CC2035

Questions Remain About Portland’s Downtown Parking Plans

September 26, 2016 By TonyJ 1 Comment

A map showing the locations of the Goodman family's proposed Ankeny Blocks project. — The CC2035 Proposal would allow an additional 1,200 parking stalls in the proposed “Ankeny Blocks” development.

Staff from the Portland Bureau of Transportation have responded to concerns that the Central City 2035 plan is taking a step backward by increasing maximum parking entitlements in the soon-to-redevelop “Ankeny Blocks.” Unfortunately, the memorandum doesn’t provide a convincing justification for allowing up to 1,200 additional parking stalls to be built between SW Washington and W Burnside, east of SW 6th Ave.

The arguments for “adjust[ing] office ratios in three existing downtown parking sectors upward [are] to reflect actual demand for parking in downtown, account for the loss of approximately half of the surface parking that existed when the current regulations went into effect in 1996, and in order to blend with other areas of the Core sub district that have current ratios varying from 1.0/1000sf to 2.0/1000sf.” The report further states that “the proposed ratio allows the sub district to continue to rely on non-auto trips for its growth yet it provides more flexibility to the market in some areas of downtown to support redevelopment.”

The Ankeny Blocks buildings would redevelop 225,000 sq/ft of surface lots, replacing approximately 750 parking stalls, many of which are currently occupied by food carts.

A graph showing the increase in allowed parking of 1,200 additional parking spaces. — Under the proposal, 1,200 additional parking stalls could be built in the “Ankeny Blocks.”

Questions Remain

Can the city meet mode split and climate action goals if we continue to increase downtown parking supplies?

Can our streets handle the traffic from drive-alone commuters we have today, let alone the potential traffic when thousands more stalls are available for workers in 2035?

If we anticipate that new technology and better transit will deliver the mode split changes we desire, then why should we signal that this additional supply in downtown is warranted, expected, or wanted?

It is true that the Central City Parking Policy Update Stakeholder Advisory Committee (SAC) recommended these ratios, but there were reservations expressed and 8/19 of the committee members (see page 12) voted for the proposed ratios “with concerns.” [disclaimer: the author of this article served on that committee and voted in favor of the policy recommendations in totality]

The staff report doesn’t quantify the effect that the new maximum ratios might have on mode split targets. While affirming that the SAC “endorsed adjusting maximum parking ratios in a manner that generally relates parking allowances to mode split targets for the Central City 2035 Plan,” there is no evidence provided to the Planning Commission or the public that the amount of parking that could be built under this plan would support the needed 25% drive alone rate to downtown in 2035. In fact, at current rates, the city of Portland will add nearly 130,000 new drive-alone commuters (citywide) by 2035 (see page 47-48).

In response to concerns that the new ratios will lead to undesired amounts of parking built, the memo is optimistic. “Given other parking policies, present and future transportation investments and past trends, it is unlikely that [a scenario where developers will build to the maximum allowable ratio] will come to pass.” This begs another question, however, what is the purpose of a set of ratios that are rarely expected to be a limiting factor? The residential ratios, for example, are set at a ratio that is more than 40% higher than the average parking ratio by building built since 1995 (.85 vs. 1.2).

Don’t Go Backward On Parking Ratios

City staff are working hard to create a proposal that pleases many masters, and there are great things in this plan, but in the face of climate change and a dire need for increased traffic safety, we must be bold in setting our goals for 2035.

Taking a step backward now and allowing more parking in parts of the city core would be a mistake.

The Planning and Sustainability Commission should recommend that no maximum parking ratios be increased in the city center. Furthermore, they should ask staff to show evidence that the maximum parking ratios, to the extent possible, are fully supportive of the most aggressive mode split goals.

Diversifying Portland’s Parking Toolkit with Unbundling Parking and Parking Cash Out

August 15, 2016 By Shoupista Leave a Comment

8715267346_57f4c2d72f_z — (Commuter traffic coming off the Broadway Bridge. Photo source: BikePortland.org)

Two weeks ago, Portlanders for Parking Reform wrote about the proposed Central City 2035 (CC2035) Plan may create more parking by increasing existing parking maximums in some of the Downtown parking sectors. While “parking is a fertility drug for cars”, to change travel behavior, parking policy cannot only target the supply side of this issue. If the City of Portland wants meaningful parking policies to help meet its mode-share targets–85% non-single occupancy vehicle (SOV) trips–and climate goals, such policies must address both supply and demand. Not only may the CC2035 Plan take a step backward on curbing parking supply, it also does not mention any parking demand management policy.

The good news is that there are viable parking policy options that can be applied to Portland’s downtown and neighborhoods to reduce the demand for parking. The Planning and Sustainability Commission and City Council ought to consider adopting unbundling parking and parking cash out for Portland’s Central City and gradually expand these policies into other neighborhoods.

Bundled Parking: Paying for Desserts That You Don’t Eat

Building and operating parking has high costs. Unbundling parking means separating the costs of parking and charging the users of parking directly. To illustrate how parking is currently bundled with the prices of housing, goods, and services that we consume and the need to unbundle it, let us think about the following scenario:

Imagine that the City of Portland requires restaurants to provide free dessert with every meal ordered by customers. The price for meals would increase to cover the cost of “free” desserts. While this may be good news to people who love desserts, such requirement has negative consequences. First, all diners now have to pay more for each meal whether or not they want to eat dessert. Second, some people would eat desserts they would not have ordered if they had to pay for them separately. Bundling desserts with food induces people to over-consume desserts, which leads to more obesity, diabetes, and heart diseases.

The City of Portland does not require free desserts with every meal but it does have parking minimum requirements for new development. Although the Central City district is exempt from such requirements, there are no guidelines on unbundling the costs of parking from development. Just as unbundled desserts would give diners more control over what they eat, unbundled parking will give travelers more choices by allowing people to decide how much parking they need and want to pay for.

When cities require developers to build off-site parking spaces, the cost of parking usually doesn’t get separated from the other costs of the development, making unbundling parking difficult. The good news is Portland’s Central City has no parking minimum requirement, which makes implementing unbundling policy more feasible. Parking can be unbundled from housing by offering residents the option to lease apartments and parking spaces separately, thereby reducing the cost of housing for those who do not own cars. Parking can also be unbundled from office and retail leases, allowing businesses to only purchase the number parking spaces they deem necessary for their employees and customers. Alternatively, parking costs can be listed as a separate line item in commercial lease agreements to show tenants how much parking costs and allow businesses to recover such cost by charging parkers directly.

Unbundling: Tried and Tested

Many cities in the U.S. has adopted unbundling parking policies. For example, San Francisco’s zoning code requires off-street parking spaces for residential buildings with 10 or more dwelling units to be sold or leased separately from the rental or sale of dwelling units. Berkeley also adopted a similar ordinance that requires unbundling parking. In central Seattle, approximately 50% of all multifamily units have unbundled parking from rent.

Lastly, Los Angeles’s Adaptive Reuse Ordinance (ARO) has permitted developers to unbundle parking to encourage converting and redeveloping old buildings. A recent research study shows that ARO apartment units with bundled parking cost about an additional $200 per month, proving that housing does become more affordable when it gets separated from parking.

Unbundling parking may be difficult to apply retroactively to all existing buildings, but it is not impossible. The City should at least explore the option of unbundling parking for current affordable housing units. This will offer existing low-income residents the same benefits of not paying for parking they do not use, freeing up more budget for housing. Portlanders for Parking Reform urge the Planning and Sustainability Commission and the City Council to consider adopting unbundling in CC2035 first for new development and then apply the same policy to existing affordable housing units.

Parking Cash Out: A Second Paycheck

According to the Parking Cash Out Report, “free parking is the most common fringe benefit offered to workers in the U.S., and 95 percent of American automobile commuters park free at work.” Most employers in Portland either provide parking for free or partially-subsidized employee parking. Even though many workplaces provide additional commuter benefits such as transit passes, the financial subsidy for parking often exceeds the subsidy for transit or other modes. Therefore, free or partially-subsidized parking is an invitation to drive alone to work.

Another policy to effectively reduce demand for parking is to offer workers the option to “cash out” their employer-paid parking subsidy. Parking cash out provides commuters the option of cashing out their employer-paid parking subsidy, and use it on other transportation modes or to keep it as a second paycheck. In addition, parking cash out would reward commuters who do not use parking by giving them financial incentives to use healthier and greener modes of transportation, such as walking, biking, and public transit, thereby changing travel behaviors and contributing to the City’s mode share targets and climate goals.

California passed a state law in 1992 that requires many employers to provide cash out options to their workers. A 1997 study in Los Angeles County estimated that mandatory cash out reduced the number of daily vehicle trips to work by 11 percent and commuter parking demand by 13 percent, or 0.4 spaces per 1,000 square feet of office space. If Portland wants to meet its mode-share targets for Downtown (85% non-SOV trips), it would need to set parking maximums at 0.25. That is an ambitious number that will undoubtedly cause a lot of political push back. However, parking cash out is an appealing policy option to help meeting that goal because it brings modest and incremental change and does not require employers and commuters to suddenly change behaviors.

Good for Employers

According to the U.S. EPA, “employers provide an estimated 85 million free parking spaces for commuters—spaces with a net worth of nearly $31.5 billion”. The same U.S. EPA report estimates that annual per space costs vary between $360 and $2,000. In the High Cost of Free Parking, Donald Shoup shows that employers save $40 a year per $1 annual cost for doing parking cash out, with the assumption that the capital cost per parking space is $10,000 (this number is likely far below the average cost of an office parking space in downtown Portland).

Subsidizing parking costs employers a lot of money. Coupled with unbundling parking, parking cash out can significantly reduce demand for parking and offer savings to businesses. There are several benefits to employers associated with decreasing commuter parking demand:

(1) Employers can reduce costs associated with leasing or owning and maintaining parking spaces.
(2) Lower parking demand allows businesses to convert employee parking to customer parking, which may attract more customers.
(3) Businesses can also convert parking spaces into profit-generating activities.
(4) Reduced commuter parking demand will eliminate the need for new parking construction.
(5) Recruit and retain workers by offering parking cash out as a valuable fringe benefit.

Good for Employees

Not only does parking cash out create benefits for employers, it also does for employees. For starters, it increases equity among all commuters. Employer-paid parking does not benefit commuters who ride public transit, walk, or bike to work. However, cash out allows commuters receive the same benefit regardless of how they travel. Secondly, cash out benefits non-auto commuters without disadvantages for auto-commuters. Workers who want to park for free can continue to do so, but they will be able to receive the same amount of benefits if they decide not to drive.

Research in transportation planning has repeatedly demonstrated that higher-income individuals are more likely to drive to work alone, while lower-income individuals are more likely to carpool, ride public transit, bike, or walk. As a matter of fact, using the best available data from the Census Transportation Planning Products, BikePortland reported that only about 5% of all downtown Portland workers who drive alone to work are low-income.*

5% of all drive-alone downtown commuter earn less than $30,000 a year — Image source: BikePortland

The same general trend is also applied for homeowners versus renters (Portland renters are 6 times more likely to not own a car). Thus, without parking cash out, many employers regressively provide subsidies to help wealthy commuters save money on transportation but excludes poor commuters from the same benefit. In addition, just as unbundling parking would lower housing costs, cash out would provide financial benefits to car-less low-income households and renters who are increasingly getting priced out of Portland’s housing market.

Basically, parking cash out is a win, win, win.

Moving Forward

On July 26th, Portlanders for Parking Reform asked the Planning and Sustainability Commission to amend the proposed CC2035 draft, incorporate unbundling parking and parking cash out as recommended policies, and direct city staff to study how these policies will be implemented and administered. Portland has set ambitious transportation and climate goals for the next twenty years, but our currently proposed policies, namely parking ratios, only focus on managing parking supply and lack demand-based approaches.

Unbundling parking and parking cash out are the other side of the parking equation that have proven to be effective, low-cost, and more politically favorable. These policy ideas are not only important to Portland’s long range plan but will also influence the results of the City’s current parking projects, such as the residential permit program, performance-based pricing, and shared parking. Unbundling and cash out will diversify our current parking toolkit but most importantly, they will also contribute to other community goals such as housing affordability and access to more travel options.

Update: *The author added a sentence and a chart to highlight percentage of drive-alone downtown commuters who are low-income

A Step Backwards: Portland May Invite More Cars Into The Central City

August 3, 2016 By TonyJ 6 Comments

Downtown needs fewer cars per worker. But the proposed Central City 2035 Plan would make room for the ratio to increase.

Portland has ambitious goals for its future, but do we have the will today to set the proper course for tomorrow? Today, 40% of trips to downtown Portland are made by people driving alone. The city has, since at least 2009, had “drive alone” mode share target for the entire central city of only 25%. The proposed draft of the Central City 2035 plan (page 5) sets a goal for only 15% of trips to downtown Portland to be via single-occupancy-vehicles (SOV). But do the policies in the proposed draft support these goals? If ample cheap car parking is a “fertility drug for cars,” then the policies probably are not sufficient to meet our goals.

Curbing Parking

Since 1975 the city of Portland has limited the amount of parking that can be built downtown. In order to improve air quality, the city placed a “parking lid” on downtown, allowing a maximum of 39,680 non-residential (or hotel) parking spaces. In 1996, the Central City Transportation Management Plan (CCTMP) removed the lid on parking. In place of the parking lid, maximum parking allotments were created for the central city. The ratios allowed a certain number of commercial spaces per 1000 square feet of office space and varied geographically based on the sector’s access to transit and other modes of transportation. The most dense parts of downtown, for example, allowed .7 stalls per 1000 square feet of office space. This ratio reflected the major investments in light rail infrastructure in downtown.

The parking regulations in the CCTMP were fairly complicated and contained provisions for monitoring and reporting which were rarely enforced. There were more than 25 different “parking sectors” each with a different set of maximum parking entitlements. In January 2015, the city began a Central City Parking Policy Update project to review, revise, and simplify these regulations.

Shared Parking: A Double Edged Sword

The Central City Parking Policy Stakeholder Advisory Committee (SAC) met nine times in 2015 and unanimously approved a proposal that greatly reduces the number of parking sectors, imposes maximum parking entitlements for all land uses in all parts of the central city, and relaxes restrictions on how parking can be used in the central city.

Under current regulations parking which is built to serve residential or hotel uses cannot also be used for commercial uses. The same is true for parking built for commuters, it cannot be leased to residents. To understand the impact of this policy on parking supply and the double edged sword of relaxing this policy, imagine the following example.

A developer is constructing a mixed-use building which needs 10 parking stalls for residents and 10 stalls for commuters to the office space. The developer builds a parking lot with 20 parking stalls.

A building with 20 parking spaces under it. In separate groups of 10. — A developer today must build separate supply for residential and commercial uses.

This policy can lead to an overbuilding of parking. Many of the stalls allotted for residential use will be empty during the day, as tenants will drive to their jobs elsewhere in the city. Conversely, many of the stalls reserved for commuter uses will be vacant during the evening hours when office workers are not at work.

The proposed draft of the CC2035 Plan aims to deal with this inefficiency by allowing buildings to use their parking entitlements for any use. Under the new plan, the developer of our hypothetical mixed-used building can take the habits of her future tenants into consideration. Suppose 80% of the residential tenants move their cars during the workday, and 80% of office workers are not at work during the evening hours. The developer can choose to “share” eight stalls between residents and commuters and might choose to build only 12 stalls (which might well save $1M dollars in subterranean construction costs).

A building with 12 parking stalls, 8 are shared between residential and commercial users. — Under new rules, a developer can build less parking, at a significant savings.

So far so good! The proposal encourages the building of less expensive parking by allowing more efficient use. This could help lower the cost of housing, lead to more development, and leave our children with fewer levels of underground parking to fill up with consumer goods when robots are driving us around.

But there’s a downside to this efficiency. In the short term the plan could lead to a substantial increase in the supply of parking for commuters to downtown, which could lead to more traffic, air pollution, and greenhouse gas emissions. When the plan goes into effect, the developer who built 20 parking stalls, 10 for their residents and 10 for their commuters, can rent additional spaces for residents and commuters.

A building with 20 parking stalls, all in one supply. — Current parking supply, which was restricted for use, can now be sold to tenants which could induce traffic.

While this might be cause for some concern, the effect of this policy could be mitigated by a parking congestion fee, parking cash-outs, TDM, and the reality that not all restricted parking spaces will be opened up for other uses. Unfortunately, that’s not the only part of the proposed plan that will lead to more parking and traffic.

Going Backwards

Downtown parking regulations are complicated. The city core is split up into 6 parking sectors with three sets of parking ratios for commercial uses.

Map showing the downtown parking sectors. In 166 aces of the central city, where the 1.5B Ankeny Blocks proposal is sited, parking maximums can increase 42% from .7 stalls to 1 per 1000/sqft. A 56 acre parcel will have maximums decrease from 2 stalls to 1 per 1000/sqft, but it is unlikely to redevelop. — More parking will be allowed in a vast swath of the city core.

In Sectors 2 & 3, salmon colored on the map, the maximum parking entitlements are currently .7 stalls per 1000 sq/ft of commercial space. These 166 acres make up the bulk of the downtown core and include the east/west MAX couplet, much of the 5th and 6th Ave transit mall, and Pioneer Courthouse Square. But it is not what currently exists in this area that we must consider, but what will be built under the new parking maximums.

Picture of the 11 towers proposed as the Ankeny Blocks Project — All 11 of these proposed towers would be entitled to 42% more parking under the proposal.

Recently the Goodman family published a long-term proposal for their considerable holdings in downtown Portland. The Ankeny Project is a plan for up to 11 new developments, many of them considerable high-rise towers with the potential for over 4 million square feet of residential, office, and commercial space. All of these buildings would be built in what are currently Sectors 2 and 3. All of these buildings, under the proposed draft of the Central City 2035 plan would be allowed 42% more commercial parking spaces than are currently allowed. If these buildings were built today, and were entirely office space, 2,800 parking spaces would be allowed. If the proposed draft is passed unaltered, 4,000 spaces could be built.

Meeting our mode share goals for the Central City will be difficult enough if we allow 2,800 parking stalls in these towers. Allowing 1,200 MORE spaces than we could build today is a major step backwards.

An Imbalanced Proposal

The Central City 2035 Proposed Draft points out that the average maximum commercial parking entitlement remains at an average of 1 stall per 1,000 square feet of office space. This average is maintained by reducing the entitlement in the 56 acre Sector 6 from 2 stalls per 1,000 square feet to 1 stall per 1,000 square feet. A closer look at Sector 6, however, reveals that this reduction is unlikely to have any impact on the number of cars parked in the future downtown.

A 3-D Image of sector 6. Most of the sector is residential condos. — Sector 6 is nearly completely residential. The two vacant parcels pictured will be developed with residential or hotel uses before the Central City 2035 plan goes into effect.

Sector 6, is almost entirely condos or hotels. The two parcels in the photo which are undeveloped are a residential complex and a 6-story Hyatt hotel. The condos near the marina are relatively new and very unlikely to redevelop in the life of the comprehensive plan. Little-to-no office space will be built in this sector. The maximum entitlement could have been reduced to literally nothing and it would not have reduced the number of drive-alone trips we can expect in 2035 to the central city.

How To Move Forward

On July 26th, Portlanders for Parking Reform asked the Planning and Sustainability commission to amend the proposed draft and recommend a maximum parking entitlement for the downtown core of no more than .6 stalls per 1000 square feet. This ratio will not be a step backwards from where we are now. To meet our mode share and climate action goals in 20 years we must ensure that downtown parking is not so abundant as to make driving alone the cheapest and most convenient option.

Even a ratio of .6 stalls may not be enough. New parking for residential uses will be allowed at a ratio of 1.2 stalls per housing unit (currently 1.35 stalls per unit are allowed in sectors 1-5 and 1.7 stalls in sector 6) and the shared parking allowance will enable these stalls to be used by commuters to downtown. If the city is serious about meeting it’s stated goals, these ratios should be much, much lower, ratios of .25 stalls per housing unit or 1,000 square feet of office space are more appropriate for our 15% drive-alone mode share goal.

The policy suggestions are generally good. Simplifying the code and allowing shared parking are smart decisions, but a holistic examination is needed to ensure that shared parking and too-high ratios won’t lead to an increase in supply that could lead to more driving.

The Planning Commission and City Council must ask to see the math that supports the proposed parking maximums. Realistic projections of new development and the likely increases in car traffic and drive-alone commutes that will come along with this proposal must be justified and mitigated. These ratios are too high to meet our goals.

The Planning and Sustainability Commission will hold its final hearing on the CC2035 Plan on August 9th at 4PM. Testimony can be sent to psc@portlandoregon.gov asking the commission to reduce the maximum parking ratios to at most .6 stalls, across the board and the commission should direct PBOT staff to show how any proposed ratios support the mode share goals. Be sure to include “CC2035 Plan Testimony” in the subject line and your full name and mailing address.

[Note: Previously this article stated that Central City Parking Review (and likely Transportation Demand Management) would be required for developments with new parking. This was incorrect. Grant Morehead from PBOT says: “Under the existing zoning CCPR (and therefore a TDM Plan) is almost never required if the parking is accompanied by new development. Office uses (see 33.510.263.A.1 and Table 510-5) and residential uses (see 33.510.263.E.4 and Table 510-9) are allowed to build up to the maximum, if the parking is in a structure, without going through CCPR. CCPR in conjunction with new development is intended to address situations where there is no maximum (applies mainly to non-office uses outside of downtown/Core Area).”]