By Jennifer Brager, Housing Land Advocates
Housing Land Advocates (HLA), a nonprofit organization,
encourages land use policies supporting affordable housing and the development
of sustainable communities. Our organization has grave concerns about the
proposal to increase parking requirements for new buildings near transit. The
process for increasing parking requirements has sped forward without sufficient
input and review, and the proposed changes show it, raising many unanswered
questions. Before Portland rushes into a fix, the city needs to more clearly
identify the problem and weigh the costs and benefits of each approach.
At its core, reducing parking requirements lowers the costs
of housing, diversifies housing types in existing neighborhoods and encourages
active transportation and transit use. Portland’s own research shows that
reducing parking requirements creates new housing units and lowers housing
costs. In a study that modeled new development, this analysis found that units
in buildings without on-site parking are priced $50 to $700 per month lower
than comparable developments with on-site parking, and significantly more units
are created on the same site (According to the report Cost Comparison: Parking
Prototype Impacts on Form and Affordability, Portland Bureau of Planning and
Sustainability, November 2012). In short, current policy generates more housing
in existing city neighborhoods at a lower price.
Existing residents raise valid concerns about new
development. They worry about their access to free street parking and about the
size and compatibility of new apartment buildings. Solutions could include
managing street parking with a permit system, as has been done in other
Portland neighborhoods, or instituting uniform design standards. However,
proposed code amendments include neither of these options, nor do the
amendments directly address the relationship between parking and housing
affordability.
HLA seriously questions the ability of the most current
proposal to address the following issues:
Equity
New housing units without parking cost less than if parking
were bundled with the unit. Lower-income Portlanders own fewer cars per
household and are more dependent on transit. Therefore, less-expensive units
without parking will, on average, be more attractive to lower-income people.
However, the proposed change to parking policy does not obligate developers to
keep any of the units affordable. HLA would support a policy where developers
are required to set aside some units as affordable housing, using Department of
Housing and Urban Development standards, if their buildings do not include
parking. Also, mandating parking spaces for all residents, which increases
housing costs, is an indirect and inefficient method of helping lower-income
people who do own cars.
Many factors besides parking influence household decisions
about car use and auto ownership. A unit that is close to work, school, child
care and other services has a significant, if not greater, impact on auto
dependency than mere access to a bus stop.
The integration of transportation policy and affordable housing policy
is critical to achieving city goals but is not addressed in the proposed
changes.
Accessibility
Proposed zoning changes do not directly address the needs of
residents with physical disabilities. As stated in HLA’s Nov. 13, 2012, comments, an on-street ADA
parking or loading space can be requested from the Portland Bureau of
Transportation, but the changes do not require accessible parking if buildings
do not otherwise provide it. Ignoring the needs of the disabled community is a
major flaw in the parking policy for infill developments.
Without a concrete plan, the proposed changes reduce access
to housing for people with physical disabilities. The proposed ordinance fails
those who need an accessible vehicle to take them where mass transit will not.
Car-sharing incentives and reductions further exacerbate the problem, since
these fleets do not offer wheelchair- or scooter-accessible vehicles, nor are
they required to.
Incentives
The proposed change requires builders to provide on-site
parking at 0.25 spaces per unit for buildings with more than 40 units. Smaller
buildings would have no parking requirement. Because parking is expensive, this
policy creates an incentive to build smaller buildings, even in situations
where larger ones would be appropriate and could provide more affordable
housing overall. Encouraging smaller
buildings and less housing is contrary to Portland’s stated land-use goals,
specifically, to increase density to meet future population growth and to
support mass transit. It also creates an incentive for developers to partition
larger sites, create separate ownerships and build multiple 40-unit buildings
in order to avoid triggering the parking requirement.
Legal issues
The recent Oregon Land Use Board of Appeals case in Richmond
Neighbors for Responsible Growth v. City of Portland complicates matters even
further. This case halted (at least temporarily) the development of an 81-unit
building without on-site parking, but the central issue in that decision had
nothing to do with parking. The only reason LUBA found against the city in that
case relates to the location of the residential entrance to the building. If
opponents’ concern is the appearance of new buildings, this should be addressed
through design standards and not by reflexively increasing parking.
HLA believes all citizens should have access to housing in
Portland’s existing residential neighborhoods. New housing in transit-rich
areas opens up neighborhoods to a wider segment of citizens at all levels of
age, ability and economic status. The current proposal for increasing parking
requirements is deeply flawed and does not adequately address these concerns.
We strongly advocate for restarting this process with the participation of a
broad group of interested citizens, including those concerned about equity and
fairness.
Jennifer Bragar is the president of the nonprofit Housing
Land Advocates
This article appears in 2013-03-15.