Parking Strategy

download as pdf

Introduction

We welcome these documents and commend Council for taking a more strategic and holistic approach to parking than has been the case to date. We are broadly supportive of the direction. Our comments are intended to help improve the strategy and ensure it delivers on the vision that Council's own transport documents have already established. 
Our submission will make some general comments about the strategy, before providing specific suggestions to the text of the document that we believe will address our comments.
As always, we welcome the opportunity to discuss this submission in person and thank you for the opportunity to provide feedback.

Comments

Parking is subsidised storage of private property on public landThere are financial and environmental costs to overproviding parking. Kerbside car parking is a subsidy from the entire community to private vehicle owners. Every square metre devoted to storing a car is space that cannot be used for cycling infrastructure, tree planting, outdoor dining, or accessible footpaths.

Re-allocating parking for greater community benefits is goodThe words “subject to a parking study” suggests improvements are predicated on not losing parking. Instead we should be weighing the various pros and cons fairly and equally – a genuine community benefit (above all other uses) for parking should be established if parking is to be retained, relocated or increased.

Mode shift and cycling are inseparable from parkingThe strategy does acknowledge that alternatives to driving are needed to lower car ownership and use. We believe that the connection between the stick (constraining parking) and the carrot (safe, pleasant cycleways, comfortable bus stops, pleasant footpaths etc.) of mode shift should be explicitly expressed. 

• Revenue from parking schemes should fund active transport improvements
• Active transport should be a key consideration in any parking study or needs assessment as a demand reduction mechanism
• Walking, cycling and public transport should prioritised in street works

Parking can be traffic calmingOn local streets, parking can be used to make the street safer for cycling:

• Alternate side, rear to kerb or angled parking can be used to make chicanes which lower vehicle speeds
• Modal filters can add a few extra parking spaces while reducing through traffic
• Rear to kerb and angled parking increases parking while narrowing travel lanes and lowering vehicles speeds

Parking permit reform should not entrench car ownershipPermit schemes are a demand management technique and not a replacement for demand reduction. In addition, permit scarcity should be seen as a feature, not a bug, of permit schemes – it reflects the reality that kerbside space is limited, valuable and owned collectively by the community, not individuals.

Removing parking minimums is goodThe proposed removal of parking minimums in new apartment buildings is long overdue. Decoupling car parking from home ownership is an incredibly important part of this.
Forcing apartment buyers to buy parking they may or may not need increases the cost of housing and obfuscates the cost of car ownership. 
Decoupling parking lowers the friction to change vehicle needs as parking can be bought or sold without having to move homes. 
Decoupling parking also allows greater flexibility for apartment buyers – some studio apartment owners may want a car space, while some two bedroom owners may want none. This choice is a great feature.

Boats, trailers and long term storageThese items are the lowest priority for the use of public land. They should be priced at least as much as a private car, if not banned outright.
Many boats or trailers being stored long term should indicate a parking provision excess and better use of that space should be investigated.

Specific suggestions

Below are some specific text changes we would like to see to address our comments above
Introduction, page 6: Replace
This repurposing should be subject to a parking study to investigate whether new parking can be created in alternative locations to offset some or all of the loss.
With
In addition to this repurposing, a parking study to investigate whether new parking can be created in alternative locations can be done if a genuine need for parking exists.

Predicating community improvements on the replacement of parking prioritises private vehicle owners over the broader community, which is not the intention of this strategy. Rather the wording should reflect that there are competing needs, each with their costs and benefits and they should be given equal weighting.

Immediate actions, page 24: Add 
Develop a pipeline of new cycleways that provide alternative ways of getting around.

Cycleways reduce the demand for parking, and so should form part of the parking strategy. This work is consistent with the Cycling Strategy and Action Plan so represents no additional burden for council.

Medium term actions, page 25: Replace
Subject to a parking study, repurpose some public domain parking space to create space for other uses such as pedestrian, bike and bus priority, landscaping, outdoor dining and affordable housing
With
Repurpose some public domain parking space to create space for other uses such as pedestrian, bike and bus priority, landscaping, outdoor dining and affordable housing, while balancing parking needs where there is a genuine need

Repurposing space for improved community benefit should not be predicated on parking impacts, rather the parking needs should be considered equally and fairly against other community benefits.

Medium term actions page 25: Replace
Price permit parking schemes to discourage multiple vehicle ownership, discourage excessively large vehicles and generate funds for transport and streetscape improvements 
With
Price permit parking schemes to discourage multiple vehicle ownership, discourage excessively large vehicles and generate funds for public and active transport, and streetscape improvements 

​We should only fund improvements to public and active transport, as they are the realistic alternatives to driving.

Changes to the objectives

The following table details changes we’d like to see to the objectives themselves

Objective	Existing text	Suggested change	Rationale
Objective 1 Draw on good practice and link to other relevant policies	Key NSW Government policies guiding this strategy are the Future Transport Strategy, Guide to Transport Impact Assessment and Freight & Servicing Last Mile Toolkit and Transport-Oriented Development Program.	Add the NSW Road User Space Allocation Policy & Procedure and Movement and Place to the list of key guiding policies	The Road User Space Allocation Policy & Procedure explicitly refers to the allocation of road space to different modes of transport. Car parking sits at the intersection of both "movement" and "place", so the guidelines in Movement and Place are very relevant.
Objective 2 Involve the community and all stakeholders	This is to ensure there is awareness-raising and a broad consensus around what is good practice.	This is to ensure there is awareness-raising and all community concerns are considered.	There needs to be acknowledgement of motornormative biases that influence community consultation so consultation should move away from an agree/disagree vote and be used as a vessel to ensure all community viewpoints and concerns are considered (even if ultimately rejected).
Objective 3 Advocate for State and National level policy improvements	Examples of these policies and actions include the former National Commuter Car Park Fund, the draft National Urban Policy, TfNSW Guide to Transport Impact Assessments…	Add: advocate for TfNSW to fund kerb-protected cycleways on arterial roads as part of any kerbside parking reallocation program, and to include cycleway delivery as an explicit outcome of the Road User Space Allocation Policy.	Parking reallocation on State roads needs TfNSW cooperation. Council should advocate for building cycleways, not just parking reform in general.
Objective 4 Reduce the need for car ownership and constrain parking	New and expanded roadways and car parks increase the attractiveness of driving, adding to demand for parking. In contrast, constraining road and parking space suppresses car use and makes sustainable transport more attractive than driving.	New and expanded roadways and car parks increase the attractiveness of driving, adding to demand for parking. In contrast, reallocating road and parking space to walking and cycling suppresses car use and makes sustainable transport more attractive than driving. Also add: an explicit mention of building cycleways as a demand reduction tool alongside carshare and public transport.	'Constraining' implies simply removing space without offering an alternative. 'Reallocating to walking and cycling' is more accurate and more persuasive. Walking and cycling are hardly mentioned as demand reduction tools compared to carshare and public transport.
Objective 5 Prioritise areas of high parking demand	In the Inner West, areas of highest parking demand include major commercial centres… railway stations… densely developed suburbs…	Add: 'Areas of high parking demand are also typically those with the highest hidden demand for cycling. Building cycleways should be explicitly coordinated with parking management in these areas, so that freed up parking space is prioritised for protected cycleways.'	The strategy currently treats high-demand areas purely as a parking management issue. These are also exactly the places where protected cycleways would have the greatest impact on mode shift.
Objective 6 Mandate constrained maximum parking rates for new developments in accessible areas and encourage flexible provision	In accessible areas, replace fixed or minimum parking requirements for new developments with maximums to facilitate flexible provision, avoid overprovision and encourage affordable housing. Facilitate the efficient use of parking space through decoupled, detached and shared parking arrangements.	In accessible areas, replace fixed or minimum parking requirements for new developments with maximums to facilitate flexible provision, avoid overprovision and encourage affordable housing. Introduce minimum cycle parking requirements. Facilitate the efficient use of parking space through decoupled, detached and shared parking arrangements.	Cycle parking does not have the same burdens of over-supply as car parking does and encourages mode shift, and so should be included in new builds. Further, these requirements are included in the draft DCP.
Objective 7 Design, manage and repurpose public domain parking for maximum benefit	Recognise parking space in inner-urban areas has a high value and can often be put to alternative use for maximum community benefit, subject to a parking study	Replace: "subject to a parking study" with "while balancing parking needs where there is a genuine need"	Street improvements should not be predicated on replacing parking, instead the pros and cons of all street space uses should be balanced fairly and equally.
Objective 8 Use technology, data, pricing and wayfinding to improve parking management	No change suggested.
Objective 9 Prioritise parking for targeted users to improve equity and efficiency of access	No change suggested.		Comment: Mobility parking is not the only way of providing access to those less mobile. Many people with mobility issues cannot drive, but can cycle an ebike or an adaptive cycle.
Objective 10 Continue to enforce parking rules efficiently, diligently and fairly	Continue to enforce parking rules efficiently, diligently and fairly to reduce the extent of non-compliance, with a focus on areas with highest parking demand and other parking demand 'hotspots'.	Add: Use infringements to identify areas where improvements should be made.	Enforcing parking rules is an important part of a fair and efficient parking system, but the same offences occurring frequently (with few repeat-offenders) indicates systemic flaws that can be addressed – e.g. frequent infringements given for vehicles blocking sightlines at intersections would indicate that a designed and built solution may be more effective than a regulatory one.

Tom Watson - Secretary
Sander Ottes - Committee Member