European Parking Association aisbl
EPA
The European Parking Association (EPA) was originally founded in 1983 as the umbrella organisation for the national parking associations in Europe.
ID: 548595616482-02
Lobbying Activity
Response to European Disability Card
13 Nov 2023
The European Parking Association (EPA, https://www.europeanparking.eu/) welcomes the publication by the European Commission (EC) on 6th September 2023 of its Proposal for a Directive establishing the European Disability Card and the European Parking Card for persons with disabilities (the Proposal). The Proposal will enhance the European Parking Card (EPC). In particular, EPA welcomes the digital format and digital features in the physical card, which will aid the prevention of fraud and forgery of the EPC. To that end, EPA welcomes the introduction of common technical specifications for a digital EPC format and for digital features in the physical card. EPA and its members are available to further contribute their experiences and learnings to this process. To ensure swift action, EPA calls on the EC to include a 12-month deadline for the introduction of the implementing acts in Article 8(2). Besides, to effectively combat fraud and forgery, more action is required. EPA calls for the introduction of regular validity checks for the EPC. This includes verifying the validity of the card every year for people with a temporary disability and every five years for people with a permanent disability. Along the same reasoning, enforcement of fraud and forgery will only be effective if public authorities and the parking sector can access national cardholder databases, which include information like their name, date of expiry of the EPC and the license/number plate(s) that are registered on their card. EPA therefore calls on EU institutions to include the creation of such databases, within a reasonable time frame. Additionally, the European Commission should be tasked with setting guidelines on the information that these databases should contain, and the parties that, at a minimum, should have access to these databases. EPA regrets that the Proposal does not harmonise eligibility criteria, conditions and assessment procedures. This is surprising, given the fact that the Staff Working Document (SWD) accompanying the Proposal concludes that different eligibility criteria result in different treatment depending on the country of origin of the card holder. While EPA understands the need for Member States (MS) to retain a certain level of competence in these matters, we fail to see how the current proposal will attain the objective of access on equal terms and conditions in all MS. EPA therefore advocates for the inclusion of a definition of the beneficiaries of the EPC in Article 3 to ensure eligibility criteria, conditions and assessment procedures are harmonised. Last but not least, EPA welcomes the reference in Annex II to the coupling of license/number plates. The registration of license/number plates allows for the allocation of differentiated tariffs, like free parking for people with disabilities, and is essential to facilitate efficient and cost-effective digital enforcement (e.g. via ANPR, automatic number-plate recognition, which is increasingly used across MS) and fraud prevention. However, for the system to work effectively, the registration of license/number plates has to be mandatory.
Read full responseMeeting with Kosma Złotowski (Member of the European Parliament, Rapporteur)
12 Jul 2023 · Cross-border exchange of information on road-safety-related traffic offences
28 Jun 2023
The European Parking Association (EPA, https://www.europeanparking.eu/) is supportive of the intention of EU Delegated Regulations under the ITS Directive to make mobility and travel data more generally available in standardised formats. EPA is happy to work with the European Commission (EC), in collaboration with the NAPCORE project (https://napcore.eu/), to promote awareness and best practice adoption across national parking associations and parking stakeholders. Parking data has relevance in several use case contexts. Associating parking data as only related to multi-modal travel and public transport, although an important use case, appears overly limited. In addition, several data sets related to the parking sector - notably on EV and alternative fuels charging points - remain within the (revised) RTTI Delegated Regulation and therefore it is of the utmost importance to ensure complementarity and interoperability between both delegated regulations (incl. at the technical level). Adoption by the parking industry of the public transport NeTEx and SIRI standards is very limited in practice. The EC are aware that the parking industry have led the development of the APDS specifications (https://www.allianceforparkingdatastandards.org/), which were published as both ISO TS 5206-1:2023 and DATEX II CEN TS 16157-6:2022. EPA therefore wishes to express its concerns about the technical requirements of the proposed Delegated Regulation on MMTIS. To ameliorate these concerns, EPA and APDS have developed a convertor to enable industry-supported APDS data into the required NeTEx format but this needs further testing by colleagues from the public transport standards developer community, with whom a constructive collaboration is sought. The requirement to provide static data concerning 1.2. (a)(a) 'location of parking places (on and off-street), including accessible parking places for persons with disabilities and persons with reduced mobility', applying to all and any parking places across the entire network (without exception), in the timescales set out in this proposed delegated regulation will be extremely challenging due to the diverse and fragmented nature of parking provision. The EC will have to monitor such implementation, whereas EPA will be happy to support, and foresee possible flanking and transitional measures if so needed. About EPA: The European Parking Association (EPA) was founded in 1983 as the umbrella organisation for national parking associations in Europe. The 23 current national member associations represent the parking sector as a whole, consisting of public bodies and private companies that are operating and managing on- and off-street parking structures and services (https://www.europeanparking.eu/en/epa/full-members/). The associate members represent the supply industry that offers all related products and services concerned with parking. EPA aims to facilitate cooperation between the professional parking organisations of different European countries, as well as the exchange and mutual support of professional experience among members relating to parking management and urban mobility (https://www.europeanparking.eu/en/epa/associate-members/).
Read full responseMeeting with Izaskun Bilbao Barandica (Member of the European Parliament, Shadow rapporteur)
26 Jun 2023 · Cross border offenses
Response to Cross-border enforcement of road traffic rules
8 May 2023
The European Parking Association (EPA, https://www.europeanparking.eu/) takes note of the publication by the European Commission on 1st March 2023 of its Proposal for a Directive amending Directive (EU) 2015/413, facilitating cross-border exchange of information on road-safety-related traffic offences. We welcome the expansion of the current Directives scope of traffic offences covered, notably with the inclusion of a reference to dangerous parking. However, the European Parking Association regrets that the Commission decided to limit this long-awaited focus on cross-border parking infringements by adding in the definitions of Article 3: (q) dangerous parking means parking the vehicle in a way that infringes the applicable rules on dangerous parking in the Member State of the offence. Failure to pay parking fees and other similar offences shall not be considered dangerous parking. The parking and urban mobility sector has long been calling for an effective mechanism at EU level to pursue the (increasing) failure to pay for parking, both on- and off-street. On-street, public authorities are grappling with foreign license plate holders that do not respect their parking management policies, especially in border regions. While off-street, many parking operators are moving to a free flow (barrier-less) model and are as such experiencing more and more failures to pay by foreign license plate holders as well. While perhaps difficult to gauge at first sight, we feel there is definitely a link between failure to pay (all) parking infringements and the current road safety situation in cities not in the least because parking offenders are more likely to generate road safety threats, hence the Commissions inclusion of the reference to dangerous parking. As cities strive to create the conditions for smooth and sustainable urban mobility, both public and private parking operators have been calling for an efficient and effective information exchange mechanism at EU level to facilitate cross-border enforcement of parking infringements. We feel that the proposal for a revised Directive is the ideal instrument to achieve this important objective to ensure both safe and sustainable urban mobility, and it would certainly be a missed opportunity if it fails to do so! For the above reasons, we suggest deleting the last sentence of article 3q. Mirroring this deletion, we invite EU decision makers to reflect on the best way to integrate failure to pay parking fees as an offence leading to the exchange of cross-border information. Indeed, Directive 2019/520 on the interoperability of electronic road toll systems and facilitating cross-border exchange of information on the failure to pay road fees in the Union does not cover the situation of parking in urban areas.
Read full response