From Councilmember Lisa Herbold, District 1

As you know, I brought forward an amendment that would allow (not require) Seattle Department of Construction and Inspections (SDCI) to mitigate parking impacts in urban villages with frequent transit service, where no parking is required in developments, and in only those locations where on-street parking occupancy exceeds or would exceed 85 percent.

The amendment did not pass, with a vote of 2 to 7. Council President Harrell joined me in voting in support of my amendment. I ended up voting against the bill entirely. This was not because I disagree with the goal of supporting people who are able to choose to live a car-free life. It was not even a vote in opposition to the 2012 legislation that removed parking minimums in urban villages with frequent transit service. My vote against CB 119221 was a vote against expanding the size of the areas in Seattle that are exempt from parking minimums without:

• First evaluating the impact of the 2012 law as to whether people who live in frequent transit areas with reduced parking requirements have less car ownership;
• An analysis of the social justice impacts of this policy on low income folks, seniors, people with limited mobility, people who are required to have a vehicle as a condition of employment, and other people who need their vehicles for a variety of reasons;
• Accepting a modest amendment that would allow - not require - SDCI the flexibility to mitigate parking impacts in very narrow circumstances;

Again, this amendment did not obligate SDCI to require mitigation through State Environmental Protection Act (SEPA), it only gave them the flexibility to do so in only those locations where on-street parking occupancy exceeds or would exceed 85 percent. Five tools were given as options:

1. Transportation management programs;
2. Parking management and allocation plans;
3. Incentives for use of alternatives to single-occupancy vehicles;
4. Increasing the amount of parking required for the development;
5. Reducing non-residential development densities.

A previous version of the amendment included language allowing SDCI to limit the number of Residential Parking Zone (RPZ) permits granted to future residents of a building proposed in an area where no parking is included and existing on-street parking occupancy exceeds or would exceed 85 percent.

This version of the amendment was heard in the Planning, Land Use, and Zoning (PLUZ) committee and failed. The version of the amendment heard in Full Council, removed that option, and prioritized the five mitigation tools, making increasing parking requirements and reducing densities the lowest of five priority tools. The amendment heard on Monday also granted SDCI the ability to craft a director’s rule before this amendment would go into effect. These are all changes I made to my proposed amendment between the PLUZ committee meeting and the Full Council meeting in an effect to address the concerns of my colleagues on the Council and garner their support.

Central Staff analyzed last year’s data and found that of 136 projects only six of them would have triggered this SEPA mitigation option. Of those six, three of the projects provided parking for other reasons. So, if last year is a good comparison, this tool would have only been a consideration of SDCI in three of 136 projects, or 2 percent.

As you probably know, the City has entirely removed the authority to use SEPA to mitigate the parking impacts of projects, when those projects are in areas where the City has removed parking requirements, areas referred to as “Frequent Transit Areas.” In other words, even though state SEPA requires developers to do parking studies as part of the permitting process, when those studies show that a development without parking is going to create a problem, SDCI can’t require mitigation. In those instances, this is what SDCI tells the public: “while impacts to parking could be substantial, we are unable to mitigate the impacts.”

Why did I suggest an 85 percent threshold in my amendment? Eighty-five percent is the capacity threshold that both SDCI and SDOT use for other parking mitigation measures. The work of Donald Shoup, The High Cost of Free Parking, has guided much of Seattle’s parking management policies. Shoup’s most famous recommendation is to implement a policy targeting an 85 percent occupancy rate for street parking by modulating parking prices because it's a compromise between optimal use of the parking spots and allowing drivers to find a parking spot easily, avoiding cars driving around for five to 10 minutes to find a parking spot.

Under state law, SEPA requires us to look not only at the impact of decisions on plants, animals, air quality, and water; but also on housing, public services, and historic preservation. This means that the state requires that we look at parking as part of that comprehensive analysis of impacts of development. In addition, when Seattle is in the top five of cities for number of hours (58 hours/year) spent looking for parking, failure to mitigate parking impacts in instances where it is warranted becomes a very big environmental issue.

In fact, in a 15-block study conducted by Donald Shoup, he said of vehicles seeking a parking spot: “Over the course of a year, the search for curb parking in this 15-block district created about 950,000 excess vehicle miles of travel — equivalent to 38 trips around the earth, or four trips to the moon. And here is another inconvenient truth about underpriced curb parking: cruising those 950,000 miles wastes 47,000 gallons of gas and produces 730 tons of the greenhouse gas carbon dioxide."

Shoup’s work is undeniably influential as it relates specifically to our paid parking rates in Seattle. His recommendations, when implemented, have borne many desired results. His work has also influenced the removal of parking minimums all over the world. (see attachment for the US 20 most populous cities and you can see how influential in Seattle!) But his book was written in 2005 and republished in 2011. An article in the Journal of American Planning Association says: “Shoup’s failure to update the book also means that he only hints at the latest scholarship. Recent research suggests the importance of considering context when implementing planning and design standards. While Shoup provides examples of places, like central business districts and universities, where parking supply could be reduced because of the availability of other travel options, he does not develop a coherent argument for context-sensitive parking policies.”

I say this because I believe that the use of academic theories should be informed by real world application and rigorous study of their impacts and outcomes towards our policy goals. Since Seattle’s 2012 removal of parking minimums in urban villages with frequent transit service, there has been no evaluation indicating that these policies have reduced car ownership in these areas. In fact, car ownership has remained flat since 2012. Of particular importance to me is whether policies that, in some neighborhoods may force people who need their cars to park far away from their homes or waste time looking for parking, have exacerbated impacts resulting from the growth of gig-economy driving jobs since Shoup’s work. Amazon Flex, Instacart, Uber, and Lyft were not the lifeblood side jobs providing supplemental income for struggling families in 2005.

We legislate our values. But in legislating we must balance our values in a way that recognizes that our cities are not urban planning models in a laboratory. Our cities are made of people with unique qualities that don’t always fit in our models of how we hope the world to be. So sometimes we have to compromise around the edges. The compromise I sought was a) to support the value of helping people to choose car-free lives when they can, but b) recognizing that I live in a neighborhood with driveways and plentiful on street parking and c) believing that when members of the public who do not live in neighborhoods like mine and with lives that are different than mine ask me to consider a compromise to my values - that it’s my responsibility and duty to do so.

I sincerely appreciate you taking the time to write myself and my colleagues to share your thoughts and concerns about this legislation.