There’s a proposed new gospel for dealing with parking and it’s going to shape our city profoundly. Here’s your step by step handy guide for an awesome, high-quality submission

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This is a three-bit post cos we assume you’re not so time-poor you need the TL;DR edition.

First, why parking’s worth your time. Then, Why now (by COP Monday that is!); and then finally the juicy bit: the Guide for your submission.

Parking is worth your time

Parking ain’t just another way we use precious public street space: it’s way more powerful than you’d think.

It suppresses lots of good stuff. Many great and fruitful street-change initiatives in Wellington have been killed off, because people feared the prospect of fewer car parks.  

And too much of it encourages bad stuff. Too much car parking (as Wellington has) encourages everyone to drive more. This holds our city back from all the good things we want to be. 

How important is it though, when we have lots of other things going on? It’s worth a quote from Timothy Papandreou, leading light of San Francisco’s world-renowned transport and movement revolution, from in the crowd after a keynote presentation. He thought, gave a deep sigh and said,

“If I can say one thing for any town or city, any of you, it’s get parking right. If your parking policy is basically wrongheaded, it will kill everything else you try to do. Get it basically right, first.”

Wellington City Council’s own carefully-worded intro to the parking policy review makes it clear: our parking is not basically right. We gotta sort it, and get onto it pronto.

Why now?

The new Parking Policy on which WCC are currently consulting is a big overarching “gospel” defining how the city will approach parking. 

Big comprehensive policy reviews like this don’t come around again for ages. One reason is that they go nowhere without a councillor champion who’s smart, relatable, and above all courageous. It’s not for nothing that parking is known as the “third rail” of local body politics.

Citywide too, the timing is important. The big important transformations Wellington called for in Let’s Get Wellington Moving, and all the potential awesomeness of making our city centre a great destination, they will all be stymied if projects have to fight, block by bitter block, against poorly-designed parking.

And – as we learned in the parking webinar with transport expert Stuart Donovan – implementing a new policy takes years. There are heaps of changes, to a whole swag of other policies, the District Plan, budgets, admin, on and on. So we gotta start strong, and keep the pace.

Help for your submission!

We’re assuming that if you’re a Talk Wellington reader you share our vision for the city: more vibrant, sustainable, resilient, accessible, and awesome.

So we’ve harvested the best submissions guide material from geeky thoughtful groups and people who share this vision too.

They’ve ploughed through the proposal [452KB PDF], the Q&A and FAQ, and the engagement quizzes.

They’ve debated hotly what a good submission should look like.

They’ve asked experts behind the scenes, who consult to councils.

They listened in to expert Stuart Donovan’s webinar then tweaked things.

They even came up with some constructive improvements to some key bits of the policy (massive nerds, bless ’em)

And we’ve compiled it all, into one über-submission, laid out below for your easy submitting pleasure!

The submission form is a multi-question survey, but it is legit to send an email. We recommend that, as we haven’t tested whether the nifty little boxes of the online form will cope with more than 200-odd words.

(If you’re getting cold feet about doing the full banana, you can always use our TL;DR option in 5 minutes.)

OK let’s go! Full banana!

Guide for your submission

In three easy steps:

1. Copy the below, paste into a document (or just download),
2. Tweak for your taste (this is important, they look askance at notably cut-and-paste submissions), 
3. Attach to an email, put PARKING POLICY SUBMISSION in the subject line
4. send to Council’s Senior Policy Advisor Helen Bolton by 5pm Monday 8th June.

Proposed Objectives

Question 1: How important are these objectives to you?

We ranked ’em all “important” or “very important”. Up to you which you pick really.

Question 2: Any objectives you think we’ve missed?

Well yeah a few…

Support economic resilience and economic localism – parking should be one of the tools used (e.g. via the District Plan) to try and encourage urban centres to have more of the locally owned and smaller-scale businesses vs the large-format, parking-heavy and also typically offshore-owned businesses.   

De-couple landuse from private motor vehicle parking requirements – all private car parking requirements should be transitioned away, so that the market can function properly to improve liveability and manifest the sustainable transport hierarchy.  

Use strong evidence and data, from here and elsewhere. We have a great head start on smart city infrastructure for parking, and should be doing trials especially to prime us ahead of LGWM change.  Evidence like SFPark is also so extremely compelling and should be a key pillar of the policy and – crucially – of the comms about it. 

Question 3: Any other comments?

over to you really… we didn’t.

Proposed Principles

4. To what extent do you think these principles will help us achieve our objectives?

Watch out here: the principles’ wording in the survey form is a pretty poor reflection of what’s in the actual proposal. We responded to the principles as they were laid out in the proposal proper, including referring to them by their letters.

• Make parking changes that are linked to improvements in the overall transport system. Helpful / Neutral 
• Manage the decreasing supply of Council-controlled parking by prioritising how space is used and who uses it.  Very helpful 
• Ensure that access to the city centre, Council facilities and suburban centres are inclusive and prioritises people who can’t use active and public transport. Very helpful
• Parking is priced at a level that achieves policy objectives and is consistent with other transport objectives.  Very helpful 
• Support local area-based parking plans where there is a need and community support. Helpful 
• Primarily focus the Council’s role on prioritising existing space, not on increasing parking supply. Very helpful 
• Provide parking space availability information. Helpful 
• Align Council business operations with the parking policy and report annually on performance – Helpful 

Question 5. Any principles we’ve missed? 

Well yeah…

Across all Council’s avenues of influence (all tools, including communication and its own corporate practice) make best use of parking to change behaviour and achieve sustainable travel and liveable city goals.  Driving and parking are neither a right nor an entitlement, and both the discourse and the policy tools need to stop perpetuating that framing.  Please use the Talking About Urban Mobility guidance.      

Where on-street private car parking is being provided in residential areas, prioritise parking for vehicles that best support mode shift and reduced car use. Examples are e-carshare and community travel vehicles, carshare (second priority), and private EVs (lower priority).

Transition of parking management must not worsen inequality. Car-centric transport systems and urban form already exacerbate several forms of inequality, and while good change will be disruptive and painful, the “pain” of change should be buffered for those who can least afford it.  This should be well researched and minimise the potential for concern trolling, including by public figures

Enable good quality parking infrastructure for sustainable vehicles. Enable the creation of secure, weather-protected, accessible parking for other forms of transport (e-bikes, bikes, mopeds, scooters, e-scooters etc) so all streets in both residential and destination areas have parking that supports good mode choice. Especially encourage use of parking structures that have a traffic calming, greening or placemaking effect.

Question 6. Anything else you’d like to tell us about the principles?

Well yes actually…

It needs to be acknowledged in this Policy that there is currently generally an oversupply and that people should expect to see less parking generally over time.  The aim should be no new provision even as new development comes on line. No new supply increases cost of parking which is the strongest financial lever.  

“Primarily focus the Council’s role on prioritising existing space, not on increasing parking supply” – this principle should be stronger, in light of principle A, to highlight that the council’s role is in is about decreasing the current overall supply of parking in the central city (and potentially elsewhere – e.g. at key recreation facilities) to a level that private car travel is playing an optimal role across the city.

“Parking is priced at a level that achieves policy objectives and is consistent with other transport objectives” – the objective here should be to make better transport modes competitive: public transport, walking, scooting, cycling.  Equity retrofits will of course be needed and are really important, but the base price of parking and of public transport should both be transitioned to the point where price plays its full role in making public transport realistically competitive.  Consideration could be given to explicitly using parking revenue to support improved public transport services, walking, biking/scooting and street amenity in order to create a clear transition path in people’s minds and minimise the psychology of loss. 

“Support local area-based parking plans where there is a need and community support.” Local area plans must be properly coupled to landuse, involve sound communication and engagement so that community are grounded in genuine need rather than simply fear of change to the status quo.   

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You’re going great! Here’s a fun New Yorker cartoon from 1976.

Parking Priority

Note there’s no opportunity to comment under the “agree/disagree” rating. So we’ve bundled all our comments / rationale info into the “any other thoughts?” question at the end.

Question 7. To what degree do you think we have this correct for key transport routes?

Strongly agree

Question 8. To what degree do you think we have this correct for the Central City? 

Strongly agree

Question 9. To what degree do you think we have this correct for suburban centres?

Agree

Question 10. To what degree do you think we have this correct for the city fringe? 

Disagree

Question 11. To what degree do you think we have this correct for residential areas? 

Disagree

Question 12. To what degree do you think we have this correct for Council parks, sports, recreation & community facilities? 

Disagree 

Question 13. To what degree do you think we have this correct for Council’s central city off-street parking? 

Disagree

Question 14. Is there anything else you would like to tell us about the proposed parking space hierarchies?

Well as a matter of fact, yes there is actually…

For all “centre” areas, 

Logistics and deliveries parking that’s provided should give priority and better provision to sustainable and low-impact delivery vehicles (e-cargo bikes, small e-vans instead of lorries etc) than traditional logistics vehicles.   District Plans ands consents should be changed to prevent use of large vehicles (HGVs et al) except in the small hours when the fewest people are around.   

We also note that off-street loading zones within buildings provide a means of freeing up scarce corridor space for use by people, so we suggest a more nuanced approach here.

For all areas, we want to see parking provision firmly coupled to the desired movement modes for the landuses.  For example, we want to see a landuse-coupled parking approach that enables 20-minute neighbourhoods instead of assuming “we’re in the outer area, therefore residents’ parking is a high priority”.  This  would otherwise tie Wellington into sprawl.  

Key transport routes: 

• Agree with the caveat that movement and exchange need to be properly optimised on “key transport” routes that are also destinations, like Lambton Quay. 
• In places like this, urban design features, and to a lesser extent bike/micro-mobility parks, can significantly improve the amenity and thereby vibrancy of a street and should have higher priority than the other types listed in here.   
• On bus and other high-capacity public transport routes, parking must not impact peak time public transport function at all and ideally never. It’s simply a daft tradeoff. 

City Fringe:

• We rated this “disagree” because dedicated car share and bike and micromobility parking should be higher up in the priority list as they provide the most space efficient options for point to point transport alternatives vs. private car ownership.
• Residents’ parking should be prioritised ahead of commuter parking but is not a higher priority than measures to reduce car dependence overall.

Outer residential: 

• Outer residential areas generally have a high degree of car dependence; a high priority needs to be given to provision for alternatives in key locations.  This is part of  creating the infrastructure for 20 minute “urban villages” and supporting increased density and low car-use neighbourhoods  in key areas. Furthermore, it’s bizarre that mobility parking should be a lower priority than residents’ parking. These should at least be swapped, hence our “agree”.  
• We would like to see a landuse-coupled parking approach that enables 20-minute neighbourhoods and doesn’t assume “we’re in the outer area, therefore residents’ parking is needed”.  

Council Parks, Sports, Recreation & Community Facilities:

Recreation travel, sports travel and other non-commuter travel are key areas for public transport growth in Wellington.  Provision of bus stops, and public bus layover need to be given high priority as part of supporting the sustainable transport hierarchy for non-commuter travel.

Pricing Approach

Question 15. Do you agree with this pricing approach? 

Yes.

Question 16. Anything else you’d like to say about it?

Buckle in…

• We are principally in agreement with pricing parking to meet demand, however the Policy’s approach is not sufficient. Parking supply and pricing must be strongly linked to landuse.  We cannot emphasise this enough, and it applies to every single area type described above.  The current descriptions are broad-brush and need to be focussed more tightly to landuse – for example, the active travel catchments of schools.       

• A commuter parking levy is a sensible sounding idea: the new state highways being built and the new sprawling developments north of Wellington city centre (including in Wellington city) will impose a serious car-dependent pressure on Wellington city centre.  We’ll need all kinds of positive pressure to discourage commuting by car, and a levy is one tool.
• Minimum pricing for parking needs to be maintained to help incentivise alternatives to the private car. Parking pricing must support the overall sustainable transport hierarchy and mode shift for the city’s big outcomes rather than be seen only as means of shuffling vehicles between high and low demand locations.

• Council must lobby whomever in central government to clarify or amend the Local Government Act such that council can charge to reflect the opportunity cost of on-street residents’ parking.  If cost recovery is to remain in the law, clarify so it can include recovering to the public the opportunity cost of the space. We cover this more in the residents’ parking section. 

• Council should have a clear eye on what outcomes are being sought, and which tools are right for which outcomes.  Revenue-raising can cloud our judgment, and obscure the value of tools that achieve higher-order goals like emissions reduction.     

• Real-time pricing and space availability information should be very readily accessible, to minimise cruising.  We should amp up the smart cities element of parking management to the maximum, but also ensure that really basic, low-tech information is provided too so noone driving and looking for a park ends up cruising. 

Residents’ Parking Scheme

Question 17. Which of the following aspects would you like to see included in a residents parking scheme?

We ticked all of them EXCEPT “Reduce, remove or relocate coupon parking where it conflicts with residents’ access/parking”. Say No to this one – and read on for why.

Question 18. Please rank the following categories in order of priority [for getting a residents’ parking permit] with 1 being the highest and 8 being the lowest. 

Frankly, this really sucks as a question. The only really clear ones are 1 and 8, everything else you can throw a dart – or leave it to the folks paid to figure this out.

FWIW, our ranking was …

1 Mobility permit holders

2 EV owners with no off-street parking

3 Pre-1930s houses or pre-1940s apartments with no off-street parking

4 Other pre-2020 dwellings with no off-street parking

7 All existing dwellings with 1 or more off-street space

5 Businesses located with the zone

6 New dwellings/homes built after 2020

8 Second permits

Question 19. Do you have anything else to add about the residents’ parking scheme, or any ideas we haven’t thought of?

Two Big Things, and a couple of Also’s.

Big: Address equity issues using a solid evidence base

Any changes to residents parking needs to avoid penalising people on lower incomes who rent, and may have limited choice about where they can find rentals.  Such people are also more likely to have shift work and may also live in higher density households.  Where people on low incomes own cars they are more likely to have raised loans to finance them.  Furthermore, the council does not have good information about whether properties are single flat or multi-flat dwellings. 

A scheme which allocates permits on the basis of property rather than occupancy will tend to favour low occupancy dwellings over higher occupancy dwellings.  There are several ways to address this, for example:

• Allocate permits per household as a percentage of occupancy, rather than equally across all households (e.g. households are entitled to have permit for 50% of adult occupants)
• Reduce the price for permits for tenants as compared with owner-occupiers
• Introduce income-based pricing for permits

Any such policies need to be supported by good information and research.

Big: A revised Resident/Coupon Exemption parking system 

To ensure that there is adequate road space for other landuse within resident parking areas going forward, we call for a halt to expansion of resident parking zones and instead to move towards more coupon parking exemptions for residents. This will provide more flexible and reliable parking options for residents in the area by allowing parking to be spread across the area. Residents with resident parks will still be able to park anywhere in a coupon parking spot as they can currently.

To ensure that any new solution does not indiscriminately disadvantage existing residents (renters, workers etc.) we encourage grandfathering into the system of existing users, at current prices for their resident and coupon exemption parking permits, for the period that they reside at that address. 

Going forward, we would encourage all new permits issued to only be coupon exemptions, and be priced more closely to the existing coupon parking permit costs. For reference, a monthly coupon park is $2400 a year ($200/month). Presently, resident coupon exemptions are provided at $120/year, or a 95% discount. These coupon exemption permits make up 23% of the overall ‘resident parking’ scheme, yet the opportunity cost of these discounted permits was $3.9m in 2018. 

We encourage the council to provide newly issued permits at a price range of 30-50% discount for off existing coupon parking rates on a monthly basis. As this is not a resident parking scheme, but instead a ‘concession for residents to existing coupon parking’, we believe that this would be permissible under the LGA.

Any such changes ought to factor in the proposals noted above, to address these. In addition we note the following:

We recognise that this will raise questions of equity. This is understandable – any increases to parking are inevitably going to hit low-income households. There are several points in response to this:

1. The proposed system does not affect any current residents: As all existing residents would keep their existing parking arrangements at the current prices, they will not be subject to any changes in equity. We recognise that this may affect future residents in their decision to move to the inner suburbs which are currently subject to the resident parking schemes. A number of contributors to this submission are renters in these areas. We can assure the councillors that parking was just one of the factors in the decision to move to the location, as was proximity to town, the cost of rent and other variables. If a new parking system was to be implemented, the cost of parking would be but just another factor among many in our decision to move, as it currently is if we choose to live in downtown where there is no resident parking provided at a discount.
2. The current scheme assumes that inner city suburb residents need cars: Wellington already faces the most expensive cost of living in New Zealand with transport (predominantly cars) being the third largest spending category after food and rent. Many residents in these areas already use or own micro-mobility vehicles, ride the bus, walk or use Mevo to get around, and mode shares of these are growing. We encourage the council to recognise that the residents of these suburbs do not view car-ownership as a necessity, and to focus on equitable transition in the context of these trends.
3. At present, the council is foregoing significant revenue.  (From providing a relatively low-cost residents parking scheme, coupled with the coupon-parking exemptions.) If increased revenue is invested in supporting measures which enable a transition away from car dependence the increased prices are likely to be both more acceptable and more equitable.  Rather than simply being seen as a rationing device, parking charges are then more explicitly tied to broader sustainability, low-carbon and equity objectives. 

With further densification planned in these areas that will enable better mass transit links and non-private car transport options, we encourage council to not let short-term or narrow arguments stop them from acting. 

Also: Additional Parking for Car Share Companies – we encourage the council to provide residents’ parking to e-carshare companies.  One carshare park can replace up to 15 households’ car ownership, so this is a really important way to help households transition off owning and running and storing their own car.  

Also: Additional Parking for Micromobility/Bikes/Mopeds – we would also encourage the development of micromobility parking infrastructure for bikes/scooters on-road or readily, safely accessible off-road (not compromising footpaths). See earlier comments.

Areas with residents’ parking often don’t have easily accessible and safe locations to store the burgeoning transport modes of e-bikes, scooters as well as more traditional mopeds. Secure parking on road areas would be welcomed. 

Barriers to public transport use

This is the last section of the submission and it’s really important too: it’s about how you see All The Other Ways to could get around that don’t need carparking. While we know Wellingtonians are hungry for better options, this section is pretty personal, so fill it in for yourself.

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Aaaaaand there you have it! You’re done!

1. Copy the above, paste into a document (or just download),
2. Tweak for your taste (this is important, they look askance at notably cut-and-paste submissions), 
3. Attach to an email, put PARKING POLICY SUBMISSION in the subject line
4. send to Council’s Senior Policy Advisor Helen Bolton by 5pm Monday 8th June.

Tags: engagement, policy