Cabinet Member Report
Meeting or Decision Maker:
Cabinet Member for Business
Date:
30 May 2013
Classification:
General Release
Title:
Bay Sensor Procurement Strategy
Wards Affected:
All
Key Decision:
Added to the list of forthcoming Key Decisions on 12
February 2013, meaning a decision can be made
from 22 March 2013 onwards
Financial Summary:
Earmarked funding for the project has been set
aside. A phased rollout of the project is
recommended with Phase 1 focussing on West End,
subsequent phases subject to business case
Report of:
Leith Penny
Management
–
Strategic
Director
for
City
1.
Executive Summary
1.1.
The continued challenge of managing traffic in a city with high parking demand,
congestion, and imbalances of bay occupancy in neighbouring streets has led to
a trial of sensor technology, which gives customers access to live parking
availability.
1.2.
The technology has helped customers to make an informed decision when
parking, and had a positive effect on occupancy distribution and payment
avoidance.
1.3.
There are further benefits to integrating the technology with the traffic marshalling
service as part of the wider 2014 parking strategy, which are detailed further in
this report.
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1.4.
This report seeks approval for a roll-out of bay sensor technology in paid for and
disabled parking bays in two phases, the West End, and subject to a further
review, across the city.
2.
Recommendations
2.1.
That the Cabinet Member for Business approves the recommendations to:
 Appoint a single operator to provide end-to-end sensor technology and a
real-time parking data solution, including on-going maintenance and support,
for a period of 3 years from 2013/14 (with 2 years’ extension provision) via an
open procurement process.
 Install bay sensor technology at all paid for and disabled bays in Westminster
in a two phased approach; an initial deployment in central Parking Zones E,
F3/6 and G, and following a review and business case justification and
subject to formal Cabinet Member approval, deployment to all remaining
Zones.
 Provide real-time parking availability to customers via free of charge web and
Smartphone applications to help motorists make an informed decision on
parking.
 Make use of a reserve of £1.5 million carried over from the 2011/12 financial
year in order to fund the capital expenditure for this project; operating costs
will be funded by the additional income generated by a projected increase in
occupancy.
3.
Reasons for Decision
3.1.
The main benefits to be gained from the expansion of the concept are fourfold;

A more balanced distribution of parking; moving demand away from oversubscribed to lower occupancy locations

Increased occupancy in underutilised bays

Reduced payment avoidance, and improved compliance in paid for spaces

Improve the customer experience of parking within the City
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4.
Background, including Policy Context
4.1.
The diverse nature of Westminster and its multiple users creates high demand
for the limited parking space available; city-wide parking occupancy averages
levels of more than 70%, and often in excess of 80% in the West End where
demand for space is most acute. The associated problems of congestion and
poor air quality are often compounded by the time taken for motorists to find
parking as they drive around the city searching for availability.
4.2.
A survey of commuting motorists in dense urban cities (including London) by IBM
in 2011 found that, on average, 30% of the urban traffic is due to drivers looking
for parking, and the average search time in a city such as London is 15 minutes.
4.3.
Evidence from Pay by Phone transactions has shown the supply of and demand
for parking bays is often mismatched in neighbouring areas, with saturated and
under-used parking often close by. Studies of parking demand in the Leicester
Square area revealed wide variance in occupancy in adjoining streets. This data
analysis informed the new Marshalling approach to managing the area, where
motorists are directed away from the square into nearby areas of low occupancy.
4.4.
It was this initial concept of redistribution that led the Parking Service to seek out
new ways of working to manage the kerbside, and adopt new technologies to
dynamically react to these acute problems and an ever changing environment.
5.
Sensor technology
5.1.
Bay sensors provide a real-time record of parking bay occupancy. The
technology works using equipment installed on, or underneath, the carriageway
which detects vehicles by means of infra-red or magnetic signals. If a vehicle is
parked over the sensor a signal bounces back to the sensor and the sensor will
register that the bay is occupied. This information is then sent to a nearby data
receiver (zone controller) mounted on a lamp column, which in turn sends the
data back to a central server which transfers the data for all sensors onto a base
map. Each sensor/bay is displayed on a map of parking spaces either as a red
(occupied) or green (unoccupied) space. The colour status for each bay changes
over time as vehicle movements are registered by the technology. This data can
be viewed in real-time, but can also be used to generate various reports and
profiles such as occupancy over a period, periods of stay, vehicle movements
etc.
5.2.
Crucially, the live data can also be integrated with customer Smartphone
applications to provide real-time parking availability for motorists to help them
make an informed choice on parking and potentially address the imbalance of
occupancy in neighbouring streets, freeing up space for other users, and
increase compliance.
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6.
Proof of Concept
6.1.
Parking undertook a Proof of Concept (POC) of vehicle sensing technology
between August and October 2012, to test if the technology could be
successfully deployed in a busy urban on-street environment, and to see if by
providing customers with live parking availability, could we positively affect
customer parking behaviour, and make it easier and quicker for a motorist to find
a parking space.
6.2.
As part of horizon scanning innovations in technology, Town and City Parking
(Smart Parking) offered to demonstrate the capability of the sensor technology
and associated IT “Smartrep” reporting system. Supply of equipment and
training were provided by TCP at no cost. The development of a Smartphone
application was provided by Parkopedia. The only financial costs incurred by the
council included the sensor installation crews (TranServ), development of two
Smartphone applications, and a business and resident letter drop.
6.3.
The appropriateness of the equipment for use on Westminster’s streets was
ratified through internal peer review. In addition, engagement with Street Lighting
and Road Management helped to minimise the impact on the kerbside. For
example, It was determined that zone controller boxes be installed where
possible behind existing lamp column signage to minimise their visual impact.
6.4.
In total, 187 sensors covering 144 spaces were installed in five streets; Savile
Row, Sackville Street, Jermyn Street and Burlington Gardens (all in Parking Zone
E), and St John’s Wood High Street (Zone C1). These locations were selected as
they reflect the wide range of demands placed on the city’s finite parking space;
from an outer zone high street, to locations very close to the West End where the
high demand for kerb side space is residential, commercial and recreational.
6.5.
Sensors were installed at all bays in the five streets, including pay by phone,
resident, disabled, loading, and diplomat. The quantities of sensors for each bay
type are listed below:
Bay type
Pay by Phone
Resident
Disabled
Diplomat
Loading
Doctor
Taxi
Car club
Spaces
104
25
7
3
2
1
1
1
144
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6.6.
The strategic indicators by which Westminster measured the successes of the
pilot were:

A successful implementation of sensor technology and broadcast of real-time
data to motorists.

To measure changes in occupancy and compliance, and any reduction in
payment avoidance.

To build up a picture of motorist behaviour and detailed trend analysis to
better understand how the on-street parking assets are being utilised.
7.
Proof of Concept - Findings
7.1.
The proof of concept trial was a success. As well as successfully implementing
the technology and Smartphone applications on time and to budget, the following
observations were made:

Payment avoidance decreased by 2.3% on average across all locations.

A real increase in paid occupancy income of 2.56%.

In two adjoining streets, Savile Row and Sackville Street, a shift in utilisation
at the paid for bays was evidenced
7.2.
All sensors and zone controllers were installed to schedule over a two week
period in August, with the minimum of disruption to parking and the highway. The
technology used in the solution successfully captured and managed the real time
parking occupancy.
7.3.
The Smartphone ‘Park Right’ applications were made publicly available from 17th
October and proved to be popular with over 5,500 downloads during the trial
period (more than 17,500 to date) and an average of 385 location searches a day
since October.
7.4.
A screenshot of the application showing Savile Row and Sackville Street is
included below.
The icons represent the various bay types and use
red/amber/green signalling to indicate availability.
Page 5 of 17
7.5.
The apps received mainly positive customer reviews, and an extensive and
positive media campaign (on radio, TV news, and press and industry
publications), helped demonstrate the technology and promote the benefits of the
app to customers.
7.6.
As was expected, data from the sensors showed high occupancy levels at all
locations (often in excess of 80% during peak periods) and predominantly shortstays and high turnover of vehicles. The overall increase in purchased time of
2.56% during the period can be attributed to the availability of real-time data
positively affecting motorist behaviour. With the data to hand, motorists spend
less time searching for available spaces, resulting in an increase in overall
parked time.
7.7.
Giving customers instant access to a wider picture of parking availability can also
lead to self-regulation of imbalances in occupancy, along the principles of the
Marshaling model adopted in Leicester Square. This was best evidenced in the
shift in occupancy from Savile Row to the adjoining and relatively under-occupied
Sackville Street.
Page 6 of 17
7.8.
The graph below details this occupancy shift and shows the average weekly
utilisation of the paid for bays in both streets. At the start of the trial in week 1,
utilisation of bays in Sackville Street was 48%, compared to 81% in Savile Row.
By week 11 this had shifted to 51% and 76%.
Average Weekly Paid for Utilisation
85.00%
80.00%
75.00%
70.00%
65.00%
60.00%
55.00%
50.00%
45.00%
40.00%
Sackville Street
Savile Row
Linear (Sackville Street )
Linear (Savile Row )
7.9. Enabling motorists with live availability of parking spaces encourages compliance
and has resulted in a reduction of payment avoidance; between the start and end
of the proof of concept the gap between the parked time and purchased time (the
total time vehicles were parked recorded by sensors, versus the total time
purchased recorded by PayByPhone) reduced by 2.3%. Whereas there remain
legitimate reasons why motorists may not pay, e.g. loading and unloading, the
physical appearance of the sensors may also have positively contributed as a
deterrent to motorists avoiding payment.
7.10. The graph below shows how the gap between parked and paid for time has
reduced. At the start of the trial (Period 1) the variance between paid time and
actual time was 10.31%, this reduced to 8% by the end of the trial (Period 2).
Page 7 of 17
Period 2
Period 1
2
1
7.11. As well as assisting the motorist, it is envisaged that data from sensors will
enable a step change in the understanding and analysis of motorists’ behaviour.
Trends can be analysed over time to accurately measure parking pressures,
attain detailed comparative trend analysis and draw robust and meaningful
conclusions; conventional vehicle count surveys only provide a ‘snap-shot’ in
time. This information can then be used to inform the strategy for how the
kerbside and parking provision is configured and managed in the future.
8.
Integration with Traffic Marshalling
8.1.
There are clear traffic management benefits to be gained by integrating real-time
parking data with the new Marshalling concept.
8.2.
The innovative use of Marshals is part of a new approach to improve parking
compliance and help to manage the flow of traffic in areas of high demand.
Marshals’ primary objective is to assist motorists to park compliantly. Marshals
make use of historic occupancy trends to re-direct drivers from areas of
prohibited parking and loading to where there is traditionally spare capacity. A
key outcome of their use in Leicester Square (where the concept was first
trialled) was an increase in casual parking utilisation of c.7% in the surrounding
area. The success of Marshalling is fundamental to the 2014 parking strategy;
the approach has recently been extended to the HOLBA (Heart of London
Business Alliance) district, and will eventually be deployed city-wide.
8.3.
It follows that giving Marshals access to real-time parking availability will enhance
their ability to deliver the positive outcomes and improve the customer
experience of parking. If a driver is unaware of the smartphone application or
doesn’t have the technology to use it then this information can be provided
Page 8 of 17
directly by Marshals from the kerb-side. With real-time data to hand, Marshals
will be able to assist and re-direct motorists looking for parking in potentially
prohibited areas into nearby available parking space.
8.4.
As a result, drivers will spend less time searching for space (improving traffic
flow), be less inclined to park non-compliantly (hence reducing the number of
penalties they receive), and fewer on-street resources will be needed to maintain
compliance.
9.
Soft Market Testing
9.1.
Following the placing of a Prior Information Notice, used to inform potential
bidders about forthcoming contracts, in November 2012, a soft market test was
carried out to gain insight into the sector, to better understand the potential
supplier base, and to test the market’s response to our proposed solutions and
gain feedback on our current approach. Although this category of service is new
to local authorities and on-street parking enforcement, the technology has been
successfully deployed in off-street locations for a number of years.
9.2.
A high-level specification was provided, and from the 14 responses received, all
respondents believed that the high level specification was deliverable.
9.3.
Other findings to note:





10.
The providers’ technology is either sunk into the highway or surface mounted,
some are flush with the highway or with a raised profile – depending upon the
installation method this affects the installation time.
All solutions require technology (Data collector) to be implemented on-street
to relay data from the sensor to the back office database.
Data collectors which can either be solar or mains/battery powered.
Installation time for 10,000 sensors ranges from 10 weeks to 18 months. The
average time is between 4-6 months
All suppliers agreed that a contract term of 3+2 would be acceptable. One
responder stated that typically contracts for this technology are between 3-5
years.
Procurement strategy
10.1. The proposed strategy is to appoint a single operator through an open
procurement process, which will provide on-going maintenance and support.
10.2. The contract, which will be directly managed by Parking will deliver the following;
Page 9 of 17

On-street technologies to detect the real time presence of a vehicle and
provide on-going maintenance and support for the duration of the contract.

A requirement to work with existing WCC contractors to install the technology
and to facilitate on-going support and maintenance.

Provide a back office solution that collates and visualises data using
mapping, and is capable of producing occupancy and movement reports for
analysis.

Provide a free of charge Smartphone application for real time on-street
parking availability.

Provide a solution to allow Civil Enforcement Officers/Marshals to view real
time parking availability at on-street locations from their hand held devices.
10.3. Evaluation will be weighted 50% on price, and 50% on technical merit (including
hardware and software functionality, maintenance and support, smarphone
solution, and future technology). The weighting reflects the importance of a
sound technical solution as vital to delivering our project objectives.
10.4. The contract duration is proposed to be 3 years with the option to extend for a
period of up to 2 years.
10.5
A separate procurement activity for technology and on-street resource, the 2014
Parking Re-let Strategy, is also underway. The new operating model behind that
strategy, and in particular how Marshals are deployed and making it easier for
the customer to find available parking, is dependent on the bay sensor
technology integrating with the kerbside management and customer solution.
Delivering the bay sensor technology solution in advance of that procurement
activity will ensure service readiness.
11.
Implementation
11.1. It is recommended that the sensor technology and access to real-time data is
rolled out across the city at paid for and disabled parking bays in two phases.
11.2. Phase 1 will incorporate the areas where parking pressure and congestion are
heaviest - the West end areas of G Zone, E Zone and F3/6 Zones. To implement
sensors across the West End would require the implementation of 2,971 sensors.
Although only representing a third of the total 10,000 bays city-wide, the West
End Zones account for a high proportion of activity at 50% of overall transactions.
11.3. The contract deliverables will be formally reviewed post implementation, during
March 2014. Providing that the West End implementation delivers a set of key
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critical success factors (see paragraph 11.4 below), then phase 2, which includes
deployment to the remainder of the city, can then be called on.
11.4. The success of Phase 1 will be evaluated against the following criteria;





Technology complying with defined KPIs for availability,
Speed of data transfer,
Fault level and rectification service levels being met.
Occupancy levels
Payment avoidance metrics being met.
11.5. A customer survey will be undertaken to further understand behavioural changes
and gain user feedback on the applications, and there is also potential to engage
with internal audit to assess the technical delivery.
11.6.Activity
Date
Issue OJEU notice and ITT (open)
May-13
Contract award and Implementation plan
Oct / Nov 2013
Phase 1 implementation
Nov 2013 to Jan 2014
Phase 1 Review
March 2014
Phase 2 implementation
August to Nov 2014
11.7. Implementation timescales will be dependent on the technical solution, but it has
been advised that to deploy bay sensor technology to 10,000 bays will take
between 4 and 6 months (on average) to implement and assuming an award
date of this contract in November 2013, a lead time of 1-3 months to carry out
Phase 1 has been estimated.
11.8. Parking will work closely with key internal stakeholders throughout the process,
to gain necessary approvals and to minimise the impact on street furniture and
the kerb-side.
11.9. The City Council’s highways maintenance contractors will implement the
technology. The Council’s service provider has a proven experience of
implementation from the trial and will reduce risk of damage to the highway and
assets, and require less Parking management to deliver.
Page 11 of 17
12.
Financial Implications
12.1
Sources of funding
A reserve of £1.5 million was carried over from the 2011/12 financial year in
order to fund the capital expenditure for this project, called “Kerbside
Management sensor reserve”. This is proposed to be used for the procurement
and installation of Phase 1. Any recommendation for future phases will be based
on review points built in to the programme; the first is scheduled in March 2014.
A Phase 2 roll out could be extended to resident or other non-income generating
bays, as well as paid for bays across the remainder of the city.
12.2
Potential Returns & Assumptions
Year
Number Sensors deployed
West End
1
2
3
4
5
-£96,700
-£96,700
-£96,700
-£96,700
2971
Costs
Purchase of equipment
Installation of equipment
Ongoing Maintenance costs
-£496,770
-£157,598
Total Project Costs
-£654,368
-£96,700
-£96,700
-£96,700
-£96,700
Income variations
Additional casual parking
income
Total occupancy & bay sensor
Var
£112,498
£547,997
£726,552
£816,722
£816,722
0.65%
2.50%
1.00%
0.50%
0.00%
£17,419,946
£112,498
£17,855,445
£547,997
£18,033,999
£726,552
Total costs/income
-£541,870
£451,297
£629,851
£720,021
£720,021
Cumulative position
-£541,870
-£90,573
£539,278
£1,259,299
£1,979,320
Total income
Total Income Variations
NPV
£18,124,169 £18,124,169
£816,722
£816,722
£1,567,092
Table 1 above shows forecast position based on implementation of Stage 1 Only
*Net Present Value (NPV) represents projects return taking into consideration time value of
money. Future cashflows are discounted at a fair rate to consider WCC cost of capital.
Phase 1 will provide a positive return on investment over the contract period –
breaking even early in year 3. This is based on the increase in occupancy and
reduction in payment avoidance.



Capital Expenditure for equipment purchase; Phase 1 & 2 = £2,108,975
(Phase 1 only = £654,368)
Operating Expenditure over 5 year contract; Phase 1 & 2 = £979,425 (Phase
1 only = £386,801)
Net Present Value(NPV) Phase 1&2 = £2.23m (Phase 1 - £1.567m)
Page 12 of 17
Income movements have been calculated based on evidence from the proof of
concept. The model considers a 3% increase in income due to reduced payment
avoidance with a further 1.5% increase in relation to increased occupancy due to
improvements in customer information and advanced awareness of availability.
Costs are based on indicative prices provided by Smart Parking, the company
used for the Proof of Concept, tender costs could vary depending on supplier.
13.
Legal Implications
13.1
Section 122 of the Road Traffic Regulation Act 1984 sets out the matters to
which a local authority must have regard when exercising its functions under the
Act, including securing the provision of suitable and adequate parking facilities on
and off the highway. Case law indicates that the generation of income is not a
relevant matter for the purpose of Section 122, even though the exercise of the
Council’s powers may incidentally lead to increased income.
13.2. Trip hazards caused by ground sensors could potentially lead to claims against
the Council. The specification for the sensors will set out the minimum
acceptable profile above the road surface, and will stipulate that road mounted
sensors should be as flush as possible with the carriageway. Sensors will sit
outside of the footway, within 1 metre of the kerb. In this way it is hoped that
claims will be kept to a minimum.
13.2. No TMO implications.
14.
Staffing Implications
14.1. It is not anticipated that there will be any staffing implications directly affecting the
Council arising from this report, however in the longer term it is expected that
efficiencies in deployment generated by the sensor technology will result in a
reduction in the on-street workforce.
15.
Consultation
15.1. Key stakeholders in Street Lighting, Highways and Planning have been consulted
with throughout. For the trial, planning approval for equipment was gained
through internal governance, and Street Lighting and Highways continue to be
closely involved in shaping the technical solution and will evaluate the sections of
the tenders appropriate to their unit.
15.2. A workshop presentation was given at a recent St John’s Wood Area Forum
(November 2012). Those attending were all local residents of St John’s Wood.
The feedback from the workshop was really positive. One resident said that it
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was great to see Westminster deliver an innovative parking solution and that
some of the negative media attention was unjust. Further workshops will be held
at all affected forums before roll-out in each Zone.
15.3. Statutory consultation is not required as no amendments will be necessary to
traffic management orders
If you have any queries about this Report or wish to inspect any of the
Background Papers please contact:
Simon Morgan, Performance Improvement Officer, smorgan@westminster.gov.uk
BACKGROUND PAPERS:
Bay Sensor Proof of Concept – End of 3 month review
NB: For individual Cabinet Member reports only
For completion by the Cabinet Member for Business
Declaration of Interest
I have <no interest to declare / to declare an interest> in respect of this report
Signed:
Date:
NAME:
State nature of interest if any …………………………………………………………..……
…………………………………………………………………………………………………..
(N.B: If you have an interest you should seek advice as to whether it is appropriate to make a decision in
relation to this matter)
For the reasons set out above, I agree the recommendation(s) in the report entitled
Bay Sensor Procurement Strategy and reject any alternative options which are referred
to but not recommended.
Signed ………………………………………………
Cabinet Member for Business
Date …………………………………………………
Page 14 of 17
If you have any additional comment which you would want actioned in connection with
your decision you should discuss this with the report author and then set out your
comment below before the report and this pro-forma is returned to the Secretariat for
processing.
Additional comment: …………………………………….……………………………………
……………………………………………………………………..……………………………
…………………………………………………………………….…………………………….
If you do not wish to approve the recommendations, or wish to make an alternative
decision, it is important that you consult the report author, the Head of Legal and
Democratic Services, Chief Operating Officer and, if there are resources implications,
the Director of Human Resources (or their representatives) so that (1) you can be made
aware of any further relevant considerations that you should take into account before
making the decision and (2) your reasons for the decision can be properly identified and
recorded, as required by law.
Note to Cabinet Member: Your decision will now be published and copied to the
Members of the relevant Policy & Scrutiny Committee. If the decision falls within the
criteria for call-in, it will not be implemented until five working days have elapsed from
publication to allow the Policy and Scrutiny Committee to decide whether it wishes to
call the matter in.
Page 15 of 17
Appendix A
Other Implications
1. Resources Implications - None
2. Business Plan Implications
The proposals in this report are in accordance with the Parking Service business
plan for 2014.
3. Risk Management Implications - None
4. Health and Wellbeing Impact Assessment including Health and Safety
Implications
4.1. A potential risk has been suggested around people driving whilst using their
smartphone or tablet. As part of the Communicaitons strategy, a message will go
out on the app to suggest drivers stop compliantly at the kerb-side before checking
availability. The existing ‘ParkRight’ application utilises existing driver guidance
applications (i.e. SatNav) for drivers once a parking bay has been selected. This
functionality provides traditional turn by turn directions to the destination.
4.2. The above requirements will be detailed within the Procurement Specification as
needing to be deliverable from Day 1 of a smartphone application. As well as
operating as a stand-alone application, there is potential for the service to be
integrated with satellite navigation systems.
4.3. Similarly, the icon signals can be calibrated so as not to encourage drivers to
compete for a small number of available spaces. For example, a red icon could
indicate availability of between 0-2 spaces, amber 3-5 and green 5+.
5. Crime and Disorder Implications - None
6. Impact on the Environment
6.1. A risk has been mentioned that the added convenience of the service will
encourage drivers into Westminster and subsequently add to congestion. However,
it is arguable that the convenience of a real-time solution would not be enough of an
economic incentive to result in a modal shift away from public transport. The
solution will more likely assist those individuals and companies who already choose
to drive in the city.
6.2. The benefits of reduced time to park should result in improvements in air quality
(Nitrogen Oxide NOx & Particle Matter PM10) and Noise pollution.
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6.3. As part of the review of Phase 1, a customer survey will be conducted in partnership
with colleagues in City Planning to measure any affects on air quality, travel time
analysis, and sustainable travel in order to provide an environmental assessment.
7. Equalities Implications - None
8. Staffing Implications – None
9. Human Rights Implications - None
10. Energy Measure Implications
10.1. A small electrical feed will be required from lamp columns to power Zone
Controller boxes. The ground sensors will be battery or solar powered.
11. Communications Implications
11.1. Parking is a sensitive issue for residents, workers, businesses and visitors. An
ongoing dialogue with service users and other stakeholders is a vital part of our
approach. In addition to transforming the service the City Council provides for
users, we are also seeking to influence the attitude of users encouraging them to
take responsibility for parking in a compliant manner.
11.2. A proactive media relations and a strategic publicity campaign explaining to
customers the benefits of the service will play a vital role in the successful
delivery of the model. Our communications plan will be developed to compliment
the City Council’s new approach to Kerbside Management so that we can
engage with service users and inform them about our plans.
11.3. The successful communication activities undertaken during the trial, which would
be re-deployed on a larger scale include:





Extensive and high profile media campaign (national press, radio and TV
news, industry publications) promoting benefits of the scheme
On-street signage. Including explanation of concept, intelligent Quick
Response (QR) codes and web-links to the application
Texts to existing high-volume Pay by Phone users
New pages on the Westminster Website
Workshops at area forums
11.4. The smartphone applications and website and associated marketing will be done
under a branding agreed between the operator and the City Council.
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