HomeMy WebLinkAbout03-01-2020 Public Comment - D. Pickard - Parking Benefit DistrictsDale Pickard
527 No. Montana
Bozeman MT
dpickard@bresnan.net
March 1, 2020
Re: Parking proposal
Dear City Commissioners,
My wife and I have lived in our home at 527 No. Montana for ~35 years. The home we
own and remodeled was originally moved to the very small lot with no provision for off
street parking.
We also own commercial property at 501 East Peach, which I fear will be subject to
similar ordinances in the near future. That property was thankfully required to have
minimum parking and some allowance for snow removal. I am pleased that our
commercial business and those others in our building are NOT reliant on street parking
especially as I witness an unprecedented explosion of traffic and parked cars in the
surrounding Northeast neighborhood.
Because we live and work in the neighborhood, we have primarily relied on walking
and bicycling for much of our transportation over the years.
I have read all of the documents provided to the City Commission including the
consultant’s report and the proposal itself. In addition, I have spent some time
researching what I think is the ideological foundation of the proposal itself. This
foundation is singularly expressed in a the book, “The High Cost of Free Parking” by
economist Donald Shoup of UCLA. If you haven’t read this, I urge you to, so that you
can verify what I write here. Some of this you can find in the Wikipedia article on the
book.
From reading this book and other work by Dr. Shoup online, I learned that the
consultant’s report, the proposal itself and the policies in the proposal are derived
almost entirely from this book. Everything in the proposal and the consultant’s report is
viewed through this lens and notably, it does not focus on or identify specific issues
challenging Bozeman, but instead serves strictly as a sales pitch for Dr. Shoup’s singular
economic ideology. I found this suspect.
I learned that, by his own admission, Dr. Shoup, a “free-market”, economist, is rather
alone with his ideas among other professionals in the field, especially traffic engineers
and urban planners. He explains opposition and resistance to his ideas by insisting that
they are “paradigm breaking” and only he has been able to crack this conventional
paradigm. There is much of this in the book, including a number of failed but amusing
analogies to his own self-described singular insight.
This insight is summed up in one sentence, from the Wikipedia article on the book, the
elements of which you can find in the current parking proposal and the consultant’s
report. This is the ideology that the proposal seeks to become public policy.
“He [Shoup] suggests [Cities] charging fair market prices for curb parking, returning parking
revenue to neighborhoods for community investment, and removing the requirements for off-
street parking for new development.”
This ideology and the policy before the commission call for recognition of
neighborhood curbside parking as an “asset” to be “leveraged” by renting use of the
neighborhood streets for parking. In classic fashion the proposal seeks to use prices to
regulate demand.
However, revenue generated is not invested in more adequate parking in afflicted areas
but instead is used to grow and maintain a parking enforcement authority. Moreover,
the cost of this program is not borne by the community as a whole but is placed entirely
on the property owners that are most afflicted.
• The parking proposal calls for the Parking Commission to determine who is forced to
pay for parking on their own neighborhood streets by their 85% rule. Not transparent
is how or when, especially what season, this 85% occupancy is calculated or what it
means in terms of real facts on the ground for any given neighborhood or street,
especially in old Bozeman. Once so designated a neighborhood will be “managed”
for 85% so it will never change.
• The proposal calls for the commission to set “fair market rates” for parking in
neighborhoods with no transparency into how these rates are set or what makes them
fair. The proposal does require that the rates be sufficiently high as to fund the
bureaucratic investment in the overhead to create, maintain and operate the parking
district. However, it gives no indication how much funding is required as the amount
of parking “management” is scaled up.
We are told that the district will be maintained and enforced through regular
surveillance of the neighborhoods with license plate readers. Apparently now night-
time has been added to the ordinance so we can presume after dark surveillance.
Other than the obvious loss of privacy brought on by data trolling license plate
readers, one has to wonder at the cost of the burgeoning parking bureaucracy that
must be necessary to maintain it.
• The proposal calls for the City to plan to profit from the operation of the district - this
is necessary to provide the “parking revenue return” to the neighborhoods promised
in the proposal. The proposal mentions funding of “curbside improvements” with
“excess revenue” but doesn’t explain how this revenue is calculated or what is meant
by “curbside improvements.” While everyone believes that the program will be
managed to create “excess funds” - no one believes that any money or improvements
will be returned to the neighborhood. I think this promise is intended to mislead.
I think that the proposed program will be expensive enough to implement and
maintain, and that the rates will have to be higher than necessary to return anything
of value to our neighborhoods.
• The proposal provides the means for developers to externalize their parking costs
onto the surrounding neighborhoods, thus maximizing their profits. Dr. Shoup’s
third tenet is that developers should not be held to minimum off-street parking
requirements for their projects and that planning should allow developers to rely on
renting City owned parking, including curbside parking, for their projects.
The problems we are addressing here do not exist as a result of the proximity to a High
School or a University. Parking problems in the neighborhoods surrounding the
downtown district are the result of the very recent massive developments that provide
for too little parking for their tenants, residents or employees. These are private,
commercial, for profit ventures.*
Parking problems in the neighborhoods that do exist clearly result from building and
business developers providing inadequate parking. The proposal calls for selling or
renting curbside parking on surrounding neighborhood streets to neighborhood
residents and to non-residents at increased prices. This represents a clear subsidy to
developers and incentive for them to build with inadequate parking and externalize
those costs onto the residents of the surrounding neighborhoods.
While owners and tenants of the very expensive new downtown housing may be
readily able to afford to pay for “market price” parking in other people’s neighborhoods
- employees and service workers of Downtown businesses will have no choice but to
subtract these costs from their income.
Externalizing the costs of development increases the profit margins of the developer at
the expense of the community. Doing so by decreasing or eliminating minimum parking
requirements has the effect of extorting residents to pay to turn our residential
neighborhoods into paid parking lots and thorough fares to downtown for non-
residents.
Recently, following this same ideology, the Cottonwood project in the NE neighborhood
was approved with much less parking than was recommended by City planning. This
decision by the City to ignore planner’s recommendations directly increased profits to
the developers while externalizing parking costs and impacts to the neighborhood.
This is not so much protection of the threatened parking needs of neighborhood
residents as it is a protection racket. Neighborhood residents whose streets have been
afflicted with the impact of over-development downtown are targeted to pay again for
City services that un-afflicted neighborhoods take for granted by means of tax dollars
already spent.
This proposal recognizes our parking conflicts as a market which can support a growing
bureaucracy that creates revenue and provides for itself without really addressing or
compensating for the need for more parking downtown. No problem is solved and the
quality of life and value of our tax contributions as residents of Bozeman suffers,
especially for those of us captive in afflicted neighborhoods.
Because these problems were created by past bad decisions on the part of the City, it is
up to the City taxpayers to come up with progressive investments in actually solving
problems. Before we add injury to insult for the surrounding neighborhoods, taxpayers
will have to find ways to fund actual parking solutions, similar to the current parking
garage.
If there is money available to have created these problems there should be money
available for real solutions. There is no amount of market based hocus-pocus that will
substitute for actually acting to solve the problem in real terms that tax paying citizens
and traffic engineers and drivers understand even if rent-seeking economists and self-
serving developers don’t.
Onerous parking taxes, expanding parking police, and building burgeoning databases
on the habits of citizens in targeted local neighborhoods should not be allowed to
substitute for real investments in tangible solutions.
Respectfully,
Dale Pickard
* For an example in Bozeman of a housing project that does provide for adequate
parking for the development, see the Village Downtown which serves as a true asset
to our community and example of the benefits of planning for off street parking.
The units available in the massive buildings downtown are likely as expensive but
come without obvious parking benefits.