HomeMy WebLinkAbout5/14/2024 Item 4a, Hershberger
From:Hans Hershberger <
To:E-mail Council Website
Subject:Parking Benefits District
Attachments:LEGAL RESEARCH AND ORDINANCE-HVH.pdf
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Members of the City Council,
First off, I want to give a genuine thank you for your investment in finding parking solutions that are financially
responsible and sustainable for the city. Reading through various public comments, I am struck by how contentious and
lose-lose this game of parking can be.
It reminded me of a draft ordinance I created for one of the MCRP classes here at Poly. It is essentially a district where
the funds incidentally raised by parking are directly injected back into the neighborhood where such parking is
managed. I know that our hands are tied in that our parking revenues are needed to pay for a new parking structure
and market based pricing is out of scope for this decision, but I hope you have a moment to peruse it. I think it is pretty
interesting stuff. That said, I wrote it so I am likely biased.
I am sympathetic and understand that any choices made tonight will likely be met with some levels of dissatisfaction and
even disgust. Yet I want you to know that I, and many others in this city, respect and applaud your bold and responsible
leadership.
Thank you again!
--
-Hans Hershberger
1
Legal Research and Ordinance
HANS HERSHBERGER
CRP 535-02
Statement of Problem
The City of San Luis Obispo has a parking problem . This problem is not simply regulated to
her downtown, but across much of the city, especially in places of high population density
near the university campus. Parking is seen as scarce, and the citizens protect
passionately and fight furiously for this resource. Everyone considers it a problem but there
is no consensus as to why. Business owners think there is not enough parking, drivers think
it is too expensive, and city hall just wants the fares to fund their new parking garage.
Compound that with a pro-development city council discussing infill incentivization and
the parking discussion is at an all-time fervor. Parking is not a new problem for planners
nor is its management novel to municipalities. From chalked tires to park-o-meters to
parking mandates, many management strategies have been tried and tested since the
advent and infiltration of the automobile into all areas of life. At the heart is the truth that
“scarce curb parking can be free, convenient, and available, but not all three at once. It
can be free and convenient but not available. It can be free and available but not
convenient. Or it can be convenient and available b ut not free.” What is the City to do?
Legal Issues
The City must show that there are legitimate government interests advanced by managing
street parking availability. Many such government interests have been listed as such over
the years including, but not limited to, improvement of traffic flow, creation of orderly
streets, reduction of parking tickets, and improvement of business access.
Once the City has determined rational bases for managing parking, notice of the changes
to parking management needs to be communicated with communities affected. This
should be done well in advance before the City Council meets to adopt the ordinance. The
proposed ordinance and respective rationale should be posted on the City’s website, on
any bulletin boards, and any other common medium the City uses to communicate with
the public. The City should also deliver notices directly to the businesses and residences
directly abutting districts of new or changed parking management. The City Council should
meet and, if desired, adopt the ordinance in line with standard practice for public meetings
and the Brown Act requirements.
Relevant Cases
Kimmel v. City of Spokane
In Kimmel v. City of Spokane, the city passed “An ordinance relating to traffic and
regulating the use of public streets and highways of the City of Spokane; providing for the
installation, regulation and control of the use of parking meters; requiring the deposit of
coins for the use of parking meters and parking meter zones; defining parking meter zones;
providing for the disposition of revenues derived from parking meters; providing for the
enforcement thereof; defining offenses and providing penalties; and declaring an
emergency.” The plaintiff sought to block the installation of the parking meters on grounds
that vehicles parked at meters in front of the premises would interfere with his rights of
ingress and egress.
The court quickly dismissed the argument that the ordinance was a tax measure. As the
ordinance was declared regulatory in purpose, the courts refused to undermine the
legislative action without evidence supporting purpose being otherwise. Summarily, it was
decided that the “sole question” to be answered was whether the city had the power to
regulate traffic on the public streets by an ordinance for the installation and maintenance
of parking meters or not.
The plaintiff made that argument that the ordinance conflicted with a state law that
restricted parking on all highways. The court pointed out the provisions in that law allowing
for local authorities to “adopt additional vehicle and traffic regulations which are not in
conflict with the provisions of this act” and allowed for parking “at all other places except a
time limit may be imposed.” To this point the plaintiff argued that the ordinance granted
the right for vehicle owners to occupy the streets with parking; the streets were meant for
travel rather than the storage of cars. Furthermore, he concluded that this allowance
conflicted with his rights as an occupant of abutting property being subservient only to the
rights of the “traveling public” and not to the parking public. However, the court disagreed
with this assumption stating that “the rights of the occupant of abutting property are not
absolute even as against persons using the streets for purposes other than actual
locomotion” and “the custom of parking cars along the streets and highways may well be
regarded as an incident to public travel.”
Contrary to the arguments of the plaintiff, the court judged the power of cites to regulate
the parking of cars on streets to be indubitable and proper exercise of police power.
Furthermore, it was opined by the court that , because parking duration limitations were
designed to simultaneously “keep traffic moving” and “afford users of the highways an
opportunity to transact business with the occupants of abutting property,” the “shorter the
limitation and the more effectually it is enforced, the greater is his freedom of access to his
premises” The court went so far as to admire the parking meter’s efficacy over the
policeman’s chalk and concluded that their installation and maintenance was indeed a
valid exercise of municipal police power.
Andrews v. City of Marion
In Andrews v. City of Marion, the plaintiffs argued that the city’s adoption of “a parking
meter ordinance for the regulation of traffic and parking in certain conges ted areas”
deprived them of their property without due process of law and amounted to a taking
without just compensation. Furthermore, an assertion was made that the ordinance was
an improper use of police power in that it authorized the city to “rent parking space on the
streets for a profit” and in doing so was a revenue measure rather than a regulatory one.
Having established that municipalities may enact traffic regulations not in conflict with
state acts, the court sought to answer two questions. The first question was whether the
ordinance deprived the plaintiffs of property without due process or took their property
without just compensation. The second question was whether such an ordinance was a
reasonable exercise of police power.
To the first question, the court began by stating that the uses for a street were not limited to
those contemplated when such space was dedicated to public use . After the street
abutting the plaintiff’s lot became public, its owners had the same rights as the rest of the
public for its use with the addition of egress and ingress . Such additional right does not
include free parking for those owners, their visitors, or associates. Rather, “parking is
considered as a privilege of the public and incidental to the use of the street for travel .
When the abutting property owner parks his aut omobile in front of his property he does so
as a member of the public and in so doing is subject to reasonable traffic and parking
regulations.” Furthermore, the court ascertained that, as parking uses part of the street as
“storage space” for an automobile, the ordinance did not infringe on the ingress and
egress right to stop a vehicle front of the plaintiff’s property for loading and unloading of
passengers and merchandise. The court concluded that the ordinance may lead to the
abutting owners having increased ingress and egress compared to before where “without
any limitations on parking in front of their lot the appellants here might well have had the
automobiles of others parked bumper to bumper, along the entire front of their lot,
throughout the entire day.”
To the second question, the court decided that “A reasonable fee may be properly charged
against those enjoying the privilege of parking, for the purpose of raising funds for the
expense of acquiring, installing and maintaining the meters and the other expenses
incidental to the enforcement of the ordinance.” The parking charge in this case was
merely a means of regulating parking availability, not to raise revenue. To that conclusion,
the court ruled that the ordinance was not a revenue measure.
Wilhoit v. City of Springfield
In Wilhoit v. City of Springfield, 95 plaintiffs sought to perpetually block the city from
enforcing a parking meter ordinance. The plaintiffs presented considerable evidence
attempting to show that revenues created by the meters far exceeded their
implementation and maintenance. The plaintiffs claimed that the city intended to collect
revenue through meters and reduce other taxes, especially gas tax.
The court first considered whether the meter o rdinance was even a valid exercise of the
city’s police power. Thier judgement in this regard was that the abutting owner has the
same rights as the rest of the public in use of the street, with the addition of ingress and
egress. This court further clarified that the owner is subject to the police power of the city
to regulate and control its streets and parking so long as in doing so the regulations do not
“unreasonably interfere” with th e abutter's rights or contravene the supremacy clause. The
court concluded that the city had a valid exercise of police power in this perspective.
The court moved on to determining “Whether the defendant city has authority to exact a
parking fee as provided by [...] the ordinance in controversy, and if so, whether the fees
charged and collected are so excessive as to constitute the ordinance a revenue measure
in fact.” The court found that municipalities have the delegated authority to regulate
parking of vehicles on the street and, in doing so, may exact a fee that is “incidental and
necessary” in effecting the regulation. The burden of proof was placed on the plaintiffs to
show evidence that the ordinance was not a regulation so much as a revenue measure,
thus voiding it as a tax. In finding that the receipts from the meters were not “substantially
in excess of the amount required for the purposes mentioned in the ordinance” the court
determined the plaintiffs failed to show the ordinance as a revenue measure and as such
ruled that the ordinance was valid.
Proposed Ordinance
1) Establishment of Parking Benefit Districts (PBD)
a) San Luis Obispo shall form a Downtown PBD in the area subtended by Pismo
St., Toro St., and U.S. 101.
b) Each current neighborhood residential permit district will become a PBD.
i) Existing residential permits will be grandfathered in at their current
price for 2 years.
ii) All other parking permits, up to an equivalent of 60% of the total street
parking spaces in the PBD, will be auctioned to residents in that PBD
and priced to the lowest bid still purchasing.
iii) At the end of the two-year period, all residential parking permits in a
PBD will be limited to 60% of the total street parking spaces and only
obtained in the auction.
c) Notice of public hearing for the creation of a PBD shall be mailed no later
than the 30th day before the hearing to owners of real estate within the
proposed district and within 500 feet of the proposed district.
d) All existing meters and pay stations will be updated to work with dynamic
pricing per the appropriate zone. New meters will be added where needed.
e) Meters must be able to be used with coins, credit cards, and tap payment.
f) The City Council may create additional PBDs or terminate a PBD by
ordinance.
2) All street parking spaces will be dynamically priced.
a) Street parking spaces will be equipped with occupancy sensors such that
each space's occupancy is known.
b) Downtown PBD street parking pricing will be by street block.
c) Residential street parking pricing will be by former permit district.
d) Parking will have three periods of pricing per day: 9am to noon, noon to 4pm,
and 4pm to 9pm.
e) At the end of the day, average occupancy for the three periods of the day will
be evaluated. The price of street parking will be incrementally raised or
lowered for each period such that a range of 60 to 85 percent street parking
occupancy is achieved.
f) The next day’s parking prices per period will be previewed on the City’s
website for transparency and personal planning.
3) Management of PBDs will be exercised by the City’s Parking Services Department.
a) The Parking Services Department will annually submit a PBD report to each
business owner and resident within a district showing metrics such as
parking occupancy, citation totals, management expenses and revenue
created.
b) The Parking Services Department will annually survey each PBD to
understand where any parking revenue would be best spent .
4) All revenues, minus expenses, collected from parking meters/pay stations/mobile
device payment systems in the PBD shall be placed in a special fund, which shall be
used exclusively for activities benefiting the P BD. The specific authorized use of
revenues shall be as follows:
a) For purchasing, leasing, installing, repairing, maintaining, operating,
removing, regulating, and policing of parking meters/pay stations/mobile
device payment systems in the PBD and for the payment of all expenses
relating thereto.
b) For purchasing, leasing, acquiring, improving, operating, and maintaining on-
or off-street parking facilities.
c) For installation and maintenance of alternative transpiration programs,
landscaping, medians or curb extensions, pedestrian linkages, sidewalk
cleaning, street furniture, wayfinding systems, and traffic -control devices
and signals.
d) For the financing of mass transit subsidies to all people who live or work in a
PBD.
e) For painting and marking streets and curbs required for traffic and parking of
motor vehicles.
f) For neighborhood policing within the PBD.
g) For the proper regulation, control, enforcement and inspection of parking
and traffic upon public streets and off-street parking facilities.
h) For transportation and parking planning, marketing and education programs
related to the PBD.
i) For construction and maintenance of public restrooms that enhance parking
facilities.
Rationale
Parking Benefit Districts primarily seek to balance parking cost and availability. Free or
cheap parking causes full street parking and, in turn, cruising. This “parking foreplay” is
one of the leading causes of traffic in a city and a distracted danger to others on the road.
Furthermore, full street parking is shown to result in larger numbers of parking citations
given as one is like to block fire hydrants, occupy bus stops, and double -park. On the other
hand, street parking that is too expensive causes businesses to lose customers,
employees to lose jobs, and residents to bear large financial car storage burdens. Utilizing
the market through dynamic pricing allows street parking to be as cheap as possible while
also allowing one to find a spot open near their destination . Parking is depoliticized by
setting transparent market driven pricing policy.
PBDs use the incidental revenue that comes from managing parking by infusing that capital
directly back into the district from whence it came. Certainly, the primary use of these
funds is to pay for the installation and maintenance of meters, but any further funds can be
spent on district uses that are complementary to the municipal goal of managing parking.
One such use is infrastructure investment and maintenance that encourages alternate
forms of transportation, lessening the need for parking in the first place. Another is in the
installation of landscaping and street trees that slow traffic and prevent out of control
vehicles from hurting people. One final such use is the payroll of neighborhood policing
and services protecting the health and safety of both vehicles and citizens of the PBD.