In Lieu of a Parking Policy, A Proposed Giveaway

A proposal to turn our city’s ‘in lieu’ parking fee policy into a lease-type arrangement for a Beverly Hills restaurant & club didn’t survive Council scrutiny this past Tuesday. But it did show in a nutshell the policy contortions involved when trying to accommodate too many cars in our compact business triangle. For one thing, it seems that we’re not clear on the problem that we need to address. It’s not a parking problem, it’s a motoring problem. We simply have too many visitors to Beverly Hills who choose to drive. But the Council discussion suggested another issue too: what is the appropriate role for parking minimums when a program designed to sidestep them might be further relaxed for an applicant seeking a one-off break from compliance?

The ‘in lieu’ parking program was established by law to respect our relatively high, required off-street parking minimums while giving permit applications the OK even  when an existing building lacks the on-site capacity to meet the zoning code for a specific commercial use. The answer is in lieu: create a pay-in program that allows property owners to pay a per-space fee to the city in lieu of creating or acquiring sufficient parking capacity to meet the law.

According to the Beverly Hills Municipal Code (Title X Planning & Zoning, Chapter 3 Zoning, Article 33 ‘In Lieu Parking’), the in lieu program is focused in application to restaurants, retail and equipment sales, convenience shops, museums and the re-use of National Register-listed buildings, and limited to properties in the business triangle only. The city then credits the project applicant with the required quantity of virtual parking spaces while collecting the in lieu fees on a schedule set by the law. Thus where parking can’t be physically provided, the program allows the substitution of existing spaces nearby should capacity exist.

Want to open a large restaurant in an older building in the business triangle without on-site parking? Calculate parking demand according to floor area (it’s a formula) and pay the in lieu fee. The fee that collected is substantial: a typical restaurant under the program would expect to pay about $30,000 or more for each required in lieu space and pay it off over a span of ten years. (These virtual spaces run with the property as long as the same use continues.) Read the staff report for how it applies in this real-world case.

Revenues offset expenditures by the city’s parking operations program that builds and operates the city garages that provide additional parking capacity. Because Beverly Hills constructs garages at upwards of $50,000 per space, the in lieu program helps recover that cost but doesn’t recover all of the cost. The loss is absorbed by the city in order to allow an incoming business to operate in a non-conforming ‘under-parked’ structure – of which there are many in our aged triangle.

In lieu is an intriguing means of pricing the benefit of providing parking for patrons on the public dime, but that’s not the problem that we need to solve. Rather we need to increase foot traffic without the accompanying vehicular traffic. The only way to do that is to support local businesses and encourage a shift to other modes of transportation (like mass transit or bicycles) to offset the parking demand.

The City of Santa Monica, for example, has decided as a matter of policy not to encourage the generation of any additional car trips in the city. To that end it has made street parking more expensive, has targeted development around the coming Expo Line, and generally encouraged non-motor transportation through an ambitious program of bike-friendly improvements to induce cycling. Beverly Hills has done none of that.

With the in lieu policy, on the other hand, City Hall appears to have its cake and eat it too:  we keep our elevated parking requirements for new and expanding establishments but relax them in exchange for an in lieu payment. It’s a kind of sleight-of-hand.

The Proposal Before City Council

The proposal before City Council would allow the backers of Spaghettini, a new restaurant, bar and club slated for North Canon drive, to take a big bite of the city’s cake by significantly relaxing the standard in lieu arrangement. In a clear departure from the in lieu policy, a change that requires an amended law under a ‘pilot’ program, the applicant would gain relief from the in lieu parking fees payable in full over a decade by spreading them out over approximately 30 years – making for a much smaller annual payment but payable only as long as the restaurant operates.

What kind of money are we talking about? The in lieu fees amount to $1.3 million – high because it’s a restaurant, bar, and associated live entertainment business proposed for a 5,000 sq. ft. space. That’s a lot of patrons and a lot of project parking demand. Here’s the math:

In Lieu fee matrix

The difference between the law as written and the proposed in lieu arrangement is clear when comparing fees at the 10-year and 30-year marks. At 30 years the applicant would have satisfied the current in lieu fee; but at 10 years only a fraction – less than a third. At the 10-year point, should the restaurant close, the difference between the current fee schedule and the proposed fee would amount to $1.3 million for all 59 spaces under the arrangement. That’s what critics call the ‘giveaway.’

In a related request, staff recommended a discounted lease rate on parking spaces in city garages. That prices restaurant parking at about the same rate paid by volume buyers for long-term vehicle storage. (This issue is less a matter of policy change than terms negotiation.) The Planning Commission has already signed off on both proposals and staff had an ordinance in hand ready for Council to sign.

But it didn’t go the applicant’s way. Vice-Mayor Bosse closely questioned planning staff about the utility of the ‘public benefits’ included in the (ostensibly neutral) staff report and even raised concerns about how those benefits were valued. Here are a few of them:

  • One-time food, beverage and music for a 200-guest centennial celebration ($20,000)
  • Annual ice-skating rink opening-day event music for the first three years ($7,000 each)
  • Music for three ‘garden concerts’ per year ($5,000 each) and
  • Music, food and production costs for three Greystone charity events per year ($15,000).

She also noted that the latter two benefits terminate after ten years while the lease arrangement continues in perpetuity. Staff acknowledged that some of the figures included in the staff report were essentially pie-in-the-sky. Speakers to Council noted that past music events benefited from free or low-cost talent – not the thousands per event cited by the applicant.

But it was the loss of fee income that critics saw as a giveaway. What staff characterized as an incentive to attract nightlife businesses to North Canon (which already has its share) critics saw instead as an imprudent departure from our in lieu policy. They said that it lets the applicant off the hook for substantial payments in exchange for those hypothetical and overvalued ‘public benefits.’ And did so without a broader discussion of the city’s planning policy.

Keep in mind that our parking operations fund is fed by in lieu fees and has already been bailed out by the general fund at the cost of city services. If the loss of income weren’t enough, critics noted that the applicant’s business could close even before having made good on the benefits. That’s allows the Spaghettini backers to defray some risk and minimize their up-front investment. (If the restaurant/club did close and the pilot program terminated, the leased spaces would, however, revert to the city (instead of running with the property.)

Now, we’re not saying that the proposal before Council is a flat-out giveaway. There may be merit in restructuring the in lieu program as a lease arrangement. Maybe the in lieu arrangement could be improved. But the city hasn’t had that discussion yet. And when we’ve seen past departures from established zoning regulations in the triangle, we’ve seen unwelcome consequences like slow-to-lease white elephants (e.g., the William Morris building on Beverly). The cost is borne by the public in subsidies that don’t pay off and a lifetime with an oversized structure relative to our height limits.


Again, this entire discussion has taken place without a review of the parking policy and the larger purpose of the in lieu program. This is an opportunity to re-think of how mobility and land use fits together in Beverly Hills. Los Angeles has already had that discussion. Yet we cling here to an outmoded belief that we’re powerless to shift people from automobiles to other modes. Pricing parking according to our broader goals is an essential part of a comprehensive mobility and land use strategy. We look forward to that policy discussion.

We Need Better Parking & Land Use Policies, Not In Lieu Fees

We think back to Donald Shoup’s in-depth analysis of parking policies across the United States in The High Cost of Free Parking [our review]. He found that parking policy is often rooted in outmoded or incorrect assumptions and even faulty data and that cities dramatically under-price parking. (It’s worth a read for anyone interested in peeling back the curtain on how planning practice actually works. You might never look at a planning staff report the same again.) Here in Beverly Hills we under-price it. Heck, we give it away – two hours free in many garages. And curb parking is way too cheap too.

What we think is particularly salient about his argument here in Beverly Hills is that parking policy (like mandatory parking minimums) can dramatically distort how we use commercial land. When we require too much parking, for example, it puts an additional cost burden on the applicant. It also causes developers to devote valuable floor area to car storage instead of other more valuable commercial uses.

Shoup notes that parking minimums in particular limit opportunity. In some of our older business triangle structures, for example, property owners can lease to a coffee shop because the code-required parking isn’t available on premises. We want more coffee shops. They generate sales taxes and employ folks. But the structures available for them – historic structures that are ‘under-parked’ in the parlance can’t can’t accommodate them.

That’s not an academic point, however. It has real-world consequences. Our planners and policymakers have been trying to jump-start development of our western gateway, where former railroad land (now vacated) sits adjacent to the kind of low-rise small shops that have sparked a retain renaissance in many other cities. But to re-use those structure under our current parking codes, planning officials are proposing to allow a much larger new structure on the vacant land if it provides beyond-code parking capacity.

Garage facade

A lovely addition to our civic architecture. And it parks cars!

Accommodating visitors who arrive by car directly affects the streetscape too. Consider the visual and economic impact of public parking garages like this one. Nobody’s idea of an award-winning design, the main problem is that we’ve devoted precious street frontage to simply warehouse cars.

At ground level, too, these garages kill street activity. They introduce in-out traffic across a busy sidewalk like on Beverly Drive, where the hazards of in-out cross-pedestrian traffic is palpable.

yet a second garage is proposed to cross those busy sidewalks.

Shoup’s key point is that mispriced parking sends a wrong signal to the marketplace. Making parking cheap only encourages motoring when instead we should be encouraging other modes of transportation – walking, cycling, and transit that are better suited to the urban context.

What we’d rather have is a set of policies that views land use and mobility as tightly integrated and that prioritizes investment in jobs and the kind of activities that we want in our business triangle rather than sinking investment into parking. Whether it’s funneling general fund monies into propping up our parking operations fund, or asking private investors to build more parking capacity, or requiring new enterprises to pay into an in lieu program, shouldn’t we ask what the problem is that we’re trying to solve?

Let’s focus on mobility and not parking. And that means all modes of mobility.  And before we move forward on this in lieu proposal or even tinker with our in lieu program arrangements, let’s give Shoup’s arguments a hearing in Council. He’s appeared before our Traffic and Parking Commission in the past, but it appears that his lessons have not been heeded. That is, our Traffic and Parking Commission has recommended no substantive changes to our parking policy.

Until we learn to encourage foot traffic without the vehicular traffic and craft our land use policies around multimodal mobility (as our own Sustainable City Plan says), we’ll be stuck in the same old parking limbo with too few spaces to accommodate the demand and ‘free’ parking that comes at too high a cost. That was a point lost on our recent Small Business Task Force – read their report to learn how we’re not solving our small business problems with outmoded parking policies.

Gateway Update: Still Under Council Consideration

City Council meeting July 26, 2012For those who have followed the progress of the proposed Gateway overlay zone for the western end of Beverly Hills, closure is still not at hand! We’ve covered this most significant rezoning policy change in many years for the past 18 months because it has clear transportation implications – and they’re not good. So we’re not disheartened that City Council held off on a final decision this past Tuesday. The slow progress of the policy change through the Hall pipeline indicates that we’re not the only concerned stakeholders!

Gateway area parcel map

Parcel map showing the three Gateway projects at Wilshire & Santa Monica boulevards.

The owners of large parts of the current T-1 (transportation) zoned land around Wilshire & Santa Monica in Beverly Hills are champing at the bit to develop the Gateway. The land is a 40′ wide strip where the Pacific Electric streetcars used to roll all along SM Blvd. (Parcels 1-3 at left.) Now this end the land is in private hands, bought many years ago under the current zoning that prohibits most uses except transportation. (For a rundown on the Gateway proposal see our recap.)

Nobody is happy to see this land unproductive, but the city’s planning apparatus appears so anxious to develop this land and adjacent commercial properties that they are willing to concede additional height and floor area on the commercial parcels if new structures built on both the commercial land and the T-1 zone behind it and if they cough up additional public parking underneath in a garage. You see, the neighborhood is called ‘under-parked,’ which means our policymakers expect many more people to drive here.

So if the proposal carries, we would see a likely 4 story building replace these modest retail shops fronting Santa Monica South (below). These shops remain undeveloped today because redevelopment would have to meet minimum parking requirements under the code, and there is no way on parcels this small. Hence the interest in combining the commercial parcels and T-1 land into one project.

Gateway shopsYet this is precisely the kind of neighborhood character that we should work to preserve. Unlike much of the adjacent Business Triangle, there’s character here in the eclecticism. Look at South Beverly: it is gaining steam economically because of its modest-scale retailing bones. Robertson and several blocks on Doheney have much of the same possible upside because they too are low-rise and ready for hipsters. But this opportunity is lost on policymakers and our city’s Small Business Task Force.

A Couple of Things

Gateway Starbucks site looking southwest

The Starbucks site looking southwest toward Century City.

The theory of ‘under-parked’ applies only if you frame commercial activity through the car windshield. That means overlooking the high cost of providing free parkingfor people who choose to drive and it ignores the fact that the Gateway is one of the most transit-accessible areas in the city! It is served by two bus lines and is only a walk away from the heart of Century City. Indeed next door a coming 48-story tower (in City of Los Angeles) will put many more shopping shoes on the ground sans car. And it is across the street from what will one day be a big complex on the Hilton property. And it is adjacent to the Business Triangle. To a walker, cyclist, or transit rider, it’s not under-parked at all because there is simply no reason to drive. We should be limiting parking opportunities and not expanding them!

And second, that T-1 land is zoned for transportation for a reason. For half a century through the streetcar era, it served that purpose very well. And it can again serve that purpose in our multimodal mobility era if we reserve/preserve some or all of the T-1 strip of land for human-powered transportation. Think walk & bike path or native plant gardens & bike path that stretches from Century City to West Hollywood. It could mirror the Beverly Gardens Park to the north and be the kind of great, green corridor suitable for this old stretch of Route 66.

The good news is that it could have sailed through on Planning’s assurance that the Gateway proposal is sound policy. But it’s not, and rightly the City Council felt enough trepidation to hold off on the Gateway overlay zone. For the moment we have a reprieve. In the meantime, planning staff will reformulate the conditions that will shape any eventual project. But the extent to which project applicants adhere to them will solely be decided on discretion: the future Planning Commission and City Council will be free to depart from them.

Gateway land use study intersection model aerial

The Gateway vision that endures today: tall buildings with plaza setbacks.

Now, we may well wind up with a behemoth project that provides no mobility, returns scant ‘public benefit’ (in planning parlance) and only serves to impede our view of the hills like so much other recent development. (See the preliminary massing study at right.) Indeed we may yet see our own Beverly Center rise on this narrow strip of land. So let’s be thankful that Council took a breather. Stay tuned!

Beverly Hills Parking Authority is Losing $4 million/yr

Garage facade

A lovely addition to our civic architecture. And it parks cars!

Call us biased, but when your Parking Authority loses $4 million per year and faces a $40 million deficit only eight years down the road, maybe it’s time to re-think our commitment to providing free and highly-subsidized parking for anyone and everyone who chooses to drive. Make that ‘over-provide’: our city has constructed at great expense more than twenty public parking structures, many with excess capacity. Yet we’ve not installed a bike rack in a commercial area in many years. At $200 per, are they simply too cheap to bother?

As Donald Shoup so cogently pointed out, there is no such a thing as free parking. In The High Cost of Free Parking, he walks us though the data to show that we spend extravagantly to over-provide every motorist with an available spot at considerable expense. He figures that a garage space can cost about $40,000, for example, which (on a per sq. foot basis) rivals the cost of constructing a residential condominium. That’s a gift to businesses; they benefit from induced (motor) traffic but get to offload the expense onto the public sector. And we pay in city services.

That dynamic was in stark relief last year when commercial interests in Beverly Hills forced onto the ballot a proposal to mandate 2 hours of free parking at most city parking facilities. Voters agreed. And now that bill is coming due: $5 million per year for the next five years with another $3 million per year for the following three years. That’s what it will cost city coffers to plug the Parking Authority operations budget hole. And that’s just to cover today’s needs.

According to the Parking Authority staff report presented to city council this week, add another $800,000 every year for additional, necessary improvements. To be clear, that amounts to $25 million $40 million by 2020-2021. [See the Parking Authority Operations and Financial Report PowerPoint delivered to City Council.]

The city can’t support it with parking receipts. It comes straight out of the general fund. (Think shortened library hours; outsourced and limited services; and consider the projects that we’d like to fund but that we won’t be able to undertake at all.)

All to accommodate car parking in public garages? Why not charge for parking commensurate with our expense of providing it, you ask? Oops – we can’t. We settled with the ballot initiative folks so we have to provide that 2 hours free. It’s a cost we simply can’t recoup.

The Public Burden of Free Parking

Shoup’s critique is a broadside against the planning & transportation professionals and the policymakers they serve for so single-mindedly upholding parking-as-a-right. Heck, if you’re a motorist, you expect to find a space near where you shop, and you’ll demand it or you’ll take your business elsewhere! At least that’s what policymakers think.

But we overlook the trump card that a city like Beverly Hills holds: it’s a distinctive destination but one marred by congestion, frustration and hassles. If you’re in a car. If you’re on foot, why we’re one of the most walkable communities going, according to the folks who evaluate these things. Yet we keep building garages with yet another one expected in the coming few years on the 200 block South Beverly. That’s the pedestrian district where people already dodge the in & out of the garage that’s already there on that block.

Like many cities, we also force private developers to over-provide parking via parking minimums built into our muni code. While not a cost directly borne by the taxpayers, there is nevertheless a cost; it is just indirect. Shoup inventories and pillories such non-fiscal costs:

Garage elevation

How does this activate the streetscape?

  • Parking minimums limits the available uses for commercial areas because so-called ‘underparked’ spaces can’t be adapted for coffee shops or other high-traffic uses;
  • Each off-street parking spot whittles away at the area available for productive use by converting to storage essentially;
  • Site challenges sometimes force developers to put car parking on the ground floor – the most economically-productive area – simply because they have to put it somewhere; and
  • Ground floor off-street parking (whether public or private) kills the streetscapes that planners tell us to activate.

Public garages, however, are economic and material black holes that devote (and devalue) high-density urban space to storage for cars 24-hours, every day, whether there is a single car to park or not. They’re often single-purpose investments in multi-use areas that are, by definition, multiple purpose. We look askance at the parking moats around malls today because they’re evidently unproductive and unpleasant to navigate, yet the parking structure brings that sensibility right into our downtowns. These civic structures are veritable monuments to misplaced priorities and misallocated capital, yet policymakers celebrate them and even commemorate new garages with a plaque. Garage commemorative plaque

In the old days, it was the library, the city hall, and the auditorium that received such a distinction. How our values have changed: our garages now assume that prominence. Yes, we’ll take your car for about 18 hours a day in any one of our many garages, but if you want to borrow a book, make sure that you check our library hours because it ain’t open as much as it used to be. And compared to other libraries, in form and function, it’s as yesterday as a horse-and-buggy.

Let’s Rediscover Our Priorities: People-Centered Mobility

Parking structures in Beverly Hills business triangle

Parking structures in Beverly Hills business triangle.

Beverly Hills owns a total of 19 structures [inventory]. Just recently we completed a facility at Foothill to serve the city’s commercial and Public Works buildings (no bike racks in evidence near either building). A few years ago went deep into the hole for the garage that serves the Montage Hotel. And now a new garage is being constructed near Crescent & Santa Monica for the Annenberg Center. Surely there will be more garages coming. (Soon, in fact, the number of public parking structures will surpass the number of bike racks available citywide.)

What’s wrong with that picture? Nothing that $25 million can’t fix.

Is it not time that we reevaluated our transportation priorities? How about a few dozen $200 racks to get people to think about riding a bike instead of dragging their iron carcass up those dreadful ramps into a parking structure? How about we install some bike safety facilities on our streets to convince motorists that it’s more convenient to ride a bike on that short-hop shopping errand than, say, to circle my block incessantly, at high speed, to find a street spot on South Beverly?

Cities are beginning to come around to the fact that commerce depends on foot traffic, not motor traffic. We’re now seeing pedestrian-oriented districts studded with new bike racks and often they are already over capacity with people dropping bucks at small shops, coffee shops, brewpubs, and bookstores. But hot here.

It seems that we’re unable or unwilling to think outside the limited and very expensive car parking box that we’ve created for ourselves. Indeed a recent Small Business Task Force findings report seemingly addressed every opportunity to stoke economic activity except alternative modes of transportation. C’mon, guys – isn’t the Chamber hip to the economic impact of new ‘locavore’ shopping districts?

It’s not like there’s not reports and data to show the way. Portland succeeded in shifting 15% of its single car traffic to other modes simply by trying. The UK finds that by doubling their cycling road network and adding 1.3 million cyclists tallies to a whopping $4 billion contribution to the national economy PLUS another $1 billion in bike and accessory sales.  Here at home, Pew finds that policy goals like enhanced safety, increased commerce, greater mobility and better environmental stewardship will be served by refocusing transportation investment. In the most focused of economic development studies, Toronto has seen bike facilities effect such a change that today, more folks arrive by foot and bicycle to the Bloor Street shopping district than in cars, and they visit more often and spend more money too.

Bloor Street is a lesson for the Chamber and our policymakers that we can do it differently if we recognize that we’re no longer in the auto-centric era. As our city begins to mull over installing a few bike racks (at this week’s Council study session) let’s hope that policymakers pick this low-hanging fruit and spend a few thousand bucks at least on some bike racks. The next step is to re-think our plans for more garages, and, eventually, revisit our parking minimums too (Shoup’s bugaboo). The very high parking minimums established by Beverly Hills was oriented toward another era. Today it is a vampire that drains the economic lifeblood from revenue-producing property: every spot that parks a car is about 300 square feet of non-revenue generating space.

That’s why businesses are so eager to offload the parking function onto the taxpayers. And why taxpayers should be eager to shift parking demand to less expensive infrastructure like some bike racks. After all, two hundred bucks parks two bikes. Maybe that’s the answer to our $25 million question, and something that policymakers should consider as they dig deeper into the general fund for the foreseeable future…simply to park cars.

High Cost of ‘Free’ Parking (Part I)

High Cost of Free Parking coverDonald Shoup’s argument for rethinking the accommodation of automobiles in urban areas begins with a counter-intuitive claim: free parking is not at all free; in fact, it’s quite expensive. Whether or not we drive, he says, we do pay, but those costs are far steeper than a simple ledger would have you believe. From unrealized urban opportunities to misallocated resources that benefit primarily motorists, the true costs of parking are borne not by those who park but everybody including motorists who have to pick up the tab.

Let me begin by saying that the The High Cost of Free Parking is not planner’s book per se. It’s a broader critique of planning as it’s practiced in the vast majority of cities. As such, it casts a wary eye on policies that are often disconnected from the vision that gives birth to them. Free Parking also highlights problematic policies that fail to serve our policy goals, at least as enumerated in our planning documents. And Free Parking reserves particular scorn for a policymaking process that looks to conventional and received ‘wisdom’ rather than undertake the rigorous, empirical observation demanded by complex urban problems (like mobility).

As if to top it off, Shoup notes that too often, our remedy for the failed policies policies of the past (like his favorite hobbyhorse, minimum required parking) is simply to require more of the same. More cowbell please!

Donald Shoup’s point of departure is the misconception that parking is ‘free.’ In fact, its very expensive to provide, he argues; urban multistory garages nip at the general fund in many cities – funds that could provide services to all residents. Underground garages exact a considerable premium. Paradoxically these spaces while universally loathed cost as much to construct on a per square foot basis as a condominium.

He is particularly eager to disabuse readers that providing all that parking is cost-free. On the contrary, it’s just not conspicuously priced. Instead it’s expensively manufactured but often given away at no cost – which is quite a different prospect than ‘free.’ In reality, providing it at no cost instrumentally obscures the many costs that do come with it.

But Shoup’s real bugaboo is how poorly-conceived policies like that which over-supplies parking as a free good will ultimately keep us on the road to ruin. Providing parking at no cost encourages an activity that we would like to actively discourage in central business districts (namely motoring). In an incipient post-carbon era, a moment when federal, state, and local policies are aligning to encourage more efficient forms of transportation (not least active mobility), continuing to over-supply parking at little or no cost to the user works against our long-term policy objectives.

Looking Back: The Origins of the Parking Crisis

In a brief digression from Shoup, let’s trace the origin of the ‘parking problem’ back to early in the century, when city downtowns were making an uneasy transition from means of mass conveyance (think horsecars and trollies) to the ascendent favorite mode of individual transportation, the motorcar. But central business districts presented a particular problem because industrial-era cities concentrated commercial activities in the center. With the waxing popularity of the automobile, there arose the need to accommodate motorists, yet making room for cars – indeed simply parking them in volume – threatened to displace those very commercial activities upon which downtowns thrived.

To remain economically viable to a new class of highly-mobile consumers, downtown retailers began to integrate parking into their structures in innovative ways. Downtown Los Angeles department used ramps and schemes to tuck cars behind and within their walls. By increasing capacity (albeit at the expense of floor area), shoppers arriving by motorcar could find a place for their car. In this way, multistory car parks literally internalized the threat to downtown viability suggested by the new automobility.

Significantly, private businesses absorbed the cost of providing parking; it was the cost of staying competitive. As automobility threatened to siphon its best shoppers to new fast-developing tony commercial districts (like Miracle Mile and Beverly Hills beyond), keeping them downtown was paramount. Problem was, it was prohibitively expensive to build sufficient capacity because greater capacity induced greater demand. In time city administrations socialized that cost: they sold bonds, built municipally-owned garages, and underpriced parking. Then policymakers crafted municipal zoning codes to explicitly require developers to provide parking.

More recently, cities began building garages as add-on components to large, private-sector developments. Providing the parking at public expense reduced the expense and risk to the developer while saddling the public sector with an expensive, resource-consuming amenity. The LA/CRA committed to build the garage for Eli Broad’s vanity museum, for example. Here in Beverly Hills, city taxpayers picked up the tab for the Montage Hotel’s garage and the park that sits atop it. (And we continue to pick up the exorbitant cost of landscaping the premium-quality hotel ‘gardens’ to the tune of $13,000/month while ponying up for garage-related cost overruns.)

Are municipal garages a sinkhole for cash? You bet! Yet we continue to pay the largely hidden costs of making available all of that ‘free’ and under-priced curbside, garage, and privately-provided parking.  To date, only a few cities have come around to Shoup’s argument and begun to cap parking requirements rather than set a progressively higher floor for parking requirements (which say, in effect, “Only provide so much parking but no more”).

For policymakers in cities like Beverly Hills, progressive anti-free parking arguments are simply hypothetical. Their concerns find their origins in the downtown boosters of yesteryear: build more parking and the shoppers will come. When I casually ask people from beyond whether they spend their dollars in Beverly Hills, I receive two kinds of responses (paraphrasing): “Rodeo Drive is for wealthy tourists” (i.e., I don’t know much about your town, but I know that it’s not for me, and I won’t like it); and “I hate to drive there, and it sucks finding a place to park.”

Nevermind that we’ve constructed many public parking garages that have put our parking budget in the tank. But I sympathize: even I wouldn’t want to park here because I hate garages! But I do like to ride my bike. Pity there’s nothing on that score to welcome me and my fellow bicycle-bound shoppers.

The Problem of Parking

Shoup begins his Free Parking broadside with an apocryphal tale that says more about planning and planners than about anything specific to parking:

“In the beginning the Earth was without parking. The planner said, Let there be parking, and there was parking. And the planner saw that it was good. And the planner than said, Let there be off-street parking for each land use, according to its kind. And developers provided off-street parking for each land use according to its kind. And again the planner saw that it was good. And the planner said to cars, Be fruitful, and multiply, and replenish the earth, and subdue it, and have dominion over every living thing that moves upon the earth. And the planner saw everything he had hade, and, behold, it was not good.”

There’s the problem right there: we’ve recognized that current approaches to parking are not good, yet we persevere by over-producing at high cost the very kind of good that undermines the planning outcomes we’d like to achieve. To wit:

  • Parking structures that rob our streets of community-enhancing retail uses rather than add to the economic activity so vital to dense urban cores;
  • Arbitrary and formulaic parking minimums that require developers to turn over valuable, developable floor space to parking functions – a least-best use that inverts what planners are taught is the proper course of action;
  • Misallocated investment that plows public money into parking structures at a cost approaching $40,000 per space when  pressing needs like affordable housing perenially go unmet.

Perhaps the most important point is that our current approach exacts a long-term negative effect on the urban environment. Constructing garages entails a significant opportunity cost because policymakers have (literally!) elevated parking above other important policy concerns, like efficient modes of mobility – an issue arguably more pressing than simply providing single-occupancy vehicles with expensive urban real estate for storage purposes.

Never mind that cars are stationary for an estimated 95% of their working life; let’s make sure that there’s a waiting space should a motorist show up. For every (leveraged) dollar we invest in a parking structure, that’s a dollar not invested in transit, or housing for people, or the commercial structures that generate jobs and all-important sales taxes.

Public Parking garage entrance

The modern parking garage: a streetscape 'nullity'!

So instead of constructing productive projects like mixed-use developments that do reflect the many functions necessary to a vibrant urban core, we build parking structures that actually displace them.

What does this mean for the urban streetscape? It means a dead space or, worse, a high-traffic cut across the pedestrian right-of-way. In this sense the modern parking garage is an urban nullity: a structure to accommodate one function but which crowds out more positive use for that valuable street frontage. To make matters worse, the investment is under-used and sits mostly idle for as much as half the time.

A Closer Look at Planning Assumptions

Planning is more art than science, Shoup says, and Free Parking peels back the curtain to reveal facile suppositions that have long informed policymakers. Shoup dives into the facts and figures with tables and charts to offer a sobering lesson: behind today’s urban parking policies are problematic premises and flimsy data. He shows that many of the policies that we assume are developed according to sound assumptions are actually insufficiently grounded in empirical research. Planners’ claims, he says, are often simply unsupported upon examination.

No wonder that we find parking problems nearly everywhere we look; the whole enterprise is built on sets of faulty assumptions. Look closely and their claim to scientific rigor dissolves into a kind of urban myth (build it and they will come!). It’s the same set of assumptions that guided early twentieth century development decisions.

If  there’s no real science behind the carefully-constructed artifice of planning, then the irony is that a field that labored through the 1960s with a ‘systems view’ of urban problems (the paradigmatic scientific approach to planning) now finds itself returning to core concepts like empiricism to redress failing concepts. Shoup leads that charge; his purpose in Free Parking is to set the record straight and to stoke debate about what a more rational, market-oriented parking policy might look like. (He even appeared before the Beverly Hills Traffic & Parking Commission in early 2011, but from all appearances his message fell on deaf ears here.)

It’s not just planners who need take an interest. Shoup includes much here that will interest lay folks too. When he asks whether more parking is really better parking, he urges us into the field. One need not be a planner to see that the upper levels of any parking structure are so clearly little-used. We don’t need an elaborate study to know that each one of those unneeded spaces has sucked resources away from pressing needs without so much as a critical thought from policymakers about whether parking was the best investment. They simply believed it.

The layman can also look to the ‘churn’ familiar to any motorist who has gobbled time, gas, and patience in trying to find a curbside spot. (Confession: I’m guilty too!) Waiting for a street spot is not only a less-efficient use of your resources; it also adds additional friction to downtown traffic. Shoup documents how slowing and circling slows street throughput and, as a seeming bonus, externalizes (as planners say) such negative effects of congestion beyond the business district and into adjacent neighborhoods.

Shoup reserves particular scorn for required parking minimums, however, as he admonishes policymakers for blindly following planning industry recommendations and the advice of boilerplate planning white papers to provide ever-more parking without taking the time to look empirically at the local evidence. More to the point, why undertake a rigorous analysis of parking need (and perhaps address it on a case-by-case basis) when a local government can just require developers to simply over-provide parking by writing into the zoning code an array of parking minimums?

If conducting such studies is too much work for planners, then it’s probably too much to ask of policymakers to review them in detail. Better perhaps to simply require private developers to provide it – no questions asked. Indeed the Beverly Hills Traffic & Parking Commission which is advisory to City Council on such matters rarely, if ever, questions assumptions underneath our city’s parking minimums. But they enthusiastically apply them to proposed developments every month.

Shoup also takes the planning profession to task for taking the lazy way out. Published pattern books and industry guidelines shape how parking is created in nearly every city, but stand without a firm foundation in analysis. More damaging, Shoup highlights patently specious claims about statistical validity that permeate such documents. What’s left after evaluating them for scientific rigor is a surfeit of claims untethered to underlying empirical research.

And finally he pillories the academy itself. We learn that there exists no standardized textbooks by which neophyte planners gain a solid understanding of parking policies.  Instead they learn ‘on the job,’ unfortunately internalizing the existing approaches that continually produce poor outcomes  instead of questioning the empirical bases of parking policies behind them.

Shoup’s highly readable account of how we’ve gotten it wrong for so long, and why we keep getting it wrong, makes High Cost not only a planner’s book; it invites every urban development and transportation policy enthusiast to consider whether subsidizing parking is a wise allocation of our scarce time and energy in the face of pressing urban problems.

As Shoup says in his introduction, “We don’t pay for parking in our role as motorists, but in all our other roles – as consumers, investors, workers, residents and taxpayers – we pay a high price. Even people who don’t own a car have to pay for ‘free parking.’” Well, we’re certainly paying that price today in Beverly Hills.

In part II we’ll look at how misguided parking policies misfire, leading to suboptimal planning outcomes here at home, in Beverly Hills.

Reconsidering Level-of-Service (LOS)

Santa Monica & Wilshire

Definitely not included in traffic counts!

The Atlantic Media Group’s Atlantic Cities site features a look at the evolving relationship between urban sustainable transportation policies and the standards and practices put in place by local governments to assess and forecast vehicular traffic demand. There is a movement underway in popular and academic circles to revisit the use of multi-modal level of service indicators (or ‘LOS’ in transportation parlance) as an appropriate metric for evaluating projects and polices under California’s Environmental Quality Act (CEQA). Journalist Eric Jaffe’s piece looks at San Francisco’s initiative to  rethink the value of LOS in the changing context of urban mobility, where moving people rather than vehicles needs to be the focus of transportation policymaking.

The Problem With LOS

Traffic counts in the business triangle

Traffic counts are the first step in calculating level-of-service.

LOS indicators provide transportation planners and engineers with a ready metric for vehicular flow. Without getting too much into the weeds, LOS is a benchmarking tool adopted by policymakers and transportation planners to gauge existing vehicular throughput and congestion.

Level-of-service table for business triangle

Translating traffic counts into project net traffic change appears like science but it is more of an art!

Under LOS guidelines, road conditions or intersections are evaluated for speed, flow and congestion-related delay; the corridor or intersection is then assigned a letter grade from A-F that represents abstractly (and simply!) vehicular traffic ‘demand’ relative to road capacity.

LOS is a commonly-used benchmark because it is clear and understandable and, well, because it is commonly used. That tautology masks the readily apparent conveniences of the LOS metric. Existing inputs like traffic counts fit well with the LOS formula because it measures vehicular flow exclusively (at least as currently employed). Transportation departments need not retool any processes because they all are already well-ingrained in professional practice. Consultants that prepare environmental reviews need not invent a new wheel and students come semi-prepared from planning programs to use LOS tables.

The LOS wheel rolls along largely because policymakers too need not learn new models for impact thresholds. According to a multi-part piece in SF Streetsblog, LOS is a pseudo-science that keeps rolling along.

One model of reform has emerged in the Bay Area. San Francisco has earned a well-earned avant garde reputation for doing things differently. A compact city/county of fewer than one million souls and a perpetually left-leaning board of supervisors, it’s been fleet-footed on all manner of social and environmental concerns. It’s no surprise that city planners have staked out a relatively radical position tying LOS to something beyond vehicular flow, namely community health and environmental quality.

Indeed, active-transportation advocates question the prudence of the LOS framework precisely because it appears to measure what we don’t necessarily need to measure: vehicular traffic alone. In the larger context of mobility, and particularly where community health and the environment are concerned, it’s looking more and more like facilitating vehicular traffic flow is not the solution but more of the same problem.

Only Engineers Seem to Like Level-of-Service Indicators

To a traffic engineer, LOS is a reasonable benchmark against which to measure policy or project impact. But the formulas set out in transportation manuals and communicated to every transportation planning student does not actually reflect real-world conditions in an area like Los Angeles, critics say. (In my experience, every traffic consultant engaged by project opponents come to a significantly different estimation of net traffic impacts than does the draft environmental impact report which contains the official estimates.)

For those not inclined to place faith in traffic engineers and policymakers, those traffic studies are a pro-forma exercise designed to facilitate development rather than accurately forecast impacts. The vehicle counts that are the basis for the studies are frequently disputed. Yet those figures and the formulas based on hypothetical impacts they’re plugged into have animated opponents inclined to question the credibility of the environmental review process.

Now, it’s important to measure vehicular traffic precisely because it’s so closely related to things we want to avoid: fuel inefficiency; greenhouse gas emissions on the increase; and that never-ending procession of injuries and deaths arising from motor vehicle collisions. Ted Rogers over at BikingInLA does a heroic job of tracking those calamities, and to date they total 65 confirmed traffic-related fatalities in year-to-date in Southern California and 21 in Los Angeles County alone.

But for opponents, an inherent limitation in LOS projections is compounded by measures (like turn pockets and signal timing) that often seem  insufficient to the task of mitigating a net anticipated increase vehicular traffic flow. Such concerns highlight an overall lack of confidence in LOS as a metric under CEQA.

Measuring flow as a benchmark for evaluating projects and policies seems like a dead-end metric to transportation advocates too for LOS is an abstraction that says little about mobility problems or opportunities. It merely indicates a relationship between vehicle throughput and roadway capacity. It doesn’t account for non-vehicular modes of travel including feet, bicycle, and rail.

Moreover, because LOS counts cars to the exclusion of every other means of transportation, it is silent on ped or bike mode choice, and silent on road safety.  It says nothing about what it’s like for people who choose to walk or bike to navigate among frustrated drivers in an overburdened intersection.

If counting vehicular traffic alone doesn’t take into account the complex issue of urban mobility, shouldn’t we be measuring what we want to measure? Think of road diets and you’ll understand why viewing such an improvement from the motorist’s perspective exclusively would be looking through the wrong end of the telescope.

What’s Wrong With This LOS Picture?

Wilshire & SM intersection aerial viewIf Beverly Hills is any indication, level-of-service is an abstraction with little application in the real world. We have several intersections that are so substandard relative to traffic volume that they are acknowledged by transportation officials as level E or F (among the worst LOS ratings). These intersections are also dangerous for people who walk or ride, however – a condition for which our Transportation Division employs no metric.

South Beverly & Olympic intersection overview

The Wilshire/Santa Monica (above) and Olympic/South Beverly (at right) intersections, for example, are acknowledged as safety concerns for all road users, yet improvements are slow to come to the aid of the walkers and cyclists who move through them. This was highlighted by a September collision at Olympic/South Beverly that resulted in a cyclist’s injury and property damage. It was an event avoidable merely by marking travel lanes to eliminate ambiguity and avoid unnecessary conflict.

That intersection remains unimproved; indeed it is not due for a safety upgrade for about a year. And that planned improvement is all about vehicular traffic flow.

Bike Backbone map missing Beverly Hills piece

Beverly Hills is the missing link in the emerging regional bikeways network.

Wilshire/Santa Monica too will wait – until mid- late-2013 under the SM Blvd. corridor improvement project. And this key east-west cycling corridor and bike backbone route may yet not even sport a dedicated bicycle lane, according to our most recent meeting with city officials.

With a standing policy of increasing vehicular throughput as a primary concern in Beverly Hills, it’s not surprising our city does not pursue pro-bike enhancements or facilities like bike lanes. Bus rapid transit corridors too don’t fit into the LOS picture and our city has declined to support them.

Policy objectives may favor environmentally-sustainable forms of transportation, and indeed it says as much in our Beverly Hills Environmental Sustainability Plan (2009) and other plan documents, but you won’t see such concerns reflected in the new BH traffic thresholds (adopted Fall of 2010). Thresholds trigger environmental review yet they are all about vehicular flow: like the old, they refer only to car trips generated. (We can’t link to the Sustainability Plan because it’s not even posted on the city’s website.)

What if a policy were formulated to help shift some of the projected increase in auto trips to other modes of travel? Wouldn’t that make new projects less taxing on our roads? We won’t know because we don’t count such non-vehicular trips. So, Beverly Hills Transportation Division officials can tell you all about LOS intersection-by-intersection, but they can’t tell you how many folks ride, or anything about safety because they simply don’t keep collision figures. (Bike blogger Ted Rogers probably knows much better about that than do our own officials.)