Parking Charges That Don’t Add Up: Why This Is a Bad Idea, Badly Thought Through

✍️ Author’s Note

This proposal to introduce widespread off-street parking charges across Wirral is being presented as a tidy, sensible reform. It isn’t.

There is no published business case, no clear return on investment, and no evidence that the income raised will outweigh the costs of installation, enforcement, administration, and lost footfall.

Worse, parking charges are being used in a way the law does not allow: as a revenue tool rather than a traffic-management measure. That exposes the Council to legal risk and local centres to economic harm.

Blanket charging in district centres and neighbourhood parades will not “improve turnover”. It will reduce casual visits, hurt independent businesses, displace parking into residential streets, and quietly hollow out already fragile places.

This article explains why the numbers don’t add up, why the strategy is flawed, and why a formal objection has been submitted under Scheme Ref TO/25/28.

 — Rory Wilmer, New Brighton, January 2026

There’s a simple test for any public policy: does it solve a real problem without creating bigger ones?

This parking charges proposal fails that test on every level.

On the surface, it looks tidy. Standardise charges. Introduce overnight fees. “Bring consistency.” The sort of thing that reads well in a spreadsheet and terribly in real life. But once you step back and apply even basic strategic thinking, the whole thing collapses.

This isn’t a demand-management scheme. It isn’t a regeneration tool. And it certainly isn’t a sound financial decision.

It’s a revenue idea pretending to be a transport policy — and those are the most dangerous kind.

The Core Problem: No Business Case, No Logic

If this were a private business proposal, it wouldn’t make it past the first meeting. There is no published business case showing that the income from these charges outweighs:

• the cost of installing machines,

• maintaining them,

• enforcing the scheme,

• processing payments and appeals,

• and dealing with the knock-on effects when drivers simply go elsewhere.

That last point matters more than councils like to admit. People don’t disappear when you charge them. They reroute. They park on residential streets. They go to retail parks with free parking. They stop making short, casual trips altogether.

So what looks like “new income” often turns out to be:

• lost footfall,

• angry residents,

• struggling independents,

• and enforcement costs chasing the same shrinking pool of drivers.

That’s not a return on investment. That’s a slow leak.

Parking Is a Behaviour Tool — Not a Cash Machine

Parking policy works when it nudges behaviour gently:

• short stays where turnover is needed,

• longer stays where it supports local use,

• free or cheap access where places are fragile and need life.

Blanket charging ignores all of that. District centres are not city centres. Neighbourhood parades are not shopping malls. And treating them as if they are is how you hollow places out. Out-of-town retail parks understand this perfectly. That’s why parking is free. They know the car is not the enemy — absence is.

Overnight Charging: The Telltale Red Flag

Nothing exposes weak thinking faster than overnight charges. If there were a genuine overnight problem — misuse, antisocial behaviour, capacity pressure — it would be documented and evidenced. It isn’t.

So the charge isn’t about management. It’s about extracting a pound because the system allows it. That’s not policy. That’s opportunism.

And it disproportionately hits the people least able to absorb it: residents without driveways, shift workers, carers, visitors.

The Strategic Mistake Councils Keep Making

This proposal treats parking as a line item, not a system.

But parking doesn’t exist in isolation. It shapes:

• how long people stay,

• where they spend money,

• whether they return at all.

Get it wrong, and you don’t just annoy drivers — you quietly drain the life out of local places. And once that happens, no amount of “regeneration strategy” PDFs will bring it back.

What Should Have Happened Instead

A serious council would have:

• published a full cost–benefit analysis,

• tested limited or time-based charging,

• trialled pilots before rolling anything out,

• worked with local businesses on validation,

• differentiated sites based on actual demand.

None of that happened.

Which is why this proposal feels less like considered policy and more like a hurried attempt to plug a financial hole — using the wrong tool, in the wrong places, with the wrong consequences.

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Formal Objection

The full legal and financial objection submitted to Wirral Borough Council is set out below, in full.

To: parking.engineer@wirral.gov.uk Dear Sir or Madam,

Re: Formal Objection to Proposed Off-Street Parking ChargesScheme Reference: TO/25/28

I write to formally object to the above proposal to introduce new charging provisions and overnight fees across a significant number of currently free off-street car parks.

My objection is grounded in financial viability, legal compliance, and protection of the public interest. In summary, the proposal fails to demonstrate that it represents a lawful, proportionate, or economically sound use of public powers or public money.

1. Failure to Demonstrate a Viable Business Case or Return on Investment

The proposal introduces charging across 22 currently free car parks, alongside an overnight charge across all off-street parking places, yet no published business case accompanies the order.

Specifically, there is no evidence that the Council has accounted for:

• Capital costs of installation (payment machines, signage, lining, enforcement infrastructure)

• Ongoing operating costs (maintenance, cash handling, card fees, enforcement, appeals administration)

• Displacement effects (drivers diverting to nearby streets, retail parks, or other centres)

• Reduced dwell time and suppressed local footfall

Absent this analysis, there is no demonstration that the scheme delivers a positive net present value or even a break-even position at a reasonable rate of return.

Introducing a scheme that is unlikely to be profitable once full lifecycle costs are considered risks damaging public finances rather than protecting them, contrary to basic principles of prudent local authority financial management.

2. Improper Use of Parking Powers for Revenue Generation

Under Sections 32–35 of the Road Traffic Regulation Act 1984, parking charges must be set to:

• Manage traffic and parking demand

• Facilitate the safe and efficient movement of traffic

• Support access to local amenities

They must not be used primarily as a general revenue-raising mechanism.

This principle has been clearly established in case law, including:

• R (Cran) v Camden LBC [2015] EWHC 3270 (Admin) – confirming that parking charges must be justified by traffic management objectives, not budgetary shortfalls

• Attfield v Barnet LBC [2013] EWHC 2089 (Admin) – where the court held that charges set to raise surplus revenue were unlawful

• R (Herron) v Sunderland City Council [2011] UKSC 2 – reinforcing the requirement for strict statutory compliance in parking regimes

In the absence of a clear, evidenced link between these charges and defined parking management problems, the proposal appears vulnerable to challenge as an ultra vires use of statutory powers.

3. Disproportionate Impact on Local Centres, Small Businesses, and Residents

Many of the affected car parks serve district centres and neighbourhood shopping parades, not high-turnover city-centre destinations.

Introducing charges at these locations is likely to:

• Reduce casual visits and short-stay trips

• Disadvantage independent traders relative to out-of-town retail parks with free parking

• Penalise residents without driveways or private parking

• Increase on-street parking pressure and enforcement conflict

This is particularly concerning given the well-documented fragility of many Wirral town centres and the Council’s stated regeneration ambitions.

4. Overnight Charging Is Unjustified and Disconnected from Harm

The proposed flat overnight fee (18:30–08:00) across all charged car parks is especially problematic.

There is no evidence presented of:

• Systemic overnight misuse

• Anti-social behaviour linked to free overnight parking

• Capacity pressures during overnight hours

Without such evidence, an overnight charge appears punitive rather than managerial, and risks penalising residents, shift workers, carers, and visitors without delivering any clear public benefit.

5. Absence of Options Appraisal and Proportional Alternatives

The notice does not demonstrate that the Council has:

• Considered limited-hours charging only

• Tested seasonal or pilot schemes

• Explored validation schemes for local businesses

• Assessed differential charging based on demand or location

Best practice in parking policy requires graduated, evidence-led interventions, not blanket charging across diverse sites with very different usage patterns.

Conclusion

For the reasons above, I submit that the proposed order:

• Lacks a credible financial or economic justification

• Risks unlawful revenue-raising contrary to the Road Traffic Regulation Act 1984

• Is disproportionate in its impact on local people and businesses

• Exposes the Council to legal, reputational, and financial risk

I therefore urge the Council to withdraw or substantially revise the proposal, publish a full business case and impact assessment, and consult meaningfully on proportionate alternatives.

Yours faithfully,

Rory Wilmer

Resident, New Brighton.