The Trust registered its grave concern about any scheme beginning at the start of a season when supporters attending matches would be unaware of it.
The May 2005 meeting was cancelled by the police and following press reports over the summer the Trust contacted both THFC and the council in August 2005. The council officer concerned said there may be further delays but that the council would provide a full update at the next meeting of the police-supporters forum which was now scheduled for September. He also agreed to advise the Trust earlier if there was other progress in the meantime. In the event, the council once again failed to attend the 14th September 2005 and the Trust requested a special meeting be convened specifically to discuss the CPZ. That meeting took place on 13th October 2005.
1. At the 13th October meeting the Trust pointed out that under regulation 6(1) of the Local Authorities’ Traffic Orders (Procedure) (England and Wales) Regulations 1996 (‘the Regulations’) table item 7 requires the council, before making an order [for a CPZ], to consult “such other organisations (if any) representing persons likely to be affected by any provision in the order as the order making authority thinks it appropriate to consult”. The Trust stated, and the council agreed, that the Trust is such an organisation, being representative of supporters and officially recognised as such by THFC. The Trust does not believe the council has taken active steps to pursue this consultation and that all moves in this regard have been made by the Trust itself.
2. Further, regulation 7(2) requires the council “Not later than the date on which paragraph (1) [the requirement to publish the notice of proposals in specified places] has been complied with … [to] send a copy of the notice of proposals to each body or person whom it is required to consult under regulation 6(1)…”. The address to which this notice should be sent to the Trust was advised to your Mr Vincent Valerio by e-mail dated 23rd October, which he acknowledged and agreed by e-mail dated 25th October. A reminder was sent by e-mail on 6th November. Despite this and the notice being formally published on 27th October 2005, no copy of the notice has yet been sent to the Trust and we therefore believe you are in breach of Regulation 7(2).
3. Further, and more importantly, regulation 7(1)(c) requires the council to “take such steps as it may consider appropriate for ensuring that adequate publicity is given to persons likely to be affected by its provisions and … such steps may include … (ii) the display of notices in roads or other places affected by the order; or (iii) the delivery of notices or letters to premises, or premises occupied by persons, appearing to the authority to be likely to be affected by any provision in the order”.
4. As to roads or other places affected by the order, no such notices were placed until after 29th October. It was made clear to the council officers attending the meeting on 13th October that after 29th October THFC had no more home games until 20th November, which is clearly beyond the 21 days allowed for objections by regulation 8. (We acknowledge that there is a match taking place at White Hart Lane this Friday, 11th November, but this is not, of course, a THFC fixture and will not be attended by the majority of regular Tottenham supporters.) It is quite obvious that supporters attending home matches are persons affected by the proposed order and it appears to the Trust that the council has decided to run the consultation period and place the notices in affected roads during a time when it is least likely that those affected persons will see them. We would also point out that the way the notices have now been placed – wrapped tightly round circular sign posts – makes them difficult to see and/or read. The Trust also believes that roads adjacent to the area to be included within the CPZ are “other places affected by the order” but no notices have been placed in these roads. We have also been unable to find any notices along the roads forming the western boundary of the proposed zone (Great Cambridge Road, The Roundway and Lordship Lane).
5. As to delivery of notices to persons affected by the order, while THFC has taken some steps to notify supporters via its match programme, website and e-mail newsletter (though we await delivery of the latter), the information provided (which THFC has advised the Trust was in turn provided by the council) was initially both incomplete (as to the area to be covered by the CPZ) and in one regard (closing date for objections) incorrect. We are not aware that the council has itself taken steps either to directly write to Tottenham supporters (using, for example, THFC’s database of season ticket holders and members) or to residents and businesses in surrounding areas.
The Trust therefore believes you should formally extend the current consultation period to take in further THFC home fixtures (the next games being on 20th November and 3rd December) and during this period make sure that all affected supporters and persons in adjacent areas are made fully aware of the proposals. This should be by more prominent street signage, leaflets and/or letters to all affected persons. Please confirm if any such measures will be taken.
Misleading Information at 13th October meeting
At the meeting on 13th October the Trust asked specifically whether residents would be charged for permits to park within the zone when it was in operation on matchdays, whether for themselves and/or their visitors. This was as a direct result of an enquiry from a Trust member who is resident in the zone and who confirmed no mention was made of charging in your previous communication to residents (to which this person responded opposing any CPZ). The council officers present on 13th October stated that such permits would be provided free of charge. However, in the notice published on 27th October, a charging scale to residents is included. It is inconceiveable to the Trust that a decision to impose charging was made only between 13th and 27th October and, even if it was, this should have been communicated to the Trust.
I would be grateful if you would advise the Trust in writing to the above address of the outcome of the current consultation and how our points have been taken into account.
Yours sincerely
Bernie Kingsley
Board Member, Tottenham Hotspur Supporters’ Trust
cc. Tottenham Hotspur FC
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