Monday, June 25, 2012

My Letter to the California APA in Support of AB 904

The California Chapter of the American Planning Association opposes reform to minimum parking requirements as required under proposed legislation AB 904. You can read about the legislation here on Streetsblog LA, here is the text of the bill, here is a Market Urbanism post about this issue, another brief explanation of the bill, Curbed LA coverage, and a story from the California Planning and Development Report.

Here is support for the bill from the Infill Builders Association. Below is the text of my letter as sent:

June 23, 2012
Dear Mr. Snow,
I am writing to express deep concern about California APA’s opposition to reforming minimum parking requirements through AB 904. I have studied parking regulations as part of my research for over a decade, half of which time I was in California. It is without question that minimum parking requirements are an egregious failure of planning, and the California APA’s position seems to suggest that, despite decades of evidence to the contrary, they know precisely how much parking should be supplied. The California APA’s position is troubling, to say the least, and actually reinforces the circular logic that got our cities into such trouble in the first place.
Minimum parking requirements increase the cost of housing, increase the amount of land needed for development, and represent the single largest subsidy to drivers. I will not dwell on these effects as the California APA’s letter of opposition suggests that you are aware of the need for reform. Parking reform should be at the top of any planner’s priorities for building better cities. I do want to challenge some of your reasons for opposing AB 904, and show why your concerns are unfounded.
In the basic issues section and in the specific concerns section you are worried that the proposed reduction in required parking minimums is not based on data. To quote your letter:
Page 4, S. 65200 (a).  It is not apparent how these parking minimums were determined.  They appear to be based on no specific data.  Of chief concern is the requirement for one parking space per thousand square feet of any non-residential project regardless of use.  Given that most jurisdictions use 3-5 parking spaces per 1000 square feet for uses that require the most parking, such as grocery stores, stadiums, park and ride lots, and medical offices, this assumes that up to 75% of those using the project would be using transit.  That is a huge leap of faith and one likely to detrimentally impact projects surrounding these facilities.”
 This quote suggests that existing parking requirements are based on something other than a huge leap of faith. They aren’t. No one knows the right number of parking spaces, and no one knows how many parking spaces are already built. Just because most jurisdictions require 3-5 spaces per 1,000 square feet does not mean they are correct. As a telling example of how supposed “correct” parking requirements have performed, consider that the amount of required parking built in the United States allows researchers to estimate retail sales by looking at images of parking lots taken from outer space. Remote Sensing Metrics, a company that specializes in counting the number of cars parked in commercial and retail lots using satellite images, correctly predicted that the 2011 holiday shopping season was going to be a success because 39 percent of parking spaces were occupied at shopping malls. We live in a world where 60 percent of parking spaces are vacant during good times. I do not see how this indicates that cities know how to set parking requirements. It does suggest that we build too many spaces. I agree that the proposed minima in AB 904 seem a bit convenient, but so are existing requirements. However, the proposed changes aim toward planning for people, building better places, and achieving a broad set of planning goals. By maintaining the status quo, the existing parking requirements make it easier and cheaper to drive.
 Another concern expressed is the definition of transit-intensive areas, and you suggest that only areas with existing transit service should be included. California is heavily investing in new transit systems, and these systems take a long time to plan and build. Reducing required parking now will make these areas better for transit when the transit arrives. Requiring lots of parking in areas where transit will be built will reduce the utility of the investment. We should build transit in areas that are not dominated by automobiles because those are the types of areas where lots of people will use transit! Lower required parking standards strengthen the relationship between transit and land use.
 Reforming parking policy is difficult, but also presents opportunities for building a new regulatory framework that supports good planning and flexibility for accommodating future needs and uses. Maintaining the status quo hampers California’s ability to pursue creative policies that are more equitable and economically viable and that promote vibrant communities. I hope you will reconsider the APA California position.
  Regards,
   David King
Assistant Professor of Urban Planning
Graduate School of Architecture, Planning and Preservation
Columbia University
  Cc:      Kevin Keller
            Sande George


Here is a link to the letter.
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