The Residential Parking Zone program is one of the most important protections that neighborhoods have. On March 31, the Seattle Department of Transportation issued proposals that would make it much harder for neighborhoods to get an RPZ, and SDOT would have almost unlimited discretion to revoke the existing ones. Many other changes would render the program almost unrecognizable--in fact SDOT proposes even to remove the word "residential" from the term RPZ! The proposals in many respects diverge dramatically from what SDOT had discussed before. The "public involvement" that SDOT engaged in seems to have been a sham.

What is worse, SDOT released these proposals only on March 31 along with a "Declaration of Non-Significance," claiming that the changes would not be a significant action under the State Environmental Policy Act. And SDOT set today, April 13, as the comment deadline. That is less than two weeks, and surely they know this is tax time! It is the wrong time and not enough time for asking comment on the DNS, and SDOT set the April 20 as the deadline for appealing the DNS to the City Hearing Examiner (see below). This gives SDOT no meaningful opportunity to revise the DNS based on the comments that it obviously does not want to hear. To be fair to those who comment on the DNS or may wish to lodge an appeal, SDOT must extend both deadlines by at least a month.

The proposed ordinance, SEPA checklist, and DNS, can be found at http://www.seattle.gov/transportation/pa… Please send in some comments today (suggestions attached), and please also ask that the comment and appeal deadlines be extended for 30 days to give a genuine opportunity for neighborhoods to learn about, discuss, and if needed, appeal these proposals. Attached is a powerful critique of the proposals by Larry Hettick, a neighborhood leader who has been following the process. Larry can be reached at [e-mail address]. Please Larry know your thoughts, and if you would like to get involved in a coalition effort to save the Residential Parking Zone program. And is there anyone out there willing to appeal the DNS by April 20, or willing to contribute to the costs of those who do?

First is it important to remember that the Residential Parking Zone (RPZ) Program was created to help ease parking congestion in residential neighborhoods while walking a fine line to balance the needs of all people to be able to use the public streets. The focus was, and to this day remains on neighborhoods and on the residential component of our neighborhoods. RPZ were to be and have been established on blocks that have adjacent residential use (houses, apts., or condos) to discourage long-term parking by non-residents. RPZ were considered necessary and appropriate where the parking congestion was caused by being near a business district with limited parking, and/or is caused by parking generated by visitors or employees of a hospital, school or factory. As such the RPZ permits are currently issued only to residents who actually have the signs installed on their block or who live within the RPZ boundary. Permits cannot be issued to non-residents, business owners or employees.

The proposed change effectively dismantles many of the basic tenets of the existing program. Right from the start the name changes from Residential Parking Zone to Restricted Parking Zone – which itself is a strong indicator that the RPZ program as we know it will morph into an entirely new entity. Upon careful review of the project goals and the list of major changes it is abundantly clear that the “residential” flavor of the program has been vastly depreciated and supplanted by the interests of the business community. I was on one of the community focus groups and I can find nothing in our group’s work that even remotely resembles the proposed changes. The substantive changes contained in the proposed SMC change are all about adding a new and dominant player to the equation – businesses whose employees or their visitors who will simply inundate residents of neighborhoods who now enjoy at least some protection via RPZs.

To support this conclusion I offer the following comments to the stated SDOT Policy Review Project Goals and the List of Proposed Changes both of which are presented in SDOTs website at http://www.seattle.gov/transportation/pa…

RPZ Policy Review Project Goals
Revise program to:

• continue to reduce traffic impacts to neighborhoods from large parking demand generators
I don’t see anything in the changes that will reduce the impacts of large parking generators. In fact the changes will promote and encourage the large generators to bombard Seattle neighborhoods with demand for parking that is already saturated.

• add support for mixed-use neighborhoods and local business districts
This was never one of the goals we were working with in our focus groups. It’s fundamental to remember that the RPZ program was implemented to mitigate parking congestion in neighborhoods caused by being near a business district with limited parking, and/or is caused by parking generated by visitors or employees of “a hospital, school or factory.” Giving or adding support for mixed use or local business districts was NOT part of our agenda and in fact it seems rather counterproductive to do so.

• maintain reductions in overall energy use and vehicle emissions
This seems to be just an obligatory “green” component. With or without RPZs the overall energy use or vehicle emissions are not impacted or affected.

• implement program with simple rules that are easily understood and clearly applied
From my perspective the proposed changes are much more complex, more confusing and accordingly suffer in their application. Enforcement remains a key unresolved issue. And as already mentions introducing the mixed-use and businesses into the RPZ equation will only exacerbate the critical parking shortfalls in nearly all Seattle neighborhoods. The permits will become meaningless in a environment will be even more saturated with a demand for on-street parking that already exceeds the supply of such spaces.

Proposed Major Changes

• Managing permit parking demand – Limit RPZ permit sales to 8 permits per household
Not sure how much of an impact this will have as I have no data to support how many “households” there are that have a need for 8 permits. During our focus group meetings it was pointed out that areas like the U district had a number of old homes that had been converted into “boarding houses” with 10 + “residents.” The simple fact is that in such areas of the city the parking is already in such an upside-down supply vs. demand posture this restriction on the number of permits per household will not have much of a positive impact. Maybe restricting the number to 2 or 3 would help but to 8 is nothing more than a cosmetic amendment to the existing program.

• Permit eligibility–Require that vehicles be registered in resident’s name and permit-eligible address
This seems like a good idea in concept but not in execution as it will be very difficult to enforce – at least until the city comse up with some easy way to cross-reference registered names with addresses. SDOT indicated in our focus group meeting that the Seattle Police Department is supposed to be getting some type of license plate scanner but I see nothing in the proposed legislation to support this nor any reference to such in SDOTs or the Police Dept’s websites.

• Major Institutions policy – For new or expanding major institutions, limit major institution permit payment to no more than two permits for first permit cycle.
I think this is a nothing more than a gift to the business community as it removes, in part, the established agreements with major institutions (such as the U and First Hill medical faculties that now subsidize the permits for the adversely impacts residential neighborhoods.. This is just another example of how these changes show an obvious and deliberate strategy to support the business community at the expense of the adversely impacted residential communities.

• RPZ location – Prohibition of RPZ implementation in downtown Seattle given high demand and multiple, competing needs for on-street parking
Once again business interests over the residential community.

• Business and institution permit pilot program – Create a pilot program that allows eligible employees in the Sound Transit LINK Light Rail Initial Segment to purchase permits
Wow, why single out transit employees is beyond me. I see as it as just another effort to depreciate the merits of the RPZ program. Pretty soon every special interest group will have a permit but with fewer and fewer on-street space what’s the point? The RPZ program becomes nothing more than an income generator for the city!

• Guest permits– Create single-day guest pass in addition to biennial permit
Seems like a good idea but in reality my be tough to actually get such passes on a timely basis and it seems there is plenty of room for misuse.

• New RPZ zone creation process – Change technical and community engagement requirements. Parking study must generally demonstrate at least 75% parking occupancy along affected blocks, and 50% non-resident vehicles. Any proposed RPZ zone would need to contain at least 10 contiguous city blocks.
This is VERY anti-residential. The Seattle Municipal Code specifies the thresholds that must be met in order to establish an RPZ. Currently the SMC states that 75% of on-street spaces must be in use for at least eight hours, with at least 25% of those spaces used by non-local vehicles, all in an area of at least five contiguous blocks. The proposed legislation marginalizes the residential focus of the existing program by allowing over 50% parking by non-resident vehicles before an RPZ can be created and by doubling catachment requirement from 5 to 10 contiguous blocks. Bottom line: no new RPZs will ever be aapproved and probably some of the existing ones will be removed when this new criteria are applied. It is especially noteworthy to highlight a key element in the draft legislation (bottom of page 12) which gives new powers to the SDOT Director: “may initiate dissolution of an RPZ when he or she determines that it best serves the public interest and meets at least one of the following criteria, including but not limited to, low permit sales in a zone, a small number of blocks with RPZ signs, or the original traffic generator no longer exists. The zone would be removed at the beginning of a new permit cycle.” Such powers would not be subject little if an public scrutiny.

• Modifying and removing zones process – Change technical and community engagement requirements.
As states above these changes bestow super powers to the SDOT Director that are above and beyond what might be considers usual and customary.

• Parking enforcement – Create additional fines to address permit abuse
Enforcement is the operational backbone of this program. Additional fines for permit abuse are just the tip of the iceberg. SDOT and the Seattle Police have yet to demonstrate that they have a workable, cost-effective plan for enforcement.

• Customer service – Create on-line permit payment and eligibility checks for permit holders
The city should have done this years ago.

• Director’s Rule –Replace existing resolution with procedures in Director’s Rule
Once again these changes bestow super powers to the SDOT Director that are above and beyond what might be considers usual and customary and are simply unnecessary. They are not justified by the supporting studies conducted in the review process.

Submitted by
Larry Hettick