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Workplace Parking Licensing (Scotland) Regulations 2022

Submission from the Scottish Retail Consortium to the Convener, 17 February 2022

Dear Convener,

We thought it might be helpful to set out the Scottish Retail Consortium’s position on Workplace Parking Taxes given that we understand the Committee will be deliberating the issue further at your next meeting on 22 February.

Firstly, retail is taking its environmental and net zero responsibilities seriously. Even prior to the publication 15 months ago of the industry’s Net Zero by 2040 roadmap, the sector was a leader in reducing the environmental impacts of its own direct operations and driving similar improvements through the supply chain. 

More broadly, we have to be cognizant of the current economic context. The pandemic has been tumultuous for much of Scotland’s retail industry. Retail sales remain lacklustre and lower than in the comparable period prior to the pandemic. Indeed, we estimate Scottish shops has missed out on £5.8 billion of revenues over the past 23 months. Shopper footfall remains 16% down, and one in every six shops lies vacant. Holyrood’s Finance Committee recently acknowledged that retailers’ accumulated debts, tax deferrals and loans have grown during the pandemic. Costs are rising, including public policy costs such as the reintroduction in April of full business rates and the increase in employers’ national insurance contributions.

230,000 Scots are employed directly in the retail industry, some of whom drive to work. This employment can be at stores, distribution centres, customer contact centres, or a firm’s headquarters. Many retailers financially support colleagues who opt for public transport to get to and from work (examples outlined in SRC’s May 2019 submission to Holyrood’s Rural Economy & Connectivity Committee as part of the Committee’s inquiry into WPLs). The numbers of staff parking at work can be more prevalent during shift times when public transport options can be less accessible or non-existent. We would therefore suggest meaningful alternative means of getting to and from the workplace are in place before levies are implemented.

As intimated in our Post-Scottish Budget submission sent to Ministers in late December, we remain concerned that workplace parking levies remain a recipe for extra cost and complexity. This is especially so as firms already pay business rates on the parking places they provide for staff, and so could be taxed twice for such parking spaces. This may lead some employers to consider whether they ought to recoup some or all of the cost of the levy from staff, so this policy could well have a bearing on the cost of living and/or the ability of employers to retain or recruit staff.

The introduction of workplace parking taxes during the coming financial year could introduce fresh unpredictability into firms’ budgeting. As such we continue to recommend that any implementation be paused over the coming financial year to aid firms’ recovery from the pandemic and would ask Committee members to endorse this. More broadly, safeguards should be built into any future consideration of WPLs - including a Scotland-wide cap on the amount that can be charged so any levies are not punitive, a sunset provision on their longevity as is the case with Business Improvement Districts, consistency amongst councils implementing the levy, and clarity over what the receipts will be used for.

I do hope this assists with the Committee’s deliberations.

David Lonsdale
Director
Scottish Retail Consortium