We have been asked to respond to proposed changes to the regulations of the Royal Parks. The details of the changes and our repsonses are below.
If residents would like to respond indiviually please send an email to
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by May 1st 2009.
For more details go to. http://www.royalparks.org.uk/consultation_document_have_your_say.cfm
The Marylebone Association is the statutory consultee for residents and businesses in an area bounded by Oxford Street, Edgware Road, Marylebone Road, and Great Portland Street. It represents a membership of over 1000 resident and business members in that area. Thus, it is particularly concerned with Hyde Park and Regents' Park, though comments may be pertinent to all Royal Parks. The comments provided have been approved by the twelve member committee, and have been made known to all those members on email.
Section 2: Proposed Changes to the Royal Parks Regulations
2.1 The Royal Parks is considering a number of changes to the regulations. Our proposals are set out below.
Introduction of Parking Charges in Bushy and Richmond Parks
2.2 Introducing parking charges in Richmond and Bushy Parks is consistent with our policy across the rest of the Royal Parks estate and supports our environmental agenda of encouraging visitors to travel to the parks by means other than private car wherever possible. It also discourages displacement of parking into the parks as a result of the imposition of parking fees by authorities outside.
2.3 The scheme we propose to put in place will introduce charges at rates that are broadly in line with those levied by the authorities in the surrounding areas. While not being punitive to those who have no option but to visit by car, we hope the charges will encourage visitors who can to travel to the park by public transport, by bicycle, or on foot. The scheme includes a maximum stay, intended both to ensure a reasonable turnover of spaces (which would be fairer to visitors than our current system) and preclude abuse by commuters and shoppers of a facility that is provided exclusively for park visitors.
2.4 The proposed scheme would raise essential revenue towards the maintenance of The Royal Parks' roads and associated infrastructure.
Details of the scheme
2.5 We propose that parking charges should be introduced in all the public car parks in
Bushy and Richmond Parks, and would welcome your views on the proposed charges and conditions as set out below.
Richmond Park
Up to 1 hour - £1.00
1 to 1½ hours - £1.50
1½ to 2 hours - £2.00
2 to 3 hours - £2.50
Over 3 hours - £3.00
Bushy Park
Up to 1 hour - £0.50
1 to 1½ hours - £0.75
1½ to 2 hours - £1.00
2 to 3 hours - £1.50
Over 3 hours - £2.00
These charges would apply whenever the car parks are open.
There would be a maximum stay of six hours in any one car park.
A set proportion of the available parking spaces would be designated for Blue Badge holders.
Blue Badge holders and motor bikes would be exempt from the charges, but subject to the maximum stay limit.
Q1: Do you support the introduction of parking charges in Richmond and/or Bushy Park?
ASSOCIATION RESPONSE
NOT OUR AREA, BUT WE BELIEVE THAT PARKING CHARGES HELP TO REGULATE TRAFFIC USE IN THE PARKS SO WOULD BE IN FAVOUR.
Q2: If you accept the introduction of parking charges in principle, do you consider that the rates we propose are about right, too high or too low?
ASSOCIATION RESPONSE
NO COMMENT
Q3: Do you agree that there should be a maximum stay for parking in Richmond and /or Bushy Park?
ASSOCIATION RESPONSE
YES
Q4: If you agree that there should be a maximum stay, do you think that 6 hours is about right, too long or too short?
ASSOCIATION RESPONSE
NO COMMENT
Q5: Do you have any further comments about our proposal to introduce parking charges?
Allowing Private Hire Vehicles (PHVs) into the Parks
ASSOCIATION RESPONSE
NO
2.6 The Royal Parks Regulations currently prohibit any vehicle that is "constructed, adapted or in use as a trade vehicle" from entering the Royal Parks unless they have express permission to do so, or legitimate business in the Parks. The only exception is for Hackney carriages ("black cabs") licensed by the Public Carriage Office (PCO), and this is on the grounds that they provide a service for visitors. However, as
Private Hire Vehicles (PHVs) in London are now also licensed by the PCO, we propose to amend the regulations and allow them into the Parks on the same terms
as are already allowed for black cabs.
2.7 This change is intended to benefit potential visitors - including the disabled who receive subsidised travel in PHVs - without making a significant difference to the volume of traffic in the Parks. Prior to the introduction of the licensing regime, PHVs had been largely indistinguishable from private vehicles, which made it difficult for us to enforce, in a proportionate way, the prohibition on PHVs using the Parks in the course of their trade. PHVs are now required to clearly indicate their PHV status.
2.8 We do not intend to relax our general prohibition on commercial vehicles entering the Parks unless they have explicit permission to do so, or legitimate business in the Parks. We would draw the new regulations as tightly as possible and only permit PHVs which, like black cabs, have been licensed in London by the Public Carriage Office. We do not intend, at this stage, to widen access to PHVs licensed by authorities outside London.
Information on the licensing regime for PHVs in London can be found at:
www.tfl.gov.uk/pco .
Q6: Do you support our proposal to allow Private Hire Vehicles that are licensed by the Public Carriage Office to enter the Royal Parks on the same terms as are already allowed in law for black cabs? If not, please give your reasons. Introduce an express provision that taxis and PHVs displaying external advertisements may still enter the Royal Parks
ASSOCIATION RESPONSE
WE STRONGLY OBJECT TO THE PROPOSAL TO ALLOW PRIVATE HIRE VEHICLES (PHVS) LICENSED BY THE PUBLIC CARRIAGE OFFICE, AS THERE IS NOW A PROFUSION OF SUCH VEHICLES ON THE LONDON ROADS. WE BELIEVE THAT THIS DECISION WILL DRAMATICALLY INCREASE THE NUMBERS OF VEHICLES USING THE ROYAL PARKS AS CUT THROUGHS IN ORDER TO AVOID HEAVIER TRAFFIC ELSEWHERE. SO TRAFFIC VOLUMES WILL INCREASE, THUS INCREASING URBANISATION OF THE PARKS, IN OPPOSITION TO ONE OF THE MAIN AIMS AND OBJECTIVES. PHVS ALSO TEND TO BE VERY POORLY DRIVEN IN COMPARISON TO LICENSED BLACK CABS, SO THERE IS A SAFETY ISSUE, IN ADDITION TO PEACE AND QUIET AND ENJOYMENT OF THE PARKS AND POLLUTION ISSUES. IN FACT, WE HAVE ALREADY NOTICED AN INCREASE IN SUCH VEHICLES USING THE PARKS, PRESUMABLY BECAUSE REGULATIONS ARE NOT BEING ENFORCED. IN ORDER TO ADDRESS YOUR CONCERN THAT THESE VEHICLES ARE USED BY THE DISABLED FOR SUBSIDISED TRAVEL, WE WOULD PROPOSE THAT ANY VEHICLE BEING USED IN THIS WAY COULD BE PERMITTED TO TRAVEL THROUGH THE ROYAL PARKS, EITHER CLEARLY DISPLAYING A RELEVANT SIGN ON THE VEHICLE OR BE WILLING TO SHOW PROOF OF VEHICLE USE FOR DISABILITY (THERE MUST BE SOME AUTHORITATIVE DOCUMENTATION PROVIDED FOR SUBSIDISED TRAVEL?)
2.9 The Secretary of State issued a direction in 1982 which set out that black cabs bearing
external advertisements may enter the Royal Parks, despite there being a prohibition
in the regulations against displaying advertising material without express
permission. (The direction was issued under the Secretary of State's power to grant
such permission). This is now a long-standing practice and one which we consider
would be appropriate to put on a statutory footing. We also propose to make the
same provision in respect of Private Hire Vehicles (PHVs) if we implement the
proposal set out at paragraph 2.6 above. The kind of advertising that can be carried
on these vehicles is restricted by the Public Carriage Office.
Q7: Do you agree with our proposal to give express statutory force to the already
accepted practice that black cabs are allowed to enter the Royal Parks even if they
are bearing advertisements?
ASSOCIATION RESPONSE
YES
Q8: Do you agree that we should make identical provision in respect of PHVs
(provided that we implement our proposal to allow them to enter the Royal
Parks)?
ASSOCIATION RESPONSE
NO - BUT HOPEFULLY PHVS WILL NOT BE GENERALLY PERMITTED TO USE ROYAL PARKS ROADS (SEE POINT 6)
Lowering the speed limit on the roads in Greenwich Park from 30 mph to 20mph
2.10 We are considering implementing an amendment to the Regulations to reduce the speed limit in Greenwich Park from its existing 30mph to 20mph. This would bring the speed limit in Greenwich Park into line with that on the roads immediately outside it. We consider it wrong that, at present, drivers may drive faster within the Park than on many of the surrounding roads. We consider that a lower speed limit will contribute towards de-urbanising the Park, safety and the protection of wildlife, improving the park atmosphere and making it a more enjoyable experience for visitors.
Q9: Do you agree with our proposal to reduce the speed limit in Greenwich Park from 30mph to 20mph?
ASSOCIATION RESPONSE
Yes
Q10: If you do not agree with our proposal to reduce the speed limit in Greenwich
Park to 20mph, please explain why.
ASSOCIATION RESPONSE
N/A
Lowering the speed limit on the roads in Bushy Park from 30 mph to 20mph
2.11 We are considering implementing an amendment to the Regulations to reduce the speed limit in Bushy Park from its existing 30mph to 20mph. This would bring the speed limit in line with nearby Richmond Park, where we successfully introduced a reduced speed limit in 2004. Bushy Park has similar landscape features, wildlife and park management challenges to Richmond. We consider that this measure will contribute towards de-urbanising the Park, safety and the protection of wildlife, improving the Park atmosphere and making it a more enjoyable experience for visitors.
Q11: Do you agree with our proposal to reduce the speed limit in Bushy Park to 20mph?
ASSOCIATION RESPONSE
Yes
Q12: If you do not agree with our proposal to reduce the speed limit in Bushy
Park to 20mph, please explain why.
ASSOCIATION RESPONSE
N/A
Animal Faeces
2.12 The regulations can be interpreted as requiring that horse riders and drivers of horse-drawn vehicles, like dog owners, clear up after their animals. This is not the intention of the regulations, so we propose to clarify that this requirement does not apply to horse owners.
Q13: Do you agree that the regulations should make clear that horse owners are not required to clean up after their animals?
ASSOCIATION RESPONSE
Yes
