The following is a copy of a letter sent to Mr. Ian Westley, director of transportation, Pembrokeshire County Council.

Sir, When introducing the seasonal pedestrianisation scheme for Tenby walled town, PCC urged residents, in particular residents within the walled town, to make use of the reserved parking bay facility provided at the multi-storey car park. This was an appropriate response to the on-street parking problems in Tenby. However, the current dramatic rise in the cost of these permits would suggest that the PCC is using these permits to raise general revenue. In R v LB Camden, the court held that the Road Traffic Act 1984 was not a revenue-raising act. In July 2013, in the High Court (Barnet CPZ Action Group v Barnet Council), Mrs. Justice Lang ruled that the Road Traffic Regulations Act 1984 'is not a fiscal measure and does not authorise the authority to use its powers to charge local residents for parking in order to raise revenue for other transportation purposes.' I have set out some comparative figures for reserved parking bays in council car parks and would be grateful if you would review these charges with the above quoted legal constraints in mind. Reserved parking bay permits in Tenby multi-storey: March 2010 - £350 per annum; March 2011 - £360 per annum; March 2012 - £360 per annum; March 2013 - £360 per annum; March 2014 - £375 per annum; March 2015 - £540 per annum. The current rate represents a 44 per cent increase over the previous year. Most expensive council car parks: There are 32 council car parks in Pembrokeshire and the eight most expensive for reserved parking bays are: Tenby multi-storey - £540 per annum; Tenby North Beach Open Air Car Park - £459 per annum; Tenby The Green Open Air Car Park - £459 per annum; Haverfordwest Castle Lake - £351 per annum; Tenby South Beach Open Air Car Park - £328 per annum; Tenby The Croft Car Park - £328 per annum; Haverfordwest multi-storey - £328 per annum; Haverfordwest Riverside Market - £328 per annum. With all five council car parks in Tenby being in the top most expensive car parks, I would suggest that to a neutral observer it would appear Tenby is not being treated fairly. I would very grateful if you would consider responding to the following questions: 1. I quite understand that Pembrokeshire County Council has to raise revenue to balance the shortfall in grants from the Welsh Assembly, but why does Tenby appear to be the main source? 2. Can you justify the increase for Tenby multi-storey from £375 per annum to £540 per annum when Haverfordwest multi-storey is only £328 per annum? 3. Can you justify Tenby North Beach (Butts Field Car Park to local residents) and Tenby The Green being set at £459 per annum when they are open air car parks with minimal maintenance costs? 4. Can you guarantee that revenue from the five Tenby car parks are not used for general revenue, but are totally reserved for transportation measures within the Tenby area? 5. The park and ride facility from both The North Beach Car Park and The Green Car Park is a vital link in attracting visitors to Tenby, yet I understand that the PCC has decided that this facility should be terminated/severely curtailed. As two of the most expensive car parks in Pembrokeshire, surely the revenue generated is sufficient to maintain and extend this facility? 6. This year you have extended the 'summer season' by two months so that the summer season commences on March 1. This would appear to be a purely revenue raising exercise and flies in the face of the efforts by the Tenby Town Council to increase visitor footfall during the shoulders of the summer season. In formulating your response, may I presume to invite your attention to the reported comments of Professor Stephen Glaister, director of RAC Foundation, in respect of the Barnet Council Case, in which he stated: "The law is explicit - parking charges are about managing congestion, not raising revenue." There is also a very detailed paper on the subject - The Control of Parking by Local Authorities (Report No 10/115) issued by the RAC Foundation which is very relevant to the issue before you. I look forward to your informative response, John H. T. Griffiths,

Tenby

CC. Simon Hart MP, The RAC Foundation, The Automobile Association, Tenby Town Council.