New York City Pays a High Price for Free Parking

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    "Climate change presents a unique challenge for economics: it is the

    greatest example of market failure we have ever seen...

    ... In common with many other environmental problems, human-inducedclimate change is at its most basic level an externality. Those who produce

    greenhouse-gas emissions are bringing about climate change, thereby

    imposing costs on the world and on future generations, but they do not face

    directly, neither via markets nor in other ways, the full consequences of the

    costs of their actions."

    -- Nicholas Stern, London School of Economicsauthor of the "Stern Report" on Climate Change (2006)

    Climate Change and all its complications and implications are the biggestthreats the world faces, but the scale of the problems and their possiblesolutions can seem too great to contemplate. The need for effective action ata national and international level is clear, but because the issue is so vast itcan be hard for any one person, or community, or even a nation to see howwe can make a difference. Yes, we can buy organic food, or offset ourcarbon footprint by paying to plant trees in the rainforest, but since so much

    of our urban infrastructure gorges on greenhouse gas-emitting fossil fuels,especially our buildings and transportation systems, on a day-to-day basishowever much we as individuals might want to reduce our contributions to

    climate change we run the risk of concluding, like Humphrey Bogart inCasablanca, that our individual efforts "... don't amount to a hill of beans inthis crazy world."

    That said, at the scale of the city, there are issues that matter and steps thatcan be taken to reduce our use of and dependency on fossil fuels, the

    primary cause of global warming. These changes, both large and small, candefinitely amount to much more than that metaphorical "hill of beans,"through reductions in air and noise pollution, resultant improvements in thequalities of our streets and other public spaces, and better efficiency for

    public transit, all of which are crucial to the healthy and sustainable functionof the urban and global environments.

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    As a first step, one very small but very positive move would be to fix ourtroubled relationship with the built environment and its largest component,the streets of the city. Since cars are primary factors in climate change, andalso have major negative impacts on the quality and carrying capacity of ourstreets, if we reduce the presence of cars we can reduce their negativeimpacts. It's easier than it sounds, and can be done step-by-step, street-bystreet. Put simply, by changing our collective sense of the rightful place of

    private cars, and in particular by "internalizing" the costs (and benefits) ofprivate cars and the provision of on-street parking, we can use themechanisms of the free market to strike a more fair balance. And in sodoing, perhaps we can improve the function of our political system ofrepresentative democracy while we are at it.

    In terms of economics, many of the same dynamics that are causing climatechange on a global scale have local equivalents. The market failure orexternalities of pollution, through which market participants are not facingup to or being held accountable for the real costs of atmospheric carbon, hasclear parallels at a more local scale, for example when some individualsexperience the private benefit from parking their cars without charge onstreets that are (or ought to be) seen as shared public capital. Like global

    warming on a worldwide scale, not paying for on-street parking is a marketfailure of metropolitan if not global proportions, and a clear example of whatGarrett Hardin described as the "Tragedy of the Commons" (** Note i )

    I accept that it is a rather large leap to move from the market failure ofatmospheric carbon pollution and climate change, zooming from the global

    panorama to a hyper-local close-up of the streets of New York City, but interms of economic theory these two very different worlds -- of "GlobalWarming" and "Free On-Street Parking" -- are surprisingly similar, at leastwhen looked at in the abstract. Some levels removed from the physical nuts-and-bolts, the similarities between these two market failures reveal a numbersignificant lessons we can draw from one to the other, and in this project I

    hope to demonstrate that by looking at the two topics side-by-side we mayfind some significant practical solutions, solutions that can start local -- atthe level of the street -- and build back up to the global level.

    The aesthetic and other benefits to the environment of reducing cars and carparking are in many ways secondary to my project -- what I want to do istalk less about urban planning or "Sustainability," and more about

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    economics. That said, in contrast to much of the invariably depressingdiscourse about Climate Change, and the seemingly impossible life-stylesacrifices that we will have to make in order to maintain and sustain ourexistence on Planet Earth, confronting the externalities and opportunity costsof Free Parking has great potential to end up with net benefits for just abouteveryone concerned. In fact, starting with these unlikely links between free

    parking and climate change lets us draw tangible connections betweensmall-scale local shifts and the much larger changes that need to be made ifwe are to have any hope of reversing the ongoing "market failure" ofgreenhouse gas emissions, which is a leading cause of climate change.

    In effect, confronting a seemingly small issue like the hidden costs of freeparking reveals the underlying dynamics of the massive market failures thathave lead to climate change, and thereby turns the answer to a local problem

    into a possible solution to a global conundrum.

    While Nicholas Stern may not have been pointing directly to "Free Parking"as a primary cause of global warming, the provision of more than two

    million free parking "externalities" on the streets of a major metropolis likeNew York City has many revealing parallels with the wider dynamics ofGHG emissions, which Stern described as "... the greatest example of market

    failure we have ever seen." If I adapt the quotation I drew as an epigramfrom the Stern Report by replacing the words "climate change" with the

    phrase "free on-street parking", you'll see there is something significant at

    work here:

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    Free on-street parking is the greatest example of market failure New York

    City has ever seen... In common with many other environmental problems,

    free on-street parking is at its most basic level an externality. Those who

    park their cars on the streets ... impose costs on the city and on future

    generations, but they do not face the full consequences of the costs of their

    actions directly, neither via markets nor in any other ways.

    -- Nicholas Stern (Not !).

    The History of Free Parking

    Seen as a city planning issue rather than in terms of global warming, parking

    (and by extension cars, the developed world's dependence upon fossil fuelsas an energy source, and the embrace of the automobile throughout the 20thCentury) has been an environmental disaster every bit as destructive asclimate change promises to be in the 21st Century. The negative impacts ofcars on 20th-Century America have been well documented, and are prettyapparent as soon as you set foot outside. New York City lost access to itswaterfronts, neighborhoods were scythed apart, but compared to other places

    the city got off pretty lightly. Across the USA, huge swathes of public spacehave been given over primarily to the parking of cars -- hideously ugly andenvironmentally destructive, impermeably paved concrete and asphaltspaces just to accommodate the cars that produce a large portion of thenation's GHG emissions.

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    First, some numbers: Parking is the single biggest developed land use is thecountry. In the USA there are at least 800 million parking spaces -- 500million of them standing empty, waiting to be used by the more than 250million registered cars. The land use infrastructure for car parking actually

    exceeds the quantity of space given over to streets, roads and highways --and there are more than 4 million miles of highway in the USA. Free

    parking, quite intentionally, encourages people to use cars -- "Ninety-ninepercent of automobile trips end in free parking and this has a major effect

    on people's choice of what means of transportation to take," writes DonaldShoup in his 734-page magnum opus"The High Cost of Free Parking"**

    ii

    Perhaps surprisingly, until San Francisco conducted a count of its 49 squaremiles in 2006 iii, there had never been any concerted, official inventory made

    of parking spaces, though best estimates are that, across the United States, anarea equivalent in size to Connecticut and New Jersey is dedicated solely toparking lots. Mikhail Chester of UC Berkeley's Department of CivilEngineering did an unfunded "best guess" census of parking in 2010, andsaid: "Automobiles are parked for roughly 95% of their lifetimes yet weknow little about how parking spaces affect the environment. Using five

    different approaches, we determined that there are between 500 million and

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    2 billion parking spaces in the US for roughly 300 million vehicles. The

    energy consumed and polluting gases emitted when constructing and

    maintaining these infrastructures, as well as by roadside paved areas,

    becomes important when considered along with the environmental impact of

    vehicles themselves."

    Nationwide the numbers are much worse than in NYC, which hasapproximately 2 million on-street spaces for the 2 million cars registered inthe 5 boroughs. Of these 2 million spaces, fewer than 40,000 are metered, soapart from a few very limited areas in Manhattan and Brooklyn, all the on-street parking in New York City is "free". To put in another way, themedian price paid for on-street parking in New York City, perhaps the mostexpensive, the most capitalism-embracing and most market oriented city on

    the planet: $0. Nothing.Nada.Nichts!

    For the record, this 2 million space estimate is conservative -- the folks atbicycle advocacy group Transportation Alternatives have calculated thatNew York City offers its citizens and visitors more than 4 million free on -street spaces along more than 12,000 miles of paved public streets. By othermeasures, the amount of land in NYC given over to parking, not including

    private or residential spaces, is astounding: 9,000 acres, equivalent to 11Central Parks. 2 million spaces or 9,000 acres adds up more than 400 millionsquare feet of highest-value, street-level real estate. At an average realestate value of land in metro NYC, acc. to Federal Reserve calculations(which in 2006 found an average price across NYC of $330 a square foot),this values NYC's "free parking" land at about $1.3 trillion... Though to befair, the true market value is probably much less since development potentialis very limited.

    In the next section I will consider some of the "opportunity costs" of givingthis valuable real estate away to car-parking for free, but considering itsnear-universality in the present day, it may come as surprise to learn that

    "free on-street parking" for cars is a relatively new use of this valuablepublic infrastructure. Up until 1952, in fact, it was officially illegal to leaveany car on New York City streets overnight, and when on-street parking wasfirst allowed the NY state legislature insisted parkers pay a substantial $60-oer-year fee for permission to park (though this annual fee seems to have

    been quickly rescinded after political pressure was brought to bear uponregulators by the Auto Club and other special interest groups.) ** Note iv.

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    But it is heartening to know that, not so long ago, regulation of on-streetparking was intended to be limited and paid for, which might have left thestreets more clear for other uses (like playing stickball, or hide-and-seek), asthis brief and possibly gratuitous gallery of nostalgic 1940s and early 1950s

    NYC street images (credit Arthur Leipzig/ Photo League) may attest.

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    Opportunity Costs

    Even though NYC is in some ways comparatively "car free" - -compared toplaces like California or Arizona or Texas, it is very manageable to live inNYC without a car, and roughly half its residents do just that. Yet densitymeans that there are more cars per square mile in Manhattan than anywhereelse, and huge swathes of the city are given over to parking cars. Not drivingor using them -- just storing them, for weeks on end. (One recent study triedto figure out why people kept cars in Manhattan and came to the conclusionthat the primary reason for driving a car in Manhattan was to move it so asto avoid getting a parking ticket!) So clearly, people are keeping cars that donot contribute to the commonweal or produce anything of much value.

    Because NYC has transportation alternatives and a sophisticatedinfrastructure, it's hard to justify keeping cars. (Especially if they are not

    being used, just parked.) While the psychology of car ownership iscomplicated, one of the many reasons car ownership can be maintained byotherwise reasonable people is precisely because of that infamous economicexternality -- most people do not play a penny to park, which means thefamously business-savvy, economically-engineering mercenary citizens of

    New York City are giving away their most valuable asset, Manhattan realestate, for free.

    This provision of free parking at public expense benefits carowners at a huge opportunity cost to everyone else -- a marketfailure and externality of huge proportions.

    Also, parking is a good illustration of what is, and what is not, a "publicgood". People might think that streets are a fine example of government inaction, but in economic terms, on-street parking places are the opposite of a

    public good :

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    A public good (like street lighting, or flood control) is at once -- non rival(as Paul Samuelson said: "...in the sense that each individual's consumption of sucha good leads to no subtractions from any other individual's consumption of that good..)

    and non excludable(meaning that it is impossible to exclude anyindividuals from consuming the good -- I can't stop you from enjoying theview of the Empire State Building, but I can block you from parking in "my"

    private executive space, for example.)

    But a parking place is both rival and excludable, so it is most definitely not a"public good" in economic terms.

    But could on-street parking be converted from a "externality" with large

    opportunity costs into a good thing for the public (if not a public good.) Andif so, how, you might ask. Pretty simply, I would answer: make people payto park. And before I propose some possible ways to "internalize" the"externality" of free on street parking, here are some numbers that attempt toshow what scale of monetary value or revenues might be gained makingdrivers pay for what is now "free on street parking."

    If every one of the 2 million car parkers in New York City currentlyenjoying the "free parking" subsidy were obliged to pay a minimal fee for a

    parking permit, the revenue stream could amount to significant sums. If each

    on-street parker had to pay $1 a day per car to "internalize" their externality,that would raise $2 million a day. Multiply the daily rate by 365 days = ~

    $700 + million a year. This would provide twice the funding to buy pre-kindergarten education for every kid in New York City, which is estimatedto cost $300 million a year. (By coincidence, $700 million is the entireannual budget of the NYC Dept of Transportation, which cleans andmaintain all the city's streets, bridges and sidewalks.)

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    And @ $2 a day per car, the revenues would come to $1.4 billion, which isenough money to provide free tuition for every student in the entire CUNYsystem (CUNY's total systemwide budget is $3 billion, 40% of which comesfrom tuition, the rest from the city and the state of NY.)

    Alternately, if variable rate parking were introduced on some of the 99.9%of NYC streets that are currently not metered, even greater sums could beraised. Numbers are hard to come by, but if the current 40,000 meters raise$150 million a year (which are the numbers the DOT shared with potentialinvestors when looking to securitize their meter income in May 2012 **from Wall street Journal:http://online.wsj.com/news/articles/SB10001424052702304070304577398482644925706?mod=googlenews_wsj&mg=reno64-wsj

    Of these 40,000 existing meters, only 8,000 are "smart" meters able tohandle variable rates, but extrapolating from the success of other "smartmeter" programs in cities like San Francisco, New York City is sitting on a

    potential windfall. With Midtown garage rates easily reaching $15-20 ahour, simply replacing 30,000 existing meters could raise $500 million ayear or more, and expanding metered areas even minimally could bring in

    billions, all the while reducing the current incentives for people to drive and

    expel those dangerous GHGs.

    And none of this takes account of parking ticket fines and similar revenues(which were $850 million in 2012). And so on. Imagine the possibilities!

    But before I discuss the potential benefits of deriving revenue frominternalizing the externality by charging for "free" on-street parking, I wouldlike to point out that the current system of providing free on street parkingdoes not even achieve its primary goal, which is to enable people to visit

    places and conduct business. The costs of this externality -- that offering aresource like parking for free removes any market forces toward moderation-- are massive, in terms of increased congestion, increased pollution, and

    many other inefficiencies. Giving away parking for free has the perverseeffect of destroying that valuable resource. Since there is no price to pay for

    parking, the resource is completely consumed, and the end result is that thereis no place left to park. At a price of zero, the demand is such that in effect100% of available supply is consumed.

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    According to Shoup, from a public policy standpoint the "right" price forcurb parking is not necessarily the one that maximizes revenue, but the pricethat best preserves the resource, which he calls the "lowest price that willavoid shortages" (Shoup page 303). A "shortage" is taken to mean a rate ofoccupancy greater than 85%, meaning too few spaces are available, thuscausing the need for "cruising" (described more fully below). Therelationship between supply and demand with regard to the price of parkingis shown by this graph:

    ===

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    The first parking meters were introduced in the 1930s, in Oklahoma City,not to raise revenue but to free up spaces--in effect, to prevent the "tragedyof the commons" resource depletion embodied by fully occupied "free

    parking." In most of New York City, all the on-street spaces are constantlyfull, so much so that studies have shown that fully 30 percent of all privateauto traffic on the streets of NYC is formed by cars looking for a place to

    park, or "cruising" as it's known in the trade. "Cruising" for free parkingcauses such substantial GHG emissions, congestion, and other negativeexternalities that studies have put a $13 billion price tag on the metropolitancost of road congestion, acc. to the Partnership for New York City, 2006.(www.pfnyc.org/reports/GrowthGridlock_4pg.pdf )

    Fortunately for NYC residents, this "cruising" is actually the one area where

    progress toward sensible parking policies is being made. Since 2008 NYChas been introducing "variable pricing" to achieve the optimal level of openavailable parking spaces or "curb occupancy" -- the ideal is generallythought to be 15% of all spaces, but in practice all that matters is that onespace is available when you pass by in need of a place to park.

    ( http://www.reinventingparking.org/2013/10/is-30-of-traffic-actually-searching-for.html )

    To do this, new technologies make changing rates better able to reflect

    supply and demand. In San Francisco -- high-tech sensor-driven metersmake it possible for rates rise and fall from minute to minute, dependingupon occupancy rates, so that there are always spaces available for cars thatneed to be parked. (The technical term for whether a on-street space isavailable or not is "Curb Occupancy.")

    In 2010 New York City tried a small test of this system out on Roosevelt

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    Island -- 22 spaces were outfitted with sensors, according to JonathanKalkin, the head of Roosevelt Islands operations committee, so that as in SF

    potential parkers could have access to " rigorous, real-time information... Ifyou want to price parking based on demand, for example, sensor data can

    provide the foundation for setting the right price block-by-block or hour-by-

    hour. If you want to accurately enforce time limits or make sure that parkers

    adhere to the time they paid for, real-time info can send enforcement officers

    directly to the scene of a violation. Or if you want to cut down on the miles

    of cruising drivers often resort to while searching for a parking space,

    sensors can direct them straight to an open spot."(http://www.streetsblog.org/2010/10/29/roosevelt-island-parking-sensors-will-point-the-way-to-smart-parking/)

    If NYC could combine variable pricing at market rates, the potential

    revenues could be truly enormous--just in Midtown, charging $15 an hourfor short-term parking on 10,000 select spaces, even if these "revenuemaximizing" spaces were only occupied at a 50% rate (4 hours a day), thesums are huge: $6 million a day, multiplied by 200 days = $1.2 billion,while cutting down on short-term cruising but reducing the amount ofsurviving "free" on-street parking by less than 1%. If sold (or leased out onlong-term deals), each space would likely bring in $200,000 at current open-

    market rates, enough to build a quality apartment, meaning that a 10%reduction in on-street parking over the next 10 years could supply the city'shousing needs, funding 200,000 units.

    Or, if residents were less willing to give up driving altogether, it is stillconceivable that each street could have its own dedicated "car share"ZipCar, with some amount of "free use" for residents included (and paid forusers of the remaining on-street-parking resource.

    Either, or both, of these options would be miles better than "free parking."

    Whatever the specific rates charged for parking, alongside the revenues

    raised there is another significant aspect of charging for what is now free on-street parking: the "Pigouvian Tax" that such fees can be said to represent. Iwould submit that paying for parking is a user fee, not a tax. The distinctionwould be significant primarily to libertarian think-tanks, but if and whensuch fee or tax was implemented, the charges would have the Pigouvianeffect of correcting at least some of the market inefficiencies embodied by"free" parking, and would likely have the secondary impact of reducing

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    demand for on-street parking, which would make it easier to find on streetparking, and perhaps reduce pollution levels. No matter what the rate,introducing charges for on-street parking would have the positivelyPigouvian economic effects of internalizing the current externality.

    Keeping Things Local: Parking Benefit Districts:

    Economics play a huge role in politics, and the perception of who receivesbenefits and who pays the price is at the basis of the equity and inequity ofboth market failures (like externalities) and market success (such as findingthe equilibrium price for transit and supporting truly sustainable options.)

    Using the on-street parking revenues to improve public transit would becrucial to political acceptance as well, perhaps making it more palatable to

    car owning voters without pre-K or college kids under their roof. Accordingto Bruce Schaller, NYC's Deputy Commissioner for Planning andSustainability, drivers backed Mayor Bloomberg's recent effort to internalizesome of the externalities of driving through his economically sound but

    politically fragile proposal to introduce congestion charging (via tolls on allManhattan-bound bridges.) The proposal was supported by NYC resident-drivers by a 67% to 27% margin -- provided that the money (which was

    estimated to total $500 million anually ) was used solely for expanded transitservice (** Note study by Quinnipiac University, 2008).

    Another alternative approach would be to introduce charges for on-streetparking near popular MTA subway stations, so that commuters pay the priceof leaving their cars near a station while at work. While the rates wouldhave to be set carefully so as not to dissuade drivers from riding publictransit, a system could be developed so that by paying (perhaps in advance)for a space they would be guaranteed quick access to parking space (perhapsvia valet parking - crazy as that sounds!). Such guaranteed space wouldlikely encourage drivers to drop their cars farther from congested areas ofthe city, and if these revenues were dedicated to improving local transit --

    for example, by funding better cleaning and brightening of the stations, andeven by supporting more frequent train services -- such parking chargeswould likely be embraced by users and local residents alike.

    So by now I have outlined some of the significant financial upsides ofmaking parkers pay for the economic externalities. The other significantinitiative has smaller financial impacts, but perhaps is even more valuable in

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    terms of longer-term political capacity and deepening awareness. This iswhat the world's parking expert, UCLA planning professor Donald Shoup(author of the excellent "High Cost of Free Parking" referred to above...)calls "Parking Benefit Districts", which aim to ensure that the monies raisedfrom charging for street parking benefit the local neighborhoods where suchcharges are incurred. Shoup deems this connection crucial to the success ofsuch plans, as revenues would be spent locally, reimbursing residents, in away, for the sacrifice of their "free parking."

    Using curb parking revenues to improve the neighborhoods around newlymetered zones can create a strong local interest in swapping "free parking"for fairly priced curb parking. Shoup studied an early success story, inPasadena California, where a run-down "skid row" neighborhood wasrevitalized in part through leveraging parking revenues, as detailed in an

    article Shoup co-wrote called "Turning Small Change into Big Changes."

    While the politics of building a base of support for these initiatives, whichlike any change usually result in an immediate backlash, are clear andsensible, the "local roots" of parking benefit districts and other small-scaledemocratic efforts are even more promising.

    Perhaps most valuable is the possibility of using spaces dedicated to cars tohelp wean people off those cars-- by generating funds from the internalizedexternality of "free on-street parking," and using those funds to improve

    public transit, thus making cars less necessary. For poor people inparticular, cars are a huge expense--running a car costs many thousands ofdollars in fuel, insurance and maintenance costs alone, not counting thecapital investment (nor the externalities of pollution et al.)

    And more ambitiously, in areas around New York City, the Dept ofTransportation (DOT) has been testing out what it calls the Plaza Program,which in effect convert parking and congestion into public spaces. Workingwith local property owners and neighborhood groups, the Plaza Program

    reclaims public land for a public purpose--using parking spaces for socialgathering space, in one instance even hosting a local community boardmeeting in a public plaza that had been converted from a bus layover. The

    best-known example of these "plazas" has been the recovery and effectivepedestrianizing of long stretches of Broadway around Times Square.

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    Through the DOT Plaza Program, other less famous New York City plazashave also been reclaimed from parking spaces, so that where cars oncedwelled people can practice yoga

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    or simply sit and rest for a while

    It is a big stretch from such small-scale reclamation to resolving theexternalities behind global warming, but dealing with the anomaly of "free"on-street parking does seem a move in the right direction. Besides reducingthe need for cars, removing some of their longstanding economicexternalities will shrink the claims which cars have long made on our urban

    spaces through parking and traffic and noise and exhaust fumes. As a next

    step, reclaiming public streets for the public benefit can fund yet moresustainable practices, and perhaps more importantly such reclamation canalso begin to build our collective capacity for political endeavor, eventually

    putting pressures on the powers-that-be. This way ever-greater externalitiescan be reversed, and market failures turn into market success stories.

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    NOTES

    iDespite the fact that Hardin later wished he'd titled his work "Tragedy ofthe Unregulated Commons," this "tragedy" is a primary concept insustainability studies. Using commons to stand for any shared resource (theatmosphere, fish stocks etc), his metaphor makes the point that free accessand unrestricted demand for a finite resource ultimately reduces or evendestroys the resource. Being a Southern Californian, living in the land ofextreme car culture, Hardin also illustrated the restrictions and regulations asociety might place on the "commons" through the example of car parking:

    "... The more the population exceeds the carrying capacity of the

    environment, the more freedoms must be given up. As cities grow, thefreedom to park is restricted by the number of parking meters or fee-

    charging garages."

    Elinor Ostom later won a Nobel Prize (for Economics!) by expandingHardin's metaphor with a externality internalizing solution:"Solving [commons] problems involves two distinct elements:

    1.Restricting access, and

    2. Creating incentives (usually by assigning individual rights to, or

    shares of, the resource) for users to invest in the resource instead of

    overexploiting it. "

    ==

    iiDonald Shoup, The High Cost of Free Parking. Chicago: Planner Press

    (2005). This is the bible for parking planners, and includes many of theconcepts around which I have structured my study.

    ==iii

    San Francisco County Transportation Authority, 2009: On Street ParkingManagement and Pricing Study . This study found that " Under-regulatedon-street parking results in limited parking availability, inefficient utilizationof spaces, and excess vehicular circulation." Full report available at:http://www.sfcta.org/transportation-planning-and-studies/current-research-and-other-projectsstudies/street-parking-management-and-pricing-study

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    ==

    iv:Adding to complexity of the "High Cost of Parking" question is theworld of New York City zoning and on-site requirements for new

    developments to include parking spaces, at a rate as high as one space perunit in most developments. I have opted to concentrate primarily on the

    provision of on-street parking, but privately owned garage parking is also abig factor in how the city works. At an average cost of $30,000 per space,perhaps twice that in pricier parts of the city, on-site parking is veryexpensive to construct. This makes building low-cost "affordable" housingeven more challenging, which is in part why these "parking minimums"have been solely eroded and revised--most recently in 2013, when theseunfunded mandates were eliminated for Manhattan south of Central Park.

    ---