Civil Enforcement of Parking Contraventions (Representations and Appeals) (Wales) Regulations 2008

Many of the points that I wished to make have been covered, but I feel that it is a promising movement in the right direction for Wales to have the regulations. It is interesting from a constitutional point of view that the regulations cover non-devolved matters that are in the process of being transferred to the Assembly. I welcome that; it is a very slow process, as the noble Lord, Lord Jones, has just said. The enforcement authorities and the representations that will be made to them are a welcome step, as is the fact that there is to be an independent adjudicator. The regulations set out the grounds for making representations and for appeals. I want to make a few points about some things in the Explanatory Memorandum. In paragraph 2.4, there is mention of civil enforcement officers acting on behalf of local authorities. First, I have a rhetorical question: do the enforcement officers already exist? I believe that they do and that they are employed by local authorities. The regulations open the door to others—agencies or private contract companies—and I am sure that those of us who live in Wales and are well acquainted with it know the situation in Cardiff, for example, where some parking has, after 10 or 12 years, become extremely expensive. Presumably, the penalties will likewise become even more expensive. It is a live issue in Cardiff, and this change may add fuel to the fire. What will the level of penalty charges be? Will they be self-financing from the point of view of employing enforcement officers? I gather from the document that, in fact, there will be no additional charges, but it seems to me that there may be. Some other points emerge from the description in paragraph 4.6 of the Explanatory Memorandum. Local authorities will perhaps already have the staff, the equipment and the action plans, but will they all be ready by 31 March? There is some doubt about that, and some provision is made for it. However, it might be a slow process. When does the Minister think that it will all be in place? In paragraph 5.1, there is mention of minor differences of detail between the administration arrangements in England and those in Wales. Can the Minister say what those might be? There are questions arising from that. The other point that I might make is that paragraph 7.7 of the Explanatory Memorandum refers to a reduction from 60 to 30 minutes after the PCN is issued before a vehicle is clamped. I assume that the same applies in England. That does not seem to be very long and it could cause grave inconvenience and unnecessary bureaucracy in the process. What is the Minister’s view on that? Paragraph 8.1, which concerns the impact of the regulations, states: "““No significant financial implications have been identified for members of the public or the public sector””." That is a very broad statement and I am not totally convinced that local authorities will not have to find more resources. Certainly the one that I live in has received only a 2 per cent increase in funding this year, which is less than inflation. In fact, some of these matters do not add up as they should. The other point that I want to make concerns the regulatory impact assessment, in which there is a very worthy statement. It refers to, "““restraining the growth in the use of the private car””." That is very desirable but in much of rural Wales—which is most of Wales—there is very poor public transport and the car is the only means of getting about. I hope that that will be taken into account in all these regulations. Not so long ago, it used to be said that there was only one set of traffic lights in mid-Wales. Now there are a few more but there are not some of the traffic-management facilities that are mentioned in these documents. Quite frankly, this will be regarded by some citizens in rural Wales as ““outer space”” legislation. I take the point that obviously not everyone will opt into this system, but the risk assessment makes a number of points on the costs and benefits of the regulations. Those may be a little out of the question in, for example, some market towns in central Wales, where there are often plenty of parking spaces and a very sparse population.