Monday, October 19, 2009

Parking as an environmental impact

The bike people are gleeful about the MTA's newly-released "Extended Meter Hours Study," because anything that makes it more difficult and expensive for people to drive in the city meets with their approval.

Not surprisingly, the SF Bicycle Coalition likes this anti-car "vision":

Executive Director Ford has called for SFMTA to lead a dramatic shift in transportation modes in the next 20 years, cutting auto usage in half (from the current 60 to 30 percent), boosting transit use from 20 to 30 percent, and doubling trips made by walking and cycling (from 20 to 40 percent). The SFMTA Board of Directors must act to support this vision and one of the best ways to support this is to discourage casual auto use and increase the cost of private auto storage in the public realm, as recommended by staff.

Executive director of the SF Bicycle Coalition Leah Shahum's vision of traffic on city streets is one of gridlock: "Imagine streets moving so calmly and slowly that you'd let your six-year-old ride[a bike] on them."

"Auto storage in the public realm" means "parking" to the rest of us. How do you "discourage casual auto use"? By making it as expensive and inconvenient as possible to drive in SF.

The Draft Environmental Report on the Bicycle Plan insists that San Francisco, unlike the rest of the state, is so special it doesn't have to worry about the environmental effects of removing more than 2,000 street parking spaces by implementing the Bicycle Plan on city streets:

In San Francisco, parking deficits are considered to be social effects, rather than impacts on the physical environment as defined by CEQA. Under CEQA, a project’s social effects need not betreated as significant impacts on the environment. Environmental documents should, however, address the secondary physical impacts that could be triggered by a social impact. (CEQA Guidelines Section 15131(a).) The social inconvenience of parking deficits, such as having to hunt for scarce parking spaces, is not an environmental impact, but there may be secondary physical environmental impacts, such as increased traffic congestion at intersections, air quality impacts, safety impacts, or noise impacts caused by congestion (page V.A. 3-500).

Okay, whether you call them primary or secondary, the effects of taking away all that street parking are going to be studied, right? Wrong! The DEIR on the Bicycle Plan tells us why not:

In the experience of San Francisco transportation planners, however, the absence of a ready supply of parking spaces, combined with available alternatives to auto travel (e.g., transit service, taxis, bicycles or travel by foot) and a relatively dense pattern of urban development, induces many drivers to seek and find alternative parking facilities, shift to other modes of travel, or change their overall travel habits. Any such resulting shifts to transit service in particular, would be in keeping with the City’s “Transit First” policy. The City’s Transit First Policy, established in the City’s Charter Section 16.102 provides that “parking policies for areas well served by public transit shall be designed to encourage travel by public transportation and alternative transportation.” The transportation analysis accounts for potential secondary effects, such as cars circling and looking for a parking space in areas of limited parking supply, by assuming that all drivers would attempt to find parking at or near the project site and then seek parking farther away if convenient parking is unavailable (V.A. 3-500, V.A.3-501).

That is, drivers will just have to keep looking for a parking space as close to being "convenient" as possible. If they can't find a place to park, tough shit. But what about the effects of all that driving around looking for parking due to a shortage of parking?

Moreover, the secondary effects of drivers searching for parking is[sic] typically offset by a reduction in vehicle trips due to others who are aware of constrained parking conditions in a given area. Hence, any secondary environmental impacts which may result from a shortfall in parking in the vicinity of the proposed project would be minor. Therefore, there would be no significant parking impacts with implementation of Project 5-10 Option 2.

The result of removing all that parking will be the ultimate benign environmental effect---drivers will simply give up trying to park in that area or "shift to other modes" of transportation due to "constrained parking conditions," which means that there will be no negative environmental impacts from removing parking anywhere in the city, even though the Bicycle Plan will eliminate more than 2000 parking spaces from city streets!

This is the same type of thinking---San Francisco is so special!---that got the city in trouble with the Bicycle Plan in the first place, since the law it violated is the California Environmental Quality Act (CEQA), a state law that even our oh so special city has to follow.

There's CEQA case law that contradicts the city's position on parking as an environmental impact: Friends of “B” Street v. City of Hayward (1980) 106 Cal.App.3d (Loss of on-street parking “indicated that a finding of significant environmental effect was mandatory”); Sacramento Old City Assn. v. City Council of Sacramento (1991) 229 Cal.App.3d (“Traffic and parking have the potential…of causing serious environmental problems.”); San Franciscans Upholding the Downtown Plan v. City and County of San Francisco (2002) 102 Cal.App.4th (Parking deficits were significant impact requiring mitigation.)

And even MTA's new meter study contradicts the city's approach to parking and the environment in the Bicycle Plan EIR:

More parking availability means that drivers will spend less time circling in search of parking spaces. Circling reduces safety, wastes fuel, and increases greenhouse gas emissions. Less circling will reduce congestion and greenhouse gas emissions, and improve the quality of life in San Francisco's neighborhoods (page 27, Extended Meter Hours Study).

That is, lack of parking is not an environmental impact when the city is pushing the anti-car Bicycle Plan, but it is an impact when it wants to extend parking meter hours on city streets. This is like the so-called safety emergency at the Market/Octavia intersection: the intersection is unsafe when the city is arguing on behalf of cyclists, but it's safe when the city is sued by a cyclist injured in an accident.

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