Agenda Item No 5
The Vale of Glamorgan Council
Audit Committee 18th November 2014
Report from the Operational Manager - Audit as the Head of Audit
Update on Civil Parking Enforcement - Shared Service
Purpose of the Report
1. The purpose of this report is to provide the Committee with an update on the Civil Parking Enforcement, shared service arrangement.
THAT the report be noted.
Reason for the Recommendation
To facilitate monitoring of the Council's overall internal control environment.
2. During the Audit Committee meeting held on the 7th July 2014 (minute number 170), Members requested that the Audit Committee Forward Work Programme 2014/15 should be updated to include a review of the shared Civil Parking Enforcement scheme. An update was scheduled for consideration by the Committee in November 2014.
3. On the 1st April 2013, Bridgend County Borough Council and the Vale of Glamorgan Council were made responsible for the enforcement of the majority of on-street and off-street parking regulations under a scheme called Civil Parking Enforcement (CPE). Most parking contraventions, including parking on yellow lines and in parking bays, are no longer classed as criminal offences. Council’s now have powers to issue a new type of parking ticket, called a Penalty Charge Notice (PCN).
4. The two neighbouring Council’s operate a shared service arrangement which is led by Bridgend County Borough Council and guided by a joint Service Agreement. The administration and income collection of a PCN is managed by the Welsh Penalty Processing Partnership (WPPP) which is part of Denbighshire County Council who also process and collect penalty charges on behalf of another eight local authorities.
5. The objective of the audit was to ensure that the Civil Parking Enforcement Shared Service arrangement is providing an efficient and effective service for the Vale of Glamorgan Council (VoGC) in compliance with the Service Agreement.
Relevant Issues and Options
6. During the audit, a number of strengths and areas of good practice were identified. Policies and procedures were found to be fully documented and available, Civil Enforcement Officers (CEO’s) are actively and well managed by the Parking Manager with issues addressed as and when they occur and a Parking Board, consisting of Nominated Representatives has been established in accordance with the "Service Agreement relating to Civil Parking Enforcement between Bridgend County Borough Council and Vale of Glamorgan Council'.
7. A number of key issues were also identified, for example, performance indicators have not been established, the Auditor found little evidence of monitoring, Parking Board meetings are not a priority and are not minuted. Additionally, the option to move CEO’s from the Alps Depot would enable Officers to be more efficient yet little action has been taken to secure an alternative base. These areas are discussed in more detail in the body of this report.
8. Section 5.4 of the Service Agreement states that parties shall, 'within 12 months of the Commencement Date, undertake a review of this Agreement with particular reference to the costs, income and effectiveness of the arrangements. Thereafter, parties should review the Agreement at 12 month intervals. 'Appendix 3 of the Agreement lists the CPE Cost Apportionment – Annual Running Costs, which are also required to be reviewed annually as stated in the contract. On meeting with various Officers, the Auditor identified that neither the Service Agreement nor the cost apportionments have been reviewed since the contract commencement date, April 1st 2013. The Auditor has therefore recommended that the Service Agreement (including Appendix 3 - CPE Cost Apportionment) should be reviewed by both immediately.
9. A Parking Board has been established and meetings were found to have taken place during January, April and June 2014, however further meetings had not been arranged at the time of the review. It was noted that meetings are not a priority for all Officers. Members of the Board were approached for copies of minutes, actions and agendas. The Parking Manager was able to provide copies of agendas for some meetings and also some personal notes that he had taken but no formal minutes are documented or disseminated to Officers. The Auditor has therefore recommended that Parking Board meetings should be held on a quarterly basis. A timetable of forward meetings should be produced in advance together with standard agenda items and all meetings should be minuted to ensure key points are documented and actioned.
10. The Auditor found little evidence in regards to regular monitoring of the service. This should be a fixed agenda item for the Parking Board as well as an ongoing priority for both authorities. The Service Agreement does not set out specific indicators or areas for performance monitoring. When the Agreement is reviewed, this area should be revisited and clarified to ensure that specific, measurable, accurate, reliable and timely (SMART) indicators are created, implemented and regularly monitored. These indicators should be qualitative as well as quantative because ultimately the key objective of the scheme is to run the CPE operation (both on and off-street) efficiently, effectively and economically. The purpose of penalty charges is to dissuade motorists from breaking parking restrictions therefore the key objective should be for 100 per cent compliance, with no penalty charges issued. The Traffic Management Act (Part 6) provides supplementary guidance to local authorities and states that raising revenue should not be an objective of CPE, nor should authorities set targets for revenue or the number of PCN's they issue. This should be taken into consideration when creating â€œindicatorsâ€.
11. The Vale's original Business Plan for the CPE was based on 7,224 PCN’s issued in year one and 70% of all PCNs paid in full. Reports provided show that in year one, VoGC had issued 8,547 PCN’s, 1,323 more than predicted and 70% of these had been paid in full as projected. The total income received from the WPPP (2013/14) was £251,745 and the charge levied by BCBC (as the host Authority) was £167,563. The Vale also incurred costs of £89,182 for repairs, advertising, hardware, consultant fees and so on. The full financial position at year end, 2013/14, is illustrated, below.
Costs and Income - 2013/14- VoGC
Income from WPPP
BCBC Partnership Charge
Associated Costs for CPE
12. As demonstrated above, the Vale CPE finished 2013/14 with a deficit of £5,000. It should be noted that the original Business Plan did predict a short term deficit for the overall scheme; therefore this deficit is neither a surprise nor concern. The projected figures for 2014/15 were provided by the Accountant and although charges and income have been estimated at this time, the Accountant has projected a surplus of £8,763 for the second year of the scheme.
13. During the audit review, the Auditor attempted to quantify whether the CPE function would breakeven sooner if the number of Officers were increased. Unfortunately, Officers have varying duties, patrols and tasks which meant that the Auditor could not identify the average amount of Penalty Charge Notices issued per month. There are also additional factors, such as whether the PCN had been paid in full or cancelled that will also have an effect on income. There is a risk that if the number of CEO’s were increased this could have an adverse effect on the service because the increased visibility may act as a deterrent therefore less PCN’s would be issued. In conclusion to this point the Auditor cannot advise on whether increasing the number of CEO’s would allow the service to break even sooner.
14. It was identified that CEO’s are roughly apportioned 70% to Bridgend and 30% to the Vale however, the Vale will only pay for the actual hours worked by the CEO and these hours can be evidenced via the rotas sent to the Vale Accountant on a monthly basis. There are five Officers that regularly patrol the Vale of Glamorgan and they have been assigned here because they live in the Vale. This is also the case for Officers who work in Bridgend. Assignment is not based on the Officer's performance. When there are staff shortages CEO’s who normally work in Bridgend will provide cover to the Vale and vice versa.
15. To reduce travelling time and costs, Civil Enforcement Officers are based at Bridgend Innovation Centre and the Alps Depot in Wenvoe depending on their nearest patrol area. It has been recommended and discussed that an alternative base is sought in the Vale because Officers are required to travel to their base twice daily to sign out their Hand Held Computers and upload them at the end of the day. This takes up approximately an hour of enforcement time per Officer, per day. The original suggestion to move the base office was made 16 months ago and although enquiries into alternate bases have been looked into by the Principal Engineer, CEO’s are still reporting to the Alps at least twice a day. This is costing the Vale Officer downtime and mileage costs. There is no deadline for the implementation of this action. Therefore, the Auditor has recommended that an alternative base for Civil Enforcement Officers in the Vale should be secured as soon as possible.
16. The Auditor requested a six month report of all cancelled PCN’s for April to September 2014 and tested a 5% sample to ensure that PCN's had been cancelled in accordance with the prescribed processes. No issues were identified.
17. During the testing process it was noted that the Vale have a potential to increase revenue by charging Blue Badge holders for car parking, in areas where other users are required to pay. The Auditor found that current practises allow the cancellation of a first time contravention for Blue Badge Holders. During 2013/14, 78 PCN's were cancelled due to a first contravention with a potential income of £3,656.
18. Based on an assessment of the strengths and weaknesses of the areas examined, and through testing, it has been concluded that the effectiveness of the internal control environment is therefore reasonable. In summary the main recommendations are:
That the Service Agreement (including Appendix 3 - CPE Cost Apportionment) should be reviewed by both Councils immediately;
That the Parking Board meetings should be held on a quarterly basis. A timetable of forward meetings should be produced in advance together with standard agenda items and all meetings should be minuted to ensure key points are documented and actions and;
That an alternative base for Civil Enforcement Officers in the Vale should be secured as soon as possible.
19. A response from Management to the above recommendations is awaited.
Resource Implications (Financial and Employment)
19. Effective audit planning and monitoring are key contributors in ensuring that the Authority's assets and interests are properly accounted for and safeguarded.
Sustainability and Climate Change Implications
20. None directly.
Legal Implications (to Include Human Rights Implications)
21. Provision of an adequate and effective Internal Audit function is a legal requirement under the Accounts and Audit (Wales) Regulations 2005 as amended.
Crime and Disorder Implications
22. Pursuing initiatives to prevent, detect and deter crime is encompassed within the terms of reference under which the audit function operates.
Equal Opportunities Implications (to include Welsh Language issues)
23. None as a direct consequence of this report.
24. The work of audit is intended to assist in the achievement of all corporate and service objectives.
Policy Framework and Budget
25. The proposals in this report are in accordance with the policy framework and budget.
Consultation (including Ward Member Consultation)
26. No further consultation is proposed.
Relevant Scrutiny Committee
27. Corporate Resources.
Helen Smith - Operational Manager - Audit Tel: 01656 754901
External Audit Manager - Grant Thornton UK LLP
Alan Jenkins - Head of Finance and Section 151 Officer