Thursday, March 31, 2016 is the deadline to make comments on the Central City 2035 Discussion Plan. The document is quite lengthy (over 200 pages) and addresses many topics. Effectively the Central City 2035 Plan is the blueprint for the next 20 years of the heart of our city. Many advocacy groups are poring over the details to submit testimony and Portland Shoupistas has drafted some comments on the parking related portions.
Our comments, which you can view on Google Docs are focused, primarily, on two aspects of the plan:
- Shared use of existing and to-be-built parking stalls for commercial and residential uses.
- Implementing parking maximums for all parking usage types.
These policy recommendations, which came out of the Central City Parking Policy Update Stakeholder Advisory Committee are designed to “limit the growth of the parking supply and encourage the use of alternative modes to support the mode split goals for the Central City.” The policies are a bargain of sorts, the city proposes to tighten parking maximum entitlements for much of the central city, but they are offsetting those restrictions by allowing building managers the freedom to use virtually all of their parking as they wish. Currently, building managers cannot lease spaces built for residential uses to commuters or downtown visitors.
Additionally the city proposes to allow developers to retain some, or all, of their parking entitlement which can be bundled into future projects nearby if they find that they beuilt too few spaces for their building.
All in all these are smart policies in our opinion and they should, in theory, lead to less structured parking being built in the central city and more efficient uses of the parking we already have. But there are some potential pitfalls and the proposal could be improved by staff or the planning commission before enactment:
- Some areas of the central business district (CBD) are seeing increases in their parking entitlement. Currently the densest, most transit-rich portions of downtown have parking maximums of .7 or .8 parking stalls per 1000 square feet of commercial or office space. The proposal, in a good-faith effort to simplify the code, has created one zone for much of downtown with a ratio of 1 stall per 1000 square feet. This is a lower maximum entitlement than some areas, but the increase in the city core should be eliminated. At the very most the parking ratio should be held at .75 stalls per 1000 square feet in the CBD.
- When combined with the shared parking allowance, we could be dramatically increasing the amount of commuter parking available downtown see this example from out testimony:
Under current maximums, a hypothetical building in the CBD might be limited to 80 spaces for 100,000 square feet of office space and might build 120 stalls to support 100 residential units. The argument for shared parking suggests that a developer might be inclined to build 120 stalls total under the new policy, rather than 200 stalls (say ⅓ of the residents don’t move their cars every day). Under the proposed policy, however, the developer would have a maximum parking entitlement of 220 stalls as the proposal increases the maximums in the CBD by 20-30% for many sites for office and commercial use.
- The biggest problem with the proposal is that it doesn’t get us closer to meeting the city’s own 2035 mode split goals. The parking built in the next decade will last for 50 years or more, inducing demand for driving downtown, taking up space, and causing pollution. Our admirable and aggressive mode split target is that fewer than 25% of trips to the city center should happen by single occupancy vehicle in 2035, just 19 years away. If PBOT is serious about meeting these goals, they should commit to developing and sharing an analysis that ties off-street parking maximum allotments to mode split targets in each zone of the central city. Without such analysis showing that the proposed maximums will be effective, we must assume they won’t be effective.
Our comments recommend cutting the residential and commercial parking entitlements by 50-75%. These lower ratios take into account the effective increase in current supply provided by the legalization of shared use parking and are an attempt to tie parking maximums to the city mode split goals.
Read our entire testimony here. If you would like to sign onto our testimony you can add a comment to the google document or comment on this story.