Open Letter to the St. Paul City Council on Off-Street Car Storage Mandates

An unnecessary Saint Paul parking lot, built because of needless regulations.

Dear Saint Paul Council Members,

I have three quick points on the debate over off-street parking minimum mandates that are on your agenda today.

#1. Eliminating parking minimums helps keep housing affordable 

During the discussion of parking minimums at the Planning Commission, some affordable housing advocates claimed that eliminating parking minimums will be a huge burden on the poor. In fact, the opposite is true. The current parking mandates are a direct subsidy from the least affluent people in St. Paul to owners of private vehicles driving in the city, a disporportionately wealthy group. 

For example:

• a study from UCLA found that requiring off-street garage parking raised rents by 17%
• A study from Los Angeles found that parking requirements increased rents by $200 a month
• A study from the Victoria Transport Policy Institute found that mandating parking in affordable housing increased costs for renters by 12.5%
• A study from the Transportation Research Policy Center found that parking minimums increased rents for low-income tenants by 15%
• The GAO found that parking minimums increased housing construction costs by $56,000 per unit in California and Arizona

(See this link for these and other studies on this topic.)

In other words, parking is expensive. Forcing everyone to pay for it is not remotely equitable.

#2. Climate change

At this point, I shouldn’t really have to discuss why climate change should be a huge priority. The IPCC report that came out this week warned clearly that we must act now to reduce carbon emissions. As one of the report authors stated, “if we do not halt our emissions soon, our future climate could well become some kind of hell on Earth.”

Currently we are not on track to meet St. Paul’s goals of reducing driving in the city (aiming for 2.5% reduction in VMT, vehicle miles traveled, every year), only one of the many changes we need to our city. Eliminating our city-policy of requiring mandatory the construction of off-street parking will allow businesses and property owners to make low-carbon choices. Removing these harmful mandates is a clear first-step toward creating a low-carbon city.

#3. Simplification is good

Part of today’s debate centers on whether to fully eliminate off-street parking minimums or reduce them, while keeping the basic structure of off-street parking minimums intact for new developments.

Frankly, the reduction policy, predicated on the benefits of “leverage” over developers, seems a bit too cute. I am sure all of you have talked to developers and entrepreneurs in the past about working in Saint Paul. When I do so, they almost always cite the complexity of the regulatory landscape in our city, and the difficult and opaque rules that exist around building homes or starting a business.  The “regulation is leverage” approach flawed because it relies on the supposed benefits of regulatory complexity, which is something our city should be avoiding when possible.

Instead we should ask developers, entrepreneurs, and property owners, clearly and simply, to make choices that match city goals. The full elimination option will allow PED staff to focus on travel demand management (TDM) policies that will help reduce driving in the city, and help bring St. Paul into a low-carbon, more equitable future.

I urge your support for the full elimination of parking minimums in St. Paul. Thanks for your time.