Consultation Document Proposed Changes to the London Congestion Charge Scheme Response from: British Vehicle Rental and Leasing Association River Lodge Badminton Court Amersham BUCKS HP7 0DD Tel: +44 1494 434747 Fax: +44 1494 434499 E-mail: info@bvrla.co.uk Web: www.bvrla.co.uk
Bona-fides BVRLA, the industry and its members Established in 1967, the British Vehicle Rental and Leasing Association is the UK trade body for companies engaged in the rental and leasing of cars and commercial vehicles. Its members operate a combined fleet of 3.3 million cars, vans and trucks. BVRLA members buy nearly half of all new vehicles sold in the UK, supporting around 184,000 jobs and contributing more than 14bn to the economy each year. By consulting with government and maintaining industry standards, the BVRLA helps its members deliver safe, sustainable and affordable road transport to millions of consumers and businesses. For more information, visit www.bvrla.co.uk. Executive Summary The BVRLA welcomes the opportunity to comment on Transport for London s (TfL) proposed changes to the London congestion charge scheme (LCCS). We note the main changes to the scheme are: Providing the option to pay CC Auto Pay accounts by direct debit Enabling discount applications and renewals to be made online Increasing the daily Congestion Charge Changing the NHS Reimbursement Scheme to allow refunds for CC Auto Pay payments Providing the option for customers to amend the date of a pre-paid charge on the day of travel Minor Congestion Charge Scheme Order changes We believe there are a number of other changes which TfL should implement to help reduce the burden on motorists. These include:- E-notification of penalty charge notices to business this would reduce costs for TfL and fleet owners by removing the need for details to be sent through the post between the parties. March 2014 Page 1
Make further administrative improvements to the discount schemes by considering a DVLA look-up facility to help verify any information contained in the vehicle registration document (V5C). This will ensure TfL obtains the information needed in a timely and cost effective manner when administering new discount applications and renewals. We provide further explanation of these suggested improvements below. Specific Comments Exemption for vehicle rental Vehicle rental and car clubs play a key role in supporting TfL s objective of encouraging the reduction of vehicles being used or kept within the congestion charge zone. The BVRLA has conducted extensive research with the Transport Research Laboratory (TRL) on why people choose to rent a vehicle and what impact this has on their transport behaviour 1. We have extracted from this research data relating only to London the following: 64.5% of those surveyed who lived in London reported not owning a car and maintaining a more sustainable, multi-modal lifestyle in comparison with 32.7% in the rest of the country. The majority of cars rented in London were small or medium cars (e.g. Ford Focus, Fiesta, VW Lupo or similar). These vehicles are less than six months old and the average CO 2 emissions for these vehicles is 121.2 g/km 2. In comparison the average UK car CO 2 emissions are 168.4 g/km. Rental customers on average make more frequent trips by bus, train, bike and on foot than the average driving licence holder in London. The main reason people rent vehicles in London is to visit family or friends, holidays/tourism and day trips or other leisure activities which suggests that people rent cars in London to visit places outside of London. These findings help to demonstrate the important role vehicle rental plays in improving the environment and reducing congestion. It is on this basis that we believe TfL should implement our calls for vehicle rental to be made exempt from the LCCS. 1 TRL Rental Customer Survey 2012 2 SMMT New Car CO 2 Report 2013 March 2014 Page 2
By exempting rental vehicles TfL will reinforce its support for sustainable travel habits and will encourage more people to use public transport instead of privately owned cars. We have also co-authored a report with the RAC Foundation Car Rental 2.0 New alternatives to car ownership 3, this report looks at the role local authorities can play in supporting alternative forms of car access through various policies. These include: Subsidies for pay-as-you-go car use schemes, for example through the Local Sustainable Transport Fund. Forming partnerships between car club and rental companies and local authorities. Providing discounted or free parking spaces, particularly at locations that link up various modes of transport, for example bus and rail stations. Allowing car clubs and rental companies to tap into systems, such as London s Oyster card so that an integrated transport proposition is developed. We hope these policies can be considered as part of TfL s wider objectives to develop London to become a world leading green city. E-notification of fines We would welcome the opportunity for TfL to consider a solution which would notify fleet owners electronically of all penalty charge notices. The current process for issuing a penalty charge involves: TfL posting a penalty charge to the rental company The rental company responding with a pack of evidence to identify the customer or pay the charge. TfL would post a new penalty charge to the customer, where a customer has been lawfully nominated. The current process is administratively burdensome, relies on documents not getting lost in the post and where they do remove duplication of information being requested and issued. A simple solution would be for TfL to identify from the data file any rental or leasing companies and sends them an e-notification of the vehicle registration mark, date and time when an offence was committed. 3 RAC Foundation March 2014 Page 3
A rental or leasing company could then simply send the e-notification back to TfL with details of the customer who is liable to pay the charge where applicable. This process will also improve cash flow benefits to TfL as rental or leasing companies would pay the charge promptly. Whilst we accept that there would be some costs associated with developing this solution, these costs would be outweighed by the benefits to TfL. This improved process would ensure penalty charge revenue is collected in a much more efficient manner and the cost of the process would be reduced significantly for both TfL and rental companies. We estimate the cost savings for our rental members to be in the region of 10 million per annum and suspect that similar costs savings could be enjoyed by TfL. If the legislation were changed to allow leasing companies to transfer PCNs to their customers as well these cost savings would double. Where the customer disputes the PCN on the basis that they were not the hirer at the time the PCN was issued, then our members would be required to provide further evidence that the vehicle was on hire or lease at the time the offence was committed. Administration of discounts We welcome TfL's proposal to allow customers registering/renewing discounts to be able to scan and upload their supporting evidence rather than having to post it. Whilst we welcome this change, we would suggest TfL could go further by removing the need for the person registering/renewing the discount to provide a copy of the vehicle registration document (V5C). For a business this is a burdensome approach as the V5C is often kept at a secured storage and the document may not be in the possession of the person who is registering the vehicle for the discount. This is particularly relevant for leased vehicles. In addition, the DVLA are implementing proposals by 2015 as part of the Government s red tape challenge for fleet customers to no longer receive a paper version of the vehicle registration document. As an alternative we would encourage TfL to consider a DVLA look-up facility to verify any information required from the vehicle registration document. This will help TfL with more timely and cost effective processing of discount applications and renewals. We believe if this approach was implemented there would be cost savings for TfL and therefore TfL should consider removing the 10 administration fee for registering/renewing 100% discount vehicles. March 2014 Page 4
Legislative defect We would welcome Transport for London s support on an amendment to the Road User Charging Regulations that we have long been seeking. The amendment required will allow leasing companies whose agreements are longer than six months in duration to transfer fines to the customer. Leasing companies inability to transfer the liability in relation to the PCN means they have to either absorb the cost or if their contracts permit they will try to recover the costs from the customer. However, this not only has a direct cost and cash-flow impact on our members, but paying the fine means that the vehicle users rights of appeal are removed or that the offender may go unpunished. We therefore call on TfL to lend their support to a legislative amendment to the Road User Charging Regulations to allow our members to transfer fines to the customer where the agreement is more than six months in duration. Daily congestion charge increase We are unable to support any congestion charge increase which will impact our members. We believe that an increase at this time when businesses are still struggling to recover from the recession is poorly timed and will impact on those offering vital services within London which have no choice but to use vehicles to offer those services and deliveries in London. Role of DVLA We would also like to take this opportunity to draw to TfL s attention the recent independent report by Mary Reilly into the work of the DVLA 4. In her report to the Transport Minister, Mary Reilly made a number of recommendations including: Recommendation 4 DVLA s value as a service provider of government should be optimised 4 A Review of DVLA March 2014 Page 5
Significant experience will be gained through delivery of IT transformation and further development of digital services. Early work suggests that DVLA will be best served by an operating model which utilises in-house capability aligned to best practice and industry standards. DVLA should use this experience to leverage its brand and become a digital leader in both the public and private sectors. DVLA should aim to be recognised as a symbol for digital excellence. This could attract growth opportunities for the business and benefit the local economy. We believe this recommendation could be of significant interest to TfL with regards to the issuance of PCNs. If the DVLA s IT transformation is successful we believe that this could position DVLA to play a key role in supporting the electronic issuance of PCNs for any offence which requires contacting the registered keeper. We believe this would deliver significant cost savings for organisations such as TfL as the administration would be handled by the DVLA and if this was on an electronic basis for fleets would give TfL access to the true offender quicker. We have provided a simple diagram below to show how this would work in practice: A congestion charge PCN is incurred TfL sends VRM details electronically to the DVLA DVLA identify the registered keeper and if the registered keeper is a fleet company through the DVLA fleet code If it is a fleet company DVLA will contact the fleet company and ask for customer details. If it is not then the DVLA will print and post the PCN to the individual The fleet company will populate the electronic file with customer details or payment details and send it back to DVLA DVLA will either process payment or print and post the PCN to the customer The normal process for PCNs will then continue The above process could facility multiple PCNs being sent to a fleet owner from all of TfL s enforcement regimes. March 2014 Page 6
Given that the Mary Reilly review of the DVLA has received Ministerial endorsement for all of the recommendations and the DVLA has been tasked with implementing these we would suggest that TfL may wish to explore this as an option with the DVLA Closing Comments We hope that our comments add value to TfL s proposals for changes to the London congestion charge scheme and that careful consideration is given to our suggested efficiency and cost saving proposals would be happy to meet and discuss our proposals in detail with TfL. Leasing Members In general, vehicle leasing is an arrangement where the user simply hires the use of the vehicle and assumes operational responsibility for a predetermined period and mileage at fixed monthly rental from the owner (the leasing company). Legal ownership is, in the majority of cases, retained by the leasing company. Short Term Rental Members Rental Members offer hourly, daily, weekly and monthly rental of vehicles to corporate customers and consumers. As explained above, rental members are the owners of the vehicle. March 2014 Page 7
Response from: Address: Contact: British Vehicle Rental and Leasing Association River Lodge Badminton Court AMERSHAM Bucks HP7 0DD Mr Jay Parmar, legal and policy director Phone: +44 1494 545706 Fax: +44 1494 434499 Email: jay@bvrla.co.uk March 2014 Page 8