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Staff Memo 09-13-23 PC Mtg 09-25-23 w-Attach PP 22-0001
503-635-0290 380 A AVENUE PO BOX 369 LAKE OSWEGO, OR 97034 WWW.LAKEOSWEGO.CITY TO: Planning Commission FROM: Erik Olson, Long Range Planning Manager SUBJECT: Climate Friendly and Equitable Communities Rules (PP 22-0001) Work Session #2 DATE: September 13, 2023 MEETING DATE: September 25, 2023 EXECUTIVE SUMMARY & ACTION REQUESTED This memo provides background for the Commission’s September 25 work session, during which a representative from the Oregon Department of Land Conservation and Development (DLCD) will provide an overview of the purpose of the Climate-Friendly and Equitable Communities (CFEC) rules for parking reform, and staff will address questions from the Commission that were raised during their July 24 work session. Staff will also provide an update on the direction received from City Council during their September 5 study session on CFEC parking reform. BACKGROUND On July 24, 2023, the Commission held a work session to receive an update on the City’s compliance with initial phases of CFEC, and to learn more about the different options for compliance with Phase B of the CFEC parking reform requirements. A summary of this information can be found in Attachment E. During their July 24 work session, the Commission raised a number of questions related to the CFEC rules, including questions related to the original purpose of parking requirements, whether other cities have removed parking requirements, the relationship between reduced parking requirements and greenhouse gas (GHG) emissions, the legal implications of requiring “unbundled” parking, and whether accessible parking may be required. See Parking Reform Questions, below, for background information and responses to these questions. On September 5, 2023, the City Council held a study session to receive a presentation from Evan Manvel, Climate Mitigation Planner at DLCD, with an overview of the purpose of the CFEC rules for parking reform (see Attachment A). Council also provided direction to staff on a Page 2 of 19 proposed work plan to develop code amendments that comply with Phase B of the CFEC parking rules by December 31, 2024. During this September 5 study session, City Council directed staff to primarily explore a potential Citywide repeal of parking requirements under CFEC Parking Phase B – Option 1. Several Council members stated a preference for a market-based approach to the provision of parking spaces in new developments, noting that the real estate market in suburban Lake Oswego provides developers with a built-in incentive to provide parking spaces in order to make their developments attractive to renters or buyers. Given that Lake Oswego is primarily a car-oriented city with limited transit access, several Council members felt that parking spaces would be included in any successful development, regardless of whether they are required, due to the market preference to provide parking spaces in the city. Several Council members also expressed support for the simplicity of Option 1, which would advance City Council goals to streamline the development code and provide a clear set of easy-to-comprehend and consistently-applied parking regulations that would be straightforward to implement. Some Council members expressed interest in supplementing this approach with responsive parking management in areas of the City where available parking spaces may be limited. Other Council members expressed interest in offering parking-related incentives to developers to provide infrastructure that supports City sustainability and accessibility goals, such as solar panels, electric vehicle charging stations, or fully-accessible dwelling units. REVIEW OF PHASE B REQUIREMENTS Parking Regulation Improvement [OAR 660-012-0405] Baseline requirements for compliance with Phase B of CFEC parking reform – referred to as “Parking Regulation Improvements” – are outlined in OAR 660-012-04051. Attachment F includes implementation guidance from DLCD for the Parking Regulation Improvements outlined in OAR 660-012-0405. Regardless of the eventual option selected for compliance with the remainder of Phase B, all Parking Regulation Improvements must be implemented in order to comply with the CFEC rules. As discussed in Attachment E and at previous work sessions, these Parking Regulation Improvements require the City to: allow for the redevelopment of any portion of a parking lot for bike or transit uses; allow and encourage redevelopment of underutilized parking for other uses; require that surface parking lots more than ½ acre in size have either 40% tree canopy, include green energy technology, or include solar panels; require street trees along driveways or a minimum of 30% tree canopy coverage over parking areas; and require the provision of pedestrian facilities between buildings and pedestrian-oriented rights-of-way. 1 Available at https://secure.sos.state.or.us/oard/viewSingleRule.action?ruleVrsnRsn=301177. Page 3 of 19 The City is likely already in compliance with provisions requiring the preferential placement of carpool/vanpool parking, allowing redevelopment of any portion of a parking lot for transit uses, allowing and facilitating shared parking, and establishing off-street parking maximums in appropriate locations, such as downtowns, designated regional or community centers, and transit-oriented developments. Parking Maximums and Evaluation in More Populous Communities [OAR 660-012-0415] Additional requirements for CFEC Phase B compliance related to parking maximums are outlined in OAR 660-012-04152, which specifies that cities with greater than 25,000 population in the Portland metro area – including Lake Oswego – must set certain parking maximums in climate-friendly areas and in regional centers and town centers, as well as on lots or parcels within the transit corridors and rail stop areas listed in OAR 660-012-04403 (see Attachment J). Attachment G includes DLCD guidance related to the “Parking Maximums and Evaluation in More Populous Communities” requirements outlined in OAR 660-012-0415. Similar to the Parking Regulation Improvements rule, there are limited options for compliance. Staff notes that, under Metro’s existing Functional Plan requirements, Lake Oswego and other Metro area cities already implement parking maximums in such areas, in compliance with the parking maximum-related rules in OAR 660-012-0405(5). However, additional code amendments will be necessary in order to fully comply with the provisions in OAR 660-012- 0415, including establishing parking maximums for multi-family residential uses and new regulations to specify that – for land uses with more than 65,000 square feet of floor area – surface parking may not consist of more area than the floor area of the building. Parking Reform Options [OAR 660-012-0420 through 0450] Further requirements for compliance with Phase B of CFEC parking reform are outlined in OAR 660-012-04204 through 660-012-04505. In general, these rules require the City to reform existing parking mandates based on the three following Parking Reform Options: (Staff Memo continues on next page) 2 Available at https://secure.sos.state.or.us/oard/viewSingleRule.action?ruleVrsnRsn=301178. 3 Available at https://secure.sos.state.or.us/oard/viewSingleRule.action?ruleVrsnRsn=293034. 4 Available at https://secure.sos.state.or.us/oard/viewSingleRule.action?ruleVrsnRsn=293030. 5 Available at https://secure.sos.state.or.us/oard/viewSingleRule.action?ruleVrsnRsn=293036. Page 4 of 19 Source: CFEC Parking Reform Overview, DLCD, November 16, 2022. Option 1 offers the simplest route to compliance, and would require the City to repeal all parking requirements in the Development Code. Options 2 and 3 are alternative routes that would both allow the City to maintain parking requirements but would require the City to impose an extensive list of additional restrictions on those requirements. Option 1 – Repeal All Parking Requirements As mentioned above, Option 1 would require the City to repeal all parking requirements in the Development Code. Such a policy would represent a significant shift for the City, as the City’s parking standards in LOC 50.06.002 have only expanded in scope since they were originally adopted in 1961 – over 60 years ago (Ordinance 781). However, staff notes that the City has already complied with DLCD’s rule that eliminates required parking within one-half mile of Bus Line #35 (see Attachment J). This compliance effectively eliminated parking requirements throughout most of the west side of Lake Oswego, including significant portions of the Birdshill, First Addition-Forest Hills, Foothills, Evergreen, Lakewood, Old Town, Hallinan, Glenmorrie, and Skylands neighborhoods, as well as a small portion of the McVey-South Shore neighborhood. Thus, Option 1 would primarily entail the removal of parking requirements in the City’s 17 other neighborhoods, in addition the Page 5 of 19 neighborhoods listed above, including those areas that are more than one-half mile from Bus Line #35. As described in Attachment D, there are now eight Oregon cities that have repealed parking mandates citywide in compliance with CFEC Option 1: Portland, Salem, Corvallis, Tigard, Bend, Albany, Central Point, and most recently Beaverton. While parking requirements no longer exist in these areas, development codes nonetheless allow developers to voluntarily provide parking, and staff still expects that developers in Lake Oswego would provide parking spaces even where they are not required. Per Attachment D: Most builders in communities without parking mandates still provide some parking with new developments. Some of them provide less than previously mandated, or provide it off-site. Others provide more than previously mandated, as their market analysis or lenders indicate that’s what their customers want. This is how builders currently act; for example, a student-focused development on the edge of Corvallis provided 2.7 spaces per unit, higher than mandated. The concept of reducing local parking requirements is not new, and such policy has been implemented in cities throughout the world with the intent of reducing housing costs, increasing business development, and producing more climate-friendly outcomes. Attachment M provides the following rationale for reducing local parking minimums: Excess parking has a significant negative impact on housing costs, business costs, the feasibility of housing development and business redevelopment, walkability, air and water pollution, climate pollution, and general community character. Parking mandates force people who don’t own or use cars to pay indirectly for other people’s parking. Carless households tend to be the poorest households. Parking demand varies significantly from development to development, and about one-sixth of Oregon renter households own zero vehicles. Planning practices of the past have imposed a one-size- fits-all requirement everywhere, creating incentives to own more cars and drive more. Compliance with Option 1 would involve a relatively straightforward code amendment to repeal the City’s existing parking requirements, with no further action required to comply with the remaining Phase B CFEC parking options. Option 1 would have a Citywide impact by all eliminating parking requirements – including those for both residential and commercial uses – applying to all neighborhoods in the City the same, rather than having parking requirements apply sporadically throughout the City under Options 2 and 3. Figure 1, below, depicts the extent of the impact of Option 1 on parking regulations for commercial uses throughout the city, in the areas where commercial is allowed as a primary use. Also see Attachment P for larger size maps of Figures 1-8, below. Page 6 of 19 Figure 1 - CFEC Option 1 Commercial Parking Requirements Figure 2, below, depicts the impact of Option 1 on residential uses throughout the City. Page 7 of 19 Figure 2 - CFEC Option 1 Residential Parking Requirements Requirements for both Options 2 and 3 Under either Option 2 or 3, CFEC rules require compliance with all eight land use regulations in OAR 660-012-04256. As discussed in Attachment E and at previous work sessions, the City already complies with three of these eight provisions, but would need to adopt new regulations related to: allowing required parking to be provided off-site (within 2,000 feet pedestrian travel of a site) and to reduce parking requirements for the provision of solar panels or wind power, dedicated car-sharing spaces, electric vehicle charging stations, or dwelling units that are fully- accessible to people with mobility disabilities. Additionally, the CFEC rules for Options 2 or 3 in OAR 660-012-0435(2)7 require the City to either remove minimum parking requirements within and ¼ mile from designated climate- friendly areas (CFAs) – which, for Lake Oswego, include the Downtown Redevelopment Design District and the Lake Grove Village Center Overlay Districts – or adopt parking management policies within those areas. Both of the options for compliance with OAR 660-012-0435(2) 6 Available at https://secure.sos.state.or.us/oard/viewSingleRule.action?ruleVrsnRsn=301179. 7 Available at https://secure.sos.state.or.us/oard/viewSingleRule.action?ruleVrsnRsn=301180. Page 8 of 19 would require the City to modify existing parking policies, either through the reduction of parking requirements in targeted areas or through the adoption of a new parking management program. Option 2 – “Fair Parking” Approach The CFEC rules for Option 2 – referred to as the “Fair Parking” approach – require the City to implement at least three of the five provisions in OAR 660-012-0445(a)8. As discussed in Attachment E and at previous work sessions, this option would require the City to adopt new regulations related to either requiring “unbundled” parking, requiring that flexible commute benefits be offered by employers of 50 or more employees, establishing a tax on commercial parking lots, or reducing parking requirements for multifamily residential development. Figure 3, below, depicts the impacts of Option 2 on parking regulations for commercial uses throughout the city, in the areas where commercial is allowed as a primary use. Figure 3 - CFEC Option 2 Commercial Parking Requirements 8 Available at https://secure.sos.state.or.us/oard/viewSingleRule.action?ruleVrsnRsn=301181. Page 9 of 19 Compliance with Option 2 would have differing impacts on residential uses throughout the city depending on which option is selected under OAR 660-012-0435(2)9 – either the removal of minimum parking requirements within and near designated CFAs, or the adoption of parking management policies in those areas. Option 2(a) involves a decision to remove parking requirements within and ¼ mile from designated CFAs, per OAR 660-012-0435(2)(a). Option 2(b) involves a decision to instead adopt parking management policies in those areas, per OAR 660-012-0435(2)(b). Figures 4 and 5, below, depict the different impacts of Options 2(a) and 2(b) on parking regulations for both commercial and residential uses throughout the city. Figure 4 - CFEC Option 2(a) Residential Parking Requirements 9 Available at https://secure.sos.state.or.us/oard/viewSingleRule.action?ruleVrsnRsn=301180. Page 10 of 19 Figure 5 - CFEC Option 2(b) Residential Parking Requirements Option 3 – “Reduced Regulation Parking Management” Approach The CFEC rules for Option 3 – referred to as the “Reduced Regulation Parking Management” approach – require the City to implement all 14 of the provisions in OAR 660-012-0445(b)10. Generally speaking, this option would require the City to adopt code amendments to reduce or eliminate minimum parking requirements for several types of development, uses, and locations, including: Eliminating all parking requirements within and ½ mile from designated CFAs, which include the Downtown Redevelopment Design District and the Lake Grove Village Center for Lake Oswego; and Eliminating parking requirements for mixed-use development, group quarters (dormitories, religious group quarters, adult care facilities, retirement homes, and other congregate housing), studio or one-bedroom units in multifamily residential developments, schools, bars and taverns, historic buildings, smaller commercial 10 Available at https://secure.sos.state.or.us/oard/viewSingleRule.action?ruleVrsnRsn=301181. Page 11 of 19 properties, the redevelopment of vacant buildings, changes of use that result in additional required parking, the expansion of existing businesses, developments built under the Oregon Residential Reach Code, and developments seeking Leadership in Energy and Environmental Design (LEED) certification; Additionally, Option 3 would require the City to implement at least one pricing mechanism for parking, either through the designation of a residential parking district or through requiring “unbundled” parking for multi-family residential units. Figure 6, below, depicts the impacts of Option 3 on parking regulations for commercial uses throughout the city, in the areas where commercial is allowed as a primary use. Figure 6 - CFEC Option 3 Commercial Parking Requirements Compliance with Option 3 could have slightly different impacts on residential uses throughout the city depending on which option is selected under OAR 660-012-0435(2). Option 3(a) would involve a decision to remove parking requirements for residential use within and ¼ mile from designated CFAs, per OAR 660-012-0435(2)(a). Option 3(b) involves a decision to instead adopt parking management policies in those areas, per OAR 660-012-0435(2)(b). Figures 7 and 8, Page 12 of 19 below, depict the different impacts of Options 3(a) and 3(b) on parking regulations for residential uses throughout the city. Figure 7 - CFEC Option 3(a) Residential Parking Requirements Page 13 of 19 Figure 8 - CFEC Option 3(b) Residential Parking Requirements Staff notes that Option 3 would require eliminating all parking requirements within and ½ mile from designated CFAs, regardless of which option is selected under OAR 660-012-0435(2). Thus, it would be easy to comply with a requirement to remove all parking requirements within and ¼ mile from designated CFAs per OAR 660-012-0435(2)(a). Accordingly, under Option 3(b), parking management regulations would be adopted in addition to the removal of parking requirements within and ¼ mile from designated CFAs. PARKING REFORM QUESTIONS During their July 24 work session, the Commission raised a number of questions and topics for further exploration related to parking reform. The section below includes background information and initial responses to a selection of these questions. What Was the Original Purpose of Parking Requirements? According to Attachment O, excerpted below, the origin of minimum parking requirements in land use planning is somewhat of a mystery: Page 14 of 19 Where do minimum parking requirements come from? No one knows. The “bible” of land use planning, F. Stuart Chapin’s Urban Land Use Planning, does not mention parking requirements in any of its four editions.11 The leading textbooks on urban transportation planning also do not mention parking requirements.12 This silence suggests that planning academics have not seriously considered – or even noticed – the topic. This academic neglect has not prevented practicing planners from setting parking requirements for every conceivable land use. Figure 1 shows a small selection of the myriad land uses for which planners have set specific parking requirements. Without training or research, urban planners know exactly how many parking spaces to require for bingo parlors, junkyards, pet cemeteries, rifle ranges, slaughterhouses, and every other land use. Richard Willson (1996) surveyed planning directors in 144 cities to learn how they set parking requirements. The two most frequently cited methods were “survey nearby cities” and “consult Institute of Transportation Engineers (ITE) handbooks.” Both strategies cause serious problems… Attachment B includes a legislative history of the original adoption of parking requirements in the City of Lake Oswego, which were adopted along with a new zoning ordinance on November 21, 1961. This history includes several Council and Planning Commission meetings where the adoption of off-street parking requirements was discussed, though no explicit rationale for the parking requirements could be located in the legislative record. This history included the following exchange regarding the feasibility of compliance with the proposed off-street parking requirements during a joint meeting of the City Council and Planning Commission on November 1, 1961: City Attorney called to the attention of the Council and the Planning Commission the off- street parking requirements stating that it is impossible to comply with, and that he has no solution to offer. 11 See Chapin (1957, 1965), Chapin and Kaiser (1979), and Kaiser, Godschalk, and Chapin (1995). 12 See Dickey (1983), Hanson (1995), Meyer and Miller (1984), and Papacostas and Prevedouros (1993). Page 15 of 19 /// It was the consensus of all concerned that the off- street parking problem must be solved by establishing some standard that has flexibility... A subsequent City Council meeting was held on November 17, 1961, to establish a more flexible off-street parking standard and resolve other remaining issues with the proposed zoning ordinance. Per Attachment B, the proposed off-street parking requirements remained as-is following this discussion, and were not modified prior to the adoption of the 1961 Lake Oswego Zoning Ordinance. Are There Other Comparable Cities that Do Not Require Parking? As described above in Option 1 – Repeal All Parking Requirements and in Attachment D, there are now eight Oregon cities that have repealed parking mandates citywide in compliance with CFEC Option 1: Portland, Salem, Corvallis, Tigard, Bend, Albany, Central Point, and most recently Beaverton. Attachment L also notes that the cities of Minneapolis, MN, Fargo, ND, Buffalo, NY, San Diego, CA, Los Angeles, CA, and Seattle, WA have eliminated parking mandates, in addition to the following communities throughout the world: What is the Relationship between CFEC Rules and GHG Emissions? The CFEC rules are intended to reduce GHG emissions resulting from transportation by reducing the amount of vehicle miles travelled. Per Attachment M, the rules are in part intended to, “ensure Oregonians have more safe, comfortable ways to get around, and don’t have to drive long distances just to meet their daily needs.” Per Attachment K, there are numerous studies that show a relationship between the availability of “free” or “copious” parking and increased car ownership and driving. Attachment K also references studies showing that household decisions about car ownership and parking are influenced by parking availability. The idea is relatively simple: reducing parking requirements can have the effect of reducing the demand for car ownership and use, Page 16 of 19 particularly for short trips or trips to areas well-served by transit. Such reductions in car ownership and use would in turn result in reduced GHG emissions. The State of Oregon measures GHG emissions pursuant to ORS 660-044-003013 – Methods for Estimating Greenhouse Gas Emissions and Emissions Reductions. The state uses the Oregon Transportation Emissions website14 to monitor the progress of the Statewide Transportation Strategy, including their progress in reducing GHG emissions through reductions in vehicle miles travelled (VMT), based on data gathered from federal, state and local governments and commercial sources. State agencies also directly gather data related to VMT, vehicle registration counts, fuel costs, what type of means people use to travel, EV charging infrastructure availability, public parking costs, and other information in order to track this progress. Can the City Legally Require Unbundled Parking? Compliance with Option 2 – the “Fair Parking” approach – would require the City to adopt regulations requiring that any parking provided for 5+ unit residential development and commercial development be “unbundled” – or separately leased/sold – from the development for which the parking was provided. Unbundled parking” is defined in OAR 660-012-000515(57): “Unbundled parking” means a requirement that parking spaces for each unit in a development be rented, leased, or sold separately from the unit itself. The parking space(s) must be rented, leased, or sold at market rates for comparable local off-street parking. The renter, lessor, or buyer of the unit must be allowed to opt out of renting, leasing, or buying the parking space. Attachment H includes implementation guidance from DLCD regarding unbundled parking. DLCD advises local jurisdictions to adopt an ordinance regulating the rental, lease, and sales agreements for unbundled parking, as well as code amendments requiring new development to unbundle parking. No laws were cited by DLCD that would preclude cities from adopting such policies or requirements, nor were any identified by City staff. Attachment H also clarifies that cities, “should establish a process for the jurisdiction to determine a minimum rate(s) for unbundled parking and for distributing that information to affected landlords and tenants.” DLCD recommends that these minimum rates be established based on a survey of monthly parking rates for off-street parking lots or garages, with adjustments for geographic distance from the parking facilities surveyed. DLCD also advises that these minimum rates be re-evaluated at a regular interval through a staff-level process that does not require action from the Commission or City Council. 13 Available at https://secure.sos.state.or.us/oard/viewSingleRule.action?ruleVrsnRsn=293065. 14 Available at https://www.oregontransportationemissions.com/. 15 Available at https://secure.sos.state.or.us/oard/viewSingleRule.action?ruleVrsnRsn=292987. Page 17 of 19 Can the City Require Accessible Parking? The Commission expressed concerns regarding the City’s ability to ensure that accessible- or Americans with Disabilities Act (ADA)-compliant parking is made available for people with a disability, given the reductions in required parking under CFEC. These concerns are addressed in Attachment I, which outlines potential approaches that local jurisdictions can take regarding accessible or ADA-compliant parking. Per Attachment I: Oregon law sets a floor and a ceiling of how much accessible parking cities and counties can require (ORS 447.23316). That statute includes a table of ADA parking in relation to total parking spaces provided [excerpt next page], and required the Department of Consumer and Business Services (DCBS) to integrate that table into the state building code (OSSC 1106.117). This means when parking is provided, ADA parking spaces are required for most housing other than single unit, duplex, and townhome development (OSSC 1106.318). Table of Required ADA parking from ORS 447.233: State building code has additional requirements for hospital, rehabilitation, and physical therapy facilities. 16 Available at https://codes.findlaw.com/or/title-36-public-health-and-safety/or-rev-st-sect-447-233.html. 17 Available at https://up.codes/viewer/oregon/ibc-2018/chapter/11/accessibility#1106.1. 18 Available at https://up.codes/viewer/oregon/ibc-2018/chapter/11/accessibility#1106.3. Page 18 of 19 Under all these codes, the number of required ADA spaces is driven by how much parking is built, not zoning ordinance requirements… Attachment I also addresses the potential impact of CFEC on ADA parking: Cities and counties have not been able to require more accessible parking than prescribed in state law, even before the CFEC rules adoption. The amount of ADA parking spaces that must be provided is still based on the number of parking spaces in the parking lot. Repeal of parking mandates does not alter the applicability or enforcement of that law. The CFEC rules explicitly exempt ADA parking from parking mandate reduction (OAR 660012-0005(29)), thereby retaining the ability of cities and counties to require ADA parking even when other parking mandates are limited. For developments with off-street parking, local governments must still require new developments to build off-street ADA parking spaces per ORS 477.233. The main impact of mandate repeals is that developments will provide ADA spaces based on the total number of parking spaces they chose to build rather than the total number they would have been forced to build. If a development does not include an off-street parking area, the local governments may still require one off-street ADA parking space, and additional spaces per the ORS 477.233 table. Additional Questions and Requests Staff notes that the Commission had additional questions and requests at their July 24th work session that are not addressed in this report. These questions related to the relationship between reduced parking mandates and vehicle idling and the extent to which the City is required to enforce parking management requirements under the “Reduced Regulation Parking Management” approach (Option 3). The Commission also requested an analysis of the pros and cons of the different options under consideration. While staff was unable to locate conclusive data related to the relationship between reduced parking mandates and vehicle idling, there will be an opportunity to discuss this issue further with the representative from DLCD at the September 25 work session. Staff will more directly analyze the pros and cons of the different options for compliance with Phase B of the CFEC parking reform rules at a future work session. This analysis will include a brief discussion related to the enforcement of parking management regulations, in addition to a discussion of the other pros and cons related to parking management. Page 19 of 19 ATTACHMENTS A. DLCD Presentation – Oregon’s Parking Reforms, 09/05/2023 B. Legislative History – Original Adoption of Parking Requirements in Lake Oswego, 08/16/2023 C. CFEC Project Schedule, 08/21/2023 D. Sightline Institute article, “Parking Mandates Are Vanishing Across Oregon,” 07/20/2023 E. Staff Report – CFEC Work Session #1, 07/14/2023; due to document size, please find the document online at: https://www.ci.oswego.or.us/WebLink/DocView.aspx?id=2515055&dbid=0&repo=CityO fLakeOswego F. DLCD Handout - Guidance on OAR 660-012-0405, Parking Regulation Improvements, 05/25/2023 G. DLCD Handout - Guidance on OAR 660-012-0415, Parking Maximums, 04/27/2023 H. DLCD Handout - Guidance on Unbundled Parking, 04/27/2023 I. DLCD Handout – Potential Approaches to ADA Parking, 02/22/2023 J. CFEC Parking Phase A Map, 01/01/2023 K. DLCD Handout - Parking Supply, Car Ownership, and Driving Rates, 11/02/2022 L. DLCD Handout - What Happens When Parking Mandates are Reduced, 10/04/2022 M. DLCD Handout - CFEC Program Overview, 07/21/2022 N. DLCD Handout - CFEC Implementation Guide, 07/21/2022 O. Donald C. Shoup, “The Trouble with Minimum Parking Requirements,” 12/09/1999 P. CFEC Parking Reform Maps, Figures 1-8 Evan Manvel Climate Mitigation Planner Oregon’s Parking Reforms Lake Oswego PP 22-0001 ATTACHMENT A/PAGE 1 OF 38 Key point No mandated parking does not mean No parking provided 13th and Olive in Eugene built two new 700 stall parking garages even though none was required Los Angeles downtown builders provided average 1.2 parking spaces/unit after reduced regulations Edge Corvallis student housing providing 2.7 spaces/unit (2.56 mandated) PP 22-0001 ATTACHMENT A/PAGE 2 OF 38 Why Parking Reform Matters PP 22-0001 ATTACHMENT A/PAGE 3 OF 38 Opportunity Cost and Land Cost Sightline PP 22-0001 ATTACHMENT A/PAGE 4 OF 38 Olympia, WA 54% of land in commercial sites for parking PP 22-0001 ATTACHMENT A/PAGE 5 OF 38 How Much Land is Used? Corvallis, OR 11% for parking 10% for roads Los Angeles, CA 14% for parking 10% for roads Parking 11% Roads 10% PP 22-0001 ATTACHMENT A/PAGE 6 OF 38 Most cities have a parking management problem, not a parking supply shortage PP 22-0001 ATTACHMENT A/PAGE 7 OF 38 How Much Does Parking Cost and What Does that Effect? PP 22-0001 ATTACHMENT A/PAGE 8 OF 38 Building a Parking Space (not including land cost and opportunity cost) Eugene: $42,000/space parking garage (2018) Corvallis:$11,000/space surface (including land) $62,000/space garage (including land, debt) Surface off-street: $1,500 - $12,000 Residential garage: $15,000 - $50,000 PP 22-0001 ATTACHMENT A/PAGE 9 OF 38 Parking’s Share of Housing Costs Litman (2019): 10-20% of Total Housing Cost Gabbe and Pierce (2016): 17% of Rent PP 22-0001 ATTACHMENT A/PAGE 10 OF 38 Choice: House Cars or House People? Oakland, CA: mandate for one space/unit costs per apartment increased 18%; 30% fewer units built PP 22-0001 ATTACHMENT A/PAGE 11 OF 38 Eugene Code Proposal Max units 2 4 Parking 1/unit 0.75/unit Reducing parking mandates means two more housing units could be supplied by the market PP 22-0001 ATTACHMENT A/PAGE 12 OF 38 Parking Reform “exclusionary zoning laws—like minimum lot sizes, mandatory parking requirements and prohibitions on multifamily housing— have inflated costs and locked families out of areas with more opportunities.” May 16, 2022 Suzanne P. Clark president/CEO, U.S. Chamber of Commerce Brian Deese director, White House National Economic Council 13 PP 22-0001 ATTACHMENT A/PAGE 13 OF 38 Affordable Housing Development (King County WA) one space/unit leasing costs +12.5% two spaces/unit leasing costs +25% Parking means cities build fewer affordable housing units PP 22-0001 ATTACHMENT A/PAGE 14 OF 38 How Much Built Parking is Unused? PP 22-0001 ATTACHMENT A/PAGE 15 OF 38 Parking Oversupplied: Multifamily Developments King County: 40% avg. unused Bay Area: 28% avg. unused Albany, OR: 30% avg. unused Hillsboro: 25% avg. unused PP 22-0001 ATTACHMENT A/PAGE 16 OF 38 Thus Far •Parking uses a lot of land •Parking is a significant expense and displaces housing •Many parking spots are underused There is significant room to more precisely meet demand and reduce excess costs PP 22-0001 ATTACHMENT A/PAGE 17 OF 38 Parking is Usually Bundled and Not Paid for Separately 96-99% of parking is bundled, meaning: higher rents and home prices, lower paychecks, higher prices, non-drivers subsidize drivers The economy picks up the tab for free parking – an enormous inducement to drive PP 22-0001 ATTACHMENT A/PAGE 18 OF 38 More Parking More Driving Bundled parking correlates with: •Higher car ownership •Higher rates of driving even with same car ownership PP 22-0001 ATTACHMENT A/PAGE 19 OF 38 Pricing Matters a Lot •Case studies LA, DC +60% driving if parking “free” •California parking cash out reduced drive to work 17% •Minneapolis: 11% fewer employees drive to work under parking cash out PP 22-0001 ATTACHMENT A/PAGE 20 OF 38 Parking and Equity (Sightline chart) PP 22-0001 ATTACHMENT A/PAGE 21 OF 38 What Happens When Parking Mandates are Reduced? PP 22-0001 ATTACHMENT A/PAGE 22 OF 38 More Diverse Parking Supply Buffalo, NY (pop 256,000) - 2017 Minneapolis, MN •Student housing 47% less parking •Mixed-use developments an average of half as many spaces; four none (shared parking) •Most single-use multifamily about the same as previous mandated; some more 23 •Units near transit built 30% less parking •Units without parking $200/month cheaper LCDC February 3, 2022 PP 22-0001 ATTACHMENT A/PAGE 23 OF 38 1.2 spaces/unit 34-50% off-site Los Angeles, CA downtown adopted 1998 Housing development increased nearly 4x with adaptive reuse ordinance 0 1,000 2,000 3,000 4,000 5,000 6,000 7,000 8,000 9,000 10,000 1970-1980 1980-1990 1990-2000 2000-2010 Net New Housing Units ARO units PP 22-0001 ATTACHMENT A/PAGE 24 OF 38 Seattle reform 2012-2017 saved $537 million PP 22-0001 ATTACHMENT A/PAGE 25 OF 38 San Diego, CA Sixfold increase in affordable housing units in density bonus program PP 22-0001 ATTACHMENT A/PAGE 26 OF 38 Fargo, ND (pop 125,000) University located architecture and business schools downtown. 104-unit mixed-use development built in downtown core. Over 4,500 more students and faculty living, working and studying downtown. PP 22-0001 ATTACHMENT A/PAGE 27 OF 38 Oregon Spurred small business Spurred small-scale housing Helped affordable housing 28 PP 22-0001 ATTACHMENT A/PAGE 28 OF 38 Oregon’s Parking Reforms •For cities in metro areas •Adopted July 2022 •Many reforms effective Jan 1, 2023 •Further reform to local schedule: Lake Oswego Dec 31, 2024 29 PP 22-0001 ATTACHMENT A/PAGE 29 OF 38 Improving Parking Management Overview Implement best practices for parking code details Cities choose a parking reform approach Populous communities do more parking management PP 22-0001 ATTACHMENT A/PAGE 30 OF 38 No Mandates in This Area 31 PP 22-0001 ATTACHMENT A/PAGE 31 OF 38 Reduced Mandates for Types No mandates for these types •Affordable housing •Publicly subsidized housing •Residential units <750 sq feet •Single-room occupancy •Childcare facilities •Emergency, transitional, domestic violence shelters •Facilities/residences for people with disabilities and in treatment No more than one space/unit for multifamily may be mandated 32 PP 22-0001 ATTACHMENT A/PAGE 32 OF 38 Implement Best Practices for Parking •Garages (ping-pong rooms) and carports can’t be required •Leased or off-site parking can meet parking requirements •New large parking lots provide either solar or trees, and have walkability features •Ease conversion of existing parking lots •More Source: Pexels PP 22-0001 ATTACHMENT A/PAGE 33 OF 38 Repeal parking mandates Nothing further Reduce burdens of how mandates can be met Waive mandates for certain types of development Reduce mandates in Metro centers Remove mandates near frequent transit Implement at least two of five policies Repeal mandates for more uses, more areas Option 1: No mandates Option 2: Fair policies Option 3: Reduced red tape PP 22-0001 ATTACHMENT A/PAGE 34 OF 38 Option 2 Fair Policies Implement at least two Parking rented separate from units, residential Parking rented separate from units, commercial Flexible commute benefits (parking cash out) of $50+/month if parking free at employer Tax on parking lot revenue Mandates no higher than 0.5 space/unit multifamily 35 PP 22-0001 ATTACHMENT A/PAGE 35 OF 38 Option 3 Reduced Red Tape No mandates Studios/one bedrooms Dormitories/group quarters Transit-oriented/mixed-use New uses/expansions Buildings in historic districts LEED/Reach Code Buildings vacant 2+ years Small businesses Schools Bars ½ mile around Metro town centers Also One residential/benefit district or unbundled parking for residential 36 PP 22-0001 ATTACHMENT A/PAGE 36 OF 38 Paths Taken Option 1: No mandates citywide Albany Beaverton Bend Central Point Corvallis Portland Salem Tigard Working on Option 2: Fair Policies Sherwood 37 PP 22-0001 ATTACHMENT A/PAGE 37 OF 38 Learn More Online Search “DLCD” “CFEC”Evan Manvel evan.manvel@dlcd.oregon.gov Source: ODOT PP 22-0001 ATTACHMENT A/PAGE 38 OF 38 LEGISLATIVE HISTORY Original Adoption of Parking Requirements in Lake Oswego •1961 Development Code - LOC 50.210 – Off-street parking This standard was originally adopted through Ordinance 781, Sec. 96, on 11/21/61 •Ordinance 781 – Adopted 11/21/61 (No clues here, ordinance basically just contains the development code) Council Minutes – 11/21/61 Meeting Ordinance passes unanimously (No findings located) •Council Minutes – 11/17/61 Special Meeting The special Council meeting was to resolve the remaining problems pertaining to the zoning Ordinance #781, which had been called to their attention at the previous public hearings. OFFSTREET PARKING - After general discussion, it was moved by Thomas, seconded by Lawrence that the parking provisions be left in as is, with an additional provision for the right of appeal. After further discussion, it was resolved that this protection is already provided in the proposed ordinance. Therefore Thomas, with the consent of his second, withdrew his motion with the result that the proposed off-street parking provision, as proposed in Ordinance # 781, shall remain as is. •Council Minutes – 11/01/61 Special Meeting The meeting was called to discuss the new zoning ordinance No. 781 by the Council and the Planning Commission and to take care of any suggested changes to be considered at the continued public hearing on the said ordinance. City Attorney called to the attention of the Council and the Planning Commission the off-street parking requirements stating that it is impossible to comply with, and that he has no solution to offer. /// It was the consensus of all concerned that the off- street parking problem must be solved by establishing some standard that has flexibility... PP 22-0001 ATTACHMENT B/PAGE 1 OF 12 •Council Minutes – 10/24/61 Special Meeting 7: 49 p.m. Public Hearing upon the new zoning ordinance No. 781 held. Approximately forty persons attended from the West end of the Lake, and the remonstrances from this area were considered first. There were no written remonstrances on file with the Recorder from this portion of the City… /// At 9141 p. m. Council reconvened to consider the objections from the East end of the Lake. Sixteen persons were in attendance at this session… /// There being no more questions or objections from the audience, the Mayor ordered the public hearing continued to a later date. At this time Councilman Coan said that he was in complete opposition to the proposed zoning ordinance as it pertained to the Lake Grove business area, stating that said ordinance would zone out as non-conforming approximately of the business in that area. After discussion between the Council and the Planning Commission, it was determined that the two bodies would meet on November 1 at 7:30 p.m. to jointly discuss some of the problems brought out in this hearing. At 10:42 p.m. the hearing was continued to a later date and the meeting adjourned. •Council Minutes – 01/01/61 Records from 1960 and first half of 1961 were lost. (There was no other mention of parking standards in other meetings in the second half of 1961). PP 22-0001 ATTACHMENT B/PAGE 2 OF 12 November 21, 1961 11 ® The regular meeting of the Council of the City of Lake Oswego convened at 7s30 p.m. • Present were Herinsen, Ross, Thomas and Mayor Stidd, Coen and L+ wrence excused; Stewart absent on account of illness. Moved by Thomas, seconded by Hers,lsen that the minutes of the previous meetings, as mailed, be approved. So ordered. REQUESTS PROP AUDIENCE, None The Mayor presented a Sewage Works Operator's Certificate for Group III plants to Marvin Thurber. This was awarded by the Oregon State University upon completion of a course of study and a written examination. CITY ATTORNEY - L. Huger,.: Crampton Bid openings on lake interceptor sewer. Kuokenberg Construction Co., Inc. 574,104.50 C. J. Monte() & Sons 657,230.00 Lord Bros. Contractors 598,781.00 R. A. Heintz Construction Co. 744,957.70 Kuckenberg apparent low bidder at $574,104.50. Referred to the Consulting Engineer Mr. Dorner, to check for errors and to make his recommendation; bid to be awarded by telephone poll. Presented bid of the American Pipe Company in the•amount of $161,856.59, which was411submittedpreviouslyand opened on October 17, 1961. Moved by Thomas, seconded by Ross that such ti d' for pipe be accepted. Carried unanimously. Opened bids for two police cars, as follows; Duden Rambler net bid for the two ears 3722. 00 Ted Gilbert 22 Gateway Chevrolet 3309.12 Dodge City Plymouth) 2231.12 Dodge City Dodge) 2261.92 Dodge City was apparent low bidder. Referred to Police Chief for review and reco aendstion. After said review, Chief reported back that Dodge City was low bidder and met specifications. Moved by Ross, seconded by Herman that the bid of Dodge City, in the amount of $2261.92, be accepted. "Carried. Liquor license renewelss Oswego Food Center, The Lodge, The Pinafore, The Cove and the Country Club. Moved by Neaten, seconded by Thomas that said renewals from the above named applicants be granted. Carried unanimously. ADMINISTRATIVE ASSISTANT - 0. D. Gleason Celled attention of the Council to the communication from 0. J. Eckert in regards 4 to zoning. Letter filed. Communications from Mr. and Mrs. Prank O'Connor end Welter K. Rush regarding zoning III ten acres or more eo agricultural land. Contents noted and referred to the Planning Commission. Chief of Police requested authorization for Officer Weber to attend a basic training school conducted by the State Police at Salem, from L$cember 4th to 9th, cost.involved to be transportation and food. Moved by Herman, seconded by Ross-PP 22-0001 ATTACHMENT B/PAGE 3 OF 12 that such author:,zation be granted. Carried unanimously. 411 CITY ENGINEER - R. N. Cruden Resolution extending time on L.X.D. 61. Moved by Thomas, seconded by Hermsen that said resolution be adopted. Upon vote, carried unanimously i , PERSONNEL - Councilman Lawrence None FINANCE - Councilman Thomas None PARKS - Councilman Hermsen None WATER PLANNING B DEVELOPMENT - Councilman Coan None SEWER PLANNING & DEVELOPMENT - Councilman Coan None COMMUNITY PLANNING & DEVELOPMENT - Councilman Roes None PUBLIC SAFETY - Mayor Stidd None I III 8$18 p.m.) ORDINANCE NO. /81 • AN ORDINANCE ESTABLISHING ZONING REGULATIONS AND REPEALING ORDINANCES NO. 348, 515, AND ALL AMENDMENTS THERETO AND DECLARING AN EMERGENCY - ' read first time in its entirety. During the reading, the following corrections were mules Page 12, Section 51, Subsection .(1), after the word "in" and before the word residential", insert "the least restrictive" and delete.the word "a". Page 16, Section 59i Subsection (20), correct spelling of the word "employing". . . Page 17, Section 61, insert Subsection (2), "All items produced or wares and merchandise handled shall be sold at retail on the premises except in the case. of Section 59 (23)." Page 21, Section 79, Subsection (7), correct spelling of the word "veterinary". Page 34, Section 105, Subsection (2), after the word "the" strike out the word shore" and insert the word "property". After the word "line"nand before the . word "in", strike out the word "at normal water level". On page 34, Street or' . Portion of Street Setback (18), correct spelling of "Troon" Road. Page 35, Street or Portion of Street Setback (28), after word "to" add "Stafford Road". 411 Page 42, Section 126, Subsection (3), after the word "ordinance" and before the word "and" insert a period and delete the following words "end the whole shall, be recorded with the county clerk." Subsection (4), after the word"the" and before the word "final", strike out the word "recorded". Subsection (5), after ' the word "the" and before the word "development" strike out the word "recorded". Subsection (6), delete the last sentence beginning with the word "the" and endingPP 22-0001 ATTACHMENT B/PAGE 4 OF 12 4, Page 44, Section 135, after the word "in" and before the word "fail" strike out Ill the words "the city". At 10:15 p.m., after discussion and all corrections having been made, it was moved by Ross, seconded by Thomas that the ordinance be read second time by title only. Carried unanimously. ORDINANCE NO. 781 read second time by title only. Before the vote was called for, Mrs. McFadden raised the question about setback requirements. Said requirements were 60 feet back from the street. The answer was 30 feet back from her property line. After further discussion, the question was called for and, upon roll call vote, the ordinance was passed unanimously. ORDINANCE NO. 780 - AN ORDINANCE ESTABLISHING A BUILDING ()ODE, REPEALING ORDINANCE , , NO. 614 AND DECLARING AN EMERGENCY • read first time in its entirety. During the discussion of theordinance, the question was raised in regards to charging fees to contractors working on city projects. It was decided that Councilman Ross Was to study this problem and may offer corrective amendment at a later date. Moved by Thomas, seconded by Hermsen that the ordinance be read second time by title only. Carried unanimously. ORDINANCE NO. 780 read second time by title only. Upon roll call vote, carried unanimously. Planning Commissioner Walt Reisner then suggested that a letter of thanks be addressed to Mark Westlingt employer, the Bureau of Municipal Research, commend- ing Mr. Westling for his untiring efforts and his fine cooperation with the Planning Commission in formulating the new zoning program. There being no further business, it was moved by Thomas, seconded by Ross that the meeting adjourn at 1Os35 p.m. Recorder PP 22-0001 ATTACHMENT B/PAGE 5 OF 12 I 40 November 17, 1961 Special meeting of the Council 'of the City of Lake Oswego convened at 8:47 a.m. Present were Lawrenoe, Ross, Thomas and Mayor Stidd. Coen and Hermsen excused - Stewart absent on account of illness, The special Council meeting was to resolve the remaining problems pertain- ing to the zoning Ordinance E1181, which had been called to their attention at the previous public hearings. M RED„EUM After general discussion, it was moved by Thomas, seconded by Lawrence that the parking provisions be loft in as is, with an additional provision for the right of appeal. After further discussion,- it was resolved that this protection is already provided in the proposed ordinance. Therefore Thomas, with the consent of his second, .withdrew his motion with the result that the proposed offstreet parking provision, as proposed in Ordinance #781, shall remain as is. t 7Ol - After lengthy discussion, it was moved by Thomas, seconded by Lawrence that service stations shell be' allowed as conditional use in a N. C. Zone. On a vote being called for, motion carried, with Ross voting 110 No.. Necessary correction made to the official Recorder's copy. Mr. Parelius' problem was discussed further, and it was the opinion of the • Council that they would' take no sedan on his suggested zone changes. COMMUNITY PLANNING & DEVELOPMENT - Councilman Ross Informed the Council that the library construction should be completed on' March 16, 1962. ADMINISTRATIVE ASSISTANT - G. D. Gleason The State' Senitery Authority informed the'Council. that.they are requesting a $165,OOO grant authorization for the 1961-62 fiscal year, and the balance of the $250,000 grant .to be allotted in 1962-63. there being no further business, the special meeting of the Council adjourned at 10:27 a.m. Recorder , PP 22-0001 ATTACHMENT B/PAGE 6 OF 12 November 1, 1961 1111 The special meeting of the Council of the City of Lake Oswego convened at 7s40 p.m. Present were Coan, Hermsen, Ross, Thomas and Mayor Stidd. Lawrence excused and Stewart absent on account of illness. Members of the Planning Commission present were Chairman Bean, Couch°, Reisner, Smith and Roddy. Also present was Bureau of Municipal Research representative Mark Yrestling. The meeting was called to discuss the new zoning ordinance No. 781 by the Coup- cil and the' Planning Commission and to take care of any suggested changes to be considered at the continued public hearing on the said ordinance. City Attorney called to the attention of the Council and the Planning Commission the off-street parking requirements stating that it As impossible to comply with, and that he has no solution to offer. The next problem discussed was Section 105 of the proposed ordinance pertaining to setbacks, particularly as it applies to Lakeview Boulevard. Mr. Wostling explained that there is an automatic exception as provided for in Section 1. His explanation answered the problem. Councilman Thomas inquired what are the problems with non-conforming build3,ngs.' City Attorney replied that this was defined in Sections 110 and illy, stating that where only a portion of a building is non-conforming, it does not make the whole structure non-conforming. After further discussion, it was the Council's 411 determination that subsection 1 wordage should be changed to "except for that portion of the setback which is listed in subsection 3." Said correction made on the Recorder's official copy. Councilman Coan then restated his objections in regards to the Lake Grove area zoning, stating he is in complete disagreement with the proposed zoning for this area. Mayor Stidd stated that this is a peculiar area in that you can't drive around the block. Pedestrian traffic is not, nor is contemplated to be, a prob- lem; that, in many respects, it is a roadside commercial Area.. The roadside commercial area concept was concurred in by all members present. Dr. Moore raised the question that there is ample acreage available for business expansion but that this is not the test. The real test for business property is the traffic flow. Question raised regarding Lot 146, Bryant Across Mr. Bean called to the atten- tion of the Council that the minutes of. the Lake Grove Zoning Commission for December 17, 1959 granted this property commercial zoning. It was therefore unanimously recommended by the Planning Commission and the Council that the zon- ing map be changed to include this lot in the commercial area. fi Councilman Thomas was worried about placing so many businesses in the Lake Grove area in a non-conforming situation. Mr. Bean explained the Planning Coumission's thinking by stating that the area was naturally contained. Upon requests for zone changes it could be developed in an orderly manner. Planning Commission members Roddy, Rohner, Couch() and Smith also entered into the discussion. PP 22-0001 ATTACHMENT B/PAGE 7 OF 12 II. The Administrative Assistant called to the Council°e attention a communication from Mr. E. F. Pearson pertaining to service stations. Councilman Thomas sug- Bested that service stations and drive-in restaurants should be' perrnitted as an additional use, and that this should be made a C. C. zone. City`:, Attorney replied that this would have to be general to all of'Lake Oswego. Councilman Thomas then rescinded his suggestion. After further discussion, it was the decision to change that area zone on the map of tho Lake Grove business dis- trict from C. C. to G.C., thus making the whole area toned red on the zoning map. Councilman Ross voted no, and the Mayor abstained. So ordered. Correc- tion made on the zoning map. Councilman Coen called to the attention of the Council the objection of the apartment owner on Pilk&ngton Road, his objection being to the proposed indus- trial zone. City :.ttorney stated that, under section 90, the zone could be enlarged, and .this decision should be left to the Planning Commission. Councilman Ross then went through the proposed zoning ordinance, wherein he.. had noted various questions. These were all answered to his satisfaction by members of the Planning Commission and the Council.ee It was the consensus of all conc:caxned that the off-street parking problem must be solved by establishing some standard that has flexibility. Mayor Stidd raised tha question of the containment of the C.C. zone in the central business area of Lake Oswego, and raised the question of the restricted L.C. zone on "A" Street. After considerable discussion, it was the decision of the Council and the recommendation of the Planning Commission to eliminate the L.C. zone from the proposed ordinance and to change that which shows zoned on the map as L.C. to C.C., to Sixth Street. 411 Mr. Bean submitted a communication from Mr. Leonard Murphy requesting the inclu- sion of a SR-20 zone. Said communication was noted and filed. Communication from Mr. Eckert requesting his property, as shown, to be changes, to C. C. This was authorized and the zoning map was changed accordingly. Verbal request from Mr. Fox for a zone change which he had previously submitted. Mr. Westling suggested to the Council that this should be handled as a zone change after the adoption of the ordinance. This met with Mr. Fox's approval and was so ordered. Administrative Assistant presented a communication from Mr. Mark Wald requesting the inclusion of an accounting office in the provisions of Section 35, subsec- tion 4. This was referred to the Planning Commission for future study. Administrative Assistant,called to the attention of the assemblage the communi • cation from the City of Portland containing a counter-offer to our letter of October 18th with regards to the treatment 'of sewage. Referred to Councilman Themes for financial analysis and report to the Council. There being no further business, the Council adjourned et 11'44 p.m. C'J Recorder PP 22-0001 ATTACHMENT B/PAGE 8 OF 12 S, III 410 October 24,,' 1961 Special meeting of the Council of the City of Lake Oswego convened at 7t34 p.m. on October 24, 1961. Present were Coen, Harmsen, Lawrence, Ross, Thomas and Mayor Stidd. Stewart excused on account of illness. Present from the Planning Commission were Chairman Bean, Smith, Bloodworth, Roddy and Reimer. Moved by Lawrence, seconded by Coen that the reading of the previous minutes be waived. Carried. Recommendation by Fire Chief O'Brien regarding the bid offering for the purchase of a fire truck which was submitted at the last regular Council meeting. His recommendation was made by letter which is attached to the official minutes and made a part thereof. Moved by Lawrence, seconded by Coan that the Council accept the Fire Chief's recommendation for the pw;chase of the Seagraves equip- 4. ment. Councilman Thomas inquired if the Seagraves offer was the low bid. Fire Chief O'BrienIIstatedno, that Coast Apparatus, Inc. was low bidder and their bid offer stated it was with no exception to the bid specifications. He counted eighteen exceptions. There was ona exception by Seagraves and, by applying all the factors involved, Seagraves then became the low bidder. Upon the question being called for, his recommendation was accepted unanimously and the award made to the Seagraves Corporation. 411 CITY ATTORNEY - L. Eugene Crampton Presented Resolution No. R-36-61 regarding the change of property between the City of Lake Oswego and the Oregon-Portland Cement Company. Councilman Lawrence inquired as to what was the monetary value involved' in this transaction. The Mayor replied that a rough estimate was around $35,000. It was then moved by Heresen, seconded by Coen that the resolution be adopted. Upon vote, it carried unanimously. 7:49 p.m. Public Hearing upon the n.tw zoning ordinance No. 781 held. Approxi- mately forty persons attended from•tee West end of the Lake, and the remonstran- ces from this area were considered first. There wore no written remonstrances on file with the Recorder from this portion of the City. qilikk.W S. Mr. Dority and Mr. Parvis, represented by Attorney Traeger, requested their property be included as commercial property. Mr. Bickel raised two objections to the new zoning ordinance (1) Lots 57, 58, 144, 145 and 146, Bryant Acres not included as commercial and (2) Lot 7, Bryant Acres, which has a service station upon it, should not be excluded as a non-conforming usage. Mr. Ken Lord objected to the zoning of all but one of the service stations in the Lake Grove area as non-conforming. 411 Mr. Neil Bosh, representative of the Shell Oi1. Company, objected to the non- conforming usage restrictions and claimed that service stations should be allowed to improve end expand. Councilman Lawrence posed the question whether service stations should be allowed es a permitted usage.PP 22-0001 ATTACHMENT B/PAGE 9 OF 12 Mr. Ken Parelius, Lots 2, 2, 4, and' 5, Lake View Villa, objected to his property-;' 111 being zoned non-commercial. Mr. James Smith called to the Council's attention Section 105 wherein they added 5 feet setback, claiming that it was unfair to change the setback lines. Chair- I man Bean of the Planning Canioission stated that this might have slipped by his Planning Commission, and he will re-study this problem and report his findings' to the Council. Mrs. Frank French objected to the provision making service stations nonconform- ing. Mrs. Lawrence Schroeder spoke in support of the non-conforming provision. She also called to the Council's attention the unsightly condition of Mr. Bickel's property, wherein he had done some bulldozing work and had never completed his job, thereby creating an eye-sore. Councilman Thomas asked.Mrs. Schroeder if she thought this area of which she complained should be zoned coauerciel. She replied that she would like to see it residential, and that the mess should be cleaned up. She also stated that multiple use would be more desirable than comtiercia l. Mr. Edward Gary, a member of the Lake Grove Zoning District, inquired as to where the industrial park was to be located, and what type of industry would be located there. The Mayor asked Chairman Bean to explain; he stated that this would be an area that is closely contained by natural boundaries, and the type of industries that could be located there are listed in the proposed'zoning ordinance. Mr. Lawrence Schroeder stated he would not like to see Boones Ferry Road become a second Barbur Boulevard because it would create a traffic hazard. He also ob)ects to Mr. Bickel's request. Mr. Wayne Brouse, a member of the Lake Oswego Zoning Commission, inquired as to the keeping of horses in the city limits. Chairman Bean replied that the land area required is spelled out in the proposed ordinance. Mr. Pox inquired in regards to his property. Chairman. Bran replied his property would be acted upon favorably when it was formally requested. Mr. Kelly suggested that there should be an R•20' provision (20,000 square foot lets). Council will take this under consideration. Mr. Schultz inquired what is an agricultural area. Chairman Bean replied 5 acres or more, and this is for assessment purposes only and has no application to the zoning ordinance. There being no further inquiries or objections from the residents of the West end of the Lake, this portion of the hearing was terminated at 905 p.m. At 9141 p.m. Council reconvened to consider the objections .from the East and of the Lake. Sixteen persons were in attendance at this session. There were written remonstrances on file with the Recorder from C. F. Pearson and Mr. and 411 Mrs. Allen W. Morris. These are attached and made a part of the official minutes. Mr. John Conglin, attorney, appeared for Mr, and Mrs. Morris. City Attorney Crampton, commenting upon Mr. Morris' request for a N.C. zoning, thought it should be C. C. Councilman Hormson stated he thought Mr. and Mrs. Morris' re- quest is reasonable. PP 22-0001 ATTACHMENT B/PAGE 10 OF 12 P r 11 4 Mr. Bert Sleeman, objecting to the zoning on "A" Avenue, stated that he thinks the C. C. zone should be extended to Tenth Street. The Mayor asked Mr. Sleeman if he believed in buffer zones. He replied he does, but the C.C. zone is not big enough. Councilman. Lawrence asked Mr. Sleeman what happens when you extend • the C. C. zone further and further out. He stated that the homes in this area are not an asset up to Ninth Street, and it should be all C.C. Councilmen Thomas asked Mr. Sleemen if he advocated extending the C.C. to Tenth. Mr. Sleeman replied no, only to Sixth, then L.C. to Tenth. The Mayor inquired es to extending the C.C. zone to "C" Street. Mr. Sleeman is not sure as to this extension because he is not informed as to the street plan, but thinks that, in the area suggested, that the town could grow. Mr. Felix F. Fors supported Mr. Pearson and Mr. Sleeman's objections. The Mayor inquired as to why multiple housing in the C.C. zones should be kept . in multiple housing. Chairman Bean replied it would be a mistake to allow large structures to be in the C.C. zone as they would be non-conforming. The Mayor then asked if these apartment houses wanted to be commercial, and-Mr. Bean replied that he couldn't give a definite answer. The Mayor inquired if there was any provision for one-night occupancy In the L.C. zone. Commission member Bloodworth answered that this would be a non-conforming use. Councilman Lawrence inquired as to the importance of the zoning map. The City Engineer replied that the map hae the same importance as an ordinance. Coun- oilman Lawrence also called to the attention of the council that the map evi- dently is in error and that the N.C. zone should be changed on the map from Hemlock to Pine Street. This will be checked by the City Engineer and, if in error, corrected. There being no more questions or objections from the audience, the Mayor ordered the public hearing continued to a later date. At this time Councilman Coon said that he was in complete oppusition to the proposed zoning ordinance as it pertained to the Lake Grove business area, stating that said' ordinance would zone out as non-conforming approximately of the business in that area. After discussion between the Council and the Planning Coons Sion, it was deter- mined that the two bodies would meet on November 1 at 700 p.m. to jointly die- . cuss some of the problems brought out in this hearing. At 10842 p.m. the hearing was continued to a later date and the meeting adjourned. At 10143 p.m. Council reconvened for the purpose of considering the September ex- penditures. It was than moved by Councilman Thomas, seconded by Councilman Coen that the September expenditures in the amount of $73,732.64, es shown by the recap which is attached, be .•r,pruved for payment. Upon roll call vote, carried unanimously. Meeting adjourned at 10145 p.m. City Recorder PP 22-0001 ATTACHMENT B/PAGE 11 OF 12 THE MINUTES FOR ALL OF 1960 AND THE FIRST HALF OF I96I WERE LOST DURING THE MOVE OF CITY HALL FROM 40 "A" AVENUE TO 348 N . STATE STREET . A THOROUGH SEARCH WAS MADE OF ALL CITY DEPARTMENTS, WITH NO SUCCESS , HELEN D , BUSH CITY RECORDER PP 22-0001 ATTACHMENT B/PAGE 12 OF 12 Climate-Friendly & Equitable Communities (CFEC) Code Amendments Rulemaking Updates & Extension Request [Jun 2022 – Jul 2023] Council Study Session #1 Jun 21, 2022 Planning Commission Update #1 Jun 27 Planning Commission Update #2 Jan 9, 2023 Planning Commission Work Session #1 Jul 24 Work Plan / Public Involvement Plan / Scoping [Aug – Sep 2023] Council Study Session #2 Sep 5 Planning Commission Work Session #2 Sep 25 Evaluation of Parking Alternatives [Oct – Dec 2023] Planning Commission Work Session #3 Nov 27 Council Study Session #3 Dec 5 Initial Concepts / Recommendations [Jan – Mar 2024] Council Study Session #4 Feb 6, 2024 Planning Commission Work Session #4 Feb 26 Community Forum / Public Workshop Mar 7 Refined Parking Concepts [Apr – May 2024] Council Study Session #5 May 7 Planning Commission Work Session #5 May 29 Draft Code Amendments [May - Aug 2024] Council Study Session #6 Aug 20 Planning Commission Work Session #6 Aug 26 Final Code Adoption [Sep – Dec 2024] Planning Commission Public Hearing Oct 14 Planning Commission Findings Oct 28 City Council Public Hearing Nov 19 City Council Findings Dec 3 Effective Date: Jan 2, 2025 Rulemaking Updates & Extension Request [Jun 2022 – Jul 2023] CFEC CC-SS #1 Jun 21, 2022 CFEC PC Update #1 Jun 27 CFEC PC Update #2 Jan 9, 2023 CFEC PC-WS #1: Review of Rules / Options Jul 24 Work Plan / Public Involvement Plan / Scoping [Aug – Sep 2023] CFEC CC-SS #2: Work Plan / Public Involvement / Scoping Sep 5 CFEC PC-WS #2: Work Plan / Public Involvement / Scoping Sep 25 PP 22-0001 ATTACHMENT C/PAGE 1 OF 2 Page 2 Evaluation of Parking Alternatives [Oct – Dec 2023] HPS Task Force Meeting #4: Contextualized Housing Need Oct 20 HPS CC-SS #4: Contextualized Housing Need Nov 7 HPS PC-WS #4: Contextualized Housing Need Nov 13 CFEC PC-WS #3: Evaluation of Parking Alternatives Nov 27 CFEC CC-SS #3: Evaluation of Parking Alternatives Dec 5 Initial Concepts / Recommendations [Jan – Mar 2024] HPS Task Force Meeting #5 Housing Strategy Alternatives Dec 8 HPS PC-WS #5: Housing Strategy Alternatives Jan 8 HPS CC-SS #5: Housing Strategy Alternatives Jan 16 CFEC CC-SS #4: Initial Concepts / Recommendations Feb 6 CFEC PC-WS #4: Initial Concepts / Recommendations Feb 26 Community Forum / Public Workshop Event Mar 7 Refined Parking Concepts [Apr – May 2024] HPS Task Force Meeting #6: Initial Recommendations 1 Feb 9 HPS Task Force Meeting #7: Initial Recommendations 2 Mar 22 HPS Community Forum / Public Workshop Event Apr 4 HPS CC-SS #6: Initial Recommendations Apr 30 HPS PC-WS #6: Initial Recommendations May 13 CFEC CC-SS #5: Refined Parking Code Concepts May 7 CFEC PC-WS #5: Refined Parking Code Concepts May 29 Draft Code Amendments [May - Aug 2024] HPS Task Force Meeting #8: Review Draft HPS Report Jun 14 HPS CC-SS #7: Review Draft HPS Report Jul 16 HPS PC-WS #7: Review Draft HPS Report Jul 22 Draft Code Amendments + Internal Review May 30 – Jul 19 CFEC CC-SS #6: Draft Code Aug 20 CFEC PC-WS #6: Draft Code Aug 26 Adoption of Code Amendments [Aug – Dec 2024] Final HPS Report Aug 2 Final Code Amendments Sep 2 DLCD Notice Sep 9 HPS PC Public Hearing (PC-PH) Sep 9 HPS PC Adoption of Findings Sep 23 Planning Commission Public Hearing (PC-PH) Oct 14 HPS City Council Public Hearing #1 (CC-PH) Oct 15 PC Adoption of CFEC Findings Oct 28 HPS City Council Public Hearing #2 (CC-PH) Oct 29 HPS Council Adoption of Findings Nov 5 City Council Public Hearing (CC-PH) Nov 19 + Adoption of Findings Dec 3 PP 22-0001 ATTACHMENT C/PAGE 2 OF 2 PARKING MANDATES ARE VANISHING ACROSS OREGON Six months into the pioneering state policy, regulatory costs are falling and projects are springing to life. Author:Catie Gould (@Citizen_Cate) on June 30, 2023 at 2:34 pm Update 7/20/23: Beaverton, the state’s seventh-largest city, unanimously voted to join the club and remove mandatory parking citywide. In cities across Oregon, parking mandates are going out not with a bang, but a whimper. “It’s sort of been a sleeper issue here,” said Anne Catlin, the comprehensive planning manager for Albany, Oregon. When Albany repealed minimum parking requirements citywide earlier this June, not a single person from the public testi ed. Catlin didn’t recall the topic even making the newspaper. Normally, parking is one of the most contentious issues for local governments. Any relaxation of parking mandates—rules that prescribe a certain minimum number of parking spaces for any new home or business—is a political hot potato. But new state parking rules have taken that status quo o the table and turned what could be a big debate into a boring compliance exercise. “There really isn’t much to provide input on,” said Sandy Belson from the City of Spring eld. “We’re just going to comply with the rules.” By June 30, a ected jurisdictions could choose to either eliminate all parking mandates or enact a host of more complicated regulations if they wish to retain minimums in some instances. The two other compliance paths include regulations ranging from pricing one in ten on-street parking spaces, to separating the cost of parking from rent, to creating parking bene ts districts. All of which would take additional sta time and oversight. Planners for the City of Salem summarized the new rules succinctly in this image: At least seven cities have voted to go with the simple but sweeping Option 1: Portland, Salem, Corvallis, Tigard, Bend, Albany, and Central Point. Now over a million Oregonians live in communities where parking is fully voluntary. More cities are poised to join them the next year, after using a deadline extension granted by the state. TRANSIT PROXIMITY ALREADY REMOVED PARKING MANDATES FROM MAJORITY OF LOTS Removing all parking minimums wasn’t the dramatic leap it would have been a year ago. Last January, state rules lifted parking mandates for all properties within a half-mile of frequent transit corridors and within three-quarters of a mile of rail stations. City-generated maps have revealed that those areas constitute the majority of lots in many cities. In Corvallis, those transit-adjacent areas covered 65 percent of the city. For Gresham, 53 percent. In Tigard, 62 percent. The slivers of city not included were likely to be low-density residential neighborhoods, industrial land, or open space. “Most of our city falls within a half-mile of our transportation corridor,” Catlin said. “It was an easy decision.” Summary of policy options presented to the Salem Climate Action Plan Committee by city sta . City of Salem. PP 22-0001 ATTACHMENT D/PAGE 1 OF 6 In Corvallis, city planners recommended removing all minimums because bus service can change over time. If transit service were downgraded, building owners might suddenly nd themselves needing to add more parking to stay legal. Service-dependent rules could also give residents who like parking mandates a reason to oppose transit upgrades, thereby deepening transportation inequities. Transit service changes are already putting zoning maps in ux. A planned improvement to bus line 71 in Milwaukie this upcoming September would have increased the fraction of the city without minimum parking requirements from 78 percent to 95 percent. Rather than keep adjusting things, they plan to fully eliminate parking mandates later this year. In addition to areas near transit, the state has also done away with parking mandates for a long list of uses for equity reasons, including for a ordable housing, small residences, childcare facilities, and more. Those rules will give more exibility to housing projects like a senior care facility that had its expansion plans scuttled over two parking spaces last year. STATE RULES REDUCE BARRIERS TO NEW BUSINESSES Local governments are often well aware of the speci c sites, like oddly shaped lots or old buildings, where parking minimums pose barriers to redevelopment. But before Oregon’s state rules, they didn’t have a lot of options for reforming those counterproductive codes without an arduous political process. One di cult property is a former restaurant in downtown Central Point, a small city outside Medford, that closed before the pandemic. After any six-month gap in use, city law requires any new user of the building to comply with current land use code, even if it hadn’t been up to code before. Albany, OR PP 22-0001 ATTACHMENT D/PAGE 2 OF 6 That is no small task for this site since the current gravel lot wouldn’t meet the city’s requirements for a parking lot. “Anybody who purchased this property and developed it would be required to pay for the parking lot, have it striped, landscaped accordingly, and then provide the required stormwater quality and quantity management facilities,” said Stephanie Holtey, planning director for the city of 20,000. “The improvements for those facilities are pretty expensive.” The planning department was planning to amend the code to give downtown properties like this relief from parking minimums, but with only two planners on its sta , the city couldn’t have started a process to consider various possible code changes until 2024. But now, the mandates are simply gone and the job is done. The City of Tigard was Oregon’s rst to o cially repeal mandates citywide back in January. Tigard had already exempted some areas of the city, like downtown and the Tigard Triangle, from parking requirements. But elsewhere, parking minimums have still regularly caused headaches for Tigard. They can be a particular problem for commercial buildings whose parking lots are stuck at the same size as di erent businesses come and go over the years. One of those businesses is owned by Jordan Elting. Obsessed with arcade games since he was a kid, he nally opened a brick-and-mortar arcade in February of 2022. It didn’t take long for the customers to start asking if they served beer. They didn’t. But demand was high enough that Elting put in his application for a state liquor license soon afterward. For nearly a year, his application couldn’t be approved because the new building use, now categorized as entertainment, required roughly 40 percent more parking than the former retail store that vacated the space two years prior. Meanwhile, Elting was watching potential revenue walk out his door. Later in the evenings, groups of adults would sometimes take o after learning there was no beer. Elting pointed out that several other businesses in the strip were already allowed to serve alcohol, and there was a second parking lot on the other side of the building that was always empty. The entire situation ba ed Elting. “I’ve never understood what they expected to change here.” This empty 1964 building has a non-conforming parking lot, adding a barrier to re-use. Image by Loopnet. Tigard Plaza. Photo by Catie Gould. PP 22-0001 ATTACHMENT D/PAGE 3 OF 6 Elting attempted to chase down documents from his landlord so the city could sign o on his application. But his issue remained unresolved when Tigard voted in December to eliminate its parking minimums citywide. “I honestly didn’t know how I felt about it when I rst read it,” Elting re ected on a news article he had seen about the parking change in Tigard. But then the city planning department called to tell him the paperwork wasn’t needed anymore. “All right, I guess that’s what it meant,” said Elting. “That got rid of what I see as absolutely ridiculous red tape. Obviously, it ends up being a good change for businesses.” The public may save money, too. Schuyler Warren, a senior planner for the city, estimated that no longer having to work through cases like Elting’s will free up about 12 hours a week for city sta to put toward other initiatives. LOCAL OPPOSITION REMAINS Many city o cials don’t like Oregon’s new rules, which the state called “Climate-Friendly and Equitable Communities,” or CFEC for short. “Horrible name, horrible changes,” Millersburg Community Development Director Matt Straite described the CFEC program to that city’s planning commission in June. “We feel like they’ve really reached down from Mount Olympus and forced cities to do things they don’t want to do.” It’s a common sentiment among Oregon cities. Fourteen local governments led a lawsuit last fall that challenges procedural issues with the state’s rulemaking process. The case is still pending. OUR WORK IS MADE POSSIBLE BY THE GENEROSITY OF PEOPLE LIKE YOU! Thanks to Clay Veka for supporting a sustainable Northwest. Donate Today “This pretty much sucks, putting it bluntly,” Corvallis City Councilor Laurie Chaplen said in a hearing last October as she voted to comply with the new state law by repealing all parking minimums. Part of the issue is that the statewide relaxation of parking minimums is just one rule in a larger adopted package. Other mandatory parking reforms include requirements for bicycle parking minimums, electric car charging, and tree canopy coverage. That is in addition to designating climate friendly areas in larger cities and changes in transportation planning. As a whole, the package has been criticized as overly prescriptive. This month, the agency received an additional $2.7 million in funding to assist cities with implementation costs—an unusually large sum, but far less than cities said they’d need. In an e ort to meet them partway, the state agency in charge, the Department of Land Conservation and Development, relaxed some rules this April. For example, the state reduced its standard for the mandatory amount of tree shade over large parking lots: 40 percent canopy coverage, down from 50 percent. A BOOST FOR MIDDLE HOUSING The additional exibility over parking spaces has been particularly helpful for projects that add more homes to existing lots. In Ashland, a fourplex is using the state’s new exibility to trade a couple of parking spaces for other outdoor amenities. In 2022, the four two-bedroom homes would have required seven parking spaces. “We could have made it work on this site,” said architect Tom DeVore, “but there are trade-o s.” After the rules were adopted in July, DeVore got together with his clients and asked, if it’s up to us, how much parking do we want to provide? “It just opens up so many more possibilities of what you can do on-site,” DeVore said. “Parking just takes up so much space.” Jordan Elting at his business, Reset Button Arcade, in Tigard. Photo by Catie Gould. PP 22-0001 ATTACHMENT D/PAGE 4 OF 6 RECOMMENDED READING Four Ways to Improve Portland’s Housing A ordability Mandate August 1, 2023 Oregon’s Land Use Law Creates Wild re- Adapted Communities July 25, 2023 From Vermont to Oklahoma, Legislatures Challenge Parking Mandates July 20, 2023 Ultimately, they determined that Ashland renters would expect at least one parking spot for each household. Trimming their design from seven parking spaces to ve allowed them to add a play area for children, shared gardens, and a larger shared patio. They plan to break ground in July. Dylan Lamar, another small-scale builder located in Eugene, called the state action a blessing. “Thank god for CFEC,” he said. Lamar, who describes himself as a market-rate developer, aims to provide housing a ordable to anyone making the median income and currently has two small projects in the works. Without any subsidy, he estimates his homes would sell for $210,000—half the price the typical detached home in Eugene. Lamar recently won a grant from the city for his rst a ordable housing development, targeting rst-time Latino homeowners in the area. The four new homes will be sold for about $115,000 apiece, with one of them being fully accessible. Referred to as “grow homes,” three of them will have an un nished attic to which the future homeowners can add more living space later on. None of the homes will have a dedicated o -street parking spot. These are exactly the type of projects Oregon hoped to create when it legalized “middle housing”—from duplexes to cottage clusters—in 2019. But though the housing types were now legal, even modest parking minimums could constrain sites too much to build. Lamar has no interest in tearing down the 1950s ranch house on his site, but it currently runs 8 feet away from the property line, too narrow for a driveway. Thanks to the new state rules, he didn’t have to worry about that. The back lot homes won’t have on-site parking, and future buyers will simply use a sidewalk to reach their cars on the street. Despite the project getting a top score from city sta recommending funding, city council wrung their hands over the lack of parking. The state rules have made these types of debates moot, tipping the scales in favor of more housing for more neighbors. “I have 100 percent con dence this project would not have happened if the state had not taken action, both on middle housing and on CFEC,” said Lamar. Grant Street Grow Homes will add these four new homes to an existing backyard. Image by Cultivate. Catie Gould Senior Researcher, Transportation PP 22-0001 ATTACHMENT D/PAGE 5 OF 6 Visit Sightline Daily for the day’s top headlines for Cascadia each Monday, Wednesday, and Friday, curated by the news editors of Sightline Institute. See our picks here Boise Poised for First Step Towards More Abundant, A ordable Housing June 9, 2023 Getting Beyond the Detached House in Vancouver, BC June 7, 2023 For press inquiries and interview requests, please contact Serena Larkin Sightline Institute is a 501(c)3 non-pro t organization and does not support, endorse, or oppose any candidate or political party. You can power us forward on sustainable solutions. Make a donation to Sightline now. Tagged in: CFEC, climate-friendly and equitable communities, Parking, Small Businesses © 2023 Sightline Institute. All Rights Reserved. PP 22-0001 ATTACHMENT D/PAGE 6 OF 6 Staff Report – CFEC Work Session #1, 07/14/2023; due to document size, please find the document Online at: https://www.ci.oswego.or.us/WebLink/DocView.aspx?id=2515055&dbid=0&repo=CityOfLakeOswego PP 22-0001 ATTACHMENT E/PAGE 1 OF 1 Implementation Guidance OAR 660-012-0405 Parking Regulation Improvements Updated to reflect temporary rules adopted April 20, 2023, effective May 12, 2023 for up to 180 days. Staff expect those rules generally to be made long-term rules at the November 2023 commission meeting. Application and Deadline for Action Cities and counties in Oregon’s metro areas are required to adopt comprehensive plan amendments and land use regulations to meet the requirements in OAR 660-012-0405 no later than June 30, 2023. (OAR 660-012-0012) Cities and counties may request an alternative deadline under OAR 660-012-0012(4), and cities under 10,000 population may request whole or partial exemptions under OAR 660-012-0100(4). Discussion OAR 660-012-0405(1): Cities and counties shall adopt land use regulations as provided in this section: (a)Designated employee parking areas in new developments shall provide preferential parking for carpools and vanpools; (b)Property owners shall be allowed to redevelop any portion of existing off-street parking areas for bicycle- oriented and transit-oriented facilities, including bicycle parking, bus stops and pullouts, bus shelters, park and ride stations, and similar facilities; and (c)In applying subsections (a) and (b), land use regulations must allow property owners to go below existing mandated minimum parking supply, access for emergency vehicles must be retained, and adequate parking for truck loading should be considered. This rule carries over and slightly expands requirements from the previous Transportation Planning Rules. Cities and counties likely have provisions conforming with (a) and the transit provisions of (b), which can be updated to include the bicycle portions of (b). Subsection (c) clarifies some standards and limits to (a) and (b). OAR 660-012-0405(2): Cities and counties shall adopt policies and land use regulations that allow and encourage the conversion of existing underused parking areas to other uses. This rule is intended to minimize the opportunity cost of parking by encouraging other beneficial uses to take its place, especially in situations where parking is underused. The primary intent is for conversion of on-street parking. Envisioned uses for conversion include parklets (installations providing protected space for gathering), bicycle parking, and vegetation/soft-scape areas. Application of this rule to off-street parking areas is also encouraged, for items such as food carts or parklets. PP 22-0001 ATTACHMNET F/PAGE 1 OF 13 There is not a specific definition of ‘underused’ in this rule. Underuse can be evaluated on a block or district basis. This can allow for conversion of frequently occupied spaces abutting storefronts if there are other underutilized spaces in the vicinity. Underuse of off-street parking areas is more likely to be determined by a property or business owner who observes actual parking demand and use of spaces. One study of repurposed parking found restaurant and bar revenue grew 19% when they were allowed to redevelop parking. Policies: Jurisdictions should adopt policies pursuant to this rule into their Transportation System Plan. Many jurisdictions include a parking chapter or element, and DLCD suggests this would be the most appropriate location for such policies. Policies should be enacted allowing conversion of parking spaces in the right-of-way. There should be a clear, consistent, and easy application process for parking conversion requests. Jurisdictions are encouraged to proactively identify underused on-street parking that can be converted to active uses. Nothing in this rule is intended to limit jurisdiction’s ability to limit the number of converted spaces in an area or district, retain an appropriate supply of ADA spaces, or to decline requests that may pose a safety hazard. Land Use Regulations: DLCD does not expect the use and conversion of on-street parking spaces to be governed by land use regulations, per ORS 197.015(10)(b)(D). Jurisdictions are encouraged, but not required, to address conversion of off-street parking spaces in their development code. See the Additional Recommendations section for suggestions regarding land use regulations to encourage conversion of underutilized off- street parking spaces. OAR 660-012-0405(3): Cities and counties shall adopt policies and land use regulations that allow and facilitate shared parking. Shared parking is a frequently used smart development strategy that minimizes the amount of land devoted to automobile parking and the costs to businesses and local builders. This rule ensures this practice is allowed within metropolitan areas. Many development codes may already allow the use of shared parking to satisfy parking mandates, and few, if any, amendments will be necessary. Policies: Jurisdictions should adopt policies pursuant to this rule into their Transportation System Plan. Many jurisdictions include a parking chapter or element, and DLCD suggests this would be the most appropriate location for such policies. It may be appropriate to restate adopted policies in a purpose statement that precedes implementing regulations. Land Use Regulations: Jurisdictions should amend the development regulations to allow shared parking to satisfy applicable parking mandates. Land use regulations will be compliant with the ‘facilitate’ provision of this rule if the shared parking process does not involve applicability limitations, approval criteria, or an application process that of discourages shared parking through unreasonable cost or delay. See the Additional PP 22-0001 ATTACHMNET F/PAGE 2 OF 13 Recommendation section below for rules that jurisdictions may chose to implement to broaden opportunities for shared parking. The department expects to consider jurisdictions opting to repeal parking mandates pursuant to OAR 660-012-0420 in compliance with this section. That action removes the burden on builders and businesses to meet parking mandates. However, jurisdictions interested in most efficient use of land may consider actions to assist with shared parking, such as providing data to landowners and businesses about underused parking spaces through utilization studies. OAR 660-012-0405(4): Cities and counties shall adopt land use regulations for any new development that includes more than one-half acre of new surface parking on a lot or parcel as provided below. Jurisdictions must establish standards that are applicable to a lot or parcel that has more than ½ acre of surface parking (21,780 square feet). This is approximately 70 or more parking spaces for typical parking lot design. This rule is intended to be a cumulative calculation for all new surface parking on a lot (e.g. rule applies if site has two ¼ acre parking areas serving the development). These standards should also apply to any new parking area more than ½ acre in total even if it spans multiple properties with less than ½ acre on any individual lot or parcel. This situation may arise in developments such as a shopping center with parking areas shared between buildings on individual parcels. Temporary rules in April 2023 clarify the regulations in this rule are applicable to new parking. Jurisdictions may use existing definitions or thresholds in their code for what constitutes new development. Parking installed over an area previously used for parking should be considered ‘new’ if the older asphalt or pavement has been excavated. Parking areas are not considered ‘new’ if the existing asphalt or pavement is left in place (surface repairs and resurfacing/overlays allowed). Calculating the ½ acre threshold should be based on the area measured around the perimeter of all new parking spaces, maneuvering areas, and interior landscaping. The department recommends reviewing OAR 660-012-0330(4) when revising development code requirements for parking lots. That rule establishes requirements for vehicle parking lot placement and design in commercial and mixed-use districts, including climate-friendly areas. OAR 660-012-0405(4)(a): “Developments must provide one of the following:” DLCD considers the rules in OAR 660-012-0405(4)(a) to allow local governments to craft code to ensure compliance with at least one of the options in (A) through (C) of the rule. While all three options are supported by the department, local jurisdictions have the option of providing just one or two of the options if they so wish. The department recommends local governments give public buildings the compliance option of meeting OAR 330-135-0010. PP 22-0001 ATTACHMNET F/PAGE 3 OF 13 OAR 660-012-0440(4)(a)(A): “Installation of solar panels with a generation capacity of at least 0.5 kilowatt per new parking space. Panels may be located anywhere on the property. In lieu of installing solar panels on site, cities may allow developers to pay $1,500 per new parking space in the development into a city or county fund dedicated to equitable solar or wind energy development or a fund at the Oregon Department of Energy designated for such purpose” This option has two parts. The first provision allows installation of solar panels on a property (on a building, over a parking lot, or on vacant land. The second provision allows a fee-in-lieu payment into a fund. Some Oregon cities (Vernonia, Klamath Falls, Roseburg, Albany) have had fee-in-lieu funds set up as an option to providing off-street parking; cities can set up a similar, separate fee-in-lieu system to be used for equitable solar or wind energy development projects. The Oregon Department of Energy has had such dedicated funds in the past, and DLCD is working with ODOE on the ability to accept payments. If your jurisdiction is interested in the fee-in-lieu option through ODOE, please let DLCD staff know. OAR 660-012-0405(4)(a)(B): “Actions to comply with OAR 330-135-0010” This option was written only to apply to public buildings already meeting green energy requirements in state law and rule. Those spending the 1.5% on green energy need not take additional steps under this subsection. The department strongly recommends this provision be codified and available as a compliance option for public buildings. The required expenditure on green energy furthers the objective to mitigate the climate impacts of large parking lots. OAR 660-012-0405(4)(a)(C): “Tree canopy covering at least 40 percent of the new parking lot area at maturity but no more than 15 years after planting.” The department recommends determining parking lot area by measuring all surface area on which a vehicle is designed to maneuver/on which a vehicle can drive, including all parking stalls, all drives and drive-through lanes within the property regardless of length, and all maneuvering areas regardless of depth. Jurisdictions can set reasonable exemptions for paved areas not for use by passenger vehicles (such as loading areas or outdoor storage of goods or materials). This calculation method differs from the calculation for the ¼ acre threshold. Excluding some areas for this portion of the rule is recommended to make the 40% standard practicable to achieve. To determine canopy coverage, jurisdictions must calculate the expected diameter of the tree canopy 15 years after planting. The 15-year time period applies regardless of whether the tree will be mature at that time. Jurisdictions may want to adopt an approved list of parking lot trees. Existing street tree lists may be a good starting point for creating such a list. It may be best to consult a list of expected canopy diameter at 20-years, as trees are usually at least 5 years old at planting, and not just canopy diameter at maturity. Existing mature trees that are preserved can be counted at their existing diameter. PP 22-0001 ATTACHMNET F/PAGE 4 OF 13 Tree cover should be measured from a plan view of the tree planting plan and expected canopy diameter at 15 years after planting. The rule does not require and is not intended to be based on calculation of tree shade (i.e., taking into account the amount of shade cast on a given date and time of day by the 3-dimensional canopy). Area under the canopy that is either paved surface or parking landscaping (interior or perimeter) should be counted toward meeting the coverage standard. Note that counting tree canopy over landscaped area will give credit for tree canopy coverage to areas that are not counted as parking lot area. A significant percentage of a tree’s canopy will necessarily cover landscaped area. This methodology makes the 40% standard more broadly achievable. Canopy that covers structures should not be counted toward meeting the coverage standard. It is acceptable to count tree canopy that covers unenclosed carports over parking spaces, such as those found in multi-dwelling developments. Jurisdictions should not double-count coverage area if there is significant overlap in canopies. The department recommends the full area based on the 20-year crown diameter be counted for tree coverage where there is an overlap of 5 feet or less (measurement to be the length of a line segment within the overlap area of a line between tree trunk/canopy centers). Example site plan providing parking lot shading in excess of 40% (source: City of Pleasanton, CA) OAR 660-012-0405(4)(b): “Developments must provide either trees along driveways or a minimum of 30 percent tree canopy coverage over parking areas. Developments are not required to provide trees along drive aisles. The tree spacing and species planted must be designed to maintain a continuous canopy, except when interrupted by driveways, drive aisles, and other site design configurations; and” PP 22-0001 ATTACHMNET F/PAGE 5 OF 13 This rule was amended in the temporary rule amendments adopted in April 2023. Compliance with this rule now has two options. As with other requirements within OAR 660-012-0405(4), this rule applies only to new parking areas. DLCD considers the rules in OAR 660-012-0405(4)(b) to allow local governments to craft code to ensure compliance with at least one of the options in the rule. While codification of both options are supported by the department, local jurisdictions have the option of providing one or the other if they choose. For the first compliance option, street trees are required along driveways serving new parking areas. “Driveway” and “drive aisles” are not specifically defined in the rules. The intent of these rules is to require tree canopy along major travel routes through a site. The typical characteristics of a driveway and drive aisle are as follows: Driveway Drive aisle • provides access to and from the surrounding streets, and connections through the site to buildings and parking lot drive aisles • does not provide direct access to parking stalls, or provides access to a limited number of parking stalls (only along a portion of its length; only on one side) • usually intersect with multiple other driveways and drive aisles along its length • a vehicular access bordered by parking spaces, • primarily serves as access to those adjoining parking spaces • will have few or no intersections, with the exception of T- intersections, usually with abutting drive aisles Parking lot driveways (blue) and drive aisles (orange) A development code will comply with this rule if a continuous canopy of street trees is required along a maneuvering area that meets the general description of a driveway. PP 22-0001 ATTACHMNET F/PAGE 6 OF 13 The second option for compliance is if the new parking lot area provides at least 30% canopy coverage. The calculation for this canopy requirement is the same as for the 40% coverage option in OAR 660-012-0405(a)(C) above. The continuous canopy requirement applies to trees planted either to meet either the street trees along a driveway option or the 30% requirement canopy coverage option. The rationale behind the ‘continuous canopy’ requirement is that trees are healthier when planted in continuous groups with continuous root zones. To the extent possible, developments should plant continuous trees in a shared trench. The rule does not require all tree canopy on a site be continuous, as drive aisles and other design considerations will necessitate breaks between planted areas. However, trees should not be isolated into disconnected individual planters. Parking lot lighting should be designed to work with a continuous tree canopy to the extent possible. Placement of lighting in a landscaped island (alongside parking spaces) can help to avoid breaks in the canopy of a parking area median (landscape strip between parking rows). One approach to implement the continuous canopy requirement is to require groupings of at least three trees with a continuous canopy before any break of more than 3 feet is allowed. Canopy spacing should be measured based on the expected diameter of the tree crown at 20 years old. This rule does not prohibit trees planted in individual interior landscape islands but does not count the canopy of such trees toward meeting requirements of this rule. This practice is not encouraged for parking lot design. OAR 660-012-0405(4)(c): “Developments must provide pedestrian facilities between building entrances and pedestrian facilities in the adjacent public right-of-way.” Street-like features were an element in the previous Transportation Planning Rules (OAR 660-012-0045(5)(d)(E), prior to 2022) and may be in existing codes. An earlier version of this rule that addressed pedestrian facilities, curbs, and building placement along driveways was part of the initial CFEC amendments in Jul 2022. The rule was amended with the temporary rules adopted in April 2023 and now addresses only pedestrian facilities. Pedestrian facilities should consist of a minimum 5-foot-wide paved path that is separate from vehicular traffic (either vertically with a curb and/or horizontally with a landscape or similar buffer). Pedestrian facility crossings at intersections with drive aisles and other driveways should be demarcated, preferably by a raised surface that slows vehicular travel, or by different surface materials. Crossings demarcated only by striping are discouraged in that they have not been demonstrated to be safe or effective for pedestrian protection. The pedestrian facilities should be illuminated to at least the same level as the on-site driveways and public right-of-way. PP 22-0001 ATTACHMNET F/PAGE 7 OF 13 Routing of the pedestrian facilities from building entrances to the public right-of-way should be as direct as possible. Driveway crossings should be minimized, and the placement of buildings and their entrances should minimize pedestrian travel distances where possible. The main building entrances should also be located on the façade of the building that abuts the pedestrian facility. Secondary entrances from the parking area are discouraged, as they decrease foot traffic and activity along the intended primary pedestrian facility. Street-like features along parking lot driveways. Many jurisdictions likely have existing site design requirements that address this rule. Implementation of this rule will need to have a review path for residential development that involves clear and objective standards. OAR 660-012-0405(4)(d): “Development of a tree canopy plan under this section shall be done in coordination with the local electric utility, including pre-design, design, building and maintenance phases.” Existing and newly planted trees are particularly susceptible to being damaged during site development. Existing trees may be damaged by inadequate protection or improper attention to utility infrastructure installation. Underground utility infrastructure can also compromise the health of newly planted trees if adequate spacing isn’t provided. This rule is intended to ensure tree health is given specific consideration in the site planning and development process. Jurisdictions shall adopt requirements for an applicant to coordinate with the electric utility provider during the project phases identified in this rule. Coordination with other utility providers is also encouraged. PP 22-0001 ATTACHMNET F/PAGE 8 OF 13 Verification of compliance can be provided by documentation from the electric utility provider and an applicant’s licensed landscape architect or arborist certified by the International Society of Arboriculture. The jurisdiction is responsible only for establishing a coordination requirement and verifying compliance with the standard, not for directly performing or facilitating the coordination. Jurisdictions are encouraged to create a list of trees appropriate for a range of available planter widths and overhead utility constraints in parking lots. This list should be created in coordination with utility providers. The list can be an initial resource for applicants and developers, but does not alone satisfy the coordination requirements for this rule. The preservation and survival of trees depends on an integrative process that considers tree health within the context of the site development process and site conditions after development. OAR 660-012-0405(4)(e): “In providing trees under subsections (a) and (b) the following standards shall be met. Trees must be planted and maintained to maximize their root health and chances for survival, including having ample high-quality soil, space for root growth, and reliable irrigation according to the needs of the species. Trees should be planted in continuous trenches where possible. The city or county shall have minimum standards for planting and tree care no lower than 2021 American National Standards Institute A300 standards, and a process to ensure ongoing compliance with tree planting and maintenance provisions.” Tree standards Jurisdictions are encouraged to adopt the latest ANSI A300 by reference as the tree care standards for trees planted to fulfill these development requirements. The department encourages broader use of these standards for tree planting requirements in development ordinances. A jurisdiction may continue to use existing tree care standards or adopt tree care standards other than 2021 ANSI A300 if they ensure an equal or better standard of care for planting and maintenance. “Trees must be planted and maintained to maximize their root health and chances for survival…” – This is a restatement of part of 2021 ANSI A300 standards. Cities following ANSI 2021 A300 standards are in compliance with this provision. Other jurisdictions are encouraged to adopt standards ensuring: • planting in a continuous trench with a minimum 3’ soil depth and 6’ width • use of silva cells, soil cells, or other similar methods to prevent root zone compaction • Adequate soil volume for each tree, with at least 700 cubic feet of soil for medium trees and 1,050 cubic feet of soil for large trees • Permanent drip irrigation that provides water deeper below the surface to encourage downward root growth “…a process to ensure ongoing compliance with tree planting and maintenance provisions.” PP 22-0001 ATTACHMNET F/PAGE 9 OF 13 Jurisdictions are encouraged to verify compliance with adopted tree planting standards at the time of site development. Jurisdictions with an arborist or staff with appropriate arboriculture training may perform inspections during site grading and at time of planting. If such resources are not available, a jurisdiction can require certification from a licensed landscape architect or arborist certified by the International Society of Arboriculture that the planting was performed per the approved site plans. The rule does not prescribe a process to ensure ongoing compliance. Trees should be monitored for 3-5 years after planting to ensure the trees have been correctly planted and maintained. Compliance can be enforced through the city or county code enforcement process. The development code will need to have a requirement for the property owner to maintain required vegetation, and an enforcement process for remedying violations of the code. OAR 660-012-0405(5) “Cities and counties shall establish off-street parking maximums in appropriate locations, such as downtowns, designated regional or community centers, and transit-oriented developments.” This is language from the previous Transportation Planning Rules. Local codes should already be compliant with no changes needed. Model Code Language OAR 660-012-0405(2): See examples in links below. DLCD staff recommends creating application packet, limiting supplemental information requirements to insurance/liability documentation, and setting review fees as close as possible to jurisdiction’s actual processing/review costs. See also: o City of Milwaukie parklet code o City of Salem parklet guide o City of Bend parklet program OAR 660-012-0405(3): Shared parking. Required parking facilities for two or more uses, structures, or parcels of land may be satisfied by the same parking facilities used jointly. Shared parking shall be approved unless peak occupancy/demand of the uses directly conflict, and provided that the right of joint use is evidenced by a recorded deed, lease, contract, or similar written instrument establishing the joint use. Shared parking requests shall be subject to review and approval through Site Plan Review. [text from TGM Model Development Code for Small Cities] OAR 660-012-0405(4): PP 22-0001 ATTACHMNET F/PAGE 10 OF 13 Codes with examples of ordinances with parking lot tree requirements are: • City of Coburg: “Planning staff will confirm the proposed off-street parking area meets the standard based on an authoritative tree guide, or on a landscaping plan prepared by a licensed landscape architect or arborist certified by the International Society of Arboriculture.” • City of Sacramento, CA code • City of Davis, CA code and guidance Additional Recommendations OAR 660-012-0405(2): • Land use regulations for conversion of spaces in private off-street parking lots should be amended to allow items such as food carts or outdoor seating and display areas. Options for incorporating such allowances may include as a temporary use, as a use allowed through a Type I or similar process, or within off-street parking regulations as activities allowed within a parking lot. OAR 660-012-0405(3): • Allow greater distances between use and shared parking area – don’t impose any distance (Model Code) or make distance ¼ mile or more; shorter distances are unnecessarily limiting • Overlaps – loosen criteria dealing with overlaps between uses. State that shared parking shall be approved unless peak occupancy/demand of the uses directly conflict; indicate policy intent that default is approval rather than putting onus on applicant to demonstrate that there isn’t substantial overlap. Other option to remove evaluation of peak demand hours – market forces will likely prevent parties from entering into shared parking agreements if they believe customers won’t have a place to park • Use/zone limitations – remove limitations that shared parking is only available for specific use types or in specific zones; no reason that residential uses cannot utilize shared parking. • Multiple use sites – recognize that sites with multiple uses have a natural shared parking dynamic. Do not require formal shared parking approval for such situations where site is under a common ownership or owners have rights to collective parking areas. Provide ‘by- right’ quantity reductions for such situations – e.g. don’t require parking to be 100% of the sum of the uses individually; provide alternate methodology (all uses calculated at 80% of required minimums; largest use at 100%, all other uses at 75%, etc.). o Example: City of Cornelius: “If several uses occupy a single structure or parcel of land, the total requirements for off-street parking shall be the sum of the requirements of the several uses computed separately with a reduction of 10 percent to account for cross-patronage and shared parking benefits. Where the peak hours of operation of two or more uses do not substantially overlap, such uses may share off-street parking spaces as required by this title.” Resources PP 22-0001 ATTACHMNET F/PAGE 11 OF 13 Evan Manvel, DLCD – the language of these rules, deadlines, etc. evan.manvel@dlcd.oregon.gov (971) 375-5979 Laura Buhl, DLCD – tree care and codes laura.buhl@dlcd.oregon.gov (971) 375-3552 Ryan Marquart, DLCD – this guidance document ryan.marquart@dlcd.oregon.gov (971) 375-5659 TGM Model Code www.oregon.gov/lcd/TGM/Pages/Model-Code.aspx Disclaimer This document aims to provide more details about the rules, and how the department intends to administer the rules. Nothing in this document should be construed as Oregon Administrative Rules. A current copy of the adopted Transportation Planning Rules should be acquired from the Oregon Secretary of State and used to fulfill planning requirements. Rule Language 660-012-0405: Parking Regulation Improvements (1) Cities and counties shall adopt land use regulations as provided in this section: (a) Designated employee parking areas in new developments shall provide preferential parking for carpools and vanpools; (b) Property owners shall be allowed to redevelop any portion of existing off-street parking areas for bicycle- oriented and transit-oriented facilities, including bicycle parking, bus stops and pullouts, bus shelters, park and ride stations, and similar facilities; and (c) In applying subsections (a) and (b), land use regulations must allow property owners to go below existing mandated minimum parking supply, access for emergency vehicles must be retained, and adequate parking for truck loading should be considered. (2) Cities and counties shall adopt policies and land use regulations that allow and encourage the conversion of existing underused parking areas to other uses. (3) Cities and counties shall adopt policies and land use regulations that allow and facilitate shared parking. (4) Cities and counties shall adopt land use regulations for any new development that includes more than one- half acre of new surface parking on a lot or parcel as provided below: (a) Developments must provide one of the following: (A) Installation of solar panels with a generation capacity of at least 0.5 kilowatt per new parking space. Panels may be located anywhere on the property. In lieu of installing solar panels on site, cities may allow developers to pay $1,500 per new parking space in the development into a city or county fund dedicated to equitable solar or wind energy development or a fund at the Oregon Department of Energy designated for such purpose; (B) Actions to comply with OAR 330-135-0010; or (C) Tree canopy covering at least 40 percent of the new parking lot area at maturity but no more than 15 years after planting. (b) Developments must provide either trees along driveways or a minimum of 30 percent tree canopy coverage over parking areas. Developments are not required to provide trees along drive aisles. The tree spacing and species planted must be designed to maintain a continuous canopy, except when interrupted by driveways, drive aisles, and other site design configurations; and (c) Developments must provide pedestrian facilities between building entrances and pedestrian facilities in the adjacent public right-of-way. PP 22-0001 ATTACHMNET F/PAGE 12 OF 13 (d) Development of a tree canopy plan under this section shall be done in coordination with the local electric utility, including pre-design, design, building and maintenance phases. (e) In providing trees under subsections (a) and (b) the following standards shall be met. Trees must be planted and maintained to maximize their root health and chances for survival, including having ample high-quality soil, space for root growth, and reliable irrigation according to the needs of the species. Trees should be planted in continuous trenches where possible. The city or county shall have minimum standards for planting and tree care no lower than 2021 American National Standards Institute A300 standards, and a process to ensure ongoing compliance with tree planting and maintenance provisions. (5) Cities and counties shall establish off-street parking maximums in appropriate locations, such as downtowns, designated regional or community centers, and transit-oriented developments. PP 22-0001 ATTACHMNET F/PAGE 13 OF 13 DLCD Guidance v 2.0 April 27, 2023 Page 1 Implementation Guidance OAR 660-012-0415 Parking Maximums in More Populous Cities Updated to reflect temporary rules adopted April 20, 2023, effective May 12, 2023 for up to 180 days. Staff expect those rules generally to be made long-term rules at the November 2023 commission meeting. DLCD and LCDC developed the Climate-Friendly and Equitable Communities rules to support communities taking action to meet Oregon’s climate pollution reduction targets, while providing more housing and transportation choices and improving equity. DLCD is providing this resource as part of our technical assistance program. Please see our website at www.oregon.gov/lcd/CL/Pages/CFEC for more information or to sign up for notices. Application and Deadline for Action Section (1) states the rule applies to: Cities with populations over 100,000, counties with populations over 100,000 outside city limits but within the urban growth boundary, and cities with populations over 25,000 within the Portland metropolitan area. As of November 2022, the department believes that includes Bend, Eugene, Salem, Clackamas and Washington Counties, and twelve cities in the Portland metro area. OAR 660-012-0012(5)(f) requires: Cities and counties shall adopt comprehensive plan amendments and land use regulations meeting requirements as provided in … OAR 660-012-0415 … no later than June 30, 2023… Jurisdictions may apply for an extension or “alternate date,” as explained in other guidance. Where Maximums Apply The second part of section (1) lists where cities and counties must set maximums: … in climate-friendly areas and in regional centers and town centers, designated under the Metro Title 6, Centers, Corridors, Station Communities and Main Streets, Adopted Boundaries map. Those cities and counties shall also set parking maximums on lots or parcels within the transit corridors and rail stop areas listed in OAR 660-012-0440. The department interprets this set of areas to adequately cover the “appropriate locations” all cities are required to set parking maximums for under OAR 660-012-0405(5), “Cities and counties shall establish off-street parking maximums in appropriate locations, such as downtowns, designated regional or community centers, and transit-oriented developments.” PP 22-0001 ATTACHMENT G/PAGE 1 OF 4 DLCD Guidance v 2.0 April 27, 2023 Page 2 The climate-friendly areas maximums should take effect concurrently with the designation of climate-friendly areas under OAR 660-012-0315. Regional centers and town centers are designated on the Metro Title 6 map. The “transit corridors and rail stop areas listed in OAR 660-120-0440” means rail stops in (2) of that rule, designated priority transit corridors under OAR 660-012-0710 in (3)(a) of that rule, and frequent transit corridors as defined by service levels in (3)(b) and (c). Section (1)(a): Residential (a) Parking maximums shall be no higher than 1.2 off-street parking spaces per studio unit and two off-street parking spaces per non-studio residential unit in a multi-unit development in climate-friendly areas and within one-half mile walking distance of priority transit corridors. These maximums shall include visitor parking; The department considers “multi-unit development” in this context to refer to developments with five or more units in a single building on a single lot or parcel. This section confusingly includes a reference to the location of where these apply, “in climate- friendly areas and within one-half mile walking distance of priority transit corridors.” This is errata and is expected to be fixed in a rules revision. That locational criteria is later overridden by subsection (d), which requires subsections (a) through (c) to apply, “in climate-friendly areas and for developments on parcels or lots within one-half mile of transit corridors and three-quarters mile of rail transit stops listed in OAR 660- 012-0440.” Section (1)(b): Commercial and Retail (b) Parking maximums shall be no higher than five spaces per 1,000 square feet of floor space for all commercial and retail uses other than automobile sales and repair, eating and drinking establishments, and entertainment and commercial recreation uses; Local codes may define these categories. For Portland Metro jurisdictions, maximums in the Regional Transportation Functional Plan Table 3.08 – 3 continue to apply, though local governments should make adjustments to 5 or below for retail/commercial and banks with drive-ins (from 5.1 and 5.4, respectively). Section (1)(c): Extremely Large Buildings (c) For land uses with more than 65,000 square feet of floor area, surface parking may not consist of more area than the floor area of the building; This is similar in scale to City of Gresham code in 9.0852. It should be read as an additive restriction to (a) and (b). The measurement of 65,000 square feet should be at the lot level, and can be interpreted by a local as either gross or net floor area. Surface parking should be measured inclusive of all surface area on which a vehicle is designed to maneuver/on which a vehicle can PP 22-0001 ATTACHMENT G/PAGE 2 OF 4 DLCD Guidance v 2.0 April 27, 2023 Page 3 drive, including all parking stalls, all drives and drive-through lanes within the property regardless of length, and all maneuvering areas regardless of depth. Paved areas not for use by passenger vehicles, such as loading areas or outdoor storage of goods or materials, are not counted as surface parking area. Section (1)(d): Exception for Non-Surface Parking (d) Non-surface parking, such as tuck-under parking, underground and subsurface parking, and parking structures may be exempted from the calculations in this section. This is a common code provision to allow additional parking if it is provided in a land-efficient manner. For other use types, or areas outside those areas, cities and counties have broad discretion on parking maximums. Section 2 Section 2 of OAR 660-012-0415 applies only to cities with populations over 200,000. As of November 2022, that includes only Portland. This guidance does not currently cover that section. What Do Cities and Counties Have to Do? Cities and counties must amend their local codes with the new parking standards by June 30, 2023 or an approved alternate date. OAR 660-012-0012(5)(f) notes “If a city or county has not done so, it may not apply parking mandates after that date.” Model Language for Development Code A community may want to put these parking requirements directly into its code. Code language will vary in each community’s parking code language and parking table. Department staff are available to review your community’s code and suggest language for consideration. Resources and Contact Information Evan Manvel, Climate Mitigation Planner evan.manvel@dlcd.oregon.gov 971-375-5979 Disclaimer This document aims to provide more details about the rules, and how the department intends to administer the rules. Nothing in this document should be construed as Oregon Administrative Rules. A current copy of the adopted Transportation Planning Rules should be acquired from the Oregon Secretary of State and used to fulfill planning requirements. PP 22-0001 ATTACHMENT G/PAGE 3 OF 4 DLCD Guidance v 2.0 April 27, 2023 Page 4 Rule Language: OAR 660-012-0415(1) 0415: Parking Maximums and Evaluation in More Populous Communities (1) Cities with populations over 100,000, counties with populations over 100,000 outside city limits but within the urban growth boundary, and cities with populations over 25,000 within the Portland metropolitan area, shall set parking maximums in climate-friendly areas and in regional centers and town centers, designated under the Metro Title 6, Centers, Corridors, Station Communities and Main Streets, Adopted Boundaries map. Those cities and counties shall also set parking maximums on lots or parcels within the transit corridors and rail stop areas listed in OAR 660-012-0440. (a) Parking maximums shall be no higher than 1.2 off-street parking spaces per studio unit and two off-street parking spaces per non-studio residential unit in a multi-unit development in climate-friendly areas and within one-half mile walking distance of priority transit corridors. These maximums shall include visitor parking; (b) Parking maximums shall be no higher than five spaces per 1,000 square feet of floor space for all commercial and retail uses other than automobile sales and repair, eating and drinking establishments, and entertainment and commercial recreation uses; (c) For land uses with more than 65,000 square feet of floor area, surface parking may not consist of more area than the floor area of the building; and (d) Non-surface parking, such as tuck-under parking, underground and subsurface parking, and parking structures may be exempted from the calculations in this section. PP 22-0001 ATTACHMENT G/PAGE 4 OF 4 Implementation Guidance Unbundled Parking Updated to reflect temporary rules adopted April 20, 2023, effective May 12, 2023 for up to 180 days. Staff expect those rules generally to be made long-term rules at the November 2023 commission meeting. DLCD and LCDC developed the Climate-Friendly and Equitable Communities program to support communities taking action to meet Oregon’s climate pollution reduction goals. The program works to help provide more housing and transportation choices and improve equity. DLCD is providing this resource as part of our technical assistance program. Please see our website at www.oregon.gov/lcd/CL/Pages/CFEC for more information or to sign up for notices. What is Unbundled Parking and Why Should Communities Consider it? Unbundled parking is paying for parking separately from paying for the rent, lease or purchase of a residential or commercial unit, with the option to not use and pay for parking. Unbundled parking is officially defined in OAR 660-012-0005(57). Separating the cost of parking from other goods can significantly impact mode choice. When there is a price on parking, commuters look to make other, more climate-friendly choices such as transit, carpooling, walking or biking. One study found a 17% decrease in solo driving to work when commuters had to pay for parking at work, versus having the costs of that parking hidden and subsidized. In that study, carpooling increased 64%, transit use increased 50%, and walking and biking increased 33%. The collective mode shifts reduced total driving commute miles by 12%. Another study found unbundling parking can cut transportation-related climate pollution by up to 15.7%. Being explicit about the cost of parking and allowing people to avoid that cost helps people make more climate-friendly decisions, such as carpooling, transit, walking and biking. Unbundling also improves equity, as the majority of households who do not own cars are in the bottom fifth of households in in terms of income, and homeowners own 50% more cars than renters. Where parking is bundled in with other goods, these households disproportionately subsidize parking for those with more resources. Application and Deadline for Action Under OAR 660-012-0420, jurisdictions must choose one of three parking reform paths by June 30, 2023, or an approved alternate date. Jurisdiction that do not repeal parking mandates (reform path 1) may either adopt a fair parking policy approach per OAR 660-012-0445(1)(a) or a reduced regulation parking management approach per OAR 660-012-0445(1)(b). Jurisdictions choosing the fair parking policy path per OAR 660-012-0445(1)(a) must implement at least two policies listed in that rule, including at least one policy in OAR 660-012-0445(1)(a)(A) through (C). One policy is to require unbundled parking for each residential unit in developments that include five or more leased or sold residential units on a lot or parcel (OAR 660-012-0445(1)(a)(A)). Another policy is to PP 22-0001 ATTACHMENT H/PAGE 1 OF 6 require unbundled parking for parking spaces serving leased commercial developments. (OAR 660-012- 0445(1)(a)(B)). For either policy, unbundling is required throughout the jurisdiction. Jurisdictions that adopt a reduced regulation parking management approach per OAR 660-012-0445(1)(b) have an option in (N) to either create a residential parking district, a parking benefit district or require multi-family residential units have unbundled parking (OAR 660-012-0445(1)(b)(N)(ii)). What Do Cities/Counties Have to Do? The department recommends unbundling occur through: (1) the adoption of a general ordinance regulating rental, lease, and sales agreements and (2) an ordinance with amendments to the jurisdiction’s development code requiring new development and redevelopment to unbundle parking. Procedural requirements described below can be contained in both ordinances, or established in one ordinance with appropriate cross-references to the other. Rental, Lease, and Sales Ordinance The ordinance regulating rental, lease and sales should apply to the geographic areas and types of development set forth in the CFEC rules. Rental and Lease The ordinance should require any lease or rental agreement entered into after the effective date of the ordinance for space in those specified developments shall unbundle parking from the rental or lease of the tenant space. This rental/lease ordinance is intended to implement unbundled parking policies for existing developments. This general ordinance is not intended to invalidate the terms of any existing contracts. It is intended to take effect separate from any land use action, allowing tenants of existing spaces to benefit. Implementing this policy broadly and expeditiously improves equity so the option to avoid paying for unused parking is not limited to tenants in new or redeveloped buildings. Residential lease and rent agreements are subject to ORS Chapter 90, Residential Landlord and Tenant Act. DLCD staff are not aware of conflicts with provision of the Residential Landlord and Tenant Act and adopting unbundled parking requirements. Jurisdictions are not precluded from adopting ordinances implementing rental or lease regulations in addition to ORS Chapter 90; one notable example is the City of Portland’s rental protection rules (Portland City Code 30.01.085). Sales Unbundling also applies to units that are sold. This will apply only to residential properties because OAR 660-012-0445(1)(a)(B) requires commercial unbundling only for leased properties. DLCD staff expects unbundling for sales of residential development will occur only in residential condominium plats. Unbundling for sales of residential condominium units applies to any condominium plat recorded after the effective date of the unbundling ordinance. Unbundling should also be required for sales of residential units in existing condominium developments, though exceptions are appropriate to include. Ownership or access to parking may be tied to ownership of the unit in existing condominium plats and/or deeds to condominium units. As such, there can be exceptions to required unbundling where the condominium plat was recorded prior to the effective date of the unbundling ordinance and either (a) the parking space(s) do not have a legal description that allows sale as an individual unit OR (b) the declarations and any legally enforceable codes, covenants and restrictions (CC&Rs) require joint ownership of the unit and parking space or restrict parking space ownership to owners of condominium units. PP 22-0001 ATTACHMENT H/PAGE 2 OF 6 Notice Notification of the rental, lease, and sales regulations should occur to landlords and tenants. In addition to the jurisdiction’s general notification requirements for an ordinance, the department recommends mailing notices to renters and owners of the properties for which unbundling will be required. This should include owner addresses on file with the assessor as well as assigned addresses within the development (address numbers, apartment numbers, suites, etc.). Absent this, a broad effort to publicize the ordinance should be made. Areas subject to unbundling will include transit corridors and climate-friendly areas and their Metro-area equivalents. All areas within the city may be subject to unbundling if a jurisdiction opts to implement OAR 660-012-0445(1)(a)(A) or (B). Within the subject areas, jurisdictions should be able to use tax lot data and assessor codes per OAR 150-308-0310 to create a list of properties that are or may likely be subject to unbundling requirements. Business licenses or rental property registrations, if required by the jurisdictions, may be additional data sources from which notification lists can be created or refined. Land Use Ordinance Jurisdictions should also amend their development code to require unbundling in the geographic areas and types of development that must have unbundled parking, as set forth in the CFEC rules. Including unbundling as a land use regulation highlights this requirement for developers so they can make an informed decision about the amount of off-street parking to construct. This land use regulation will limit the oversupply of parking because developers will construct only the amount of parking that they expect tenants will opt to pay for. This will lead to better utilization of land and building space, create a more walkable and bikeable urban form, and reduce vehicle ownership. Including unbundling in the development review process also increases the visibility of this requirement and makes it easier to track as a condition of approval, development casefile notation, and/or notation on the affected property(s) in the jurisdiction’s development permitting system. Applicants receiving land use approval after the effective date of the ordinance should be notified about the rates. Failure to offer tenants who do not use parking the ability to opt out of paying for it, and failure to charge the minimum rate should be considered a violation of the ordinance. Determining Market Rates for Comparable Local Off-Street Parking The rule specifies spaces must be rented, leased, or sold at market rates for comparable local off-street parking (in OAR 660-012-0005). A local unbundling ordinance should establish a process for the jurisdiction to determine a minimum rate(s) for unbundled parking and for distributing that information to affected landlords and tenants. Minimum rates should be re-evaluated at regular interval and should be able to be set by staff rather than requiring council or commission action. Where possible, comparable rates should be established by surveying monthly parking rates for off-street parking lots or garages. Unbundled parking for sites near the surveyed lots or garages should reflect these market rates. Rates may be adjusted for unbundled parking that is geographically distant from the surveyed lots or garages. Another option is to survey rates for car storage; the department usually finds these rates ranges from $60 to $200/month. Generally, it would be surprising for appropriate unbundled parking rates to be less than $50/space/month. Where Unbundling Applies Unbundling pursuant to OAR 660-012-0445(1)(a)(A) and (B) applies everywhere within the jurisdiction’s boundaries. PP 22-0001 ATTACHMENT H/PAGE 3 OF 6 Developments that Must Have Unbundled Parking OAR 660-012-0445(1)(a)(A) requires “… each residential unit in developments that include five or more leased or sold residential units on a lot or parcel be unbundled parking. Cities and counties may exempt townhouse and rowhouse development from this requirement.” OAR 660-012-0445(1)(b)(N)(ii) requires “… parking for multi-family residential units to be unbundled parking.” In the context of residential development, parking should be unbundled when located in a general or common area, such as surface parking surrounding a building or in a parking garage, podium parking, or tuck-under parking. Townhouse and rowhouse development is exempt (OAR 660-012-0445(1)(a)(A) states this explicitly; OAR 660-012-0445(1)(b)(N)(ii) should be read the same way). This exemption is intended to apply for parking spaces that are structurally attached to and accessible directly from the dwelling unit, or surface parking located exclusively on the same lot or parcel as the dwelling unit. OAR 660-012-0445(1)(a)(B) requires parking spaces serving leased commercial developments be unbundled parking. For this rule, commercial development should be understood as inclusive of retail, service, and office uses. The department recognizes the lease or ownership status of a commercial development is not necessarily reviewed in a land use application, and that the status is subject to change. For existing developments, the issue of unbundling should be resolved between the commercial tenant and landlord as new lease agreements are executed, with local staff being involved if a complaint is received. As new commercial development or redevelopment occurs, it is recommended a condition of approval, development casefile note, and/or similar notation in a development permitting system be placed on the property. This notation will make it easier to research whether commercial parking is required to be unbundled in the event the commercial space is leased. The department does not intend the rule to require local staff to actively track commercial development lease status. Commercial landlords should have awareness of unbundling requirements from the initial outreach conducted during adoption of the rental/lease ordinance or from the land use application review. Enforcement Enforcement of the unbundling land use ordinance can be handled in the same manner as other violations of the development code, and enforced consistent with a jurisdiction’s code enforcement policies and prioritization. Unbundling is a new area of regulation for many jurisdictions. However, it is similar to other more common operational regulations such as hours of operation in certain zones, ground-floor commercial doors being open during business hours, or activity limitations for home occupations. Jurisdictions are advised to consult their legal counsel in drafting the rental, lease and sales ordinance, including the enforcement provisions. Violations of this ordinance can be failure to offer unbundled parking, failure to charge appropriate market rates for unbundled parking, or failure to comply with any reporting about unbundled parking. Enforcement may be based on code enforcement used for land use, nuisance, and other jurisdictional ordinances. While a complaint-based enforcement approach is acceptable, random spot checks may increase compliance. Any complaint-based enforcement approach should work to protect those filing complaints. Another option may be to specify damages and fees for ordinance violations that can be a cause of action in court (this is Seattle’s). Model Language for Development Code Codes with land use regulations requiring unbundled parking: PP 22-0001 ATTACHMENT H/PAGE 4 OF 6 • City of Seattle (Chapter 23.42.070) - https://library.municode.com/wa/seattle/codes/municipal_code?nodeId=TIT23LAUSCO_SUBTI TLE_IIILAUSRE_CH23.42GEUSPR_23.42.070PARELEMUDWUNCOUS. • City of Berkeley (Title 23.334.030.A, part of Transportation Demand Management requirements) – https://berkeley.municipal.codes/BMC/23.334.030(A). • City of San Francisco (Article 1.5, Section 167) - https://codelibrary.amlegal.com/codes/san_francisco/latest/sf_planning/0-0-0-19298. • City of Oakland (Section 17.116.310) - https://library.municode.com/ca/oakland/codes/planning_code?nodeId=TIT17PL_CH17.116ORE PALORE_ARTVSTREPALOFA_17.116.310UNPA • City of Santa Monica (Section 9.28.110) - https://library.qcode.us/lib/santa_monica_ca/pub/municipal_code/item/article_9-division_3- chapter_9_28-9_28_110. • City of Bellevue (Chapter 20.25J.050(B)) - https://bellevue.municipal.codes/LUC/20.25J.050 Unbundling required for lease and rental agreements: • City of Seattle (Chapter 7.24.030.G) - https://library.municode.com/wa/seattle/codes/municipal_code?nodeId=TIT7COPR_CH7.24REA GRE_7.24.030REAGRE Contact Information Evan Manvel, Climate Mitigation Planner evan.manvel@dlcd.oregon.gov, (971) 375-5979 Disclaimer This document aims to provide more details about the rules, and how the department intends to administer the rules. Nothing in this document should be construed as Oregon Administrative Rules. A current copy of the adopted rules should be acquired from the Oregon Secretary of State and used to fulfill planning requirements. PP 22-0001 ATTACHMENT H/PAGE 5 OF 6 Rules Language OAR 660-012-0005: Definitions […] (57) “Unbundled parking” means a requirement that parking spaces for each unit in a development be rented, leased, or sold separately from the unit itself. The parking space(s) must be rented, leased, or sold at market rates for comparable local off-street parking. The renter, lessor, or buyer of the unit must be allowed to opt out of renting, leasing, or buying the parking space. *** OAR 660-012-0445: Parking Management Alternative Approaches (1) In lieu of adopting land use regulations without parking mandates under OAR 660-012-0420, cities and counties shall select and implement either a fair parking policy approach as provided in subsection (a), or a reduced regulation parking management approach as provided in subsection (b). (a) A fair parking policy approach shall include at least two of the following five provisions, including at least one provision from paragraphs (A) – (C): (A) A requirement that parking spaces for each residential unit in developments that include five or more leased or sold residential units on a lot or parcel be unbundled parking. Cities and counties may exempt townhouse and rowhouse development from this requirement; (B) A requirement that parking spaces serving leased commercial developments be unbundled parking; […] (b) A reduced regulation parking management approach shall include all of the following: […] (N) Implementation of at least one pricing mechanism, either: (i) Designation of at least one residential parking district or parking benefit district where on-street parking is managed through paid permits, meters, or other payments; or (ii) Requirements that parking for multi-family residential units be unbundled parking. PP 22-0001 ATTACHMENT H/PAGE 6 OF 6 ADA Parking Potential Approaches This guidance is part of an overall effort to support communities tasked with implementing the Climate-Friendly and Equitable Communities (CFEC) program to reduce climate pollution, increase transportation and housing choices, and create more equitable outcomes. Background People with disabilities have a right to full access to, and participation in, their communities. This includes accessible and convenient transportation options, including transit, safe connections for walking and rolling, and parking for cars and vans. The Americans with Disabilities Act (ADA) generally requires facilities and services open to the public, and publicly funded housing, to provide accessible options for people with disabilities equal to those provided to the general population. Conversely, if no program or service is provided for the general population, there is no requirement to do so for people with disabilities. Under the ADA and Oregon state law, if no off-street parking spaces are provided for the general population, there is no national or state requirement to provide off-street parking spaces for people with disabilities. A few cities and counties have voiced concerns about their ability to ensure adequate ADA parking is available given the parking reforms in the CFEC program. During rules development, the department hired a disability consultant and held a focus group of people with disabilities. Those people did not have concerns about CFEC’s approach to ADA parking. However, some participants in the 2022 ODOT ADA survey and stakeholder advisory committee raised concerns about sufficient ADA parking. This is common in conversations about any sort of parking. Among advocates for people with disabilities, there is no broad agreement about how many ADA parking spaces should be required. (See, for example, this roundtable discussion). Oregon law sets a floor and a ceiling of how much accessible parking cities and counties can require (ORS 447.233). That statute includes a table of ADA parking in relation to total parking spaces provided [excerpt next page], and required the Department of Consumer and Business Services (DCBS) to integrate that table into the state building code (OSSC 1106.1). This means when parking is provided, ADA parking spaces are required for most housing other than single unit, duplex, and townhome development (OSSC 1106.3). ad a . g o v / t o p i c s / p a r k i n g / PP 22-0001 ATTACHMENT I/PAGE 1 OF 5 Table of Required ADA parking from ORS 447.233: State building code has additional requirements for hospital, rehabilitation, and physical therapy facilities. Under all these codes, the number of required ADA spaces is driven by how much parking is built, not zoning ordinance requirements. Impact of CFEC Program Cities and counties have not been able to require more accessible parking than prescribed in state law, even before the CFEC rules adoption. The amount of ADA parking spaces that must be provided is still based on the number of parking spaces in the parking lot. Repeal of parking mandates does not alter the applicability or enforcement of that law. The CFEC rules explicitly exempt ADA parking from parking mandate reduction (OAR 660- 012-0005(29)), thereby retaining the ability of cities and counties to require ADA parking even when other parking mandates are limited. For developments with off-street parking, local governments must still require new developments to build off-street ADA parking spaces per ORS 477.233. The main impact of mandate repeals is that developments will provide ADA spaces based on the total number of parking spaces they chose to build rather than the total number they would have been forced to build. If a development does not include an off-street parking area, the local governments may still require one off-street ADA parking space, and additional spaces per the ORS 477.233 table. See discussion below under ‘Potential Approaches.’ PP 22-0001 ATTACHMENT I/PAGE 2 OF 5 Many of the jurisdictions concerned about ADA parking have previously had areas with zero parking mandates, the same situation they now face under CFEC rules. Many local jurisdictions also allow reductions to required off-street parking. Those jurisdictions had not before indicated a major shortage of ADA parking. That said, the department is unaware of significant qualitative or quantitative data, or ongoing engagement of people with disabilities, on this question. Lack of accessible parking is not the only mobility barrier for people with disabilities, and not the biggest obstacle for many. National data show people with disabilities tend to walk/roll and use transit more than people without disabilities, and are two to three times more likely to live in a car-free household than people without disabilities (although many of those people travel as car passengers). Oregon-specific data on this question are hard to come by. Improved transit and an improved pedestrian network – intended outcomes of the CFEC program – will do more to improve mobility for people with a wide range of support needs. It is important to holistically work toward a fully connected and accessible network. Potential Approaches LCDC, DLCD, and DCBS (Building Codes Division) do not have authority to allow cities and counties to require more accessible parking spaces than in statute. Only the legislature can change laws to allow cities and counties to require more accessible parking spaces. Disability advocates and parking management experts are not all in agreement about how much ADA parking is best practice, as parking needs are nuanced and site-specific. DLCD recommends local governments meet their ADA Title II responsibilities by working with local disability advocates to find an approach that best works for people with mobility disabilities in your community. There are several ways to create more available ADA spaces for people who need them, some of which fall outside implementation through development regulations: Dedicating on-street spaces. After a road reconfiguration safety project on N. Lombard Ave, the City of Portland dedicated on-street ADA spaces on perpendicular streets to ensure access. The City also has a program to apply for a dedicated on-street ADA space. While this can work for certain ADA users, and diagonal parking spaces work for most users, parallel parking spaces have limited utility for van-dependent ADA users (given the need for ramps), and convenient ADA-compliant access to the sidewalk is critical. Given the pending adoption of standards in the Pedestrian Right of Way Accessibility Guidelines (PROWAG) for on-street ADA parking, ODOT is continuing to explore this issue for ODOT-owned roadways and adjacent locally-owned roads and spaces. Voluntarily dedicating spaces in parking lots. Cities can dedicate ADA spaces in public parking lots, or pay or request private lot owners to dedicate spaces for ADA users. Sharing information about demand with builders. As demographics shift, cities can publicize the ongoing shortage of accessible and visitable housing and infrastructure to meet demand. PP 22-0001 ATTACHMENT I/PAGE 3 OF 5 Local builders may find it profitable to provide ADA-compliant facilities even if not required to by law. In redoing its Green Lot near the state capitol, the State of Oregon is providing 43 ADA spaces out of 307 total spaces, when only eight are required. Enforcing against wrongful use of existing ADA spaces. Some of the concerns reported to ODOT’s accessibility team are about existing ADA spaces being misused. Local communities can increase enforcement to ensure ADA spaces are free for those allowed to use them. Portland has launched a volunteer ADA parking enforcement and education program. Requiring one ADA off-street parking space in certain circumstances, where no other parking is required. The department and the building codes division believe this is consistent with state statute and rules. As the parking table in ORS 447.233 is silent on zero parking spaces, and the rules in OAR 660-012-0005 specifically exempt ADA parking from parking reforms, the department believes the statute allows local governments to require one ADA off-street parking space, and additional spaces in line with the statutory table. Should a community decide to take this approach, the department recommends focusing larger developments, in certain areas, and having a fee-in-lieu option so parking could be provided adjacent to, or near, the site. Existing buildings with zero off-street parking should also be given an exemption for remodels or changes of use. Some specific approaches: • The City of Bend is requiring one ADA space in larger commercial developments on lots of 20,000 square feet or more outside its downtown and Central District.1 • One possibility is requiring an ADA parking space when a developer is already providing a curb-cut and off-street loading zone. This reduces the cost of providing an ADA space. • In areas with no required off-street parking, the City of Austin, TX requires uses of 6,000 square feet or greater to provide ADA spaces equal to at least 20% of the parking spaces required for that use in areas where off-street parking is required. The spaces can be provided off-street, on-street within 250 feet of the site, or mitigated by payment of a fee in lieu to a city program to construct and maintain nearby ADA parking. The City may revisit and remove this requirement later this year, as it has not proved effective. • The City of Minneapolis, MN requires new residential developments of four or more units that have no off-street parking to include a labeled drop-off and pick-up parking space, with an accessible route to the building. Focusing on the loading function allows more flexible design requirements. The provision does not require a curb cut should one 1 Bend Development Code in Chapter 3.3 “If parking is not otherwise provided on-site, all developments subject to Site Plan Review in BDC Chapter 4.2, Minimum Development Standards Review, Site Plan Review and Design Review, must provide a minimum of one van-accessible parking stall on-site except as follows: a. Developments in the Central Business (CBD) District. b. Developments in the Bend Central District. See BDC 2.7.3200, Bend Central District (BCD). c. Developments on lots or parcels smaller than 10,000 20,000 square feet. PP 22-0001 ATTACHMENT I/PAGE 4 OF 5 not otherwise be provided. (Code 530.155) Five such proposed developments have requested alternative compliance to this provision, so it may not be a functional approach. Informing landlords of their responsibilities to provide reasonable accommodation under the Fair Housing Act, and tenants of their rights to request them. The Fair Housing Act right to reasonable accommodations usually includes the ability to request a designated ADA parking space if parking spaces are provided to tenants. While this puts burden on the person with disabilities, it more precisely fits the supply to the location-specific demand, and side-steps the statutory limits. Changing state statute. Some other states set a floor for how many ADA parking spaces local governments must require, but not a ceiling. This allowed the City of Anchorage, Alaska to set higher ADA parking space requirements when they eliminated other parking mandates citywide. Pay Close Attention to Design Communities should consider the design requirements for ADA van parking in street and sidewalk design. People with disabilities should be engaged when designing changes to existing parking layouts, allocations or streetscapes. Contact Evan Manvel, Climate Mitigation Planner, evan.manvel@dlcd.oregon.gov, (971) 375-5979 David Morrisey, ADA Program Manager, ODOT Office of Equity and Civil Rights, david.n.morrissey@odot.oregon.gov, (503) 979-5827 Heidi Shobom, State Roadway Engineer, ODOT Engineering and Technical Services, Heidi.e.shoblom@odot.oregon.gov, (503) 986-3557 This document draws on research by Catie Gould at Sightline Institute. We are grateful for her work. Read the Sightline research here. Disclaimer This document aims to provide more details about the CFEC program, and how the department intends to administer the program. Nothing in this document should be construed as Oregon Administrative Rules. A current copy of the adopted rules should be acquired from the Oregon Secretary of State and used to fulfill planning requirements. PP 22-0001 ATTACHMENT I/PAGE 5 OF 5 S Sergi \ City of Lake Oswego Properties a Half Mile* from Bus Lines 35 *Half mile is straight out from bus route. - - -Lake Oswego City Limits 0 SE O k Grove Blvd USB Boundary -Rte. 35 0.25 en rn ;:: PP 22-0001 ATTACHMENT J/PAGE 1 OF 1 Parking Supply, Car Ownership, and Driving Rates The evidence from five studies Including parking with rent makes a household 60-80% less likely to be vehicle-free. Households with parking included with rent (“bundled”) are 60 to 80 percent less likely to be vehicle- free than households without. There is reason to believe that bundled parking causes additional vehicle ownership. Households on the margin for the decision to have an additional vehicle may opt for the additional vehicle when the cost of parking is hidden in the price of housing. Regulations that reduce the incidence of bundled parking may reduce vehicle ownership and by extension vehicle use. 2017 research paper based on American Housing Survey data. Manville, Michael. Bundled parking and vehicle ownership: Evidence from the American Housing Survey. The Journal of Transport and Land Use, Vol. 10 No. 1 [2017] 27-55. Access to private or reserved parking triples the likelihood of car ownership. People with access to owned and reserved parking have about three times higher car ownership levels than those without. Overall trip frequency (regardless of mode) does not change with car ownership or access to home parking; non-car owners make about the same number of trips as car owners. There is a reduction in the percentage of trips by car if parking is not on-site, related to the distance between the residence and parking location. 2017 research paper based on data from Norwegian National Travel Survey. Christiansen, Fearnley, Hanssen, Skollerud. Household parking facilities: relationship to travel behavior and car ownership. Transportation Research Procedia 25C (2017) 4189–4199. Guaranteed parking at home leads to a greater propensity to drive. There is a clear relationship between guaranteed parking at home and a greater propensity to use the automobile for journey to work trips even between origin and destinations pairs that are reasonably well served, and very well served, by transit. Because journey to work trips to the downtown are typically well served by transit, the research infers non-commute trips are also made disproportionately by car from areas of high on-site parking. 2012 research of New York City parking using city tax lot data, Google earth data, and work and travel data from the 2000 Census Transportation Planning Package. Weinberger, Rachel. Death by a thousand curb-cuts: Evidence on the effect of minimum parking requirements on the choice to drive. Transport Policy 20 (2012). 93–102. Available, “free” parking is associated with increased car ownership Copious parking means more driving PP 22-0001 ATTACHMENT K /PAGE 1 OF 2 Increases in available parking is associated with an increase in driving mode share. When parking spaces provided increased from 0.1 to 0.5 per resident or employee, commuter automobile mode share increased roughly 30 percentage points (roughly from 53% to 85%). Based on causality criteria, researchers assert it is likely that providing excess parking is a cause of increased automobile use, rather than provision of excess parking being a result of increase automobile use. 2016 research paper based on US Census commute data and parking supply from aerials photographs from approximately 1950-2009 from nine mid-sized cities American cities. McCahill, Garrick, Atkinson-Palombo; Polinski. Effects of Parking Provision on Automobile Use in Cities: Inferring Causality. Transportation Research Record: Journal of the Transportation Research Board, No. 2543, 2016, pp. 159–165. A household’s decision about the number of cars owned and share of trips made by car are impacted by the availability of parking. Parking has a causal effect on car ownership and mode choice. Transportation behavior and outcomes are hard to study as populations are hard to randomize. This study looks at a population randomly assigned to live in particular places, by reviewing outcomes from households in San Francisco’s housing lottery. The lottery is highly competitive; those that receive housing through the lottery will typically move into the dwelling unit regardless of factors such as location or parking availability. The results show households adapt car ownership and mode choice based on availability of parking and access to other modes of travel. Greater transit accessibility reduces the propensity to own and drive a car, while increasing the propensity to ride transit. Greater walk and bicycle accessibility also increase the propensity to use those modes. A building’s parking ratio not only influences car ownership, vehicle travel, and transit use, but has a stronger effect on these decisions than transit accessibility. Buildings with at least one parking space per unit have more than twice the car ownership rate of buildings that have no parking. If parking is provided on-site for free or at a reduced price, then households appear to take advantage of this amenity. In contrast, households without access to on-site parking are more likely to forgo car ownership altogether. The potential for private automobile trip reductions is large and does not depend on car-free households relocating to car-free buildings. 2021 research paper based on transportation choices of 779 households receiving below-market-rate housing through San Francisco’s Inclusionary Housing program between 2015 and 2018. Millard-Ball, West, Rezaei, Desai. What Do Residential Lotteries Show Us About Transportation Choices? Urban Studies (forthcoming, written January 2021). Questions? Evan Manvel, Climate Mitigation Planner evan.manvel@dlcd.oregon.gov or 971-375-5979 Household decisions about car ownership and driving are influenced by parking availability PP 22-0001 ATTACHMENT K /PAGE 2 OF 2 October 4, 2022. For the most recent version visit our web site. Questions to evan.manvel@dlcd.oregon.gov page 1 More Housing, More Business, Lower Costs, and Parking Still Supplied: What Happens When Parking Mandates are Reduced New Oregon standards reduce how much parking can be mandated by local governments in metro areas. Reducing one-size-fits-all, costly parking mandates isn’t new. It’s been done for decades around the world, and in Oregon, with significant success. Cities that lower parking mandates have seen reduced housing costs, increased business development, and more diverse developments, with creative approaches to providing parking. Most builders in communities without parking mandates still provide some parking with new developments. Some of them provide less than previously mandated, or provide it off-site. Others provide more than previously mandated, as their market analysis or lenders indicate that’s what their customers want. This how builders currently act; for example, a student-focused development on the edge of Corvallis provided 2.7 spaces per unit, higher than mandated. After seeing outcomes, communities instituting reforms have retained or expanded them. There are likely already examples in your community or a nearby community without parking minimums, either in code or by variance. Many Oregon communities have no parking requirements for commercial downtown developments (for example, Hillsboro, Monmouth, Milwaukie, Forest Grove, and Stayton). Others have no or limited parking mandates in downtowns at all (Salem, Coburg, Eugene, Portland). Here are some examples: Salem gave a variance for a new housing development, and subsequently reduced parking mandates in its downtown, along transit corridors, and for traditional missing middle housing types. Eugene saw the construction of two large parking garages as part of a residential development in its downtown, though no parking was required. Oregon City saw creative, more affordable infill housing, after waiving mandates for single-family homes. Tigard repealed parking mandates in the Tigard Triangle in 2017, and has seen healthy redevelopment levels in the area since. Builders have included off-street parking, slightly under the old requirements. Madras recently repealed parking mandates in its downtown, aiming to spur business development. Minneapolis, MN saw typical rents of studio apartments fall 17% (from $1200 to $1000) in buildings without parking. Fargo, ND (pop. 125,000) saw a downtown economic renaissance, with new businesses and thousands of new residents, after repealing parking mandates. Buffalo, NY (pop. 255,000) saw significant new development after repealing parking mandates, with single-use projects providing more than previous requirements, on average, and mixed-use projects providing less. San Diego, CA saw a five-fold increase in affordable housing, and an increase in market-rate housing, after adopting reforms including parking reforms. The city later cut commercial parking mandates. Los Angeles, CA saw a four-fold increase in downtown housing development, focused on redevelopment of older buildings. Units provided an average of 1.2 spaces per unit; about 40% were off-site. Seattle, WA saw builders saving $537 million ($30,000 per unit) over five years after reducing mandates near transit and in centers. Still, two-thirds of developments provided more parking than mandated. PP 22-0001 ATTACHMENT L/PAGE 1 OF 5 October 4, 2022. For the most recent version visit our web site. Questions to evan.manvel@dlcd.oregon.gov page 2 More Housing, More Business, Lower Costs, and Parking Still Supplied What Happens When Parking Mandates are Reduced Further Details (builds on one-page summary above) Buffalo, New York Buffalo adopted a “Green Code” in 2017, which included a repeal of minimum parking requirements citywide. Among the 36 major developments in the two years following passage, 47% included fewer parking spaces than previously mandated, indicating requirements may have been excessive. Mixed-use developments provided 53% fewer parking spaces than previously mandated, as developers found business models with less off-street parking. While parking built for single-use housing projects varied significantly, the total spaces provided exceeded what would have been required by earlier mandates, meaning lenders and builders may have been wary to deviate from previous assumptions about parking demand. In short: Buffalo developments had a more diverse parking market. Some places built just as much or more as previously required. Others had none. Others had some, but not as much, as would have been mandated. Full article: Minus Minimums (tandfonline.com) Zoning rules change in Buffalo shows parking reform could reenergize downtowns - News Bit Fargo, North Dakota After Fargo (pop. 125,000) repealed its downtown parking mandates, redevelopment followed. Builders built a 104-unit mixed-use development, and North Dakota State University moved its architecture and business schools downtown. Over 4,000 more students and faculty ended up living, working and studying downtown. The downtown “renaissance zone” saw a ten-fold increase in property tax dollars. https://www.strongtowns.org/journal/2015/11/23/robust-growth-and-development- without-mandating-parking Minneapolis, Minnesota After Minneapolis reduced its parking mandates in 2015, typical rents for a new studio apartment without parking fell from $1,200 a month to about $1,000 a month, saving renters $2,400 per year. That decrease is in line with previous studies noting structured parking can cost about 17% of monthly rent. New developments near transit provided roughly 30% less parking than mandates would have been required. People Over Parking (planning.org) What Happens When You Ease Parking Requirements for New Housing — nickmagrino.com Mixed-use developments provided 53% fewer parking spaces… Total spaces for single-use projects exceeded what would have been previously required; but there was variation by development Thousands more people moved downtown, leading to a ten-fold increase in property tax dollars in the area. Typical rents for a new studio apartment without parking fell from $1,200 a month to about $1,000 a month PP 22-0001 ATTACHMENT L/PAGE 2 OF 5 October 4, 2022. For the most recent version visit our web site. Questions to evan.manvel@dlcd.oregon.gov page 3 Los Angeles, California Los Angeles removed downtown parking mandates in 1999, as part of its Adoptive Reuse Ordinance (ARO). In the previous 30 years, downtown Los Angeles added about 4,300 housing units. In the decade following the ordinance, over 9,200 housing units were added, about 70% of which relied on provisions in the ARO. One analyst argues, “the ARO created more housing in less than ten years than had been created in the previous thirty.” The ARO also provided alternative regulations on fire and earthquake standards, and allowed changes of use without variances. Because some of the Developers revamping old commercial buildings under the ARO were particularly creative in meeting the demands for parking. In an analysis of 56 ARO building redevelopments, Professor Michael Manville found half of the parking for apartments was provided off-site. While total parking provided exceeded previous mandates (providing 1.2 spaces/unit), the relaxed mandates allowed more flexibility in location, and different amounts of parking provided among developments. Meanwhile, condo redevelopment provided 1.3 spaces per unit, well under the previous mandate of 2.0 spaces per unit, with 34% of parking off-site. In short, parking reform helped create thousands of new housing units, and a more nuanced approach to parking supply. Parking Requirements and Housing Development: Regulation and Reform in Los Angeles – ACCESS Magazine San Diego, California In 2019, San Diego removed parking mandates in transit priority zones. This, combined with a density bonus program, led to a more than five-fold increase in affordable housing unit production. While previous years saw up to 289 affordable units built, 2020 saw 1,564 new affordable units. Market-rate housing also increased. The real costs of providing parking, and its crowding out of housing, became clear. In 2021, San Diego built on this success and reduced commercial parking mandates. https://cal.streetsblog.org/2021/05/19/parking-requirements-are-not-a-useful- bargaining-chip-for-increasing-affordable-housing/ Seattle, Washington Seattle reduced parking mandates in centers and near frequent transit in 2011. In the five years following that reform, developers built 18,000 fewer (40% less) parking spaces than previous mandates would have required while building over 60,000 housing units, saving $537 million. On average, developers provided two parking spaces for every three units. About one in five housing developments provided no parking spaces, but two-thirds provided more than required. All but one of the 868 developments had less than two spaces per unit. High-end developments provided more parking than more affordable units. https://transfersmagazine.org/wp-content/uploads/sites/13/2020/11/Issue-6- Gabbe_finalv2.pdf The package of reforms helped lead to a five-fold increase in affordable housing unit production. Builders saved $537 million ($30,000 per unit) by building fewer parking spaces. Yet two-thirds of developments provided more parking than mandated. Housing development increased nearly 4-fold. Less parking was built; though units still averaged 1.2 parking spaces/unit. Much of it was off-site. PP 22-0001 ATTACHMENT L/PAGE 3 OF 5 October 4, 2022. For the most recent version visit our web site. Questions to evan.manvel@dlcd.oregon.gov page 4 In Oregon Coburg Eager to boost development in its downtown, Coburg updated its codes in 2020 to repeal parking mandates, except for employee parking. It is too early to judge the outcomes. Eugene Eugene has not required off-street parking for downtown developments for several years. Despite that, a large new development at 13th and Olive included hundreds of units of 2, 3 and 4-bedroom housing (1308 bedrooms total), and two large new parking garages, as part of a business model. They’re in part used for paid public parking, and monthly rentals. In the absence of mandates, hundreds of parking spots were developed. Tigard In an effort to spur redevelopment, Tigard adopted a “Lean Code” in 2017 for the Tigard Triangle. That code included a removal of off-street parking mandates while adding requirements for on-street parking and public bike parking spaces. In the five years since, the City has seen significant redevelopment in the area. Builders continue to provide off-street parking, at levels slightly lower than previously required. Builders have also found creative ways to use shared parking. Unnecessary building expenses have been reduced. The city is now developing a Curbside Management Plan to ensure effective use of the curb for parking, deliveries, ride hailing, transit, and micromobility options, as use of the area intensifies. Madras Eager to boost development in its downtown, in 2022, the Madras City Council passed a resolution to repeal its parking mandates in the downtown core. The decision was made as part of a code update funded by Oregon’s Transportation and Growth Management program. It is too early to judge the outcomes. Portland Portland has had limited parking mandates for quite some time, helping housing get built and providing for more infill. One oft-cited anecdote about parking is challenges finding spaces in the SE Division Street corridor. People understand that different ways. One way is parking in the neighborhood is difficult because too many people love the neighborhood and want to live there or visit. Another would note the city hasn’t yet fully managed the area’s parking demand with permits, pricing, signage, and other parking management techniques. Most of Portland also has no parking mandates but gets little attention. Attempts to build a new parking garage in Northwest Portland, near 21st and 23rd, have run into realities of the costs of doing so. Hence, Portland has worked in various ways to decrease demand for parking, such as its Transportation Wallet (providing affordable transportation choices) funded through parking permits, and on-street permit costs of $195/year in Northwest (less for low-income people). … too many people love the neighborhood and want to live there or visit. Despite not having to build parking by mandate, one downtown builder included two parking garages with hundreds of spaces. PP 22-0001 ATTACHMENT L/PAGE 4 OF 5 October 4, 2022. For the most recent version visit our web site. Questions to evan.manvel@dlcd.oregon.gov page 5 Oregon City Since 2013, Oregon City has not required off-street parking for single-family detached housing and duplexes. Most new homes are still typically built with garages and driveways, due to market preferences. But in a few cases, the lack of parking mandates has allowed infill development to be constructed at a lesser cost. One creative example is these smaller homes that hit a $325,000 sales price in the city where median home price is $575,000. Salem In 2019, the City of Salem approved an application for a six-story, mixed-use downtown development for ground-floor commercial space and 148 units above. The development has 14 parking spaces in addition to secure bicycle parking. The units consist mainly of micro-housing studios, with some one and two-bedroom units. Building on the positive outcomes from that experience, and at staff recommendation, City Council passed code updates in 2020 that aimed to remove barriers to the development of multifamily housing. The code changes eliminated parking mandates for multifamily developments throughout downtown and within ¼ mile of the core transit network. Several local builders testified they would continue to build parking, as it was part of their business model. In 2022, the city implemented HB 2001 to allow traditional missing middle housing throughout Salem; that code change eliminated parking mandates for two, three, and four-unit developments and cottage clusters. Later in 2022, the city updated its Comprehensive Plan and associated maps and zoning code. As part of that citywide project, the city aimed to further incentivize infill housing and redevelopment near frequent transit service. It did so by eliminating parking mandates for any use in a mixed-use zone near the core transit network as long as multifamily housing was included. Reform Communities Around the World Scores of communities throughout the world have eliminated their parking mandates. Some of them: Alameda, CA Albermarle, NC Ann Arbor, MI Auburn, ME Bandera, TX Bastrop, TX Berkeley, CA Berlin, Germany Boston, MA Boston, MA Branson, MO Bridgeport, CT Calgary, AB Cambridge, MA Canandaguia, NY Dover, NH Dunwoody, GA Ecorse, MI Edmonton, AB Fayetteville, AR Greensboro, NC Hartford, CT High River, AB Hudson, NY Jackson, TN Kingston, ON Lunesurg, NS Mancelona, MI Mason City, IA Mexico City Minneapolis, MN New Zealand (metro areas) Norman, OK Ottowa, ON Peoria, IL Raleigh, NC Raleigh, VA Richmond, VA River Rouge, MI Sacramento, CA Saranac Lake, NY Seabrook, NH South Bend, IN Spartanburg, SC St Paul, MN Toronto, ON Questions, Corrections or Comments Evan Manvel, Climate Mitigation Planner (971) 375-5979, evan.manvel@dlcd.oregon.gov One reduced-parking housing project led to broader reforms. Those reforms then led to further reforms. PP 22-0001 ATTACHMENT L/PAGE 5 OF 5 Climate-Friendly and Equitable Communities Why this Rulemaking In 2007, Oregon legislators adopted a policy and goal to reduce Oregon’s climate pollution by 75% by 2050. That’s what the science calls for, if we’re going to avoid catastrophic impacts to our environment, communities, and economy. Fifteen years later, we’re far off track in our efforts to meet those goals – and we’re already experiencing real-world impacts of climate disruption, with increasing wildfires, in size, severity, and timing, and record heat waves that have cost Oregonians their homes, and their lives. We’re particularly off-track in reducing pollution from transportation, responsible for about 38% of Oregon’s climate pollution. On our current path, Oregon will only reduce transportation pollution by about 20% by 2050. That means we’re polluting far more than we hoped, meaning more extreme weather events, more wildfires, more ocean acidification, and more record heat waves. In response, Governor Brown directed state agencies to promote cleaner vehicles, cleaner fuels, and less driving. Meanwhile, the State of Oregon is grappling with a troubling history and current patterns of inequity and discrimination, including in our land use, zoning, and transportation investment (and disinvestment) decisions. Wealth and health have been concentrated in the privileged, at the expense of others. This rulemaking aims to take some steps in redressing past harms. Rulemaking Overview and Desired Outcomes The Land Conservation and Development Commission launched the Climate-Friendly and Equitable Communities rulemaking in September 2020. The commission directed the Department of Land Conservation and Development (DLCD), Oregon’s land use planning agency, to draft changes in Oregon’s planning system for communities in Oregon’s eight most populated areas (see map at right). The rules require those communities to change their local transportation and land use plans to do more to ensure Oregonians have more safe, comfortable ways to get around, and don’t have to drive long distances just to meet their daily needs. The rules also aim to improve equity, and help community transportation, housing, and Thousands of Oregonians have lost their homes in recent wildfires. Missing our climate goals will mean more extreme and more frequent weather events such as heat bombs, droughts, and wildfires. The rules apply in Oregon’s eight metropolitan areas shown above. Oregon is dramatically off-track. If current trends continue, Oregon will release more than 4 times more transportation pollution than our goal by 2050. PP 22-0001 ATTACHMENT M/PAGE 1 OF 6 planning serve all Oregonians, particularly those traditionally underserved and discriminated against. What does that mean on the ground? It means having some areas where rules don’t get in the way of more walkable neighborhoods. The rules ask 15 communities to designate climate- friendly areas, and to allow people to build taller buildings providing more housing. The rules don’t require taller buildings, but make sure those buildings are allowed. In climate-friendly areas, a minimum density standard would help ensure transit can serve the neighborhood. Other provisions of the rulemaking call for new buildings to support the growing electric vehicle transformation, reduce one-size-fits-all parking mandates, and increase local planning requirements to address critical gaps in our walking, biking, and transit networks. The rules ask communities to identify transportation projects needed so our climate goals could be met. The rulemaking is mainly about letting climate-friendly development happen where people want to build it and the market calls for it. There’s a lot of demand for housing where people can walk to where they want to go. While single-family homes will continue to be allowed and provide most housing, Oregonians have a diverse set of housing desires and deserve more affordable and climate-friendly choices. Those could better meet the changing shape of American households, as nearly a third of homes hold just one person. But again, people can choose what best meets their needs. Equitable Mapping, Engagement and Decision-Making One central outcome of this rulemaking is an increased emphasis on equity. The rulemaking has worked to integrate equity, starting with the rulemaking charge and title. Equity was key as DLCD attempted to have the composition of the advisory committee reflect the diversity of Oregon’s communities, and equity was one of the first tasks tackled by the group. The rulemaking advisory committee spent significant time at many of its meetings discussing equity, and developed an Equitable Outcomes Statement to guide the rulemaking drafting and implementation. The rulemaking conducted a racial equity analysis of the rules and an analysis on how the rules could be improved to serve people with disabilities. The committee subsequently reviewed a table listing how each item in the Equitable Outcomes Statement was or was not brought forth into the draft rules, and what next steps might be. The rules define traditionally underserved populations to include Black and African American people, Indigenous people, People of Color, people with limited English proficiency, people with disabilities, low-income Oregonians, youth and seniors, and more. They require mapping of traditionally underserved populations, local consideration of a set of anti-displacement actions should decisions contribute toward displacement, centering the voices of underserved populations in decision-making, and regular reporting on efforts to engage traditionally underserved populations. 1938 Redlining map of Portland. Redlining allowed white people to build wealth through homeownership. PP 22-0001 ATTACHMENT M/PAGE 2 OF 6 Climate-Friendly Areas A climate-friendly area is an area where residents, workers, and visitors can meet most of their daily needs without having to drive. They are urban mixed-use areas that contain, or are planned to contain, a greater mix and supply of housing, jobs, businesses, and services. These areas are served, or planned to be served, by high quality pedestrian, bicycle, and transit infrastructure to provide frequent, comfortable, and convenient connections to key destinations within the city and region. Why are climate-friendly areas important? A key component of Oregon’s plan to meet our climate pollution reduction and equity goals is facilitating development of urban areas in which residents are less dependent upon the single occupant vehicle. Before the automobile became common in American life, cities grew more efficiently, with a variety of uses in city centers and other areas that allowed for working, living, and shopping within a walkable or transit accessible area. Over the last 100 years, the automobile and planning practices have served to separate activities, creating greater inequities within cities and widespread dependence upon climate- polluting vehicles to meet daily needs. Climate-friendly areas will help to reverse these negative trends, with some actions taking place in the short term, and others that will occur with development and redevelopment over time. The rules require cities, and some urbanized county areas, with a population over 5,000 within the seven metropolitan areas outside of Portland Metro to adopt regulations allowing walkable mixed-use development in defined areas within urban growth boundaries. The rules for the Portland Metro area support implementation of the region’s 2040 Growth Concept. Areas will be sized to accommodate a portion of the community’s housing, jobs, and services. Local governments will determine where these areas will be located, but many of these areas will likely be established in existing downtowns that may currently allow for mixed uses and higher densities. Associated requirements will ensure high quality pedestrian, bicycle, and transit infrastructure is available within these areas to provide convenient transportation options. The rules provide a process for local governments to first identify potential climate-friendly areas, then later to adopt development standards for the areas best-suited for this purpose. The rules provide some minimum requirements for climate-friendly areas, with a set of clear and objective standards that may be adopted, or a process for local governments to craft their own standards. Cities of more than 10,000 will monitor housing production within these areas over time and develop strategies to facilitate desired development. Reforming Costly Parking Mandates Excess parking has a significant negative impact on housing costs, business costs, the feasibility of housing development and business redevelopment, walkability, air and water pollution, climate pollution, and general community character. Parking mandates force people who don’t own or use cars to pay indirectly for other people’s parking. Carless households tend to be the poorest households. Parking demand varies significantly Parking uses a huge amount of high-value land. Off-street parking in downtown Corvallis in red. Oregon already has some climate-friendly areas, pleasant places to meet one's needs without needing to drive. PP 22-0001 ATTACHMENT M/PAGE 3 OF 6 from development to development, and about one-sixth of Oregon renter households own zero vehicles. Planning practices of the past have imposed a one-size-fits-all requirement everywhere, creating incentives to own more cars and drive more. The rules encourage the diversity of parking needs to be met by the diversity of development. The rules would reduce or remove costly parking mandates for desired types of development, such as smaller housing types, small businesses, childcare facilities, multi-family housing, and historic buildings. The rules would completely remove parking mandates within one-half mile of frequent transit and three-quarters of a mile of rail stops, where parking demand is lower per unit. The rules give communities options to improve parking management. Those who adopt best practice parking policies would get more flexibility. The rules require cities with over 100,000 population that choose to continue to mandate off-street parking to eventually charge at least 50 cents per day for 10% of on-street parking spots. Getting Ready for Oregon’s Electric Vehicle Future Making our vehicles cleaner is a key part in meeting Oregon’s climate goals. Oregon has a vision where 90% of new vehicles will be electric by 2035. To meet that goal, we need to ensure people can charge their vehicles. The most convenient place to do so is at home, but many Oregonians live in older multi-family homes that would be very expensive to retrofit. Thus, the rules require new housing and mixed-use development with at least five units would include electrical conduit (pipes) to 40% of spots, ready for adding wiring and charging stations to support electric vehicles as the market expands. Planning for a Future of Transportation Options DLCD and other state agency partners including the Oregon Department of Transportation will provide a range of new and amplified services to help meet greenhouse gas reduction goals, including grants, technical assistance, tools, and publications, to help local governments adopt plans that meet or exceed the state’s climate pollution reduction goals. Local governments in Oregon have been required to make coordinated land use and transportation plans for decades. The updated rules would require local governments in metropolitan areas to: • Plan for greater development in transit corridors and downtowns, where services are located and less driving is necessary; • Prioritize system performance measures that achieve community livability goals; • Prioritize investments for reaching destinations without dependency on single occupancy vehicles, including in walking, bicycling, and transit; • Plan for needed infrastructure for electric vehicle charging; and • Regularly monitor and report progress. Transportation options are critical for everyone, but particularly the roughly one-in-three Oregonians who cannot drive. Building a complete network of EV charging stations at commercial and multi-family housing locations could cut up to 11.9% of climate pollution PP 22-0001 ATTACHMENT M/PAGE 4 OF 6 Planning to Meet Our Climate Goals DLCD’s regional greenhouse gas reduction program allows areas to work together to consider statewide, regional, and local needs and issues. The flexible regional planning process allows communities to study economic development, fiscal impacts, resource use, pollution impacts, and the effects of different choices on the state, region, community, or households. The results are intended to help local government community members, elected and appointed leaders better understand issues and quantify the effect of potential policies as they review and update the area’s long-range plans and make investment decisions. The rules expand requirements for regional plans to meet the state’s climate pollution reduction targets from the Portland metropolitan area to the next largest metropolitan areas in the state (Eugene-Springfield and Salem-Keizer) initially. Other metropolitan areas will be required to evaluate their local plans towards meeting the state’s climate pollution reduction targets and amend their local plans towards meeting the target. Community Engagement We’ve heard from lots of Oregonians over the past eighteen months. We’ve heard from a 40-person advisory committee including representatives from all of Oregon’s impacted eight urban areas, several people who are home builders, realtors, representatives of the trucking industry, affordable housing advocates, land use advocates, community-based and other community- serving organizations. To supplement those deliberations, staff held two separate series of virtual community conversations in 2021 – five in the spring, and four in the fall. Staff have hosted a series of nine technical work group meetings on specific topics, a series of practitioner meetings with local government staff in each region, and dozens of additional meetings with local elected officials, planning staff, and interest groups. Upcoming conversations include events focused on what will be needed at the community level to support implementation and ongoing engagement strategies. We’ve heard from hundreds of Oregonians who have attended one or more of the scores of meetings, community conversations, work groups, or practitioner meetings, and from hundreds of people who’ve submitted comments (summary here). Our rules are better for it, having continued to evolve and improve. But the engagement won’t end there – the rules require local governments to engage their communities as they make key decisions on how the rules apply locally. If you’re interested in these issues, we encourage you to stay engaged. Some members of the rulemaking advisory committee PP 22-0001 ATTACHMENT M/PAGE 5 OF 6 Implementing the Rules: Resources and Timelines Local governments are responsible for implementing the rules. Many of the rules take effect when a community next conducts a major update of its Transportation System Plan (TSP), a community’s core document describing its transportation needs and future plans. The rules state most plans should be updated by December 31, 2029. The rules have Salem-Keizer and Eugene-Springfield areas on a schedule to do regional scenario plans and update their TSPs by the end of 2027. The land use components of the rules have specific deadlines. Communities are asked to study potential Climate-Friendly Areas by December 31, 2023, and adopt Areas by December 31, 2024. Parking reform is scheduled to happen in two phases - the first at the end of 2022, and the second by June 30, 2023. Communities may ask for some flexibility around most of these dates. DLCD is providing or working to find resources for local governments to do this work, along with our agency partners at the Oregon Department of Transportation (ODOT) and the Oregon Housing and Community Services Department. The Oregon Legislature provided $768,000 to assist with implementation on land use, and ODOT has identified another $18 million to assist with transportation plan updates. Learn More Information on how to get implementation updates via email and many additional materials can be found at www.oregon.gov/lcd/CL/Pages/CFEC.aspx Contact Information Evan Manvel, Climate Mitigation Planner evan.manvel@dlcd.oregon.gov 971-375-5979 Cody Meyer, Land Use and Transportation Planner cody.meyer@dlcd.oregon.gov 971-239-9475 Kevin Young, Senior Urban Planner kevin.young@dlcd.oregon.gov 503-602-0238 July 2022 PP 22-0001 ATTACHMENT M/PAGE 6 OF 6 C limate-Friendly and Equitable Communities Implementation Guide This document provides guidance for cities and counties within metropolitan areas that are expected to implement the Climate Friendly and Equitable Communities rules. The information provided in this document are based on the rules adopted by the Land Conservation and Development Commission on July 21, 2022. This guide is for information and is not determinative regarding the content or applicability of the adopted rules. Pages 1-3 contain an overview of the implementation and reporting requirements of the rules. The table of implementation dates on pages 3-8 shows the year in which these requirements become applicable, grouped by metropolitan area. The task summaries on pages 9-12 outline the sections of the Division 12 rules that are involved with the major task groups. Alternative Dates: Cities, counties, or Metro may, optionally, propose alternative implementation dates for some deadlines as provided in OAR 660-012-0012(3). Alternative dates would be submitted to the department, reviewed against criteria, and approved (or not) by the DLCD Director. Alternative compliance dates for Eugene-Springfield and Salem-Keizer metropolitan area would use this process and the work program process for scenario planning in OAR 660-044-0100. Rules whose implementation dates can be modified through this process are in italics in the guide. Division 12 Exemption: The DLCD Director may grant a full or partial exemption from Division 12 to cities and counties with a population under 10,000 within the urban area (OAR 660-012-0055(7)). The exemption must be requested by the jurisdiction. Exemptions granted shall last for a specified period. Major Task Groups Requirements for the implementation of each task are outlined in the schedule. Details of the rules involved with each task are listed after the schedule table. CFA Study – Study potential climate-friendly areas (CFA) (660-012- 0315). CFA Codes – Designate and make comprehensive plan, zoning map and code changes to implement climate-friendly areas (660-012- 0320). Parking A – For new development applications, apply reduced parking mandates near frequent transit and for certain development types (code changes not mandatory; may apply 660-012-0430 and 0440 directly). Parking B – Implement parking regulation improvements, and parking mandate reform (660-012-0400 through 0450). TSP Updates – These rules only apply at the time of a major update to a transportation system plan (TSP). PP 22-0001 ATTACHMNET N/PAGE 1 OF 12 TPR Development Regulations – Transportation Planning Rules (TPR) related regulations; required with major transportation system plan updates, no specific update timeline unless indicated. Implement commercial and residential land use regulations (660-012-0330), and bicycle parking (660-012-630). HNA – Housing Needs Analysis (HNA) (Also known as a Housing Capacity Analysis, or HCA). Update required by OAR Chapter 660-008- 0045 for cities over 10,000 population. HNA within Metro must be updated every 6 years; outside of Metro must be updated every 8 years. HNA is an additional task that is not part of Climate-Friendly and Equitable Communities. Individually Applicable Rules Rules separate from the major task groups and with their own applicability date are listed below and in the schedule. EV Conduit – Cities only; for new multifamily and multi-use development applications, require 40% of spaces have conduit to serve electric vehicle charging (OAR 660-012-0410); implement by March 31, 2023 per OAR 660-012-0012(5)(d); either directly apply state administrative rules or amend local development standards. Transportation Modeling – transportation modeling or analysis used for a land use decision must comply with OAR 660-012-0210; decision must not increase VMT per capita; effective as of June 30, 2024 per OAR 660-012-0012(5)(a). Performance Standards – Implement multiple transportation performance standards for plan amendments and development review per OAR 660- 012-0215; effective as of June 30, 2025 per OAR 660-012-0012(4)(b). Additional CFA Designations for UGB Expansions is required beginning June 30, 2027 (OAR 660-008-0010(3)). Note: TSP Update and TPR Development Regulations apply to all jurisdictions in the table listed below. The proposed rules do not establish an implementation deadline if ‘TSP Update’ and ‘TSP Development Regulations’ are not shown in the schedule. They are not exempt from these requirements. A deadline for these tasks may be established through approval of alternate compliance dates. TPR Reporting OAR 660-012-0900 requires cities and counties outside of Metro to submit yearly reports. The reporting requirements are listed in the row of each metropolitan area (light blue background). The designation of major reports in this guide are based on expected dates of Regional Transportation Plan (RTP) updates. The timing of a major report will be as determined by actual RTP adoption (OAR 660-012-0900(5)). The reporting requirement applies to each jurisdiction individually, although jurisdictions may coordinate to submit one report for the metropolitan area. Inside Metro, annual reporting will be completed by Metro (cities and counties within Metro not required to submit individual reports). PP 22-0001 ATTACHMNET N/PAGE 2 OF 12 Population Growth Climate-Friendly Areas- OAR 660-012-0310(4)(a) and (b) specify CFA compliance timelines for jurisdictions that surpass population thresholds of 5,000 or 10,000. Such jurisdictions must submit a CFA Study within 545 days of exceeding the population threshold, and adopt CFA Codes within 365 days of the deadline for submittal of the CFA Study. Additionally, OAR 660-008-0010(2) requires the designation of additional climate friendly areas as cities over 10,000 grow, in conjunction with required HNA updates. Parking – OAR 660-012-0012(4)(f)(A) allows one year for jurisdictions that surpass population thresholds in OAR 660-012-0400 to comply with the parking rules to which they become subject. Compliance date for tasks in italics can be modified per OAR 660-012-0012(3) 2022 2023 2024 2025 2026-2028 2029 Albany Area TPR major report (5/31)1 TPR minor report (5/31) TPR minor report (5/31) (major in 2028) TPR minor report (5/31) Albany Parking A CFA Study EV Conduit Parking B CFA Codes Transportation Modeling Performance Standards 2028 HNA Additional CFA for UGB expansions after June 2027 TSP TPR Dev. Regs. Benton County, Linn County, Marion County (fewer than 5,000 population inside UGB) Transportation Modeling Performance Standards Jefferson, Tangent, and Millersburg Parking A EV Conduit Parking B Transportation Modeling Performance Standards 1 Next expected RTP updates: 2022: Central Lane, Corvallis; 2023: Albany, Salem-Keizer; 2024: Middle Rogue; 2025: Bend, Rogue Valley. TPR major report expected the year following adoption of RTP update. Future RTP updates expected every 4 years. PP 22-0001 ATTACHMNET N/PAGE 3 OF 12 Compliance date for tasks in italics can be modified per OAR 660-012-0012(3) 2022 2023 2024 2025 2026-2028 2029 Bend Area TPR minor report (5/31) TPR minor report (5/31) TPR minor report (major report 2026) (5/31) TPR minor report (5/31) Bend Parking A CFA Study EV Conduit Parking B CFA Codes HNA Transportation Modeling Performance Standards Additional CFA for UGB expansions after June 2027, and with HNA Updates TSP TPR Dev. Regs. Deschutes County 2 Transportation Modeling Performance Standards TSP TPR Dev. Regs Central Lane Scenario Plan work program (6/30) Scenario Plan (12/31) TPR minor report (5/31) TPR minor report (5/31) Scenario Plan code amendments and TSP (12/31) TPR minor report (5/31) (major in 2028) TPR minor report (5/31) Coburg Parking A EV Conduit Parking B Transportation Modeling Performance Standards TSP (2026) TPR Dev. Regs. Eugene Springfield Parking A CFA Study EV Conduit Parking B CFA Codes Transportation Modeling Springfield HNA Performance Standards TSP (2026) TPR Dev. Regs. Eugene 2026 HNA Additional CFA for UGB expansions after June 2027 Lane County3 Transportation Modeling Performance Standards TSP (2026) TPR Dev. Regs. 2 Deschutes Co. population within UGBs in the metropolitan area is >5,000. However, Parking A, Parking B, CFA Study, and CFA Codes are not assumed to be applicable because the county does not provide urban services to these areas (OAR 660-012-0310(3); OAR 660-012-0400(1)(b)). 3 Lane Co. population within UGBs in the metropolitan area is >5,000. However, Parking A, Parking B, CFA Study, and CFA Codes are not assumed to be applicable because the county does not provide urban services to these areas (OAR 660-012-0310(3); OAR 660-012-0400(1)(b)). PP 22-0001 ATTACHMNET N/PAGE 4 OF 12 Compliance date for tasks in italics can be modified per OAR 660-012-0012(3) 2022 2023 2024 2025 2026-2028 2029 Corvallis Area TPR major report (5/31) TPR minor report (5/31) TPR minor report (5/31) (major in 2028) TPR minor report (5/31) Adair Village Parking A EV Conduit Parking B Transportation Modeling Performance Standards Corvallis Philomath Parking A CFA Study EV Conduit Parking B CFA Codes Transportation Modeling Performance Standards Corvallis 2027 HNA Additional CFA for UGB expansions after June 2027 TSP TPR Dev. Regs. Benton County (fewer than 5,000 population inside UGB) Transportation Modeling Performance Standards Middle Rogue TPR minor report (5/31) TPR major report (5/31) TPR minor report (5/31) TPR major report (5/31) Gold Hill Rogue River Parking A EV Conduit Parking B Transportation Modeling Performance Standards Grants Pass Parking A HNA CFA Study EV Conduit Parking B CFA Codes Transportation Modeling Performance Standards Additional CFA for UGB expansions after June 2027 TSP TPR Dev. Regs. Jackson County Josephine County (fewer than 5,000 population inside UGB) Transportation Modeling Performance Standards PP 22-0001 ATTACHMNET N/PAGE 5 OF 12 Compliance date for tasks in italics can be modified per OAR 660-012-0012(3) 2022 2023 2024 2025 2026-2028 2029 Rogue Valley TPR minor report (5/31) TPR minor report (5/31) TPR major report (5/31) Ashland Central Point Eagle Point Medford Talent Parking A CFA Study EV Conduit Parking B Medford HNA CFA Codes Transportation Modeling Performance Standards Central Pt 2027 HNA Ashland 2029 HNA Additional CFA for UGB expansions after June 2027 TSP TPR Dev. Regs. Jacksonville Phoenix Parking A EV Conduit Parking B Transportation Modeling Performance Standards Jackson County (fewer than 5,000 population inside UGB) Transportation Modeling Performance Standards PP 22-0001 ATTACHMNET N/PAGE 6 OF 12 Compliance date for tasks in italics can be modified per OAR 660-012-0012(3) 2022 2023 2024 2025 2026-2028 2029 Salem/Keizer Scenario Plan work program (6/30) Scenario Plan (6/30) TPR major report (5/31) Scenario Plan code amendments and TSP (6/25) TPR minor report (5/31) TPR minor report (5/31) (major in 2028) TPR minor report (5/31) Salem Keizer Parking A CFA Study EV Conduit Parking B CFA Codes Salem and Keizer HNA Transportation Modeling TSP TPR Dev. Regs. Performance Standards Additional CFA for UGB expansions after June 2027 Marion County Parking A CFA Study Parking B CFA Codes Transportation Modeling TSP TPR Dev. Regs. Performance Standards Polk County (fewer than 5,000 population inside UGB) Transportation Modeling TSP TPR Dev. Regs. Performance Standards Turner Parking A EV Conduit Parking B Transportation Modeling TSP TPR Dev. Regs. Performance Standards PP 22-0001 ATTACHMNET N/PAGE 7 OF 12 Compliance date for tasks in italics can be modified per OAR 660-012-0012(3) 2022 2023 2024 2025 2026-2028 2029 Portland Metro TPR major report (5/31) TPR minor report (5/31) TPR minor report (5/31) (major in 2028) TPR minor report (5/31) TPR Rules specific to Metro: OAR 660-012-0140, Transportation System Planning in the Portland Metropolitan Area; OAR 660-012-0012(4)(d), Climate- Friendly Area implementation within Metro; OAR 660-012-0900(2), TPR Reporting. Metro UGMFP Region 2040 Centers [various jurisdictions] Metro to establish requirements for adoption of Centers Non-adopters to adopt Center boundaries and zoning Durham, Johnson City, Maywood Park, Rivergrove, King City, Wood Village Parking A EV Conduit Parking B Transportation Modeling Performance Standards Beaverton, Cornelius, Fairview, Forest Grove, Gladstone, Gresham, Happy Valley, Hillsboro, Lake Oswego, Milwaukie, Oregon City, Portland, Sherwood, Tigard, Troutdale, Tualatin, West Linn, Wilsonville (10k+) Parking A EV Conduit Parking B Beaverton, Fairview, Gresham, Happy Valley, Hillsboro Lake Oswego, Milwaukie, Portland, West Linn, Wilsonville HNA Transportation Modeling Forest Grove HNA Performance Standards HNA 2026: Sherwood, Troutdale, Tualatin; 2027: Gladstone, Cornelius, Tigard, Oregon City Clackamas County, Washington County Parking A Parking B Transportation Modeling Performance Standards Multnomah County4 4 Cities within Multnomah Co. have land use authority for unincorporated areas within UGB. PP 22-0001 ATTACHMNET N/PAGE 8 OF 12 Task Summaries Parking A Reduced Mandates – OAR 660-012-0430 and OAR 660-012-0440 Effective date December 31, 2022 per OAR 660-012-0012(5)(e)– applies to development applications submitted after that date; either directly apply state administrative rules or amend local development standards o Reduced mandates for specific developments – cannot mandate more than 1 space/unit for residential developments with more than 1 unit o No mandates for small units, affordable units, childcare, facilities for people with disabilities, shelters o Reform near transit - no parking mandates allowed within ¾ mile of light or heavy rail stations or ½ mile of frequent transit corridors Parking B Parking Regulation Improvement – OAR 660-012-0405 By June 30, 2023 per OAR 660-012-0012(4)(f) - amend development standards o Preferential placement of carpool/vanpool parking o Allow redevelopment of any portion of a parking lot for bike or transit uses o Allow and encourage redevelopment of underutilized parking for other uses o Allow and facilitate shared parking o Parking lots more than ¼ acre in size must install 50% tree canopy OR solar panels, solar/wind fee-in- lieu, or green energy per OAR 330-0135-0010; requires street trees and street-like facilities along driveways o Adopt parking maximums in locations such as downtowns, regional or community center, and transit- oriented developments. Parking Maximums and Evaluation in More Populous Cities – 660-012-0415 By June 30, 2023 per OAR 660-012-0012(4)(f) o Cities >100,000 population, or >25,000 population if in Portland Metro, set certain parking maximums in specified areas o Cities >200,000 population also: Study use of on-street timed parking in CFA and transit areas (OAR 660-012-0435 & 0440) Implement parking management before authorizing new 100+ stall parking garages Implement TDM management strategies before authorizing new 300+ stall garages Adopt design requirements so ground floor of parking garage convertible to other uses PP 22-0001 ATTACHMNET N/PAGE 9 OF 12 Parking Mandate Reform Effective date June 30, 2023 per OAR 660-012-0012(4)(f) Option 1 OAR 660-012-0420 Options 2 and 3 OAR 660-012-0425 through 0450 Repeal all parking mandates within the jurisdiction no additional action needed Reduce parking burdens – adopt eight land use regulations related to reduced mandates based on factors such as shared parking, solar panels, parking space accessibility, on-street parking; unbundling of parking from rent for multifamily units near transit (OAR 660-012- 0425) Cities with populations 100,000+ adopt on-street parking prices equivalent to at least 50¢/day per spot for 5%/10% of total on-street parking supply by September 30, 2023/2025 (OAR 660-012-0450; effective dates per OAR 660-012-0012(4)(g)) Parking Reform Approaches Choose ONE of the following (option 2 -or- option 3) Policies to take effect no later than June 30, 2023 (effective date per OAR 660-012-0012(4)(f)) Option 2 OAR 660-012-0445(1)(a) - Adopt at least 3 of 5 policies below Option 3 OAR 660-012-0445(1)(b) - Adopt regulations minimizing or exempting required parking for 15 development types (summarized below) 1. Unbundle parking for residential units 2. Unbundle leased commercial parking 3. Flexible commute benefit for businesses with more than 50 employees 4. Tax on parking lot revenue 5. No more than ½ space/unit mandated for multifamily development No mandates for a variety of specific uses, small sites, vacant buildings, studio/one bedrooms, historic properties, LEED or Oregon Reach Code developments, etc. No additional parking for redevelopments/additions. Adopt parking maximums. No parking mandates within ½ mile walking distance of Climate-Friendly Areas. Designate district to manage on-street residential parking. PP 22-0001 ATTACHMNET N/PAGE 10 OF 12 Climate-Friendly Areas CFA Study OAR 660-012-0315 Due December 31, 2023 per OAR 660-012-0012(5)(b) CFA Codes OAR 660-012-0320 via OAR 660-012-0315(6) Due Date December 31, 2024 per OAR 660-012-0012(4)(c) • CFA location and size standards per OAR 660-012-0310(2) • >10,000 population Dwelling Unit Capacity of at least 30% of current housing needs analysis (OAR 660-012-0315(1); capacity calculated per methodology in OAR 660-012- 0315(2) • Population 5,000 -10,000 Designate at least 25 acres of CFA (OAR 660-012-0315(3)) • Displacement analysis, fair and equitable outcomes plan, and narrative summary of public engagement (OAR 660-012-0315(4)) Required for all CFAs: • Allowed uses per OAR 660-012-0320(2) • Inclusion of existing abutting residential and employment zones without zoning amendments per OAR 660-012-0320(3) • Prioritization of public buildings, open spaces per OAR 660-012- 0320(4) • Block length maximums per OAR 660-012-0320(5) • Address other development regulation requirements per OAR 660-012-0320(7) • Eliminate mandates in and near climate-friendly areas or adopt parking management policies; unbundle parking for multifamily units (OAR 660-012-0435) Housing and Employment Targets OAR 660-012-0320(8) or (9) Option A Residential minimum density standards and allowed building height not less than specified by OAR 660-012-0320(8) Option B Standards other than Option A proposed by jurisdiction that achieve target dwelling unit and employment per acre Transportation System Plan Update • TSP updates may use OAR 660-012-0015 if OAR 660-018-0020 is notice provided by December 31, 2022 (OAR 660-012-0012(2)(a)). • Minor TSP updates need not meet all updated requirements if the updated portions of the plan meet new requirements, and OAR 660-018-0020 notice is provided by June 30, 2027 (OAR 660-012- 0012(2)(b)). • Compliance deadline for Eugene-Springfield and Salem -Keizer determined by OAR 660-044-0015 Scenario Planning. • Cities and Counties over 5,000 population and outside the Portland metropolitan areas must adopt major TSP update by December 31, 2029 (OAR 660-012-0012(4)(a)). Generalized Scope and Process • Overall TSP update requirements (OAR 660-012-0100 and 0105) • Public Engagement and Equity o TSP Planning Engagement generally (OAR 660-012-0120) o Equity and Underserved Populations (OAR 660-012-0125, identifying underserved populations; OAR 660-012-0130, Decision-Making with Underserved Populations; OAR 660-012-0135, Equity Analysis) PP 22-0001 ATTACHMNET N/PAGE 11 OF 12 • System Inventories and Existing Conditions o General inventory requirements (OAR 660-012-0150) o Transportation System Planning Area (OAR 660-012-0110) o Land use assumptions (OAR 660-012-0340) o Modal inventory requirements: Pedestrian (OAR 660-012-0505); Bicycle (OAR 660-012-0605); Transit (OAR 660-012-705); Streets and Highways (OAR 660-012-0805) o Funding projections (OAR 660-012-0115) • Goals, Targets, and Project Prioritization o VMT Targets – base year and horizon year (OAR 660-012-0160) o Adoption of Transportation Performance Standards (OAR 660-012-0215) o Project Prioritization (OAR 660-012-0155) • TSP Contents o Modal design and planning requirements: Pedestrian (OAR 660-012-0510); Bicycle (OAR 660-012- 0610); Transit (OAR 660-012-710); Streets and Highways (OAR 660-012-0810) o Modal projects: Pedestrian (OAR 660-012-0520); Bicycle (OAR 660-012-0620); Transit (OAR 660-012- 720); Streets and Highways (OAR 660-012-0820) o Transportation Options Planning (OAR 660-012-0145) – transportation demand management, transit options and incentives o Enhanced review of select roadway projects (OAR 660-012-0830) – for facilities that may increase driving capacity o Prioritization framework (OAR 660-012-0155) o Unconstrained Project List (OAR 660-012-0170) – combination of modal projects; must meet VMT per capita targets from OAR 660-012-0160; Project Prioritization Framework (OAR 660-012-0155) o Financially-Constrained Project List (OAR 660-012-0180) Created from unconstrained list per procedures in OAR 660-012-0180(3) Sum of projects on list not to exceed 125% of funding available from OAR 660-012-0115 Transportation Planning Rule Development Regulations Land use requirements (OAR 660-012-0330) Effective date per OAR 660-012-0012(4)(e) – TSP Adoption note – implementation of OAR 660-012-0330 within a CFA is required upon adoption of CFA Zoning (OAR 660-012- 0320(7)) • Neighborhood circulation (OAR 660-012-0330(3)) • Mixed use and commercial districts (OAR 660-012-0330(4)) • Bicycle parking regulations in compliance with OAR 660-012-0630 (OAR 660-012-0330(4)(g)) • Slow streets for neighborhoods (OAR 660-012-0330(5)) • Auto-oriented land uses (OAR 660-012-0330(6)) • Allow for Low car districts (cities of 100k+, OAR 660-012-0330(7)) • Protection of transportation facilities (OAR 660-012-0330(8)) PP 22-0001 ATTACHMNET N/PAGE 12 OF 12 Victoria Transport Policy Institute Website: www.vtpi.org Email: info@vtpi.org 1250 Rudlin Street, Victoria, BC, V8V 3R7, CANADA Phone & Fax 250-360-1560 “Efficiency - Equity - Clarity” The Trouble With Minimum Parking Requirements Donald C. Shoup Department of Urban Planning School of Public Policy and Social Research University of California, Los Angeles (UCLA) Los Angeles, California 90095-1656 shoup@ucla.edu 9 December, 1999 Originally Published in Transportation Research Part A Vol. 33 (1999), pp. 549-574 Posted at the Victoria Transport Policy Institute website with author’s permission. Abstract Urban planners typically set the minimum parking requirements for every land use to satisfy the peak demand for free parking. As a result, parking is free for 99 percent of automobile trips in the United States. Minimum parking requirements increase the supply and reduce the price–but not the cost–of parking. They bundle the cost of parking spaces into the cost of development, and thereby increase the prices of all the goods and services sold at the sites that offer free parking. Cars have many external costs, but the external cost of parking in cities may be greater than all the other external costs combined. To prevent spillover, cities could price on-street parking rather than require off-street parking. Compared with minimum parking requirements, market prices can allocate parking spaces fairly and efficiently. PP 22-0001 ATTACHMENT O/PAGE 1 OF 30 The Trouble With Minimum Parking Requirements Donald Shoup 1 How can a conceptual scheme that one generation admiringly describes as subtle, flexible, and complex become for a later generation merely obscure, ambiguous, and cumbersome? THOMAS KUHN Urban planners set minimum parking requirements for every land use. These requirements typically ensure that developers will provide enough spaces to satisfy the peak demand for free parking. This article examines (1) how urban planners set parking requirements, (2) how much the required parking costs, and (3) how parking requirements distort the markets for transportation and land. As a way to eliminate this distortion, I will propose that cities should price on-street parking rather than require off-street parking. The Shaky Foundation of Minimum Parking Requirements Where do minimum parking requirements come from? No one knows. The “bible” of land use planning, F. Stuart Chapin’s Urban Land Use Planning, does not mention parking requirements in any of its four editions.1 The leading textbooks on urban transportation planning also do not mention parking requirements.2 This silence suggests that planning academics have not seriously considered–or even noticed–the topic. This academic neglect has not prevented practicing planners from setting parking requirements for every conceivable land use. Figure 1 shows a small selection of the myriad land uses for which planners have set specific parking requirements. Without training or research, urban planners know exactly how many parking spaces to require for bingo parlors, junkyards, pet cemeteries, rifle ranges, slaughterhouses, and every other land use. Figure 1 Selected Land Uses With Minimum Parking Requirements Asylum Indoor Soccer Facility Rifle Range Bingo Parlor Junkyard Slaughterhouse Convent Kennel Taxi Stand Diet Clinic Landfill Ultra-Light Flight Park Exterminator Massage Parlor Veterinarian Fraternity Night Club Wastewater Treatment Gunsmith Oil Change Shop Zoo Horse Stable Pet Cemetery Source: Selected from the minimum parking requirements for 179 land uses in Planning Advisory Service (1991, 3) Richard Willson (1996) surveyed planning directors in 144 cities to learn how they set parking requirements. The two most frequently cited methods were “survey nearby cities” and “consult Institute of Transportation Engineers (ITE) handbooks.” Both strategies cause serious problems. 1. See Chapin (1957, 1965), Chapin and Kaiser (1979), and Kaiser, Godschalk, and Chapin (1995). 2. See Dickey (1983), Hanson (1995), Meyer and Miller (1984), and Papacostas and Prevedouros (1993). PP 22-0001 ATTACHMENT O/PAGE 2 OF 30 The Trouble With Minimum Parking Requirements Donald Shoup 2 Survey Nearby Cities Although surveying nearby cities seems a sensible way to set parking requirements, the Planning Advisory Service (1971, 1-3) explains a serious problem with this approach: Since the establishment of the principle that zoning ordinances may legally require the provision of off-street parking, ordinance drafters have been asking questions like: “How many spaces should be provided for a drive-in restaurant?”–or any other land use for that matter. The question is typically answered by relying upon what ordinances for other jurisdictions require… The implicit assumption is that other areas must know what they are doing (the ordinances were adopted, after all) and so it is a relatively safe bet to adopt a parking standard “close to the average.” This may simply result in a repetition of someone else's mistakes. Nevertheless, the planner who needs to present a numerical standard by the next planning commission meeting can't answer the original question by saying, “I don't really know.” (italics added) Setting parking requirements by relying on what other cities require not only risks repeating someone else’s mistakes, but also fails to reveal where the requirements came from in the first place. Consult ITE Handbooks To base parking requirements on more objective data, planners consult Parking Generation, published by the Institute of Transportation Engineers. For each land use, this publication reports the “parking generation rate,” defined as the peak parking occupancy observed in surveys by transportation engineers. A vast majority of the data . . . is derived from suburban developments with little or no significant transit ridership… The ideal site for obtaining reliable parking generation data would . . . contain ample, convenient parking facilities for the exclusive use of the traffic generated by the site… The objective of the survey is to count the number of vehicles parked at the time of peak parking demand (ITE 1987a, vii-xv, italics added). The ITE summarizes the survey results and reports the average peak parking occupancy observed at each land use as the parking generation rate for that land use. Half of the 101 reported parking generation rates are based on four or fewer surveys of parking occupancy, and 22 percent of the parking generation rates are based on a single survey. Because parking is free for 99 percent of all automobile trips in the United States, parking must be free at most of the ITE survey sites.3 Parking generation rates therefore typically measure the peak demand for parking observed in a few surveys conducted at suburban sites that offer ample free parking and lack public transit. Urban planners who use these parking generation rates to set minimum parking requirements are making a big mistake. 3. For all automobile trips made on the previous day, the 1990 Nationwide Personal Transportation Survey (NPTS) asked 48,000 respondents, “Did you pay for parking during any part of this trip?” Ninety-nine percent of the 56,733 responses to this question were “No.” PP 22-0001 ATTACHMENT O/PAGE 3 OF 30 The Trouble With Minimum Parking Requirements Donald Shoup 3 Parking Generation is a questionable resource for several reasons. First, parking generation rates are inflated by the ample free parking. Second, no information is provided on several key issues. Why and where were the surveys were conducted? How long did the surveys last? How long did the peak parking occupancy last? Finally, nothing is said about off-peak parking occupancy. Parking Generation raises more questions than it answers. Figure 2 shows Parking Generation’s report for one land use, fast-food restaurants. At the 18 survey sites parking generation ranges from 3.55 to 15.92 parking spaces per 1,000 square feet of floor area.4 The R2 of 0.038 shows that the variation in floor area accounts for less than 4 percent of the variation in peak parking occupancy. Parking generation is essentially unrelated to floor area in the sample. Nevertheless, the average parking generation rate–normally interpreted as the relationship between parking demand and floor area for a land use–is reported as precisely 9.95 parking spaces per 1,000 square feet of floor area. Figure 2 Parking Generation at Fast Food Restaurants with Drive-In Windows Source: Institute of Transportation Engineers (1987a., p. 146) 4. Gross floor area is the building’s total floor area, including cellars, basements, corridors, lobbies, stairways, elevators, and storage. Gross floor area is measured from the building’s outside wall faces. PP 22-0001 ATTACHMENT O/PAGE 4 OF 30 The Trouble With Minimum Parking Requirements Donald Shoup 4 When urban planners consult ITE publications they behave like frightened natives before a powerful totem. For example, the median parking requirement for fast-food restaurants in the United States is 10 spaces per 1,000 square feet of floor area, the same as the ITE’s average parking generation rate.5 Beyond the ITE’s impressive professional reputation, the ITE data appeal to urban planners because minimum parking requirements are intended to meet the peak parking demand, and no one else provides systematic data that relate peak parking demand to land use. Minimum Parking Requirements Inflate Trip Generation Rates How do minimum parking requirements affect the demand for vehicle trips? The ITE publishes Trip Generation to show the demand for vehicle trips associated with various land uses. For each land use, this publication reports the “trip generation rate,” defined as the number of vehicle trips that begin or end at a land use during a given period. In choosing a survey site the ITE (1987b, 23) recommends, “the site should be self-contained with adequate parking not shared by other activities.” Half of the 1,533 reported trip generation rates are based on four or fewer surveys, and 26 percent of the trip generation rates are based on a single survey. As with Parking Generation, the survey sites probably offer free parking. The trip generation rates therefore typically measure the number of automobile trips observed in a few surveys conducted at sites with free parking. Free parking inflates the trip generation rates because vehicle trip demand is higher where the price of parking is lower. Figure 3 shows Trip Generation’s report for fast-food restaurants. It shows the total number of vehicle trips to and from each survey site during a 24-hour period from Monday through Friday. Trip generation ranges from 284 to 1,359.5 vehicle trips per day per 1,000 square feet of floor area among the eight survey sites. The R2 of 0.069 shows that the variation in floor area accounts for less than 7 percent of the variation in vehicle trips. Trip generation is essentially unrelated to floor area in the sample. Nevertheless, the average trip generation rate–normally interpreted as the relationship between vehicle trips and floor area for a land use–is reported as precisely 632.125 vehicle trips per day per 1,000 square feet of floor area. 5. The Planning Advisory Service (1991) surveyed the parking requirements in 127 cities. The median of 10 spaces per 1,000 square feet is for the cities that base their requirements on gross floor area. PP 22-0001 ATTACHMENT O/PAGE 5 OF 30 The Trouble With Minimum Parking Requirements Donald Shoup 5 Figure 3 Trip Generation At Fast Food Restaurants With Drive-Through Windows Source: Institute of Transportation Engineers (1987a., p. 1119) Parking Generation Compared with Trip Generation To test the reliability of parking and trip generation rates, we can compare the number of vehicle trips per day to fast-food restaurants with the peak parking demand at fast-food restaurants. The number of daily round trips to a site divided by the number of parking spaces at the site can be interpreted as the parking turnover rate, which is the number of different cars that occupy a parking space during the day. Table 1 shows both the trip generation rates (expressed in round trips, or half the number of trip ends) and parking generation rates per 1,000 square feet of floor area for all the land uses that are common between the Trip Generation and Parking Generation editions published in 1987 (the most recent edition of Parking Generation). The final column of Table 1 shows the parking turnover rate. For example, on an average weekday a fast-food restaurant generates 316.1 vehicle-round-trips and a peak parking occupancy of 10 spaces per 1,000 square feet of floor area. Therefore, 32 different cars occupy each parking space during an average day (316.1 ¸ 10). PP 22-0001 ATTACHMENT O/PAGE 6 OF 30 The Trouble With Minimum Parking Requirements Donald Shoup 6 Table 1 Trip Generation Rates Compared With Parking Generation Rates Land Use Trip Generation (round trips/day) Parking Generation (parking spaces) Trips Per Parking Space (round trips/space/day) Manufacturing 1.9 1.6 1.2 Furniture store 2.2 1.2 1.8 Industrial park 3.5 1.5 2.4 Residential Condominium 2.9 1.1 2.6 Quality restaurant 47.8 12.5 3.8 Warehousing 2.4 0.5 4.9 Motel 5.1 0.9 5.7 Retirement community 1.7 0.3 6.1 Church 3.8 0.4 9.0 Government office 34.5 3.8 9.0 Discount store 35.6 3.6 10.0 Hardware Store 25.6 2.4 10.6 Supermarket 62.8 2.9 21.9 Tennis courts/club 16.5 0.7 23.2 Fast food w/ drive-thru 316.1 10.0 31.6 Fast food w/o drive-thru 388.6 11.7 33.3 Bank w/ drive-thru 145.6 4.2 34.4 Bank w/o drive-thru 95.0 0.6 150.8 Convenience market 443.5 1.4 314.6 Per 1000 Square Feet Sources: Institute of Transportation Engineers (1987a, b) The parking turnover rate at furniture stores is only 1.8 cars per parking space per day, implying slow business. At churches it is a busy nine cars per space per day, heralding a religious awakening. At government office buildings it is also nine cars per space per day, suggesting that the state has not withered away. At tennis courts it is 23.2 cars per space per day, implying very short games but many of them. These turnover rates are unreliable because the underlying parking and trip generation rates are often based on scant evidence (the parking or trip generation rate is based on only one survey for 4 of the 19 land uses). The surveys of parking generation for each land use were probably conducted at different sites and at different times from the surveys of trip generation. These bizarre turnover rates also suggest a more serious problem: the parking and trip generation rates are misleading guides to transportation and land use planning. The Tail That Wags Two Dogs Free parking is an unstated assumption behind both parking generation rates and minimum parking requirements. Transportation engineers do not consider the price of parking as a variable in estimating parking generation rates. When urban planners set parking requirements they make the same mistake. Urban planners interpret the ITE parking generation rates as the demand for parking, neglecting the fact that demand has been observed only where parking is free. The following five steps describe the dysfunctional interaction between transportation engineers and urban planners. PP 22-0001 ATTACHMENT O/PAGE 7 OF 30 The Trouble With Minimum Parking Requirements Donald Shoup 7 1. Transportation engineers survey parking occupancy at sites that offer ample free parking and lack public transit. The ITE summarizes the peak parking occupancies observed at each land use and reports the parking generation rate. 2. Urban planners use the parking generation rates to set minimum parking requirements for all land uses. Because the required parking supply is so large, the market price of parking is zero, and most new developments offer free parking. 3. Transportation engineers survey vehicle trips to and from sites that offer free parking. The ITE summarizes the data on vehicle trips observed at each land use and reports the trip generation rate. 4. Transportation planners design the roads and highways to satisfy the trip generation rates. Therefore, the transportation system provides enough capacity to satisfy the expected demand for vehicle trips to and from land uses that provide free parking. 5. Urban planners limit land use density so that new development will not generate more vehicle trips than nearby roads and highways can carry. In this five-step process, the unstated assumption of free parking underpins planning for both transportation and land use. Peak parking occupancy observed at sites that offer free parking becomes the minimum number of parking spaces that all development must provide. Ubiquitous free parking then stimulates the demand for vehicle travel. The observed travel demand becomes the guide for designing the transportation system that brings cars to the free parking. Planners limit development density to prevent traffic congestion around the sites that offer free parking. Because of this circular reasoning, free parking is the tail that wags two dogs–transportation and land use. The Cost of Complying With Minimum Parking Requirements Theory and data play small roles in setting parking requirements, and so we should not be surprised that the requirements often look foolish. This foolishness is a serious problem because minimum parking requirements increase development cost and they powerfully shape land use, transportation, and urban form. While urban planners rarely consider the cost of parking requirements, developers rarely have the luxury of not considering this cost. The Cost of Parking Spaces What does it cost a developer to comply with minimum parking requirements? We can estimate this cost by taking into account the number of required parking spaces and the cost per space. The Appendix presents evidence that aboveground structured parking often costs about $10,000 per space and that underground parking often costs about $25,000 per space. The most common parking requirement for an office building is four spaces per 1,000 square feet of floor area.6 If 6. Two surveys of parking requirements in 117 cities in Southern California suggest that the typical parking requirement for office buildings is 4 spaces per 1,000 sq-ft. of floor area. The first survey was conducted in 1975, and it was repeated for the same cities in 1993 (Shoup 1995). In both years the most frequent parking requirement (the mode) was 4 spaces per 1,000 sq-ft. of floor area. Sixty-five percent of the cities that required less than the mode in 1975 had increased their requirement by 1993, and none had reduced it. Eighty percent of the cities that required more than the mode in 1975 had reduced their requirement by 1993, and none had increased it. These changes doubled the percentage of cities requiring 4 spaces per 1,000 sq-ft. from 27% in 1975 to 54% in 1993. PP 22-0001 ATTACHMENT O/PAGE 8 OF 30 The Trouble With Minimum Parking Requirements Donald Shoup 8 aboveground parking costs $10,000 per space, the cost of providing the required parking is $40 per square foot of floor area (4 x $10,000 ¸ 1,000). If underground parking costs $25,000 per space, the cost of the required parking is $100 per square foot of floor area (4 x $25,000 ¸ 1,000). In Los Angeles the average construction cost of an office building, excluding the cost of parking, is about $150 per square foot.7 Therefore, in this example, the cost of four aboveground parking spaces per 1,000 square feet of office space increases the cost of the office space by 27 percent ($40 ¸ $150). The cost of four underground parking spaces per 1,000 square feet of office space increases the cost of the office space by 67 percent ($100 ¸ $150). Because motorists park free for most vehicle trips, they clearly do not pay the cost of providing parking spaces. If motorists do not pay for parking spaces, who does? Minimum parking requirements bundle the cost of parking spaces into the cost of development, and thereby increase the cost of all the goods and services sold at the sites that offer free parking. These requirements “externalize” the cost of parking, so that you cannot reduce what you pay for parking by consuming less of it. Minimum parking requirements bypass the price system in the markets for both transportation and land. The Cost of Parking Spaces Compared with the Cost of Cars Minimum parking requirements increase the supply and reduce the price–but not the cost– of parking. To reveal the size of the resulting subsidy for parking, we can compare the value of parking and cars with what motorists pay for parking and cars. Table 2 shows the number of registered vehicles and the capital value (in current dollars) of these vehicles for the years 1985 to 1995.8 For example, 202 million vehicles were registered in 1995, and this stock of vehicles was valued at $1,079 billion, or $5,352 per vehicle.9 How does this value of vehicles compare with the value of parking spaces? 7. The average cost of $150 per square foot refers to Class A, steel-framed office buildings. This figure includes construction cost, tenant improvement costs, and “soft” costs such as financing, insurance, and real estate taxes during construction, but excludes the cost of parking. This figure was supplied by the Los Angeles County Assessor. 8. The U.S. Department of Commerce has estimated the total value of all fixed reproducible tangible wealth in the United States for the years 1929 to 1995. One category of this wealth is the capital value of all vehicles (cars and trucks). The capital value of an asset in each year is defined as the cumulative value of past gross investment in that asset minus the cumulative value of past depreciation. 9. Because 65 percent of all vehicles were more than five years old in 1995, depreciation explains the low average value of $5,352 per vehicle. PP 22-0001 ATTACHMENT O/PAGE 9 OF 30 The Trouble With Minimum Parking Requirements Donald Shoup 9 Table 2 The Value of Motor Vehicles in the United States Year Registered Vehicles Capital Value of Vehicles (million)Total (US$ billion)Per Vehicle (US$/vehicle) 1985 172 614 3575 1986 176 688 3918 1987 179 731 4085 1988 184 790 4286 1989 187 833 4446 1990 189 868 4595 1991 188 879 4673 1992 190 910 4778 1993 194 961 4952 1994 198 1032 5211 1995 202 1079 5352 Sources: Katz and Herman (1997) for capital values and Federal Highway Administration (1995) for number of vehicles. Values are expressed in current dollars of each year. Minimum parking requirements are intended to satisfy the expected peak demand for parking at every land use–at home, work, school, banks, restaurants, shopping centers, movie theaters, and hundreds of other land uses from airports to zoos. Because the peak parking demands at different land uses occur at different times of the day or week, and may last for only a short time, several off-street parking spaces must be available for every motor vehicle. Although no one knows the number of parking spaces per car, Victor Gruen (1973) estimated that for every car there must be at least one parking space at the place of residence and three to four spaces elsewhere. Suppose there are four parking spaces per vehicle. If the average vehicle is worth $5,352 and if there are four parking spaces per vehicle, the average vehicle value per parking space is $1,338 ($5,352 ¸ 4). Therefore, if the average land-and-improvement value of a parking space exceeds $1,338, the average value of four parking spaces exceeds the average $5,352 value per vehicle they serve. Because $1,338 is a very modest sum for both the land and construction cost of a parking space, the total value of all parking spaces probably exceeds the total value of all vehicles. Motorists pay for their vehicles (worth $1.1 trillion in 1995) but they park free for 99 percent of automobile trips.10 Motorists pay so little for parking because parking requirements bundle the cost of parking into the cost of development. Parking is free for most automobile trips only because its cost has been shifted in to higher prices for everything else. Everyone pays for parking whether they use it or not. Cars have many external costs, but the cost of parking in cities may be 10. The total receipts of all private and public parking operators in the United States was only $4.4 billion in 1992. Private operators received 83 percent of this revenue, and municipalities received 17 percent. The 1992 Census Data on Service Industries reports the revenue for private parking facilities, and the 1992 Census of Governments reports revenue from municipal parking facilities. Parking operators receive revenue that motorists do not pay when someone else pays it for them–as with validated and employer-paid parking. On the other hand, the Census data do not include the parking receipts of establishments primarily engaged in activities other than parking (department stores, hospitals, and restaurants, for example). If these two factors cancel each other, motorists paid about $4.4 billion for parking in 1992. PP 22-0001 ATTACHMENT O/PAGE 10 OF 30 The Trouble With Minimum Parking Requirements Donald Shoup 10 far greater than all these other external costs combined. By hiding a huge share of the cost of owning and using cars in cities, minimum parking requirements intensify all the other problems of external cost (such as air pollution and traffic congestion), making an already bad situation far worse. Minimum parking requirements distort transportation and land use. They are not, however, the first example of an unwise professional practice that has produced unintended consequences. A medical analogy illustrates the problem. An Analogy: Lead Poisoning Parking requirements in urban planning resemble lead therapy in medicine. Lead has antiseptic properties because it is toxic to microorganisms, and until the twentieth century physicians prescribed lead to treat many ailments. One popular medical treatise recommended the using lead as a therapy for abscesses, burns, cancer, contusions, gout, gunshot wounds, inflammation, itch, piles, rheumatism, ruptures, sprains, stiffness of the joints, and ulcers.11 Early physicians did not realize that lead is toxic to humans, and lead poisoning went largely unnoticed as a medical problem until the end of the nineteenth century. Nevertheless, a few early critics had recognized lead’s harmful effects. As a printer, Benjamin Franklin had much contact with lead, and he wrote to a friend in 1786, The Opinion of this mischievous effect from lead is at least above sixty years old; and you will observe with Concern how long a useful Truth may be known and exist, before it is generally receiv’d and practis’d on.12 Lead continued to be used as medicine for more than a century after Franklin’s warning, and folk remedies continue to use it as an ingredient today. Lead has local antiseptic properties, but any local benefit comes at a high price to the whole person. Lead exposure occurred in many ways unrelated to medicine when no one suspected that lead was harmful.13 Minimum Parking Requirements: Urban Lead Therapy Like lead therapy, minimum parking requirements produce a local benefit–they ensure that every land use can accommodate all the cars “drawn to the site.” But this local benefit comes at a high price to the whole city. Minimum parking requirements increase the density of both parking spaces and cars. More cars create more traffic congestion, which in turn provokes calls for more 11. Goulard (1784, p. 2) says, “when the reader has perused the following treatise he will be inclined to think that this metal [lead] is one of the most efficacious remedies for the cure of most diseases which require the assistance of surgery.” 12. Quoted in McCord (1953, pp. 398). 13. Lead poisoning has even been suggested as a cause of the decline of the Roman Empire. Romans prepared their food in lead pots, stored their wine in lead vessels, used lead oxide as a cosmetic, and drank water delivered in lead pipes (the word “plumber”comes from the Latin word for lead, plumbum). Nriagu (1983, 400) estimates that Roman aristocrats’ diets led to an average absorption of 250 micrograms of lead per day, or almost six times the tolerable amount recommended by the World Health Organization. Nriagu conjectures that a diet rich in lead helps to explain why only one of Rome’s original aristocratic families appeared to have any surviving members by the second century AD. PP 22-0001 ATTACHMENT O/PAGE 11 OF 30 The Trouble With Minimum Parking Requirements Donald Shoup 11 local remedies, such as street widening, intersection flaring, intelligent highways, and higher parking requirements. More cars also produce more exhaust emissions. Like lead therapy, minimum parking requirements produce a local benefit but damage the whole system. Minimum parking requirements resemble other primitive medical practices that were adopted without good theory and careful empirical research. Describing a leading medical text written in 1896, Lewis Thomas (1981, 40) says, The public expectation then, as now, was that the doctor would do something. There was no disease for which a treatment was not recommended…. Every other page contains a new, complex treatment always recommended with the admonition that the procedure be learned by rote (since it rarely made any intrinsic sense) and be performed precisely as described. Acute poliomyelitis had to be treated by subcutaneous injections of strychnine; the application of leeches; the administration of belladonna, extract of ergot, potassium of iodide, and purgative doses of mercury; the layering of thick ointments containing mercury and iodine over the affected limbs; faradic stimulation of the muscles; ice-cold shower baths over the spine; and cupping …each of these with a dosage schedule to be followed precisely, some of them singly, others in various combinations… All of this has the appearance of institutionalized folly, the piecing together of a huge structure of nonsensical and dangerous therapy, and indeed it was. The pieces were thought up and put together almost like thin air, but perhaps not quite. Empiricism made a small contribution, just enough in the case of each to launch it into fashion. I suspect that, looking backward a century from now, urban planners will see minimum parking requirements to have been no better than physicians now see lead therapy: a poison prescribed as a cure. Like many discredited and abandoned medical practices, minimum parking requirements are “institutionalized folly.” Many parking spaces are provided voluntarily rather than in response to requirements. And far from being a poison, parking is an indispensable part of the transportation system. What is poisonous, however, is for planners to require massive overdoses of parking. Sometimes a disaster must occur to stimulate the reexamination of customary practices. Minimum parking requirements have produced no single disaster, but evidence of their harm confronts us everywhere–traffic congestion, air pollution, energy imports, the orientation of the built environment around the automobile, perhaps even global climate change. Although not their sole cause, minimum parking requirements magnify all these problems. Likening parking requirements to lead poisoning is a criticism of current planning practice, not of individual planners. Physicians who prescribed lead were making an honest mistake. Urban planners who prescribe parking requirements are, I believe, also making an honest mistake. Although many planners may agree with this criticism, they may also feel that it is unhelpful unless the critic can propose a better way to deal with the parking problem. I will propose an alternative: cities should price on-street parking rather than require off-street parking. PP 22-0001 ATTACHMENT O/PAGE 12 OF 30 The Trouble With Minimum Parking Requirements Donald Shoup 12 An Alternative: Let Prices Do The Planning Minimum parking requirements are a mistake but they respond to a real problem–spillover parking. If a land use does not provide enough off-street parking, some motorists drawn to the site will park on nearby streets, competing for the scarce curb parking supply. Urban planners know that this spillover parking creates enormous political problems. If spillover parking from a new development congests the adjacent curb parking, everyone nearby will angrily ask planners and politicians, “How could you let this happen?” To prevent parking spillover where adjacent curb parking is free, new land uses must provide enough off-street spaces to satisfy the demand for free parking. Free curb parking explains why planners consciously or unconsciously base off-street parking requirements on the demand for free parking. In his survey of planning directors in 144 cities, Richard Willson (1996) asked “Why does your city have minimum parking requirements?” The most frequent response was the circular explanation “to have an adequate number of spaces.” In effect, planners treat free parking as an entitlement, and they consider the resulting demand for free parking to be a “need” they can measure. Because parking requirements are so ingrained in planning practice, complaining about them may seem futile, like complaining about photosynthesis or gravity. If free parking were an entitlement and the goal is to prevent parking spillover, requiring enough off-street parking to meet the demand at zero price would make sense. But free parking is not an entitlement. As the alternative to requiring off-street parking, consider pricing curb parking. The Market Price for Curb Parking The market price for curb parking is the price that matches demand with supply and keeps a few spaces vacant. Traffic engineers usually recommend a vacancy rate for curb parking of at least 15 percent to ensure easy parking access and egress.14 If cities priced curb parking to balance supply and demand with a few vacant spaces on every block, motorists could always find a convenient parking space close to their final destination. 14. See Brierly (1972), May (1975), and Witheford and Kanaan (1972). PP 22-0001 ATTACHMENT O/PAGE 13 OF 30 The Trouble With Minimum Parking Requirements Donald Shoup 13 Figure 4 The Market Price of Curb Parking Figure 4 illustrates the policy of market prices for curb parking. Because the supply of curb spaces is fixed, the supply of curb spaces available with a 15 percent vacancy rate is a vertical line positioned above the horizontal axis at an 85 percent occupancy rate. The demand curve slopes downward, and the market-clearing price of parking occurs where the demand curve intersects the vertical supply curve. For example, when parking demand is high (demand curve D1), the price that will yield a 15-percent vacancy rate is high (P1 is 60¢ an hour). When demand is lower (demand curve D2), a price of only 20¢ an hour will yield a 15-percent vacancy rate. When parking demand is lowest (demand curve D3), the vacancy rate will be 50 percent even when parking is free. If the price of parking is set too high, many parking spaces remain vacant, and a valuable resource is unused. If the price of parking is set too low, the occupancy rate reaches 100 percent, and motorists hunting for a vacant space waste time, congest traffic, and pollute the air. Because the demand for parking rises and falls during the day but the supply of parking is fixed, demand- responsive parking prices would necessarily rise and fall to maintain an “inventory” of vacant parking spaces on each block. The lowest price that will yield a vacancy rate of about 15 percent is the market price of curb parking. Obviously, prices cannot constantly fluctuate to maintain a vacancy rate of exactly 15 percent, but they can vary sufficiently to avoid chronic over- or under-occupancy. Commercial parking operators always set prices high enough to avoid regularly putting out the “full” sign, and cities could contract with commercial operators to price curb parking properly, if necessary. PP 22-0001 ATTACHMENT O/PAGE 14 OF 30 The Trouble With Minimum Parking Requirements Donald Shoup 14 Parking Benefit Districts Elsewhere I have argued that market prices can effectively regulate the off-street parking supply, and that the government’s chief contribution should be to set market prices for curb parking. I have also argued that, to make this pricing solution politically popular, cities could establish Parking Benefit Districts that dedicate curb parking revenue to pay for public services in the neighborhood where the revenue is collected.15 If the benefits financed by parking charges were visible and local, residents would want to charge market prices for curb parking for the revenue, not because they thought it good public policy. Residents who benefit from parking charges paid by strangers would begin to think like parking lot owners. The economic argument to charge for curb parking is efficiency–the benefits would outweigh the costs. The political argument to create Parking Benefit Districts is distribution–the benefits for neighborhoods would lead residents to vote for the proposal. Parking meters have few friends if their revenue disappears into the city’s general fund. Curb parking revenue needs the appropriate recipient–its neighborhood–before residents will recommend market prices for parking. For example, parking revenue could pay to plant street trees, repair sidewalks, or underground utility wires. Curb parking charges would yield more revenue than the property taxes in many neighborhoods, so many residents could reap enormous benefits. Charging strangers to park in front of your house is like Monty Python’s scheme for Britain to tax foreigners living abroad. Charging for parking does not require a meter at every space. Several payment systems–from high-tech electronic in-vehicle meters and multispace meters to low-tech paper stickers–have eliminated the practical and aesthetic objections to charging for parking. Where the potential revenues are high and the collection costs are low, the transaction costs of charging for parking are not a serious objection. The problem is political, not technical, and dedicating curb parking revenue to its neighborhood can solve the political problem. A Model of Parking Choice If market prices allocated parking spaces, how would motorists decide where to park? A simple model of parking choice will help to answer this question. To anticipate the results, market prices will allocate the most convenient parking spaces to motorists who: (a) carpool, (b) park for a short time, (c) walk slowly, and (d) place a high value on reducing walking time. Conversely, market prices will allocate the peripheral parking spaces to motorists who: (a) drive alone, (b) park for a long time, (c) walk fast, and (d) place a low value on reducing walking time. Variables in the Model of Parking Choice Suppose the price of parking is highest at the destinations where parking demand is highest, and that the price declines with distance from these destinations. Since the price of parking increases as you drive toward your destination, you will pay more money to park closer to your destination but you will also spend less time walking from your car to your destination. Given the trade-off 15. See Shoup (1992, 1994, 1995, 1997) for the proposal to use the revenue from market-priced curb parking to finance neighborhood public services. Several new technologies can charge for curb parking without using conventional parking meters. Cities have also begun to subcontract with private enterprises to collect curb parking revenue. PP 22-0001 ATTACHMENT O/PAGE 15 OF 30 The Trouble With Minimum Parking Requirements Donald Shoup 15 between money spent on parking and time spent on walking, where should you park your car and walk the rest of the way? To find the optimal parking space, consider the following variables (and their dimensions): d the distance from parking space to final destination (miles) p(d)the price of parking at distance d from the final destination ($/hour) t parking duration (hours) w walking speed from parking space to final destination (miles/hour) n number of persons in the car (persons) v average value of time spent walking ($/hour/person). The total cost associated with parking at any location is the money cost of parking plus the time cost of walking from the parking space to the final destination and back. The money cost of parking equals the parking duration multiplied by the price per hour, or tp(d).16 The time to walk from the parking space to the final destination and back is 2d/w, the distance walked divided by the walking speed. To convert this time cost of walking into its money equivalent we can multiply the walking time by the dollar value of time, v. Because everyone in the car, n, experiences this time cost, the (monetized) cost of time spent walking equals 2nvd/w.17 At distance d from the final destination the total cost of parking and walking is therefore tp(d) + 2nvd/w.(1) The first term of the expression is the money cost of parking, and the second term is the (monetized) time cost of walking from the parking space to the final destination and back. The Optimal Parking Space What parking location minimizes the total cost of parking and walking? As you drive toward your destination the cost of parking increases and the cost of walking decreases. The minimum total cost of parking and walking occurs where the increase in the money cost of parking balances the decrease in the time cost of walking. If the money cost of parking increases less than the time cost of walking decreases as you approach your destination, you should keep driving. If the money cost of parking increases more than the time cost of walking decreases, you have driven too far.18 16. I assume that you know how long you want to park. Alternatively, you may know only the expected value of how long you want to park. In either case, you pay only for the exact time that you park. The parking charge is a linear function of the number of minutes you park, with no advance commitment to how long you will park. 17. The value of time is the price you are willing to pay to reduce the time spent walking between your parking space and your final destination. It will depend on whether you are in a hurry, how tired you are, packages you are carrying, the weather, and many other circumstances that can vary greatly from trip to trip. 18. This parking location model resembles the Alonso-Mills-Muth housing location model. Muth (1969, 22) explains that the equilibrium housing location is where “the reduction in expenditure necessary to purchase a given quantity of housing that results from moving a unit distance away from the market [equals] the increase in transport costs occasioned by such a move.” If we substitute the words “parking” for “housing” and “walking” for “transport” in this extract, Muth is describing the equilibrium parking location. The quantity of space occupied is variable in the housing decision but fixed in the parking decision, while the time that space is occupied is fixed in the housing decision but variable in the parking decision. PP 22-0001 ATTACHMENT O/PAGE 16 OF 30 The Trouble With Minimum Parking Requirements Donald Shoup 16 Differentiating equation (1) with respect to d and setting the result equal to zero gives the distance from a final destination that minimizes the total cost of parking and walking. t¶p/¶d + 2nv/w = 0, and -t¶p/¶d = 2nv/w.(2) The changes in the money cost of parking (t¶p/¶d) and the time cost of walking (2nv/w) are equal in value and opposite in sign for any small movement from the location that minimizes the total cost of parking and walking. A parking space substantially closer to your final destination will increase the money cost of parking by more than it reduces the time cost of walking. A parking space substantially farther from your destination will increase the time cost of walking by more than it reduces the money cost of parking. The optimal parking space perfectly balances greed and sloth. An Example Suppose the price of parking is $1 an hour at your destination, and that the price declines with distance from your destination according to the negative exponential formula p(d) = $1e-2d.(3) Equation (3) implies that the price of parking, p, declines with distance, d, from the center, and that the slope of the curve relating price to distance also declines with increasing distance from the center (see Figure 5). A negative exponential curve is typical of the relationship between commercial parking prices and the distance from activity centers. Figure 5 The Cost of Parking and Walking Suppose that you want to park for 4 hours (t = 4), you are alone (n = 1), your time is worth $8 an hour (v = $8), and you walk 4 miles an hour (w = 4). Figure 5 shows the cost of parking and of PP 22-0001 ATTACHMENT O/PAGE 17 OF 30 The Trouble With Minimum Parking Requirements Donald Shoup 17 walking as a function of parking d miles from your destination. The money cost of parking 4 hours is $4e-2d, which declines with distance from your destination.19 The time cost of walking is (2x1x$8/4)d, which increases with distance from your destination. The total cost of parking and walking (the upper curve in Figure 5) reaches its minimum value of $3.35 at a distance somewhere between 0.3 and 0.4 miles from your destination. To minimize the total cost of parking and walking you should park about a third of a mile from your destination and walk the rest of the way.20 Solving equation (2) gives the exact distance that minimizes the total cost of parking and walking. Substituting equation (3) into equation (2) and solving for the optimal distance from a final destination, denoted as d*, gives d* = [-loge(nv/tw)]/2.(4) Given the values of n = 1 person, v = $8 an hour, t = 4 hours, and w = 4 miles an hour, the value for d* in equation (4) is 0.34 miles. At this distance the price of parking is 50¢ an hour, so the cost of parking four hours is $2. Walking the round trip of 0.68 miles from parking space to final destination and back at four miles an hour will take about 10 minutes. If time costs $8 an hour, 10 minutes will cost $1.35. The minimum total cost of parking and walking to your destination is thus $3.35 for the trip (see Figure 5).21 The total money-and-time cost curve is flat between 0.25 and 0.5 miles from the destination because the slopes of the money-parking-cost and monetized-time-cost curves are about equal in absolute value but opposite in sign within this range.22 The total cost of parking and walking is about $3.35 anywhere between 0.25 and 0.5 miles from your destination. Parking less than 0.25 miles or more than 0.5 miles from your destination increases the total cost of parking and walking. For example, the total cost of parking and walking is $4 both at your destination and also at 0.8 miles from your destination. Implications of the Model 19. The exponential relationship implies that the parking price gradient gets steeper as you approach your destination (the absolute value of ¶p/¶d increases as d approaches 0). 20. Automobile speed and operating cost have been neglected but are easily added to the model. Parking closer to your destination increases driving time and automobile operating cost. Therefore, the total time-and-money cost of driving, parking, and walking is minimized where the total value of driving and walking time saved by parking closer equals the total parking and automobile operating cost added by parking closer. If a denotes automobile operating cost ($/mile), and s denotes driving speed (miles/hour), total cost is minimized where t(¶p/¶d) = -2nv(1/w - 1/s) + 2a. If a is low and s is high, they are negligible parts of the decision, and the solution for d* reduces to equation (4). 21. If you want to spend 4 hours at your destination, the 10 minutes walking time must be added to the time at your destination, so the total parking duration will be 4 hours and 10 minutes. The additional parking duration will add another 8.5¢ to the parking cost. This result suggest that you should park a bit closer to your destination when you consider the effect of walking time on the total parking cost. To simplify the discussion, this factor has been neglected. A negative value of d* implies that you should park at your destination. 22. The monetized time cost of walking from your parking space to your destination and back increases with distance from your destination at a constant rate of $4 per mile. The money cost of parking decreases with distance from your destination at a rate of $4 per mile at 0.34 miles from your destination. At parking locations closer than 0.34 miles from your destination, the money cost of parking decreases with increasing distance from your destination at a rate of more than $4 per mile. At parking locations farther than 0.34 miles from your destination, the money cost of parking decreases with increasing distance from your destination at a rate of less than $4 per mile. PP 22-0001 ATTACHMENT O/PAGE 18 OF 30 The Trouble With Minimum Parking Requirements Donald Shoup 18 Motorists do not make mathematical calculations when choosing where to park. The proposed parking location model merely expresses in mathematical form some of the various factors that motorists surely consider when they pay to park. The model confirms common sense, but several of its predictions are not immediately obvious. First, the number of persons in a car is as important as the value of their time in determining parking location. For example, a carpool of four people who each value time at $5 an hour (nv = 4 x 5) will choose the same location as a solo driver who values time at $20 an hour (nv = 1 x 20), all else equal. A higher vehicle occupancy and a higher value of time justify parking closer to the final destination. Second, parking duration is as important as the value of time in determining parking location. For example, a solo driver who values time at $10 an hour and parks for one hour (v/t = 10/1) will choose the same location as another solo driver who values time at $20 an hour and parks for two hours (v/t = 20/2), all else equal. A shorter parking duration justifies parking closer to the final destination. Third, the number of persons in a car is as important as parking duration in determining parking location. For example, a solo driver who parks for one hour (n/t = 1/1) will choose the same location as a three-person carpool who park for three hours (n/t = 3/3), all else equal. Table 3 shows the derivatives and elasticities of the optimal distance, d*, with respect to the variables that determine it. The derivative of d* is positive with respect to t and w, which implies that the longer you park and the faster you walk, the farther away you should park. The derivative of d* is negative with respect to n and v, which implies that the more people in your car and the higher value of their time, the closer in you should park. TABLE 3 Elasticity of D* With Respect to Parking Choice Variables Variable Partial Derivative of d* with Respect to Variable i Elasticity of d* with Respect to Variable i t (parking duration)¶d*/¶t = +1/(2t) >0 Ît = +1/(2d*) >0 w (walking speed)¶d*/¶w = +1/(2w) >0 Îw = +1/(2d*) >0 n (number of persons)¶d*/¶n = -1/(2n) <0 În = -1/(2d*) <0 v (value of time)¶d*/¶v = -1/(2v) <0 Îv = -1/(2d*) <0 Note: d* = [-loge(nv/tw)]/2 and Îi = (¶d*/¶i)/(d*/i). The elasticities of d* with respect to the variables that determine it decrease with increasing distance from the center (see Figure 6). For example, the elasticity of d* with respect to the parking duration, t, is +1/(2d*). At d* = 0.25 miles from the center, the elasticity of d* with respect to t is +2, so a 10-percent decrease in the length of time you want to park will shift your optimal parking location 20 percent closer to your final destination.23 23. This result follows from the assumed functional relationship between p and d. In this particular case, the same relative increase in t, w, n, or v will always produce the same absolute change in d*. As d* approaches zero, the elasticities approach infinity. PP 22-0001 ATTACHMENT O/PAGE 19 OF 30 The Trouble With Minimum Parking Requirements Donald Shoup 19 Figure 6 Elasticity of Parking Location Choice These predictions are consistent with previous research on parking choices. David Gillen (1978) developed a model of parking location choice similar to the one expressed in equation (4), although he did not consider the number of persons in a car. Using data from Toronto, Gillen found that motorists who pay for parking by the hour are willing to trade a shorter parking duration for a closer parking location. Using trip data from Vancouver, Brown and Lambe (1972) showed that allocating parking spaces by market prices will minimize the total walking time from parking spaces to final destinations. A linear programming model that minimizes total walking time predicted commercial off-street parking prices with an average error of only 20 percent. The price of curb parking was well below the level that would minimize total walking time. Naturally, a simple model of parking prices like the one presented here does not describe most current parking decisions because parking is free for 99 percent of all automobile trips. The model is a simplified description of parking choice, but its assumptions are far more sensible than the assumptions behind minimum parking requirements.24 24. Several relevant variables and interactions between variables have also been left out of the model. For example, parking closer to your destination incurs additional driving time and automobile expense. How long you want to park depends on the price of parking because you can reduce the parking cost by staying a shorter time at your final destination. How long you want to park also depends on how much time you spend walking because the parking duration is the sum of the time at the final destination and the time walking to and from it. A further complication is that the value of time spent driving can be different from the value of time spent walking. PP 22-0001 ATTACHMENT O/PAGE 20 OF 30 The Trouble With Minimum Parking Requirements Donald Shoup 20 Efficiency and Equity of Charging For Curb Parking If curb parking were priced to yield a minimum vacancy rate of about 15 percent in every location, the resulting price gradients would shift predictably throughout the day as demand shifts. The peak parking prices might occur at employment centers during the day, at entertainment centers during the evening, and in high-density residential areas during the night. Many overlapping price gradients would form a three-dimensional parking price surface whose height at any point is the vertical summation of all the individual gradients. The individual gradients would form around many dispersed centers, like anthills covering a terrain that itself has peaks (the central business districts) and valleys (low density neighborhoods). The price of parking at any location would rise and fall during the day, and the local peaks would shift around like kittens fighting under a blanket. Efficiency Market prices would allocate parking spaces among motorists in a logical way. The more convenient parking spaces would go to carpoolers, those in a hurry, those who want to park for only a short time, those who have difficulty walking, and those more willing to spend money. The best parking spaces could always be reserved for those with physical disabilities. The more distant parking spaces would go to solo drivers, those with time to spare, those who want to park a long time, those who enjoy walking, and those more eager to save money. Even if market prices can efficiently allocate a fixed stock of parking spaces, can market forces alone supply enough spaces to meet the demand for parking? If minimum parking requirements are eliminated, the ratio of parking spaces to cars will decline, and the price of parking will rise. This price rise will have two effects on demand and supply. First, motorists will economize on parking by changing their travel behavior. Shifting to higher occupancy vehicles to spread the cost of parking among more people will reduce the demand for parking. Shifting to walking, cycling, or public transit will also reduce the demand for parking. Shifting vehicle trips to off-peak will reduce the demand for parking at peak hours. Finally, citizens can choose to own fewer cars, and this will reduce the demand for parking. Second, freed from minimum parking requirements, developers will supply parking spaces in response to parking prices. The higher price of parking will encourage developers to voluntarily supply more parking in places where the resulting revenue will cover the cost of providing the parking. Parking will tend to become unbundled from other transactions, and firms that specialize in providing parking will manage more of the parking supply. Off-street parking prices will tend to cover the cost of providing parking spaces, including the cost of land, and these off- street prices will put a ceiling on the price of adjacent curb parking. Flexible market prices can equate demand with the fixed supply of parking in the short run, and these prices will signal where the supply can profitably be increased in the long run. The proper role for the government is to price curb parking to maintain a minimum vacancy rate so that “enough” parking will always be available if motorists are willing to pay for it. PP 22-0001 ATTACHMENT O/PAGE 21 OF 30 The Trouble With Minimum Parking Requirements Donald Shoup 21 Market prices for parking resemble a spot market for land. Demand-responsive parking prices would reveal what parking spaces are really worth, and how motorists are willing to change their travel choices to save money on parking. Motorists could choose parking spaces according to how long they want to stay, how many people are in the car, how they value walking time (are they in a hurry? are they carrying heavy packages? are they tired? are they short of money?) and many other circumstances of time and place that only the individual motorists can know. In contrast to the “spontaneous” order created by market prices and individual choices, urban planners require almost every land use to provide at least enough parking spaces to satisfy the peak demand for free parking. As a result, parking is free for almost every automobile trip because the cost of parking is shifted into higher prices for almost everything else. Minimum parking requirements in zoning ordinances are a disastrous substitute for millions of individual evaluations of what a parking space is worth. Equity The proposal to price curb parking rather than require off-street parking raises a serious political question. Is it fair to charge motorists for parking? To judge whether charging for parking is fair, it must be compared with the alternative–minimum parking requirements. Minimum parking requirements force everyone to pay for parking through higher prices for all other goods and services, but everyone does not benefit equally from free parking.25 On average, households with incomes below $10,000 a year own only one car, while households with incomes above $40,000 a year own 2.3 cars. Eight percent of non-Hispanic White households, 19 percent of Hispanic households, and 30 percent of African-American households do not own a car. In total, 10.6 million American households do not own a car, yet even these households indirectly pay the costs imposed by minimum parking requirements.26 Because cars are not distributed equally in the population, charging motorists only for the parking they use is fairer than requiring everyone to pay for parking whether they use it or not. Market prices would not allocate the best parking spaces only to the rich. With market prices, motorists can pay less for parking if they carpool, stay for a shorter time, or park farther away, and they will pay nothing for parking if they walk, bicycle or ride public transit. Even those who cannot regularly afford to park in the best spaces can park in them on occasions when time is very important. Because income is only one factor that determines the value of time on a particular trip, and because the value of time is only one factor that determines parking location, income is only one of many factors that determine parking location. Given the eternal debate on the merits of markets versus planning, many skeptics will distrust using prices to allocate parking spaces. But even those who doubt the ability of markets to allocate resources fairly may agree that relying on prices to allocate curb parking spaces and using 25. Shoup (1997) explains how parking requirements increase the price of housing, and Willson (1995) explains how they increase the price of office space. 26. The 1990 NPTS reports the distribution of vehicle ownership by household income (Pisarski 1995, 3-24). The 1990 Census reports the distribution of households that do not own a car (Pisarski 1996, 36). PP 22-0001 ATTACHMENT O/PAGE 22 OF 30 The Trouble With Minimum Parking Requirements Donald Shoup 22 the revenue to fund public services will contribute to a host of social, economic, and environmental goals they support. Some Advantages of Market Prices for Parking Market prices for parking will allow motorists to make many small adjustments to optimize their parking choices according to countless individual circumstances. Compared with minimum parking requirements, demand-responsive parking prices have major advantages. 1. Charging for parking will give everyone an incentive to consider the alternatives to solo driving for every trip. Motorists will save money if they carpool, park for a shorter time, or walk farther. 2. Motorists who stay for a short time will tend to choose the higher-priced central spaces. The resulting faster turnover of the central parking spaces will tend to minimize motorists’ total walking time to their final destinations. 3. Motorists who stay for a long time–commuters, for example–will tend to choose the lower-priced peripheral spaces. They will also save money by riding transit, bicycling, or walking. 4. Motorists will have flexibility. They can pay extra to park in the central spaces when they are in a hurry, and can save money by parking in the peripheral spaces when they are not in a hurry. Everyone can park in the more convenient spaces at off-peak times. 5. If market prices reveal the economic value of on-street parking, cities can more rationally allocate scarce roadway space between parking and traffic. The cost of another lane for vehicle movement is the opportunity cost of a lane of parking spaces, and market prices for parking will take some of the guesswork out of regulating the on-street parking supply. Conclusions: Time for a Paradigm Shift Although it would be presumptuous to call urban planning a science, minimum parking requirements in planning resemble a paradigm in science. According to Thomas Kuhn (1996), a paradigm is a conceptual scheme that has gained universal acceptance throughout a profession, and each profession’s practices embody its ruling paradigms. Kuhn argued that scientific education inculcates in students an intense commitment to the existing scientific paradigms. But planning education ignores parking requirements, and therefore does not inculcate in students any commitment to them. Instead, motorists have come to expect the free parking that the requirements produce. The planning profession’s commitment to parking requirements is based not on education and science but on motorists’ yearning to park free. Discussing the difficulty of paradigm shifts in science, Kuhn asks, “How can a conceptual scheme that one generation admiringly describes as subtle, flexible, and complex become for a later generation merely obscure, ambiguous, and cumbersome?”27 Without doubt, minimum parking requirements are obscure, ambiguous, and cumbersome. In addition, minimum parking 27. Kuhn (1957, 76) was describing how latter-day astronomers looked back at the Ptolemaic, earth-centered concept of the universe. PP 22-0001 ATTACHMENT O/PAGE 23 OF 30 The Trouble With Minimum Parking Requirements Donald Shoup 23 requirements impose enormous hidden costs, and they impede our progress toward important social, economic, and environmental goals. Planning for parking deserves a new paradigm. Minimum parking requirements are based on two highly unreasonable assumptions: (1) the demand for parking does not depend on its price, and (2) the supply of parking should not depend on its cost. This neglect of price and cost stems from a belief that planners can assess community needs and can regulate the land market to meet these needs. Regulation is justified in many cases where market prices fail to communicate social costs. But market failure does not justify minimum parking requirements. Without considering the price of parking--as if it were irrelevant--urban planners foretell how many parking spaces every land use needs. In practicing the art of predicting demand without considering price, urban planners resemble the Wizard of Oz, deceived by his own tricks. After he is exposed, the Wizard laments, “I have fooled everyone so long that I thought I should never be found out… [but] how can I help being a humbug when all these people make me do things that everybody knows can't be done?”28 Letting prices determine the number of parking spaces will transfer to the market an important function that urban planners now perform. But this does not mean an end to planning for parking because planners should regulate many other features of parking that affect the community, such as aesthetics, landscaping, layout, location, pedestrian access, provisions for the handicapped, setback, signage, and stormwater runoff. Pricing curb parking rather than requiring off-street parking will improve urban design, reduce traffic congestion, restrain urban sprawl, conserve natural resources, and produce neighborhood public revenue. Eliminating parking requirements will also reduce the cost of housing and of many other goods and services. In conclusion, deregulating the quantity and increasing the quality of parking will improve transportation, land use, and the environment. 28. See L. Frank Baum (1903, pp. 148 and 160-161). In the 1939 MGM film version, the Wizard roars “Do you presume to criticize the Great Oz?” PP 22-0001 ATTACHMENT O/PAGE 24 OF 30 The Trouble With Minimum Parking Requirements Donald Shoup 24 APPENDIX: THE COST OF PARKING SPACES How much does a parking space cost? This question has no easy answer because the cost of parking depends on the value of land, which varies greatly among sites. But in the case of structured parking we can account for the value of land as its opportunity cost for surface parking. The number of spaces a parking structure adds to the parking supply is the number of parking spaces in the structure minus the number of surface parking spaces lost as a result of building the structure. The structure’s construction cost (excluding land value) divided by the number of parking spaces added to the parking supply gives the structure’s cost per parking space added, which accounts for land value as the opportunity cost of the surface parking spaces lost (Shoup 1997). This methodology was used to calculate the construction cost per parking space added by twelve parking structures built on the UCLA campus between 1961 and 1991.29 Each structure's original cost was converted into dollars of 1998 purchasing power by adjusting for construction cost inflation since the structure was built. The average cost of the six structures built in the 1960s was $13,400 per space added, while the average cost of the six structures built since 1977 was $25,600 per space added. The newer parking structures are more expensive because they are smaller and partly or entirely underground, compared with the larger, aboveground structures built earlier. That is, the type of parking structure–not an increase in the real cost of parking spaces (above the rate of inflation of general construction costs)–can explain the higher real cost of new parking spaces. Table 4 Cost of Aboveground and Belowground Parking Spaces (Costs Per Space Added by Parking Structures in Los Angeles) Abovegound (UCLA)Underground (UCLA Underground (Pershing Sq.) 1964 Structure 1995 Addition 1983 Structure 1998 Addition 1950 Structure Current US$$1,946 $13,712 $19,752 $26,300 $2,500 1998 US$$12,214 $14,725 $28,540 $26,300 $28,000 The original portion of the Structure 3, built in 1964, contains 1,168 spaces in five aboveground levels; the addition built in 1995 contains 840 spaces in seven aboveground levels. The original portion of Structure 4, built in 1983, contains 448 spaces in two underground levels; the addition built in 1998 contains 1,263 spaces in two aboveground levels. The Pershing Square Garage in downtown Los Angeles contains 2,150 spaces in three underground levels. The ENR Construction Cost Index is used to convert original construction costs to 1998 values. 29. See Shoup (1997) for the details of the cost per parking space added by the twelve parking structures. The 20-city average of the ENR Construction Cost Index for March 31, 1998, was divided by the average ENR Construction Cost Index for the year in which the parking structure was built. This ratio was then multiplied by the original construction cost to yield the construction cost expressed in dollars of 1998 purchasing power. PP 22-0001 ATTACHMENT O/PAGE 25 OF 30 The Trouble With Minimum Parking Requirements Donald Shoup 25 We can test this hypothesis that the type of parking structure explains the increase in cost after 1977. Since the initial study of the twelve structures built between 1961 and 1991, UCLA has built two new campus parking structures as additions to existing parking structures. The first is a 1995 aboveground addition to the aboveground structure built in 1964. The second is a 1998 underground addition to the underground structure built in 1983. Table 4 compares the cost per parking space added by the two original structures and their subsequent additions. The ENR Construction Cost Index is used to convert the original construction costs to 1998 dollars. The cost was $12,214 per space for the original aboveground structure built in 1964, and $14,725 per space for the addition built 31 years later.30 The cost was $28,540 per space for the original underground structure built in 1983, and $26,300 per space for the addition built fifteen years later.31 The close match between the cost of each original parking structure and the cost of its later addition suggests that, after correcting for inflation, the cost of building parking structures has changed little in recent decades. To test this finding of cost stability, Table 4 also shows the cost of an underground garage constructed beneath Pershing Square in downtown Los Angeles in 1952.32 When the original cost of $2,500 per space is converted to its equivalent in 1998 purchasing power, the cost of the Pershing Square garage is $25,700 per parking space, very close to the cost of the two underground garages built at UCLA in 1983 and 1998. In real terms, the cost of building underground parking has not changed in half a century. If these high costs are surprising, it is only because the cost of parking is rarely calculated. Nevertheless, there is other evidence about cost because some cities allow developers to pay a fee in lieu of providing required parking spaces. To justify the in-lieu fees, some of these cities carefully document their cost of providing public parking spaces.33 In Palo Alto, California, the 30. The original aboveground structure contains 39 percent more parking spaces than the aboveground addition, and its footprint is twice as large as that of the addition. Economies of scale help to explain the original structure’s lower cost per space. The UCLA parking structures built in the 1960s look like the aboveground parking structures built in suburban areas where vacant land is abundant. In case studies of suburban office developments in Southern California in 1994, Willson (1995, 39) found “the average combined land and construction cost for structure parking in the case study sites was $12,300 per space.” This cost is almost identical to the average cost of $12,400 (in 1994$) per parking space added by the aboveground parking structures built at UCLA in the 1960s. 31. The underground addition is almost three times the size of the original underground structure, and economies of scale help to explain the newer structure’s lower cost per space. The UCLA parking structures built since 1977 are typical of the parking structures built in dense areas where vacant land is scarce. The higher cost of recent parking structures at UCLA thus reflects the higher cost of building parking structures in dense urban areas. 32. Klose (1965, 190) gives the original cost of constructing the Pershing Square garage. 33. See Shoup (forthcoming). These costs refer to the values that were used to justify the cities’ in-lieu fees in 1996. In Beverly Hills the cost refers to the average estimated land and construction cost of municipal parking spaces for projects that applied to pay the in-lieu fees between 1978 and 1992; the highest cost was $53,000 per parking space. PP 22-0001 ATTACHMENT O/PAGE 26 OF 30 The Trouble With Minimum Parking Requirements Donald Shoup 26 cost is $17,848 per space added by a municipal parking structure. In Lake Forest, Illinois, the cost is $18,000 per space for the land and construction cost of surface parking lots. In Walnut Creek, California, the cost is $32,400 per space added by a municipal parking structure. In Beverly Hills, California, the average cost was $37,000 per space for the estimated land and construction cost of municipal parking structures. The cost of parking spaces at UCLA is thus in line with the cost of parking spaces in cities that allow developers to pay in-lieu fees. The cost of many surface parking spaces is less than the cost of structured parking spaces, but land values understate the cost of surface parking because developers who are required to provide parking spaces will bid less for land. Therefore, the market value of land subject to a minimum parking requirement will understate the cost of surface parking spaces. For example, when Oakland, California, introduced its parking requirement of one space per 1,000 square feet for apartment buildings, land values fell by 33 percent (Shoup 1997). Willson (1995) estimated that increasing the parking requirement for office buildings in Southern California by 1.3 spaces per 1,000 square feet would reduce land values by 32 percent. Because minimum parking requirements depress land values, low land values do not necessarily imply that minimum parking requirements have a low cost. PP 22-0001 ATTACHMENT O/PAGE 27 OF 30 The Trouble With Minimum Parking Requirements Donald Shoup 27 REFERENCES American Public Transit Association (1997) 1997 Transit Fact Book. American Public Transit Association. Washington, DC; www.apta.com. Brierly, J. (1972) Parking of Motor Vehicles. Applied Science Publishers, Second Edition. London. Brown, S. A. and Lambe, T. A. (1972) Parking prices in the central business district. Socio-Economic Planning Sciences, 6, 133-144. Chapin, F. S. (1957) Urban Land Use Planning. Harper & Brothers. New York. Chapin, F. S. (1965) Urban Land Use Planning. University of Illinois Press, Second Edition. Urbana, IL. Chapin, F. S. and Kaiser, E. (1979) Urban Land Use Planning. University of Illinois Press, Third Edition. Urbana, IL. Federal Highway Administration (1995) Highway statistics summary to 1995, taken from www.bts.gov/site/news/fhwa/HighwayStats-Summary95/section2.html. Office of Highway Information Management. 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Institute of Transportation Engineers (1987b) Trip Generation. Institute of Transportation Engineers, Fourth Edition. Washington, DC; www.ite.org. Kaiser, E., Godschalk, D., and Chapin, F. S. (1995) Urban Land Use Planning. University of Illinois Press, Fourth Edition. Urbana, IL. Katz, A. and Herman, S. (1997) Improved estimates of fixed reproducible tangible wealth, 1929-1995. Survey of Current Business, May 1997. PP 22-0001 ATTACHMENT O/PAGE 28 OF 30 The Trouble With Minimum Parking Requirements Donald Shoup 28 Klose, D. (1965) Multi-story and underground garages [Parkhäuser und Tiefgaragen]. Verlag Gerd Hartje. Stuttgart. KMPG Peat Marwick (1990) Dimensions of parking, prepared for the United States Department of Transportation, Urban Mass Transportation Administration, Office of Budget and Policy, September 10, 1990. Kuhn, T. (1957) The Copernican Revolution. Harvard University Press. Cambridge, MA. Kuhn, T. (1996) The Structure of Scientific Revolutions. University of Chicago Press, Third Edition. Chicago. Lin-Fu, J. (1992) Modern history of lead poisoning: a century of discovery and rediscovery. In Human Lead Exposure. ed. H. Needleman. CRC Press. Boca Raton, FL. May, A. D. (1975) Parking control: experience and problems in London. Traffic Engineering and Control. May. McCord, C. (1953) Lead and lead poisoning in early America. Industrial Medicine and Surgery, 22(9), 393- 399. Meyer, M. and Miller, E. (1984) Urban Transportation Planning. McGraw Hill Book Company. New York. Muth, R. (1969) Cities and Housing. University of Chicago Press. Chicago. Jerome Nriagu. 1983. Lead and Lead Poisoning in Antiquity, New York: John Wiley & Sons. Pisarski, A. (1995) The demography of the U.S. vehicle fleet: observations from the NPTS. 1990 Nationwide Personal Transportation Survey, Special Reports on Trip and Vehicle Attributes. U.S. Department of Transportation. Washington, DC; www-cta.ornl.gov/npts/1995/doc/index.html-ssi. Pisarski, A. (1996) Commuting in America II: The Second National Report on Commuting Patterns and Trends. Eno Transportation Foundation. Landsdowne, VA; www.enotrans.com. Planning Advisory Service (1971) An Approach to Determining Parking Demand, Planning Service Report Number 270. American Planning Association. Chicago; www.planning.org. Planning Advisory Service (1991) Off-Street Parking Requirements: A National Review of Standards, Planning Advisory Service Report Number 432. American Planning Association. Chicago; www.planning.org. Shoup, D. C. (1992) Cashing Out Employer-Paid Parking. U. S. Department of Transportation. 156 pp. Washington, DC. Shoup, D. C. (1994) Cashing in on curb parking. Access (http://socrates.berkeley.edu/~uctc), 4, 20-26. Shoup, D. C. (1995) An opportunity to reduce minimum parking requirements. Journal of the American Planning Association, 61(1), 14-28. PP 22-0001 ATTACHMENT O/PAGE 29 OF 30 The Trouble With Minimum Parking Requirements Donald Shoup 29 Shoup, D. C. (1997) The high cost of free parking. Journal of Planning Education and Research. 17(1), 1- 18. Shoup, D. C. (forthcoming) In-lieu parking fees. Journal of Planning Education and Research. Shoup, D. and Breinholt, M. J. (1997) Employer-paid parking: a nationwide survey of employers’ parking subsidy policies. In The Full Social Costs and Benefits of Transportation. ed. D. Greene, D. Jones and M. Delucchi. Springer-Verlag. Heidelberg. Thomas, L. (1981) “Medicine without science.” The Atlantic Monthly. April 1981, 40-42. Willson, R. (1995) “Suburban parking requirements: a tacit policy for automobile use and sprawl.” Journal of the American Planning Association. 61(1), 29-42. Willson, R. (1996) Local jurisdiction parking requirements: a survey of policies and attitudes. Working Paper, Department of Urban and Regional Planning, California State Polytechnic University, Pomona, California. Witheford, D. K. and Kanaan, G. E. (1972) Zoning, Parking, and Traffic. Eno Foundation for Transportation. Westport, CT; www.enotrans.com. ACKNOWLEDGMENTS I am grateful to the Federal Transit Administration and the University of California Transportation Center for financial support. For their many suggestions for improving this paper I am also grateful to Ellison Alegre, Lee Burns, Jeffrey Brown, Eric Carlson, Joy Chen, Elke Daugherty, D. Gregg Doyle, David Gillen, Daniel Hess, Eugene Kim, Kristen Massey, Andrew Mondschein, Virginia Parks, John Pucher, Thomas Rice, Gian-Claudia Sciara, Patricia Shoup, Seth Stark, Richard Willson, and Matthew Zisman. PP 22-0001 ATTACHMENT O/PAGE 30 OF 30 SE R i v e r R d Qu a r r y R d O l d R i v e r D r R e e s e R d SW Bonita Rd S outh Shore B l v d S S t a t e S t H w y 2 1 7 S B ergis Rd I5 M c n a r y P k wy CarmanDr We s t l a k e D r Br y a n t R d SW Haines St HallinanSt A Ave S S u n c r e s t D r SW Uppe r D r Boones FerryRd S W Lower Boones F e r r y R d N S t a t e S t S W Riverside Dr SW Stephenson St Ir o n M o u n t a i n B l vd Co r n e l l S t SW St affordRd S T e r w i l l i g e r B l v d Coun t r y C l u b R d M c v e y A v e S W B o o n e s Fe rry R d To u c h s t o n e S W U p p e r B o o n e s F e rry R d S W A t l anta St SW Dartmo u t h S t Hillcrest Dr Lakevi e w B l v d SWGreen B l u f f D r S Crestline D rWest vi e w Dr Pi l k i n g t o n R d SW W a l u g a D r At w a t e r R d Melrose St Lake v i e w B l v d W a l u g a D r SW Nyberg St 10t h S t P a c i f i c H w y S W Car m a n Dr B Ave SW 65th Ave C Ave Jean Rd Boc a Ratan Dr Be r g i s R d SW 72nd Ave S R i v e r s i d e D r S W J o h n son Rd D Ave Staf f o r d R d S W L a k e F o r e s t B l v d M a r y lh u r s t D r S W T e r w i l l iger B l v d SE Courtney Ave SW Jean Rd K e r r P k w y Greentree Rd SW P i l k i n g t o n R d U p p e r D r G o o d a l l R d Childs Rd F ernwood Dr SE Oak Grove Blvd SW B a n g y R d Kruse Way SW 72nd Ave Knaus Rd Su n c r e s t D r W i l l a m e t t e D r SW Beveland Rd Bot t i c e l l i S MilitaryR d Ba n g y R d Cherry Ln O v e r l o o k Dr S W L e s s e r R d Kel o k R d SW 68t h Ave SW ChildsRd Jefferson P k w y 65 t h A v e Bonita Rd Washington Ct Twin Fir Rd Rive r s i d e D r Oak S t SW K n a u s R d Lake Grove Ave Monroe Pkwy Parkview Dr SW 6 8 t h Pkwy G l e n m o rrie Dr S SkylandDr Tr e e T o p L n B o n niebraeDr 5t h S t 3r d S t 1s t S t 2n d S t WembleyP a rk R d 4t h S t SW G o o d a l l R d Kr u s e W o o d s D r G r e e n B l u ff Dr O ld RiverR d Meadows Rd Timberli ne Dr S Old River R d SW M c e w a n R d SW Nyberg Ln T e r w i l l i g e r B l v d Mce w a n R d West B a y R d Chandler R d S R ose m ont Rd S W Sequoia Pkwy Fo s b e r g R d S Wilda Rd Fir Ridge Rd Ro y c e W a y Oswego L a k e W i l l a m e t t e Riv e r City of Lake Oswego - CFEC Parking ReformCommercial Option 1: Repeal Parking Mandates Citywide 0 0.25 0.5 Mile 9/14/2023 µCity Limits Urban Services Boundary No Parking Required for Commercial Use Commercial Not Permitted as Primary Use Figure 1 PP 22-0001 ATTACHMENT P/PAGE 1 OF 8 SE R i v e r R d Qu a r r y R d O l d R i v e r D r R e e s e R d SW Bonita Rd S outh Shore B l v d S S t a t e S t H w y 2 1 7 S B ergis Rd I5 M c n a r y P k wy CarmanDr We s t l a k e D r Br y a n t R d SW Haines St HallinanSt A Ave S S u n c r e s t D r SW Uppe r D r Boones FerryRd S W Lower Boones F e r r y R d N S t a t e S t S W Riverside Dr SW Stephenson St Ir o n M o u n t a i n B l vd Co r n e l l S t SW St affordRd S T e r w i l l i g e r B l v d Coun t r y C l u b R d M c v e y A v e S W B o o n e s Fe rry R d To u c h s t o n e S W U p p e r B o o n e s F e rry R d S W A t l anta St SW Dartmo u t h S t Hillcrest Dr Lakevi e w B l v d SWGreen B l u f f D r S Crestline D rWest vi e w Dr Pi l k i n g t o n R d SW W a l u g a D r At w a t e r R d Melrose St Lake v i e w B l v d W a l u g a D r SW Nyberg St 10t h S t P a c i f i c H w y S W Car m a n Dr B Ave SW 65th Ave C Ave Jean Rd Boc a Ratan Dr Be r g i s R d SW 72nd Ave S R i v e r s i d e D r S W J o h n son Rd D Ave Staf f o r d R d S W L a k e F o r e s t B l v d M a r y lh u r s t D r S W T e r w i l l iger B l v d SE Courtney Ave SW Jean Rd K e r r P k w y Greentree Rd SW P i l k i n g t o n R d U p p e r D r G o o d a l l R d Childs Rd F ernwood Dr SE Oak Grove Blvd SW B a n g y R d Kruse Way SW 72nd Ave Knaus Rd Su n c r e s t D r W i l l a m e t t e D r SW Beveland Rd Bot t i c e l l i S MilitaryR d Ba n g y R d Cherry Ln O v e r l o o k Dr S W L e s s e r R d Kel o k R d SW 68t h Ave SW ChildsRd Jefferson P k w y 65 t h A v e Bonita Rd Washington Ct Twin Fir Rd Rive r s i d e D r Oak S t SW K n a u s R d Lake Grove Ave Monroe Pkwy Parkview Dr SW 6 8 t h Pkwy G l e n m o rrie Dr S SkylandDr Tr e e T o p L n B o n niebraeDr 5t h S t 3r d S t 1s t S t 2n d S t WembleyP a rk R d 4t h S t SW G o o d a l l R d Kr u s e W o o d s D r G r e e n B l u ff Dr O ld RiverR d Meadows Rd Timberli ne Dr S Old River R d SW M c e w a n R d SW Nyberg Ln T e r w i l l i g e r B l v d Mce w a n R d West B a y R d Chandler R d S R ose m ont Rd S W Sequoia Pkwy Fo s b e r g R d S Wilda Rd Fir Ridge Rd Ro y c e W a y Oswego L a k e W i l l a m e t t e Riv e r City of Lake Oswego - CFEC Parking ReformResidential Option 1: Repeal Parking Mandates Citywide 0 0.25 0.5 Mile 9/14/2023 µCity Limits Urban Services Boundary Residential Use Not Permitted No Parking Required for Residential Use Figure 2 PP 22-0001 ATTACHMENT P/PAGE 2 OF 8 SE R i v e r R d Qu a r r y R d O l d R i v e r D r R e e s e R d SW Bonita Rd S outh Shore B l v d S S t a t e S t H w y 2 1 7 S B ergis Rd I5 M c n a r y P k wy CarmanDr We s t l a k e D r Br y a n t R d SW Haines St HallinanSt A Ave S S u n c r e s t D r SW Uppe r D r Boones FerryRd S W Lower Boones F e r r y R d N S t a t e S t S W Riverside Dr SW Stephenson St Ir o n M o u n t a i n B l vd Co r n e l l S t SW St affordRd S T e r w i l l i g e r B l v d Coun t r y C l u b R d M c v e y A v e S W B o o n e s Fe rry R d To u c h s t o n e S W U p p e r B o o n e s F e rry R d S W A t l anta St SW Dartmo u t h S t Hillcrest Dr Lakevi e w B l v d SWGreen B l u f f D r S Crestline D rWest vi e w Dr Pi l k i n g t o n R d SW W a l u g a D r At w a t e r R d Melrose St Lake v i e w B l v d W a l u g a D r SW Nyberg St 10t h S t P a c i f i c H w y S W Car m a n Dr B Ave SW 65th Ave C Ave Jean Rd Boc a Ratan Dr Be r g i s R d SW 72nd Ave S R i v e r s i d e D r S W J o h n son Rd D Ave Staf f o r d R d S W L a k e F o r e s t B l v d M a r y lh u r s t D r S W T e r w i l l iger B l v d SE Courtney Ave SW Jean Rd K e r r P k w y Greentree Rd SW P i l k i n g t o n R d U p p e r D r G o o d a l l R d Childs Rd F ernwood Dr SE Oak Grove Blvd SW B a n g y R d Kruse Way SW 72nd Ave Knaus Rd Su n c r e s t D r W i l l a m e t t e D r SW Beveland Rd Bot t i c e l l i S MilitaryR d Ba n g y R d Cherry Ln O v e r l o o k Dr S W L e s s e r R d Kel o k R d SW 68t h Ave SW ChildsRd Jefferson P k w y 65 t h A v e Bonita Rd Washington Ct Twin Fir Rd Rive r s i d e D r Oak S t SW K n a u s R d Lake Grove Ave Monroe Pkwy Parkview Dr SW 6 8 t h Pkwy G l e n m o rrie Dr S SkylandDr Tr e e T o p L n B o n niebraeDr 5t h S t 3r d S t 1s t S t 2n d S t WembleyP a rk R d 4t h S t SW G o o d a l l R d Kr u s e W o o d s D r G r e e n B l u ff Dr O ld RiverR d Meadows Rd Timberli ne Dr S Old River R d SW M c e w a n R d SW Nyberg Ln T e r w i l l i g e r B l v d Mce w a n R d West B a y R d Chandler R d S R ose m ont Rd S W Sequoia Pkwy Fo s b e r g R d S Wilda Rd Fir Ridge Rd Ro y c e W a y Oswego L a k e W i l l a m e t t e Riv e r City of Lake Oswego - CFEC Parking Reform Commercial Option 2: Fair Parking 0 0.25 0.5 Mile 9/14/2023 µ Bus Route #35 DRDD / LGVC Overlays City Limits USB No Parking Required for Commercial Use Full Commercial Parking Requirements Commercial Not Permitted as Primary Use Figure 3 PP 22-0001 ATTACHMENT P/PAGE 3 OF 8 SE R i v e r R d Qu a r r y R d O l d R i v e r D r R e e s e R d SW Bonita Rd S outh Shore B l v d S S t a t e S t H w y 2 1 7 S B ergis Rd I5 M c n a r y P k wy CarmanDr We s t l a k e D r Br y a n t R d SW Haines St HallinanSt A Ave S S u n c r e s t D r SW Uppe r D r Boones FerryRd S W Lower Boones F e r r y R d N S t a t e S t S W Riverside Dr SW Stephenson St Ir o n M o u n t a i n B l vd Co r n e l l S t SW St affordRd S T e r w i l l i g e r B l v d Coun t r y C l u b R d M c v e y A v e S W B o o n e s Fe rry R d To u c h s t o n e S W U p p e r B o o n e s F e rry R d S W A t l anta St SW Dartmo u t h S t Hillcrest Dr Lakevi e w B l v d SWGreen B l u f f D r S Crestline D rWest vi e w Dr Pi l k i n g t o n R d SW W a l u g a D r At w a t e r R d Melrose St Lake v i e w B l v d W a l u g a D r SW Nyberg St 10t h S t P a c i f i c H w y S W Car m a n Dr B Ave SW 65th Ave C Ave Jean Rd Boc a Ratan Dr Be r g i s R d SW 72nd Ave S R i v e r s i d e D r S W J o h n son Rd D Ave Staf f o r d R d S W L a k e F o r e s t B l v d M a r y lh u r s t D r S W T e r w i l l iger B l v d SE Courtney Ave SW Jean Rd K e r r P k w y Greentree Rd SW P i l k i n g t o n R d U p p e r D r G o o d a l l R d Childs Rd F ernwood Dr SE Oak Grove Blvd SW B a n g y R d Kruse Way SW 72nd Ave Knaus Rd Su n c r e s t D r W i l l a m e t t e D r SW Beveland Rd Bot t i c e l l i S MilitaryR d Ba n g y R d Cherry Ln O v e r l o o k Dr S W L e s s e r R d Kel o k R d SW 68t h Ave SW ChildsRd Jefferson P k w y 65 t h A v e Bonita Rd Washington Ct Twin Fir Rd Rive r s i d e D r Oak S t SW K n a u s R d Lake Grove Ave Monroe Pkwy Parkview Dr SW 6 8 t h Pkwy G l e n m o rrie Dr S SkylandDr Tr e e T o p L n B o n niebraeDr 5t h S t 3r d S t 1s t S t 2n d S t WembleyP a rk R d 4t h S t SW G o o d a l l R d Kr u s e W o o d s D r G r e e n B l u ff Dr O ld RiverR d Meadows Rd Timberli ne Dr S Old River R d SW M c e w a n R d SW Nyberg Ln T e r w i l l i g e r B l v d Mce w a n R d West B a y R d Chandler R d S R ose m ont Rd S W Sequoia Pkwy Fo s b e r g R d S Wilda Rd Fir Ridge Rd Ro y c e W a y Oswego L a k e W i l l a m e t t e Riv e r City of Lake Oswego - CFEC Parking ReformResidential Option 2(a): Fair Parking with Reduced Mandates inClimate-Friendly Areas 0 0.25 0.5 Mile 9/14/2023 µBus Route #35 DRDD / LGVC Overlays City Limits USB No Parking Required for Residential Use One Required Parking Space per Dwelling Unit Residential Use Not Permitted Figure 4 PP 22-0001 ATTACHMENT P/PAGE 4 OF 8 SE R i v e r R d Qu a r r y R d O l d R i v e r D r R e e s e R d SW Bonita Rd S outh Shore B l v d S S t a t e S t H w y 2 1 7 S B ergis Rd I5 M c n a r y P k wy CarmanDr We s t l a k e D r Br y a n t R d SW Haines St HallinanSt A Ave S S u n c r e s t D r SW Uppe r D r Boones FerryRd S W Lower Boones F e r r y R d N S t a t e S t S W Riverside Dr SW Stephenson St Ir o n M o u n t a i n B l vd Co r n e l l S t SW St affordRd S T e r w i l l i g e r B l v d Coun t r y C l u b R d M c v e y A v e S W B o o n e s Fe rry R d To u c h s t o n e S W U p p e r B o o n e s F e rry R d S W A t l anta St SW Dartmo u t h S t Hillcrest Dr Lakevi e w B l v d SWGreen B l u f f D r S Crestline D rWest vi e w Dr Pi l k i n g t o n R d SW W a l u g a D r At w a t e r R d Melrose St Lake v i e w B l v d W a l u g a D r SW Nyberg St 10t h S t P a c i f i c H w y S W Car m a n Dr B Ave SW 65th Ave C Ave Jean Rd Boc a Ratan Dr Be r g i s R d SW 72nd Ave S R i v e r s i d e D r S W J o h n son Rd D Ave Staf f o r d R d S W L a k e F o r e s t B l v d M a r y lh u r s t D r S W T e r w i l l iger B l v d SE Courtney Ave SW Jean Rd K e r r P k w y Greentree Rd SW P i l k i n g t o n R d U p p e r D r G o o d a l l R d Childs Rd F ernwood Dr SE Oak Grove Blvd SW B a n g y R d Kruse Way SW 72nd Ave Knaus Rd Su n c r e s t D r W i l l a m e t t e D r SW Beveland Rd Bot t i c e l l i S MilitaryR d Ba n g y R d Cherry Ln O v e r l o o k Dr S W L e s s e r R d Kel o k R d SW 68t h Ave SW ChildsRd Jefferson P k w y 65 t h A v e Bonita Rd Washington Ct Twin Fir Rd Rive r s i d e D r Oak S t SW K n a u s R d Lake Grove Ave Monroe Pkwy Parkview Dr SW 6 8 t h Pkwy G l e n m o rrie Dr S SkylandDr Tr e e T o p L n B o n niebraeDr 5t h S t 3r d S t 1s t S t 2n d S t WembleyP a rk R d 4t h S t SW G o o d a l l R d Kr u s e W o o d s D r G r e e n B l u ff Dr O ld RiverR d Meadows Rd Timberli ne Dr S Old River R d SW M c e w a n R d SW Nyberg Ln T e r w i l l i g e r B l v d Mce w a n R d West B a y R d Chandler R d S R ose m ont Rd S W Sequoia Pkwy Fo s b e r g R d S Wilda Rd Fir Ridge Rd Ro y c e W a y Oswego L a k e W i l l a m e t t e Riv e r City of Lake Oswego - CFEC Parking ReformResidential Option 2(b): Fair Parking with Additional Parking Management 0 0.25 0.5 Mile 9/14/2023 µBus Route #35 DRDD / LGVC Overlays City Limits USB No Parking Required for Residential Use 1/2 Required Parking Space per Dwelling Unit One Required Parking Space per Dwelling Unit Residential Use Not Permitted Figure 5 PP 22-0001 ATTACHMENT P/PAGE 5 OF 8 SE R i v e r R d Qu a r r y R d O l d R i v e r D r R e e s e R d SW Bonita Rd S outh Shore B l v d S S t a t e S t H w y 2 1 7 S B ergis Rd I5 M c n a r y P k wy CarmanDr We s t l a k e D r Br y a n t R d SW Haines St HallinanSt A Ave S S u n c r e s t D r SW Uppe r D r Boones FerryRd S W Lower Boones F e r r y R d N S t a t e S t S W Riverside Dr SW Stephenson St Ir o n M o u n t a i n B l vd Co r n e l l S t SW St affordRd S T e r w i l l i g e r B l v d Coun t r y C l u b R d M c v e y A v e S W B o o n e s Fe rry R d To u c h s t o n e S W U p p e r B o o n e s F e rry R d S W A t l anta St SW Dartmo u t h S t Hillcrest Dr Lakevi e w B l v d SWGreen B l u f f D r S Crestline D rWest vi e w Dr Pi l k i n g t o n R d SW W a l u g a D r At w a t e r R d Melrose St Lake v i e w B l v d W a l u g a D r SW Nyberg St 10t h S t P a c i f i c H w y S W Car m a n Dr B Ave SW 65th Ave C Ave Jean Rd Boc a Ratan Dr Be r g i s R d SW 72nd Ave S R i v e r s i d e D r S W J o h n son Rd D Ave Staf f o r d R d S W L a k e F o r e s t B l v d M a r y lh u r s t D r S W T e r w i l l iger B l v d SE Courtney Ave SW Jean Rd K e r r P k w y Greentree Rd SW P i l k i n g t o n R d U p p e r D r G o o d a l l R d Childs Rd F ernwood Dr SE Oak Grove Blvd SW B a n g y R d Kruse Way SW 72nd Ave Knaus Rd Su n c r e s t D r W i l l a m e t t e D r SW Beveland Rd Bot t i c e l l i S MilitaryR d Ba n g y R d Cherry Ln O v e r l o o k Dr S W L e s s e r R d Kel o k R d SW 68t h Ave SW ChildsRd Jefferson P k w y 65 t h A v e Bonita Rd Washington Ct Twin Fir Rd Rive r s i d e D r Oak S t SW K n a u s R d Lake Grove Ave Monroe Pkwy Parkview Dr SW 6 8 t h Pkwy G l e n m o rrie Dr S SkylandDr Tr e e T o p L n B o n niebraeDr 5t h S t 3r d S t 1s t S t 2n d S t WembleyP a rk R d 4t h S t SW G o o d a l l R d Kr u s e W o o d s D r G r e e n B l u ff Dr O ld RiverR d Meadows Rd Timberli ne Dr S Old River R d SW M c e w a n R d SW Nyberg Ln T e r w i l l i g e r B l v d Mce w a n R d West B a y R d Chandler R d S R ose m ont Rd S W Sequoia Pkwy Fo s b e r g R d S Wilda Rd Fir Ridge Rd Ro y c e W a y Oswego L a k e W i l l a m e t t e Riv e r City of Lake Oswego - CFEC Parking Reform Commercial Option 3: Reduced Regulation Parking Management 0 0.25 0.5 Mile 9/14/2023 µBus Route #35 DRDD / LGVC Overlays City Limits USB No Parking Required for Commercial Use Full Commercial Parking Requirements Commercial Not Permitted as Primary Use Figure 6 PP 22-0001 ATTACHMENT P/PAGE 6 OF 8 SE R i v e r R d Qu a r r y R d O l d R i v e r D r R e e s e R d SW Bonita Rd S outh Shore B l v d S S t a t e S t H w y 2 1 7 S B ergis Rd I5 M c n a r y P k wy CarmanDr We s t l a k e D r Br y a n t R d SW Haines St HallinanSt A Ave S S u n c r e s t D r SW Uppe r D r Boones FerryRd S W Lower Boones F e r r y R d N S t a t e S t S W Riverside Dr SW Stephenson St Ir o n M o u n t a i n B l vd Co r n e l l S t SW St affordRd S T e r w i l l i g e r B l v d Coun t r y C l u b R d M c v e y A v e S W B o o n e s Fe rry R d To u c h s t o n e S W U p p e r B o o n e s F e rry R d S W A t l anta St SW Dartmo u t h S t Hillcrest Dr Lakevi e w B l v d SWGreen B l u f f D r S Crestline D rWest vi e w Dr Pi l k i n g t o n R d SW W a l u g a D r At w a t e r R d Melrose St Lake v i e w B l v d W a l u g a D r SW Nyberg St 10t h S t P a c i f i c H w y S W Car m a n Dr B Ave SW 65th Ave C Ave Jean Rd Boc a Ratan Dr Be r g i s R d SW 72nd Ave S R i v e r s i d e D r S W J o h n son Rd D Ave Staf f o r d R d S W L a k e F o r e s t B l v d M a r y lh u r s t D r S W T e r w i l l iger B l v d SE Courtney Ave SW Jean Rd K e r r P k w y Greentree Rd SW P i l k i n g t o n R d U p p e r D r G o o d a l l R d Childs Rd F ernwood Dr SE Oak Grove Blvd SW B a n g y R d Kruse Way SW 72nd Ave Knaus Rd Su n c r e s t D r W i l l a m e t t e D r SW Beveland Rd Bot t i c e l l i S MilitaryR d Ba n g y R d Cherry Ln O v e r l o o k Dr S W L e s s e r R d Kel o k R d SW 68t h Ave SW ChildsRd Jefferson P k w y 65 t h A v e Bonita Rd Washington Ct Twin Fir Rd Rive r s i d e D r Oak S t SW K n a u s R d Lake Grove Ave Monroe Pkwy Parkview Dr SW 6 8 t h Pkwy G l e n m o rrie Dr S SkylandDr Tr e e T o p L n B o n niebraeDr 5t h S t 3r d S t 1s t S t 2n d S t WembleyP a rk R d 4t h S t SW G o o d a l l R d Kr u s e W o o d s D r G r e e n B l u ff Dr O ld RiverR d Meadows Rd Timberli ne Dr S Old River R d SW M c e w a n R d SW Nyberg Ln T e r w i l l i g e r B l v d Mce w a n R d West B a y R d Chandler R d S R ose m ont Rd S W Sequoia Pkwy Fo s b e r g R d S Wilda Rd Fir Ridge Rd Ro y c e W a y Oswego L a k e W i l l a m e t t e Riv e r City of Lake Oswego - CFEC Parking ReformResidential Option 3(a): Reduced Regulation Parking Managementwith Reduced Mandates in Climate-Friendly Areas 0 0.25 0.5 Mile 9/14/2023 µ Bus Route #35 DRDD / LGVC Overlays City Limits USB No Parking Required for Residential Use One Required Parking Space per Dwelling Unit Residential Use Not Permitted Figure 7 PP 22-0001 ATTACHMENT P/PAGE 7 OF 8 SE R i v e r R d Qu a r r y R d O l d R i v e r D r R e e s e R d SW Bonita Rd S outh Shore B l v d S S t a t e S t H w y 2 1 7 S B ergis Rd I5 M c n a r y P k wy CarmanDr We s t l a k e D r Br y a n t R d SW Haines St HallinanSt A Ave S S u n c r e s t D r SW Uppe r D r Boones FerryRd S W Lower Boones F e r r y R d N S t a t e S t S W Riverside Dr SW Stephenson St Ir o n M o u n t a i n B l vd Co r n e l l S t SW St affordRd S T e r w i l l i g e r B l v d Coun t r y C l u b R d M c v e y A v e S W B o o n e s Fe rry R d To u c h s t o n e S W U p p e r B o o n e s F e rry R d S W A t l anta St SW Dartmo u t h S t Hillcrest Dr Lakevi e w B l v d SWGreen B l u f f D r S Crestline D rWest vi e w Dr Pi l k i n g t o n R d SW W a l u g a D r At w a t e r R d Melrose St Lake v i e w B l v d W a l u g a D r SW Nyberg St 10t h S t P a c i f i c H w y S W Car m a n Dr B Ave SW 65th Ave C Ave Jean Rd Boc a Ratan Dr Be r g i s R d SW 72nd Ave S R i v e r s i d e D r S W J o h n son Rd D Ave Staf f o r d R d S W L a k e F o r e s t B l v d M a r y lh u r s t D r S W T e r w i l l iger B l v d SE Courtney Ave SW Jean Rd K e r r P k w y Greentree Rd SW P i l k i n g t o n R d U p p e r D r G o o d a l l R d Childs Rd F ernwood Dr SE Oak Grove Blvd SW B a n g y R d Kruse Way SW 72nd Ave Knaus Rd Su n c r e s t D r W i l l a m e t t e D r SW Beveland Rd Bot t i c e l l i S MilitaryR d Ba n g y R d Cherry Ln O v e r l o o k Dr S W L e s s e r R d Kel o k R d SW 68t h Ave SW ChildsRd Jefferson P k w y 65 t h A v e Bonita Rd Washington Ct Twin Fir Rd Rive r s i d e D r Oak S t SW K n a u s R d Lake Grove Ave Monroe Pkwy Parkview Dr SW 6 8 t h Pkwy G l e n m o rrie Dr S SkylandDr Tr e e T o p L n B o n niebraeDr 5t h S t 3r d S t 1s t S t 2n d S t WembleyP a rk R d 4t h S t SW G o o d a l l R d Kr u s e W o o d s D r G r e e n B l u ff Dr O ld RiverR d Meadows Rd Timberli ne Dr S Old River R d SW M c e w a n R d SW Nyberg Ln T e r w i l l i g e r B l v d Mce w a n R d West B a y R d Chandler R d S R ose m ont Rd S W Sequoia Pkwy Fo s b e r g R d S Wilda Rd Fir Ridge Rd Ro y c e W a y Oswego L a k e W i l l a m e t t e Riv e r City of Lake Oswego - CFEC Parking ReformResidential Option 3(b): Reduced Regulation Parking Mgmt. w/ Add'l Parking Mgmt. 0 0.25 0.5 Mile 9/14/2023 µBus Route #35 DRDD / LGVC Overlays City Limits USB No Parking Required for Residential Use One Required Parking Space per Dwelling Unit Residential Use Not Permitted Figure 8 PP 22-0001 ATTACHMENT P/PAGE 8 OF 8