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HomeMy WebLinkAbout07-22-26 Public Comment - E. Talago - Public Comment for Transportation Board re_ PBZFrom:Emily Talago To:Bozeman Public Comment Cc:Nicholas Ross Subject:[EXTERNAL]Public Comment for Transportation Board re: PBZ Date:Wednesday, July 22, 2026 12:02:49 PM Attachments:Public Comment- PBZ.pdfSCC Concept Report Draft.pdf CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe. Please distribute public comment and concept report to members of the transportation board at your earliest convenience. With gratitude, Emily Talago Dear Members of the Transportation Advisory Board, Thank you for the time and consideration you gave to our Midtown neighbors' concerns at your last meeting regarding the RPPD for Bozeman HS. I appreciated the opportunity to be heard, the thoughtful questions raised, and the intentional direction you offered. As I mentioned in my written and spoken public comment, some neighbors on the east side of N 7th have been contemplating a parking management strategy since the city adopted zero parking requirements for the corridor in 2017. We are contending with the ELM, a 1100 person event venue with no parking, along with a sizable bolus of 1000+ units of high density residential and commercial development approved and at various phases of construction. Despite a vision for shared parking leases and structured city-owned supply, those things have yet to materialize and thus compels the request that you take up the parking management conversation sooner than later. Before describing our request, it's worth summarizing the two mechanisms Bozeman's code currently provides for neighborhood-level parking management, since our request sits at the intersection of both: ● Residential Parking Permit Districts (RPPDs)— Sec. 36.04.330 et seq.— are established by City Commission ordinance following a public hearing, and are the mechanism used for districts like the MSU Residential District and the Bozeman High School district. RPPDs set fixed day/hour restrictions and permit rules directly in ordinance. ● Parking Benefit Zones (PBZs)— Sec. 36.04.601 et seq.— sit within an already-established Parking Management District (currently only the Downtown district) and are created, amended, or dissolved by the Parking Commission (Transportation Board) itself through a resolution and neighbor-notice process, rather than requiring a Commission ordinance for each change. PBZs also allow surplus revenue to be reinvested directly in the zone. Because east of N 7th falls within the already-adopted Downtown Parking Management District, the PBZ pathway is the one squarely within this Board's authority, and administratively it is the better fit for our situation— it doesn't require a separate ordinance each time the zone needs adjustment. As mentioned last month, we have been developing a parking allocation model, the Shared Curb Credit (SCC) framework, intended to work within that PBZ structure. We're attaching a preliminary concept report describing the SCC methodology for the Board's review, with the understanding that it is a work in progress and will be finalized as our policy request is refined and the underlying code is potentially amended. We looked closely at both the RPPD and PBZ frameworks, and here's the issue we keep running into: both mechanisms hard-code permit allocation rules in ordinance rather than basing them on any underlying analysis of cost, demand, or curb capacity. Both RPPDs and the current PBZ ordinance (Sec. 36.04.604) prescribe fixed, uniform figures— a set number of resident permits per dwelling, a set number of visitor permits, a blanket weekday restriction window— regardless of what a given block's infrastructure costs, curb inventory, or demand pattern actually look like. That level of one-size-fits-all detail is exactly what the SCC framework is designed to replace with a transparent, data-driven allocation, and it's a structural mismatch with either existing tool as currently written, not just a Downtown-versus-neighborhood issue. In particular, the existing PBZ ordinance's fixed permit counts and blanket weekday hours run counter to a proportional, PBZ-specific allocation model like SCC. We think the underlying PBZ-creation and enforcement framework in Division 3 is sound, but the eligibility provisions need to be loosened to let individual PBZs adopt different, locally-appropriate allocation strategies instead of one fixed permit formula for every zone. I’d like to request that the Board place this on future meeting agendas to consider recommending that the Bozeman City Commission: 1. Update Chapter 36, Article 4, Division 3 to reflect the “house-keeping” definitional change from "apartment building" to "multi-unit building" adopted in Chapter 38, so the two chapters stay consistent; 2. Amend the overly prescriptive eligibility language in Sec. 36.04.604 (fixed days/hours, fixed permit counts per dwelling, blanket multi-unit exclusion) to allow individual PBZs to adopt disuniform, PBZ-specific parking management strategies grounded in actual cost and demand analysis; and 3. Establish the North Seventh Association of Neighbors East (NSANE) Parking Benefit Zone, using the SCC framework, under the amended code. Regarding budgets, Sec. 36.04.605 requires PBZ permit fees to be set at a level that at minimum covers administration and enforcement costs, but to date we don't believe the City has developed a line-item cost estimate for administering a PBZ of this kind. We'd suggest that a program budget breaking out fixed costs (e.g., signage, initial GIS setup, notice mailings) versus variable/ongoing costs (e.g., annual permit processing, enforcement staff time, SCC recalculation) would give the Board a much stronger basis for evaluating our request and setting appropriate participation fees, and we'd welcome the opportunity to help develop that estimate alongside staff. Open questions we'd welcome the Board's or staff's guidance on, several of which came up in our own internal discussion and which may need to be resolved before or alongside any code change: ● PBZ boundary clarity: Sec. 36.04.601 describes the Downtown district as the B-3 zoning boundary plus 1,000 feet beyond it. We'd like clarification on whether the B-3 zoning district itself is included within the parking management district, or whether the district consists only of the 1,000-foot extension around it. ● "Dwelling" definition: Sec. 36.04.604 conditions permits on a per-"dwelling" basis but doesn't define the term. We'd propose this be clarified to mean each uniquely taxable parcel, and would appreciate the Board's or staff's view on that. ● Multi-unit/apartment eligibility: Residents of multi-unit buildings are currently excluded from resident and visitor permits under 36.04.604.F–G, despite paying into the same street assessments. We think this may merit reconsideration. ● Day/hour specificity and why our situation is different: The Midtown commercial corridor has had zero off-street parking requirements since the B2-M zoning designation was adopted in 2017. Combined with the elementary school and the ELM event center— a roughly 1100-person venue with no dedicated parking of its own— our neighborhood experiences very specific, predictable peaks in demand for on-street parking. On show nights, residents returning home from middle-shift jobs frequently cannot find parking on for a few blocks because event attendees have filled it. This is a fundamentally different demand pattern than the fixed 8:00 a.m.–5:00 p.m., weekday-only restrictions built for the MSU or Bozeman High School districts, and a uniform M–F daytime restriction doesn't address it. The only way we see to get commercial property owners and event operators to eventually increase off-street parking supply is if this Board and the Commission support exercising real authority to prioritize on-street parking for residents during our actual peak demand periods, which do not track a standard commuter schedule. ● Special assessments within urban renewal districts (URDs): We understand properties within a URD still pay special assessments, but only for local streets. We'd like to confirm this is accurate, as it affects the cost-allocation side of our model. ● Maintenance-to-reconstruction cost ratio: Is there an established or recommended ratio between annual maintenance assessments and amortized reconstruction assessments that the city uses, or is this left to case-by-case bond structuring? This affects how consistently our model could be applied citywide. We recognize this may require pairing our request with broader policy cleanup work that may be already identified as outstanding, and we're glad to support that effort in whatever way is useful. Thank you again for your consideration. We're happy to attend a future meeting to present the SCC model directly and answer questions. Sincerely, Emily Talago Midtown Neighborhood Association, Steering Committee Shared Curb Credits — Concept Report (Preliminary Draft) E. TALAGO Shared Curb Credits (SCC) A GIS-Based Cost Allocation Framework for Parking Benefit Zone Permit Eligibility Concept Report — Preliminary Draft Prepared for the Bozeman Transportation Advisory Board Pilot PBZ: North Seventh Association of Neighbors East (NSANE) Note: This report is a preliminary concept draft, shared to illustrate the SCC methodology. It will be finalized as policy is refined and applicable code provisions are potentially amended. The reconstruction costs used in the case study are hypothetical and included only to demonstrate the calculation; they are not a proposed assessment. Existing Residential Parking Permit Districts and Downtown Parking Management District Page 1 Shared Curb Credits — Concept Report (Preliminary Draft) E. TALAGO Executive Summary Residential parking permit programs are traditionally designed around one question: Who should receive access to a limited public parking resource? This report proposes an alternative: base permit eligibility on the same objective facts the City already uses to fund its streets, and let a small internal marketplace handle the rest. Rather than allocating parking permits through first-come, first-served registration, waiting lists, lotteries, or uniform permit limits, this proposal ties each property's permit eligibility to that property's share of the neighborhood's street costs — adjusted for any curb the property already has to itself through a driveway. The resulting accounting unit is called a Shared Curb Credit (SCC). SCCs represent a parcel's annual share of the neighborhood's shared curb resource. Property owners can use SCCs to obtain residential parking permits within a Parking Benefit Zone (PBZ), or voluntarily trade unused credits to neighbors who need more — a kind of small, resident-led exchange for parking supply, described in more detail below. This report demonstrates the concept using a single block as a case study. Because it relies on parcel, street, curb, and parking data the City already maintains in GIS, the same approach can be applied block-by-block across the neighborhood, and recalculated automatically as conditions change. The technical formulas behind these calculations are provided in the Appendix for reference. This body of the report focuses on how the concept works and what it would mean in practice. Purpose The objective is not to privatize public parking. The objective is to create a transparent, repeatable framework that answers three questions objectively: ● How much does each property contribute toward the neighborhood street system? ● How much public curb has already been set aside for that property's exclusive use (i.e., its driveway)? ● How much of the remaining shared curb should that property have a claim to? How SCC Works Every property on a residential street already contributes to the cost of that street, through maintenance assessments (based on lot size) and, when a street is rebuilt, reconstruction assessments (based on frontage). SCC simply uses those same, already-existing cost shares as the basis for parking permit eligibility, rather than assigning every household the same fixed permit count regardless of what it contributes or how much curb it already occupies with a driveway. The steps are: ● Add up what each property pays annually toward street maintenance and reconstruction. Page 2 Shared Curb Credits — Concept Report (Preliminary Draft) E. TALAGO ● Determine each property's percentage share of the total neighborhood street cost. ● Inventory the curb: how much is off-limits for safety reasons, how much is already private driveway, and how much is left over as shared public curb. ● Give each property that same percentage share of the shared curb. ● Subtract any curb that property's own driveway already occupies, since that household already has private off-street access other residents don't. ● Convert the resulting footage into a number of "Shared Curb Credits," using a standard 22 feet per parking space. A property that pays more into the street and has little or no driveway ends up with more credits. A property with a long driveway curb cut that already provides off-street parking ends up with fewer, since it has less need to draw on the shared curb. One credit buys one resident permit. The SCC Marketplace: A Mini Exchange for Parking Supply Not every household will want to use all the credits it receives, and not every household will receive enough credits to cover the permits it wants. SCC addresses this with a small, resident-led marketplace app— conceptually similar to a limited internal stock exchange, but for curb space instead of shares. ● Each year, every property is issued its SCC allotment, based on the calculation above. ● A property that doesn't need all its credits (for example, a single-permit household that receives several) can voluntarily transfer the surplus into a neighborhood pool or directly to another resident. ● A property that needs more permits than its allotment provides (for example, a household with multiple vehicles) can acquire additional credits from that pool or from a neighbor, rather than being capped by a flat per-dwelling limit. ● The City's role is limited to administering the accounting: issuing SCCs annually and issuing permits only when sufficient credits are surrendered. The City does not pick who gets extra permits — that is worked out among residents through the exchange app. This is the feature that most directly answers a problem with the existing PBZ code: rather than the City prescribing a fixed number of permits per dwelling regardless of actual need or contribution, the marketplace lets supply flow to the households that value it most, while still keeping the total number of permits tied to the physical curb actually available. Why This Approach The current PBZ and RPPD frameworks allocate permits by fixed, uniform rules — a set number of resident permits and visitor permits per dwelling, regardless of lot size, frontage, driveway access, or financial contribution. SCC replaces that fixed formula with a proportional one grounded in data the City already collects, and adds a market mechanism so unused allotments aren't wasted. Because the framework is based on percentages and existing GIS data rather than fixed dollar amounts or fixed permit counts, it does not need to be rewritten if assessment rates, financing terms, or curb inventories change in the future. The same steps are simply re-run with updated numbers. Page 3 Shared Curb Credits — Concept Report (Preliminary Draft) E. TALAGO Illustrative Case Study The following case study demonstrates the SCC calculation on a single hypothetical block, using the City's real assessment methodology for maintenance costs. Reconstruction costs, bond terms, and the resulting reconstruction assessment are hypothetical, included only to show how a reconstruction cost share would be incorporated if and when a street is rebuilt — they are not a proposed or pending assessment. Existing Assessment Methodology The case study uses the City's existing assessment methodology. Maintenance ● Assessment based upon parcel area ● Rate: $0.040217/square foot Reconstruction ● Cost: $350/linear foot ● Bond term: 20 years ● Interest: 5% ● City contribution: 50% ● Property-owner contribution: 50% ● Reconstruction cycle: 50 years Parcel Geometry Parcel Frontage Depth A (corner) 75 125 B 60 125 C 65 125 D 50 125 E 50 125 F 60 125 G 65 125 H (corner) 75 125 Corner parcels include an additional 125 feet of assessment frontage for reconstruction purposes. Page 4 Shared Curb Credits — Concept Report (Preliminary Draft) E. TALAGO Financial Contribution Maintenance (actual City rate) Total parcel area: 62,500 square feet Annual maintenance, using the City's current $0.040217/sq. ft. rate: $2,513.56 Reconstruction (hypothetical, for illustration only) No reconstruction is proposed or pending for this block. The figures below use a hypothetical construction cost and bond structure solely to show how a reconstruction share would factor into the calculation if a street were ever rebuilt. Street length assessed: 750 feet; hypothetical construction cost of $350/linear foot: $262,500 Hypothetical property-owner share (50%): $131,250, amortized over a 20-year bond at 5% interest and a 50-year reconstruction cycle: an equivalent annual cost of $4,213.18 Total Annual Neighborhood Cost (illustrative) Combining the actual maintenance figure with the hypothetical reconstruction figure: $2,513.56 + $4,213.18 = $6,726.74 Parcel-Level Cost Allocation Maintenance columns below reflect actual City rates; reconstruction and total columns are hypothetical. Page 5 Parcel Frontage Area (SF) Maintenance Assess. Frontage Reconstruction Annual Total A 75 9,375 $377.03 200 $1,123.52 $1,500.55 B 60 7,500 $301.63 60 $337.06 $638.69 C 65 8,125 $326.76 65 $365.14 $691.90 D 50 6,250 $251.36 50 $280.88 $532.24 E 50 6,250 $251.36 50 $280.88 $532.24 F 60 7,500 $301.63 60 $337.06 $638.69 G 65 8,125 $326.76 65 $365.14 $691.90 H 75 9,375 $377.03 200 $1,123.52 $1,500.55 Totals 500 62,500 $2,513.56 750 $4,213.18 $6,726.74 Shared Curb Credits — Concept Report (Preliminary Draft) E. TALAGO GIS Curb Inventory Using existing GIS data, classify every linear foot of curb. Use Length Public safety 155 ft Exclusive driveway use 180 ft Shared public parking 431 ft Total curb 766 ft Using a planning assumption of 22 feet per parking space: 431 ÷ 22 ≈ 19 permit spaces Shared Curb Credit Allocation Each parcel's annual street contribution determines its proportional responsibility for supporting the shared curb resource. After deducting driveway occupation, the remaining balance becomes annual Shared Curb Credits. Parcel Annual Cost Cost Resp. Shared Curb Alloc. Driveway Net SCC (ft) Permit Credits A $1,500.55 22.31% 136.3 32 104.3 4.74 B $638.69 9.49% 58.0 26 32.0 1.45 C $691.90 10.29% 62.8 28 34.8 1.58 D $532.24 7.91% 48.3 18.5 29.8 1.35 E $532.24 7.91% 48.3 18.5 29.8 1.35 F $638.69 9.49% 58.0 29 29.0 1.32 G $691.90 10.29% 62.8 0 62.8 2.85 H $1,500.55 22.31% 136.3 28 108.3 4.92 Page 6 Shared Curb Credits — Concept Report (Preliminary Draft) E. TALAGO Marketplace Example, Using the Case Study Applying the marketplace concept described earlier to this case study's numbers: ● Parcel A receives 4.74 credits but only needs one permit. The remaining 3.74 credits can be voluntarily transferred into the neighborhood pool. ● Parcel B receives 1.45 credits but wants two permits. Parcel B acquires the additional 0.55 credit it needs from the pool or from a neighbor before obtaining its second permit. No City action is required to make this exchange happen — the City's role stays limited to issuing the annual credits and issuing permits once sufficient credits are surrendered. GIS Implementation This methodology relies exclusively upon datasets already maintained by the City, which include: ● Parcel polygons ● Parcel dimensions ● Parcel square footage ● Assessment frontage ● Street centerlines ● Curb inventories ● Driveway curb cuts ● Parking restrictions ● Safety no-parking zones ● Residential permit districts Using these datasets, the SCC calculations can be automated on a block-by-block basis and recalculated annually as assessment rates or curb inventories change. Adaptability The SCC methodology is intentionally independent of any particular assessment rate, bond amount, or permit price. If maintenance rates, reconstruction costs, financing terms, or assessment formulas change, the methodology remains unchanged. Each year: ● Calculate annual parcel costs using the City's adopted assessment methodology. ● Determine each parcel's proportional responsibility for neighborhood street costs. Page 7 Shared Curb Credits — Concept Report (Preliminary Draft) E. TALAGO ● Inventory shared, exclusive, and safety curb using GIS. ● Allocate Shared Curb Credits according to proportional responsibility. ● Deduct exclusive driveway occupation. ● Issue annual SCCs. ● Exchange SCCs for parking permits. Because the framework is based on proportional responsibility rather than fixed dollar values, it remains scalable and adaptable to future policy or financing changes. Conclusion Shared Curb Credits redefine residential permit parking within a Parking Benefit Zone as an infrastructure accounting problem rather than a parking allocation problem. Instead of asking who deserves parking, the SCC framework asks: ● Who finances the public curb? ● How much of that public curb has already been dedicated to exclusive private use? ● How should the remaining shared resource be allocated transparently and equitably? By leveraging existing GIS datasets and current assessment practices, SCC provides a technically defensible, scalable framework that integrates transportation planning, public finance, and curb management. It also introduces flexibility by allowing residents to voluntarily transfer unused parking rights, ensuring that scarce curb space flows to households with greater demand while recognizing the financial contributions of all property owners. Page 8 Shared Curb Credits — Concept Report (Preliminary Draft) E. TALAGO Appendix: Mathematical Framework This appendix sets out the formulas underlying the calculations described in the body of this report, for technical reference. Annual Street Cost For each parcel i: Cᵢ = Mᵢ + Rᵢ ● Cᵢ = Total annual street cost assigned to parcel i ● Mᵢ = Annual maintenance assessment ● Rᵢ = Equivalent annual reconstruction assessment Annual Maintenance Mᵢ = Aᵢ × r ● Aᵢ = Parcel area ● r = Annual maintenance assessment rate ($/square foot) Reconstruction Rᵢ = (Fᵢ ÷ ΣF) × B ● Fᵢ = Assessment frontage ● ΣF = Total assessment frontage ● B = Annualized property-owner share of reconstruction costs Total Neighborhood Street Cost CTotal = Σ Cᵢ (i = 1 to n) Shared Public Curb L = L − Lsafe − Lexclusive ● L = Total curb length ● Lsafe = Public safety exclusions ● Lexclusive = Driveway curb cuts Relative Cost Responsibility Pᵢ = Cᵢ ÷ Ctotal Page 9 Shared Curb Credits — Concept Report (Preliminary Draft) E. TALAGO Shared Curb Allocation SCᵢ = Pᵢ × L Shared Curb Credit SCCᵢ = SCᵢ − Dᵢ ● Dᵢ = Driveway curb-cut length Permit Credits Permit Credits = SCCᵢ ÷ 22 using a planning assumption of one parking space per 22 linear feet. Page 10