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Workplace Parking Licensing (Scotland) Regulations 2022

Submission from the Food and Drink Federation Scotland to the Convener, 14 February 2022

Dear Convener,

The Food and Drink Federation and our food and drink manufacturing members are very supportive of the Scottish Government’s ambition to reduce Scotland’s greenhouse gas levels to net zero. We were proud to launch our Net Zero roadmap (https://www.fdfscotland.org.uk/fdf/resources/publications/guidance/net-zero-roadmap/net-zero---overview/) setting out how food and drink manufacturers will achieve net-zero emissions by 2040. Our members have a long track record of reducing emissions associated with their operations including switching to low emission/electric vehicles and reducing food miles. 

Introducing levies on parking will make little difference to vehicle emissions associated with our members operations due to:

• limited public transport from major population hubs
• 24hr operations and multiple shift patterns making public transport more challenging
• For food production staff, working from home is, of course, not possible.

We are concerned that allowing local authorities to place uncapped levies on Scotland’s food and drink producers (who are 95% SME) will subsidise public transport links for other more centrally located businesses and organisations that do not operate 24/7. Whilst the net revenue generated by WPL schemes will raise revenue that could be used to improve public or active transport, our members are unlikely to see any benefits for their staff. 

WPLs are therefore likely to become yet another financial burden on food and drink producers, diverting money from other investment in jobs/productivity. One of our members calculated implementation of the WPL could reduce their operating profit by more than 5% (Based on the WPL set by Nottingham council of £415 per parking space per annum) at a time when they are already under huge financial pressure.

Our members are strongly opposed to passing on any levies to their employees, especially as people face exponential rises in their cost of living. Our food and drink manufacturing staff who have kept the nation fed during the pandemic do not have the luxury of choosing to work in a “hybrid” way from home and should not be penalized for working in manufacturing, where shift working and working away from areas well serviced by public transport is common. 

In our recent response to the Workplace Parking Licensing Regulations, we suggested exemptions for WPL should be explored for “greener car spaces” - parking spaces for car sharing also known as High Occupancy Vehicles and electric/low emission vehicles.  We also stressed the need to review availability and safety of public transport alternatives ahead of any scheme being implemented.  Workplace parking levies should not be introduced where:

• Lack of credible public transport options are available to access a particular business including at certain times of day/night.
• Where a business has safety concerns about employees commuting to/from work.
• A business has a car park that accounts for shift patterns: Large manufacturing sites need to provide “extra” spaces for shift changeover patterns. Therefore, at any one time, they may have a higher number of car parking spaces than the number of cars that will actually be parked during a shift.

David Thomson

Chief Executive Officer

Food and Drink Federation Scotland