Last week SNP, Green & Lib Dem Councillors agreed to progress to consult on the introduction of a Wordplace Parking Levy. This was despite some predictable concerns raised by myself in response to an integrated impact assessment published by the Council. Failure to consult on robust mitigation options to deal with (1) displacement parking, (2) support for low paid workers & (3) shift workers will lead to the public opposing the plans and the collapse of the SNP/Green/Lib-Dem Coalition supporting the consultation. Opportunity, time and money will have been wasted.

From Edinburgh EIS
I am emailing with some comments on the Interim Integrated Impact Assessment that has been carried out in respect of the proposal to introduce a Workplace Parking Levy.  In particular, I am very concerned that there is no reference at all to the impact on pupils of introducing such a levy – particularly the impact on pupils in schools in the most deprived parts of the city.  The following are some key points that I feel are worthy of much greater consideration by your committee when both deciding on the detail of the forthcoming consultation, and on the final nature of any levy.

PSAs/other support staff
You must be aware that there is a massive issue with both recruitment and retention of our vital Pupil Support Assistants. These people do absolutely crucial work in supporting pupils, especially pupils with additional support needs, yet are amongst the lowest paid workers in the council. We are already at the stage where headteachers in our special schools have had to consider sending classes home due to lack of sufficient PSAs to safely care for pupils, and where successful inclusion in our mainstream classes is not able to be delivered due to the shortage of PSAs. This is one of the major drivers in the surge in dysregulated behaviour in our classrooms that is of such concern. It is also a key barrier to schools being to close the poverty related attainment gap, and to enable pupils to overcome barriers to learning. Imposing a workplace parking levy on these staff is highly likely to make the current crisis far worse, and to have a major negative impact on pupils.

Geographic issues
The IIA does not seem to consider that many schools are based in areas that are not well served by public transport – and this is particularly true for schools in areas with higher levels of deprivation. A workplace parking levy will be a major disincentive for people considering working in those schools – we already know that these schools struggle to retain experienced teachers, particularly in shortage subject areas, so introducing a levy is likely to mean that existing disparities will be exacerbated. It is already the case that supply teachers who rely on public transport will not go to schools in certain areas during the winter months, due to the length of the commute, safety considerations around waiting for buses in the dark etc. This, again, impacts on pupils, as the odds on them getting subject specialist supply teachers are reduced – a workplace parking levy that does not take account of this is likely to lead to greater inequality.

The cost of housing in Edinburgh is very high and many staff must move out to afford the size of property required for their family. Retention of experienced staff would become more challenging as they may find employment outwith the city in a local authority which does not expect them to pay a levy. The challenge for staff who live outside the city and need to travel in would be particularly acute for schools in areas that do not have a rich network of different transport options. Once again, it is pupils, and their families, that would suffer from the consequences of this.

Safety considerations
The IIA states that female and LGBT school workers travelling by public transport would be at increased risk of experiencing hate crime. Many of our school staff are already the target of verbal and physical violence within schools, and there are already documented cases of them being subject to abuse and attack on the way to and from work. Travelling on public transport would increase these experiences and lead to a rise in the already high number of cases of work related stress experienced in our schools, and in levels of absenteeism, with all the obvious impacts on pupils.

Other issues
Your IIA states that the majority of school workers are women at an age when many will have children in school or nursery provision. In order for children to be delivered and collected from different schools or child care establishments, workers must be able to travel quickly, and to a variety of places, not on direct bus routes, without the fear of their child being left before school starts or after the other children have gone. School workers who are parents of children with ASN, and who no longer have access to after-school provision in Edinburgh, must be able to pick their children up as quickly as possible to avoid anxiety or distress. This simply cannot be managed if travelling on public transport. At present, to travel by public transport would double commute times for school staff with the significant negative effect on their ability to perform their family roles and responsibilities, and on them being able to maintain a good work-life balance. Again, this is likely to lead to staff leaving, and moving to schools that do not present the same transport challenges, so that not only the staff but the pupils will suffer.

Many school staff would refuse to pay a Work Place Levy simply because they couldn’t afford it. Instead, they will resort to parking on neighbouring residential streets around school building, which will create additional safety concerns for pupils and their families in these areas.

These are just a few points, and are obviously entirely focused on schools. I suspect similar considerations will apply for staff working in social work and other parts of the council. I note you will be carrying out a public consultation on the proposal soon, and I hope that this consultation will give scope to explore all the issues that introduction of this levy will raise.

As members of the Transport and Environment Committee, I trust you will scrutinise the questions carefully before it goes live, to ensure a high quality and open engagement process. You might well want to engage proactively with the unions to ensure that the full range of impacts of the levy are considered and that you do not find that there are unintended negative consequences from any decisions you take.