Bike Parking Ordinance Comment Letter – Support Bike Parking and Affordable Housing
13 May 2011
Green L.A. Transportation Work Group has recently been grappling with issues related to parking requirements and how they relate to affordable housing. Many of us (myself included) are generally Shoupistas – followers of Donald Shoup. In The High Cost of Free Parking, Shoup makes a convincing case that unjustifiedly high suburban parking requirements drive up the cost of housing.
For example: in L.A. a typical new housing unit (ie: a condominim in a multi-story building) 2.5 parking spaces, and each space costs $20,000-$50,000+ to build… so… the parking requirement adds $50,000-$100,000+ to the cost of new home. Reducing this requirement effectively reduces the cost of housing. While developers may not pass this reduced cost savings on to occupants/owners… overall, reducing excessive parking requirements generally can get more housing built more cheaply, which, based on market forces (supply and demand) should reduce the cost of housing.
Recapping: less required parking leads to more affordable housing.
But there’s a catch… some of the city’s most effective mechanisms for building and preserving affordable housing are built on incentives that are based on those excessive parking requirements. Basically, when housing developers build affordable housing, the city allows the developer to build less parking (under what’s called the Density Bonus.) Additionally, in some cases, excessive parking requirements prevent owners from converting rent-stabilized apartments into condominiums.
So… if we’re not careful, moving towards more rational (reduced) parking requirements can actually result in developers chosing to build market rate housing, instead of affordable housing.
Currently working their way through various legislative process, there are three initiatives that include reducing car parking requirements:
- AB710 (California State Legislation)
- Modified Parking District Ordinance (City of Los Angeles CPC-2007-2216-CA)
- Bicycle Parking Requirements (City of Los Angeles CPC-2011-309-CA)
There’s a lot of commenting and dialog on all three of these… and, generally, the most suburban NIMBY types are out in opposition to anything that will remove any of their god-given parking… but for now, I am just going to focus on #3 the Bicycle Parking Requirements.
The Bicycle Parking Requirements (full text posted here) proposes to beef up the city’s requirements for bike parking – short-term, long-term, residential, commercial, etc. Similar to car parking requirements, it sets bike parking requirements – stuff like this:
For all institutional uses which require automobile parking under subsection 12.21 A.4 (d), except government office buildings, all buildings will provide short-term bicycle parking at a rate of 5 percent of required automobile parking spaces with a minimum of 2 short-term bicycle parking spaces. In said institutional uses, long-term bicycle parking shall be provided at a rate of 10 percent of the required automobile parking spaces with a minimum of 2 long-term bicycle parking spaces.
What’s interesting, and actually innovative, is that the proposed bike parking ordinance, in many cases, allows developments to swap some car parking for some bike parking (depending mostly on proximity to transit, up to 20% or up to 30% of car parking can be swapped for bike parking, at a ratio of four bike spaces for each car space.) And what’s tricky about that is that it ends up effectively reducing the cost of providing parking… hence it undermines those tools for incentivizing affordable housing…
So… Green L.A. Transportation Group discussed this earlier in the week… and formed a subcommittee which generated the following comment letter. Below is the text of the comment letter (also available as a pdf.)
May 12, 2011
Regarding: Equity/Affordability Impacts of Bicycle Parking Ordinance
To the City of Los Angeles Planning Commissioners:
We, members of the Green L.A. Transportation Work Group, support reforming city parking code to ensure a more equitable, more livable and more sustainable Los Angeles. We generally support both reducing the city’s
excessive suburban car parking requirements and making bicycle parking ubiquitous.
We’re pleased to see the city taking a more comprehensive approach to require supplying both short and long-term bicycle parking with new multi-family, commercial, institutional and industrial developments. We are
impressed that the city has had the foresight to also include some level of swapping car parking for bicycle parking and we strongly support this policy for commercial and industrial uses.
We are, however, very concerned about this sort of parking swap for housing. Reducing residential parking requirements without a requirement to produce affordable housing undermines state and local housing policies
and goals. These state policies include the State Density Bonus Law (SB 1818) that requires local jurisdictions to incentivize affordable housing by providing increased density and parking reductions in exchange for the
inclusion of a minimum of 5% affordable units. The parking reduction is a critical part of this package. By effectively relaxing car parking requirements, the ordinance will undermine use of the density bonus in Los
For buildings that contain residential units, we recommend that both the proposal to swap 20% of the required car parking spaces for bicycle parking and the additional proposed incentive to allow a 30% car-bike swap in areas
located within 1,500 feet of transit facilities, including bus stops, be limited solely to developments that accept the City’s affordable housing density bonus and offer affordable units. Furthermore, we recommend that an
exception be added so that swapping out car spaces for bicycle parking spaces shall not be made available in connection with condominium conversions or any development that demolishes rent-stabilized apartments or apartments with affordability restrictions, unless each rent-stabilized unit or affordable unit is replaced on a one-for-one basis.
We therefore request that the proposed bike parking ordinance be amended to ensure bicycle parking without undermining mechanisms for creating and preserving affordable housing.
Alexis Lantz, Los Angeles County Bicycle Coalition
Ryan Lehman, Green L.A. Transportation Work Group
Joe Linton, CicLAvia
Serena W. Lin, Public Counsel
The letter was delivered to the Planning Commissioners today, at their hearing on the proposed ordinance. They were sympathetic to GLATWG’s concerns and continued the item, basically postponing it until staff has modified it. While it’s a bit unfortunate that the passage of the Bike Parking Ordinance was delayed, I think that we’ll get a better code at the end of the day – one that supports bicycling and affordable housing.