One of the most important directions in the Auckland Plan, in my opinion, was the strong emphasis on shifting away from the current way we manage parking regulation. This may sound like a pretty mundane issue, but if you read on, you will discover the complete and utter madness of the way parking is managed at the moment – and how ensuring that the Auckland Plan’s direction comes to fruition in the Unitary Plan is going to be one of the most important transport issues that this blog will focus on in relation to the Council’s new planning rulebook.

Here are the directives in the Plan that relate to parking, somewhat hidden away in the Urban Auckland chapter:

Inappropriate regulations and inflexible standards can impact negatively on good design. They impede the development of more intensive housing and mixed developments. For example, at times traditional parking standards (minimum numbers of car parking spaces) are imposed in areas where alternative options (parking buildings or investment in public transportation) imply that such minimums are counterproductive to delivering the goal of intensification, mixed use and affordability. The Auckland Council intends to review its approach to parking, as part of the development of the Unitary Plan (see Chapter 13: Auckland’s Transport).

Directive 10.6

Parking standards and innovative parking mechanisms should take account of multiple objectives, including the need to:

  • facilitate intensive and mixed-use developments within strategic locations
  • improve housing affordability
  • reduce development costs
  • encourage use of public transportation
  • optimise investments in public parking facilities, civic amenities and centre developments
  • foster safe, convenient and attractive walkable neighbourhoods.

Interpreting this, the Plan may as well have said “the Unitary Plan shall not include minimum parking requirements”.

So what are minimum parking requirements and why are they so mad? Well let’s have a look at them for a moment, courtesy of the legacy District Plan which applies to the isthmus area. Parking is considered from page 15 onwards. Here are the objectives and policies of the parking section, highlighting what the rules are trying to achieve:

I suppose before we give this too much stick, it must be remembered that the isthmus plan was drafted up in the early 1990s when public transport use was at record lows, petrol was dirt cheap, we didn’t mind too much about sprawling and so forth. Transport planning was pretty much solely about traffic capacity so perhaps it’s not too surprising that all the matters now considered important in the Auckland Plan (as per above) in relation to parking regulation weren’t yet seen as important by those writing the isthmus plan.

Some further detail, explanation and reasons are outlined in the plan, and included below:

To paraphrase, the assumption is that everyone will drive for every activity, any on-street parking is the horror of horrors and therefore it should be required that huge chunks of our off-street urban environment must be dedicated to the storage of vehicles. Once again absolutely not consideration of the potential adverse outcomes like stymieing development or subsidising driving – but I guess they weren’t too concerned about such matters in the early 1990s.

Where things get really hilarious though is in the application of different parking standards for all sorts of activities.   

These numbers raise some pretty amusing questions.

  • Why does an entertainment facility require one space for every three people but premises for cultural activities or natural displays only one for every five people?
  • Why do integrated housing developments require more parking spaces than non-integrated developments?
  • Why are healthcare services one for every 20 square metres, offices one for every 40 square metres but laboratories one for every 50 square metres?
  • Why is there a distinction between indoor and outdoor eating areas?
  • Why do places of assembly require one space for every 4.5 square metres – and do they realise that means any site will become around 80% parking because a car is bigger than that?

Surely with the imposition of any regulation a process needs to be undertaken which seriously asks the question of whether or not that rule or regulation generates benefits that outweigh its costs. Not just financial costs but also the regulatory burden and how these rules might discourage development that would otherwise happen.

In future posts I’ll look to go into some further detail around the negative impacts of minimum parking requirements but generally I find myself wondering why we bother with something that seems to be a huge amount of hassle for next to no gain. Really, what’s the point?

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73 comments

  1. I have spent way too much of my working time as a consultant using these tables. My suspicion is that they were based on some demand surveys done at the time, and then tweaked to fit what people considered important, based on their own judgements (I can for example see some some engineer or manager saying “Well, indoor eating areas are used during all weathers, outdoors, not so much – so the outdoor areas need less parking, let’s add a rule on that”).

    Even with such best of intentions to capture actual effects, and extensive baseline data (which I suspect was a lot more limited in reality, and of dubious relevance once applied across the board), this kind of approach creates a very prescriptive and complex approach which often does not fit the local situation – or the higher-level planning policies for the city, because the parking rules generally do not get changed a a lot (being part of the District Plan, they are harder to change than a lot of other strategies).

    Ironically, most for the time I worked with these numbers, I seem to have been working with developers on getting exemptions from these rules – which were generally granted, if you were willing to go to the expense of spending several thousands of dollars for traffic assessments, demand surveys etc…

    1. If only they were based on demand surveys, from everything I have heard about parking minimums across the world the numbers were all just made up without any evidence behind them. If the council wants to continue with parking minimums then they need to provide clear evidence that the values set are at the correct levels. They should also have to explain how the CBD can function with no minimums yet why other town centres would collapse if minimums weren’t imposed.

      At the end of the day, if there isn’t enough parking in an area then that is where a company like Wilsons or Tournament can come in and provide some, that is the market meeting the demand. Further, many of the most valued suburbs around town, Parnell, Ponsonby etc. were all developed at a time when there were no such regulations and they are much more interesting places as a result.

      1. “They should also have to explain how the CBD can function with no minimums”

        Yeah, I had some fun times arguing applications for parking shortfalls by explaining how 50m down the road, the rules suddenly required 100 car parks more / less for the absolutely the same activity!

        Regarding parking demand… well, even if surveys were done, what would they say. Bit of a chicken and egg question anyway: If you provide lots of car parking, little PT and free roads, your car parking demand is going to be higher than if the inverse were true. So it’s really trying to create a had-and-fast rule for a flexible requirement. Which would be an acceptable move if the minimums were minimums – rather than the “this should cater for pretty much all your demand”-type higher levels required in Auckland District Plans.

  2. I think the key thing that seems to be lost in these debates is that removing minimums isn’t the same as removing car parking, it’s just no longer forcing developers to provide car parking they don’t want.

    Without a minimum, people can retain or construct as much parking as they want, Westfield can still surround their malls in a sea of parking of they so desire. All it means is that the council no longer forces them to provide some fairly arbitrary amount as a minimum.

    1. Actually, in my experience, most applications that provide a lot more parking than the minimums are already scrutinised quite a lot, even though we have no maximums outside of some very limited areas. But that’s just another example of treating the minimums as the “desirable average” to which all should gravitate to – and look what that attitude did to Auckland.

      1. Wouldn’t treating minimums as desirable averages actual lead to many places having less than the minimums? I think you mean that provision has drifted well above the minimums in many places, which is what happens when minimums are treated as well… minimums. It’s really a ‘more must be better’ approach.

        The curious thing about Auckland’s parking on first encountering it is how often it seems like there isn’t enough of it e.g. Westfield St Luke’s which is famously impossible to get parked at. It’s only after being here a while that you realise that it’s free parking and hence the unlimited demand that is the real problem.

        1. Sorry David, I guess I came across wrong – what I meant is “the minimums are too high in my opinion, yet we often treat them as the goal to aim for – i.e. don’t go below OR above them” – as if they represented some sort of desirable goal, rather than a relatively arbitrary target unrelated to what is actually desirable or appropriate for location X.

        2. And as has been pointed out above, car parking may well be one of those few area where “the market will sort it” is quite true – much more than in many other areas. Where developers provide too little car parking (like really too little, even once figuring in the ability to reach the site with other transport modes), their property values will suffer, and the next developer will change it (or they will change it themselves in the next renovation of the site). Yet the fear of…. I don’t know exactly what fear of what – crazed parking-seekers who can’t find a car park? – keeps us REQUIRING minimums. It’s that discrepancy between the actual effects of less parking and the regulatory regime that this blog has correctly been harping on about for years.

        3. Whether the market can sort it out or not remains to be seen.

          In more densely developed places with alternative modes of access, then I completely buy the idea.

          But I can think of scenarios especially out in ‘the sprawl’ in situations with very ‘lumpy’ demand (e.g. retail at Christmas) where accommodating peak demand might be seen as a sensible risk-averse business strategy, and we end up with just as much land (or more) given over to parking as we have now. The downside of too little parking provision is potentially banruptcy, while the downside of too much parking is an increase in costs (which it may be possible to pass on to the customer), and which might also be offset by a perception that the larger asset (bigger land parcel) will hold or increase its value over time. I don’t know enough about the psychology of entrepreneurs and developers to be able to say with any certainty whether they are likely to over- or under-provide parking, if left to their own devices.

        4. Yet, David, that situation you describe already exists! So reducing or abolishing the minimums and letting the market find a better balance can only go one way in this case – towards less car parks.

          Also, if you leave car parking (more) out of the regulatory sphere, and more in the responsibility of the individual developer, you also allow them to CHANGE their parking more easily. They can risk building a building with what might turn out to be 70% of the demand – because they know they can add more later. With minimum regulations, you can’t (unless, as I noted earlier, you are willing to pay a consultant a lot of money to make a case for it).

        5. David, what you’re saying would only be the case if the minimum requirements were actually a good and accurate level set appropriate to actual demand at each particular site, but they are only a dubious broad brush attempt to quantify parking demands en masse across sectors of land use.

          Simply, it comes down to what developers would consider most accurate, their own evaluations and advice regarding their parking needs for their site, or some ‘magic’ formulas cooked up by the council decades ago. Anyway, without the regulation they could still go back to the old formula if they wanted to.

        6. Completely agree that removing minimums is likely to see the parking provision fall overall.

          But in autodependent parts of the region and wider country, it’s completely imaginable that parking provision won’t fall at all – especially if, as has been implied, many developers provide well above the minimums at present. If on the other hand, most developments are providing the required minimum parking then that would suggest downward pressure once the regulatory constraint is removed – highly likely in the CBD.

          Incentives to reduce parking (see Matt Clouds comment below) might be needed in such settings to get the ball rolling so that the risk-averse can see that less parking is not equal to the apocalypse. After all, it was (often unintended) incentives to switch to the car-dependent way of thinking that got us where we are today.

    1. And she’s absolutely right isn’t she Andrew? This is a costly building tax through unnecessary regulation. This is the single change- and at absolutely no cost- that the Council can do with the UP to improve AK’s performance economically, socially, and in terms of quality of place.

      No matter what anyone builds the first thing they have to do is try to solve the car parking issues. Now with no minimum regs in place they may still choose to do that but there is no reason on this planet why we should compel everyone to do it.

    2. She presented on this subject to the Auckland Council Transport Committee this morning.

      Cue Dick Quax raising a point of order once Julie-Anne’s implications of her message started becoming clear to the Councillors. Chair Mike Lee adroitly handled Quax’s mini-crusade to shut down Julie-Anne.

  3. If parking minimums truly go then it’s not really relevant, but one idea that occurred to me (may have been suggested by someone else here and my mind has just dredged it up) would be to offer bonus floor area that doesn’t count towards calculations for parking supply if a mall, say, integrates with public transport. So Sylvia Park, for example, constructs a train station fully at the developer’s expense and gets, say, a 10% bonus on allowable floor area without having to provide corresponding parking spaces. And if they put in a bus exchange (a proper one, adjacent to the mall, not just a couple of bus shelters on the outer edge of the parking lot), give them another 10%, or whatever. That would encourage integration with PT through direct financial benefit, and also encourage uptake of PT as a way of getting to the mall.

  4. I think part of the above confusion is due to the fact that our minimums aren’t a ‘bare minimum’ of the safety net sort, the minimum requirement is actually more or less enough for maximum occupancy. So at minimum, you must provide for maximum parking demand.

  5. Sorry, last sentence was supposed to say “with minimum parking limits, you can’t try out whether less parking works for you – and you can’t even reduce your car parking later if someone builds a busway & busway station directly next door”

  6. Parking minimums are usually based on other data, like all the offices in City A have an average of X s.f. and have an average of Y parking spaces, so therefore, you should use that as a guideline. However, this makes no sense because no two urban areas are the same, and an office in a suburban area is going to require a lot more parking spaces than in an urban one, where some employees can walk or take public transit to work. Another maddening thing is that these parking facilities are often overdesigned, that is, we think the demand will be 45 spaces for this suburban office building (since there are 40 people who work here, plus we’ll add 5 for visitors, clients, etc.) so let’s be space and put 60 spaces in. Another example is any suburban supermarket. Local codes require a very high number of parking spaces per 1000 s.f. because that’s what it’ll need at the peak demand (before a blizzard or when a major hurricane is coming, or perhaps the day before Christmas or Thanksgiving). But it’s ludicrous to design for the extremes, because the other 99% of the time, the lot will be at 50%-60% capacity. Think of all the extra land you could have for green space, sidewalks, more businesses, etc. if you didn’t have such absurd parking codes.

    1. I assumed you were from the USA when I read “transit” and further reading confirmed that. We don’t have Thanksgiving or blizzards in Auckland!

      1. Or hurricanes for that matter, too far south (although we do catch the tail of the odd cyclone).

        A good point though, even if they are based on some analysis of existing conditions you’ll never get such a broad proscription being accurate for any given site.

      2. We do, however, have Easter weekend, and Christmas.
        The thing I found interesting when I paid attention to parking around Christmas was that Countdown Greenlane, even on Christmas Eve, did not fill the parking lot. Not even close. Clearly the required parking capacity is in excess of what’s necessary even on the busiest day of the year for a supermarket, which means hundreds of square metres of wasted space that’s largely only useful for parking Fulton Hogan trucks when the guys go to McDonald’s for dinner during their night shifts.

        1. that’s a very interesting observation Matt.

          I’ve always thought it ironic that the single most important determinant of parking demand is simply the success of the business, or in a residential environment, whether someone’s having a party.

          And they’re the perfect examples of factors that cannot be taken into account from the outset. Imagine if resource consents had to predict how successful their businesses or when parties were going to be held?

          Basically, “predict and provide” just don’t work – and the unintended negative consequences are enormous.

  7. The main methodological problem with minimum parking requirements is that they assume parking should be free. That’s simply not true: Malls from Australia to Norway charge for parking as a way of managing demand and encouraging turnover.

    And they would so more if demand were higher. So rather than assuming parking should be free, let’s just allow the market to work out how much to provide and how it should be managed. All Council needs to do is manage demand for public (usually on-street) parking, but that’s easily done and usually revenue positive,

    To be frank, minimums parking requirements are a bit of old bollox. They were a way of managing localised congestion and overspill caused by a lack of off-street parking back in the day of rampaging growth in vehicle travel. Nowadays we simply don’t need them, Mainly because our urban form has been drastically re-shaped to favour cars, and because developers now realise the value of off-street parking.

    R.I.P MPR

    1. It’s the free parking part that’s the problem, I agree, Stu.

      Guarantees unlimited demand, so that no matter how much is provided someone will think it’s not enough at some stage. It also creates a sense of entitlement, and endless searching for the elusive spot.

      Westfield St Luke’s is a case in point. It’s pretty close to capacity many weekends of the year, and is completely unbearable around Christmas, so it’s not especially guilty of over-provision. If parking was priced at something like (say) $5 an hour (and maybe more at Christmas) I doubt that would remain true, although given the current road layout, I wouldn’t much want to live in a residential street near there if that happened (since the first impulse of the tight-fisted would be to find a park in the street).

      In the absence of compulsion to charge for parking, it’s hard to see any mall owner volunteering to be the first to charge… If there was a mechanism to force Westfield to return the profits from parking to the retailers (via reduced rent) and to the customer via reduced prices for goods, and you could convince people that this was actually happening, then maybe it could be done, but without such compulsion, it’s Prisoners’ Dilemma again – no mall operator will want to be the first to ‘cooperate’ due to fear of lost custom.

      1. Except Westfield have that one big outlier to their business model the (recently sold) Downtown. Not one car park, and none on surrounding streets. None free that is. Makes a good profit. But you will say it is well served by public transport. Exactly. Soon most other shopping centres in AK are going to be getting decent PT too. Sad fact is that those transit riders will still be paying for the parking, they will be subsidising the drivers.

        1. I must somehow be coming off as against market provision of parking. I’m not. I am completely in agreement with the title of this post. I’m just not convinced this is a magic bullet in the absence of serious thought about what else is required to make developers change their default settings and business model. There’s generally a great deal more to a business model than economics, ideology, group-think, culture, etc.

          It’s taking developers a long time to recognise that freeing up space in town for development would do more to address high land costs than freeing up greenfield on the edge of town. The former course of action makes them carry more of the costs, while the latter allows them to offload costs (infrastructure) on everyone else. I am more or less certain that even if you made half of Albany available for development by reducing the space devoted to parking there will be many developers who will continue to lobby for greenfields on the edge of town in preference. I don’t know why that’s their preference, but it pretty clearly is.

          It’s going to require a great deal of fortitude from the council to refuse this special pleading – and they’ve already given ground on that front (the 60-40 infill-sprawl split instead of the 70-30 originally proposed), even with Len Brown in charge (the most PT-friendly option available). Things _are_ improving and removal of MPRs is an important part of that (a sine qua non even), but it’s no magic bullet.

        2. Yep, we’ll you have a number of developers whose business model is based on stand-alone homes and sections – they have neither the will nor the expertise to produce high density development and so keep pushing for more greenfield land.

          And I get sick of people who obsess about land value as the sole measurement of development potential/hinderance. Land development in recent decades has had it’s infrastructure heavily subsidised by the general taxpayer – if the true cost was factored in, then a number of suggested greenfield areas would be too expensive for the market to deliver. It would be even worse if you could put an economic cost on environmental damage caused by these new green fields (even when best practice is implemented).

          The greenfield areas around Auckland all feature significant costs and problems if they were to be developed (and thats one of the reasons they have not developed in the past), so Auckland has to intensify in order to deliver both the housing numbers needed and reduce costs in housing delivery.

  8. Patrick Reynolds:

    I agree with getting rid of the minimums, and replacing them with a market model of charging. I came up with the idea of a “cellphone gate” system, whereby toll gates might only cost about $50 each to install, so you can use them as efficient parking meters as well as for toll roads. I have argued for this extensively (on FrogBlog) if anyone is interested:

    http://blog.greens.org.nz/2012/08/28/what-greece%E2%80%99s-motorways-mean-for-nz/

    However, releasing land via converted car parks will not lead to a reduction in land costs in itself, because Auckland council will just use it as an excuse to restrict greenfield development even further.

    1. Why bother with toll gates? They’re expensive and ugly. Why not just use HOP cards, and for those who don’t mind ,a GPS?

      1. Wait for a sudden switch to untaxed allowances for transport. It’ll happen. It’s better than provision of parking spaces, since they can also be spent on transport passes, but it will deprive the government of tax income that I’m sure is being budgeted.

        I hope that the Greens give Labour a bit of a slap for their reaction to this. Labour are supposed to be favouring moves that reduce our reliance on cars and roads, and this move is good from that perspective even if it is coming under the auspices of Revenue not Transport.

        1. Yes disappointed by Labour’s response. Those guys are douche-bags: They just don’t know how to maintain a facade of credibility long enough for you to blink.

        1. Well there’s a rumour going round that BECA charge their staff to park a bike in the vast underground car park of their new building [the old and unloved, but solid, ARC building with such fine views over the CMJ]

        2. I must admit to idly wondering earlier today if the logical endpoint of this is paying to use any communal land – toll charges on pavements, entry fees for parks, anyone? At what point do we consider our right to use land paid for out of rates or taxes? I think it’s reasonably clear that occupying 15 or 20 sq metres of land with your car for a couple of hours has a commodity value, but how do we decide the cut-off point at which ‘treading lightly’ (as it were) comes for free?!

        3. That’s not something to get too worried about IMO.

          Putting principles to one side, the transaction costs associated with charging for very small increments of space simply overwhelm any potential efficiency benefits you would get from doing so.

  9. Oh yeah… the 1 space per 4.5 sq m for places of assembly is plain bizarre. Did someone accidentally add a decimal point?! Our house would require parking for 29 under that rule. That’s what? 600 sq meters of parking? Probably more if you were going to actually be able to use the spaces!

    1. Is your house a church? Are even the storage cupboards used for reading sessions? Does your kitchen often serve as an auditorium? “Places of assembly” refers to a totally different use… 😉

      1. No, I was just doing the maths to get an idea, that’s all. It seems like a lot of parking for a not very big building.

  10. I don’t think we can expect removing minimums to result in a massive decrease in parking overnight. But that’s surely not the point. Removing them will at least mean Council’s regulations don’t make things worse.

    I think there’s a good analogy with the saying “do no harm”. Minimums are clearly a regulation that does more harm than good.

    1. If I remember rightly there was even an old Environment Court case that dealt with a site in Ponsonby. It basically smacked down Auckland City’s demands for each business to have x parking in a centre – essentially requiring the whole fabric of a town centre to be fundamentally altered or destroyed by providing huge amounts of car parking. But then the district plan remained relatively unchanged.

      I found in my experience that very few businesses in built up areas could ever meet these requirements, tying up consent departments with parking shortfall resource consents and requiring businesses to get parking leases that were poorly monitored.

      However, it was seemingly a hot topic for local politicians in the old Auckland City, given that shortfalls of more than 6 spaces had to be referred to committee for determination.

  11. David,

    The fact that we have to pay ~$200,000 for land on the urban fringe (or whatever it is exactly now, on average) is to me a violation of human rights. If anything should be a birth right it’s land under your feet to live on.

    1. Hang on, just above you are saying how we should be charging for parking as you obviously recognise that having lots of free parking creates market distortions yet now you are saying that we should give everyone free (or very cheap) land. How much land do you think I have a right to have, what if I wanted more or less. The land is currently owned by somebody so are you suggesting that they be forced to sell it cheaply ignoring their existing property rights. You suggestion all sounds very communist.

    2. You can get sections for under a hundred grand in the Auckland region, and for as little as ten grand elsewhere in the country.
      Or by land do you mean ‘prepared subdivision site with roading, services and infrastructure conveniently located to the motorway’?

    3. How is land a birth right??? Apart from the fact that we’re in a capitalist society (you don’t own it, then you don’t own it), the fact is that growth of population is occurring, but Auckland’s geographical size isn’t.

      So unless you support gobbling up more and more nature (until a few scraggly city parks are all you have to enjoy nature in) then constantly using up more land is NOT a human right (or even possibility) at all.

  12. How about we just take the word minimum and replace it with the word maximum. Seems an elegant way to amend the lawbooks, as the minimums are intended to require enough parking for maximum usage anyway.

      1. Ah … the old “moral high-groud versus sordid ethical squalor” debate.

        I’m with Swan on this one: Stick to the high-ground. That tends to matter more than you would think if this were to get to the Environment Court.

    1. Tried doing exactly that (replacing the Waitakere minimums as the new maximums) on a plan change out west. Council’s consultant looked at it, and rubbished it for the key components (retail, offices). And that was with the developer agreeing with replacing the minimums and maximums! And this happened a year ago, not “back in the old days”.

  13. The strange thing about minimums is that the only places where they make a difference will be the very places where they do the most damage in terms of reducing development potential and subsidising the car unnecessarily in areas with good transport alternatives. In other places, where the minimums won’t actually make a difference (as the market wants to provide that much parking anyway) it’s hard to see why minimums are necessary as they’re not changing anything.

    So we find ourselves in the interesting position of minimums either making a difference, but that difference largely being negative. Or on the other hand, minimums not making a difference and therefore being completely unnecessary.

    I don’t agree that minimums should be turned into maximums. Maximums are imposed for a particular reason (discouraging car trips to that location because of road capacity constraints) that really only apply in some locations. In most of the city, just leave it to the market.

    1. Bang on Peter M: Minimums are either extremely damaging or they’re irrelevant.

      Not to mention that even if you were really, really worried about spillover parking demands there’s far better ways to manage it – like pricing.

  14. Mathew,
    I’m all for market rates. The MUL’s create a distortion in market rates. Urban fringe land should be its “natural” rural value.

    However, in any circumstance, land to live on should indeed be a natural inheritance; like natural resources alround, in principle. No man created the earth which is ultimately every man’s natural inheritance. My view is that in a context of scarcity property rights should not work so that one lucky person inherits a farm, yet another only a shoe box. That is just wrong.
    With plenty of land about no-one should have to go into deep debt for it. Laws and regulations should ultimately work to respect this.

    1. Not quite sure how that relates to the topic of this discussion Andrew. I’m assuming that you would support the removal of minimum parking requirements as they drive up the cost of development and therefore are a factor in poor housing affordability? Plus they’re an unnecessary regulation.

  15. It would be great to see some mega-malls convert some of their parking areas to high-rise apartments. The land is professionally managed, and it’s unlikely NIMBY’s would object to a car park “desert” being converted to a high-rise. There should be good demand for such units because it’s walking distance from shops and good PT. For example, in Melbourne recently a 5-storey apartment block near the South Morang shopping centre was 50% committed by off-the-plan sales within a few weeks of going on sale. It was advertised as 200 m from a regional shipping centre, and 600 m from a train station.

    1. Actually, their parking rate for visitors (mourners) is pretty low. But NO staff member at a funeral parlour EVER arrives by anything other than a car, as you can see.

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