The announcement of the Commercial Bay development last week got me thinking about minimum parking requirements.

MPRs were removed from the city centre back in the late 1990s. Prior to that point,all new developments were required to provide parking at roughly the same rate as suburban developments. After that point, individual developers, businesses, and residents got to choice how much parking they wanted.

I’ve always thought that this was a strong factor in the downtown revival we’ve seen since then. If they hadn’t been removed, money that has gone into developing housing and space for businesses would have been diverted into unproductive parking spaces instead.

City Centre Population - 1996-2015 2

Precinct’s new 39-storey tower on the waterfront shows what a difference MPRs make to development. Commercial Bay will ultimately have 39,000 m2 of commercial office space, 18,000 m2 of retail space, and 278 carparks. It’s going to be a big, bold addition to the waterfront. But it simply wouldn’t be possible if MPRs were still in place.

Tower 1

To get a sense of the difference that MPRs would make, I went back to the Auckland isthmus district plan, which will soon be replaced by the Unitary Plan. For developments outside the city centre, it required:

  • one carpark for every 40m2 of office space, and
  • one carpark for every 17m2 of retail space.

In other words, if those MPRs still applied to the city centre, Commercial Bay would have required over 2000 carparks. That’s seven times as much parking as the developers actually want to build. Effectively, it would mean constructing the equivalent of AT’s Downtown Car Park at the bottom of the tower. Say goodbye to ground-floor retail. Say goodbye to laneways through the building. Say hello to bad air quality and inhospitable accessways cutting up the footpath.

Furthermore, MPRs would have dire financial implications for the project. According to Precinct, Commercial Bay will cost $681 million to build. If MPRs required the development to include another 1750 carparks, at a cost of $30-50,000 apiece, it would add $50-90 million to the cost of the project. That suggests that MPRs would impose a “regulatory tax” of  7-13% on downtown development.

But would all those extra carparks have any value? In a word, no. The fact that Precinct chose not to build them suggests that they don’t see the value in providing parking spaces rather than office or retail space. And, as a corollary, it’s likely that their tenants and customers don’t see the value in having seven times as much parking, either.

It’s not as though there are any pressing social requirements for another 1750 carparks, either. Three six-car electric trains can deliver the same number of people to the city centre. At present, Britomart can do that every ten minutes at peak times. After the City Rail Link is constructed, it will be possible to double rail frequencies through the city centre. And our public transport system can do all of this without adding to road congestion – which you can’t say about people driving into the city centre.

AT Rail Capacity Image

The high costs of minimum parking requirements aren’t limited to the city centre. Down in Christchurch, for example, a neighbourhood bar and restaurant is having to shut up shop due to MPRs:

Two Christchurch business owners are “disgusted” by the city council’s ruling they need to create 62 extra car parks to continue operating as is, saying they will likely close their bar.

Dwayne and Tiffany Vaughan, who run Kaizuka Eatery and Garden Bar in Cashmere, have been engaged in a year-long stoush with the Christchurch City Council over its licensing arrangements.

The council said the owners changed the scale of the business operating under the on-licence. The cafe was initially a small part of a garden centre but had grown to take over the premises.

The owners needed an on-licence variation that would in turn trigger resource management and building consent requirements.

According to the City Plan, 10 carpark spaces were required per 100 square metres of public floor area, but reductions could apply. The 800sqm bar had 18 car parks, meaning it would need another 62 to meet the requirements.

Setting aside the complete insanity of even having MPRs for bars – why on earth would we want to encourage people to drive to the pub? – this requirement imposes large costs for parking spaces that don’t seem to be necessary for the business. (After all, it’s been operating since March 2014 with the current number of parking spaces.)

It would probably cost over $1 million for the bar’s owners to comply with MPRs, assuming that they would have to spend around $20,000 to buy land and build carparks. The benefits of this policy are vaguely defined and potentially negative, if abundant parking encourages more people to drive and drink.

All of which begs the question: Why do we still have this costly and useless policy?

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  1. A great post Peter.

    Posts like this need to be repeated frequently. Furthermore, I would like to see it repeated in other local media so that those people who neither think or care are exposed to some of the realities of what makes certain cities desirable places in which to live………….because we don’t really need ever- widened motorways. They are just plain crass.

    1. yes, space intensive car-based transport systems are rather incompatible with moderately dense urban environments. As Peter notes, the costs of meeting these requirements makes many developments nonviable. Usually such costs are “hidden”, because the developments themselves simply don’t occur – so people don’t know what they’re missing out on.

      The Christchurch example highlights what happens when the costs of MPRs are actually made transparent: Otherwise successful businesses are unable to establish. The result? Fewer businesses, reduced competition (higher prices), less employment, reduced density. Basically: Less urban “happy”.

      One can’t help but feel that future generations will look back on MPRs and ask “WTF”?!? Especially when they see recordings of John Key in Paris talking about removing subsidies for fossil fuels so as to mitigate runaway global warming. C’est la vie!

      1. Excellent article from Peter. Its really interesting to see the shift in thinking from about downtowns 20 years ago compared with thinking about suburban centers today. It seems obvious that more people and fewer cars in the CBD makes sense, therefore we have MPRs to match. Today its still very difficult to get the broader public onside in applying this logic to the suburbs. The cultural attitude of “suburbs are for cars” still prevails, and many businesses strongly believe that without abundant parking, they will fail. I think only very recently is the tide of public opinion beginning to turn on this issue.

        As you point out, the Christchurch example perfectly illustrates the ridiculousness of MPRs and helps to the cause for fresh thinking in the suburbs. (For the record the CCC proposed to remove all MPRs in suburbs and was overturned by the hearings panel for the District Plan Review).

        1. Yes excellent article from Peter, as always. And yes public opinion is changing, so I’m confident we’ll see the back of these regulations well within our life-times. Probably in the next 10-20 years if I was to hazard a guess. The only question is how much damage they do before then?

          Unfortunately all the evidence suggests that MPRs are really, really damaging to all sorts of socio-economic outcomes, so time is somewhat of the essence, at least if we want NZ to prosper.

        2. What evidence is there that MPRs are damaging to socio-economic outcomes? Nothing pops up on Google Scholar

        3. Here’s what comes up for me:

          There’s also several books which summarise the evidence, e.g.:
          The high cost of free parking, by Donald Shoup (many citations to published research); and
          Parking management best practice, by Todd Litman

          And in the NZ context you can find a number of reports, conference papers, presentations etc which discuss the same issues. So, all the evidence which does exist suggests MPRs have negative impacts, while there appears to be no evidence demonstrating they have positive effects.

          Some which I have been involved can be found here:

          Perhaps your keyboard is mistakenly set to 18th century Prussian?

        4. Touche, but even then (from skimming the sources, admittedly) I don’t think “really, really damaging” is at all accurate. Something like smoking is “really, really damaging.” Ebola as well. Terrorism would be up there. MPRs? What we have here is a small effect on a small number of economic (not socio-economic) indicators.

          PS I think MPRs are ridiculous because I think there are much better mechanisms such as immediate towing for vehicles using someone else’s parking space. But I don’t think they are “really, really damaging.”

        5. @Early Commuter, 1:19 –

          Really, really?

          I’m hearing you say that there’s nothing to be concerned about unless it’s “damaging” on the scale of people dying…?

          Oh wait. We do make transport decisions on that basis far too often.

        6. The diseases of inactivity kill tens of thousands every year. MPRS reduce activity through dispersion. They also increase travel and housing costs dropping thousands of people into poverty.

        7. No, really really damaging seems accurate for a variety of reasons.
          – Economic: Adding ~10% to the cost of housing (and development more generally) will have a massive negative impact on development. Housing is the single largest component of household budgets, so increasing that costs really does have an income effect.
          – Environmental: MPRs reduce density, increase impermeable surfaces, and contribute to higher emissions from increased driving
          – Health and well-being: as others have noted, MPRs increase driving and reduce physical activity,

          I’ve never done a comparison myself (and I don’t think the issues are that comparable) but my economic intuition is that the annual costs of MPRs exceeds the costs of terrorism and ebola to NZ, by a factor of about 10.

        8. Thanks Nick, glad you enjoyed the post!

          In a suburban context, I think the important argument is less about *viability* of developments, and more about *choice* and *competition*. In the absence of MPRs, people are quite welcome to apply the same parking ratios as before – but they’re also welcome to test out a different model.

          A bunch of the suburban shops and restaurants I use almost certainly don’t satisfy the MPRs as they were built before they were written. I’d hate to think that they would be forced out of business if somebody complained.

  2. 90% of planning regulations are unnecessary. Not only do they cause land owners and developers a lot of extra cost, they are also too slow to evolve with the changing dynamics of a city and its residents.
    What makes planners think they know better than the property owner? Let people do what they want with their land (within reason).

    It seems really stupid to have a ‘free market’ government and a ‘do what we tell you’ council. Surprisingly the right wing councillors are even more against a free market than the left!

    1. “It seems really stupid to have a ‘free market’ government and a ‘do what we tell you’ council. Surprisingly the right wing councillors are even more against a free market than the left!”

      We don’t really have a free market government. They are a status quo government that believes in protecting existing privilege (in so far as they believe in anything at all). This government supports many forms of corporate welfare and restrictive regulations that keep the existing order in place.

      And the “right wing” councillors aren’t right wing in any free market sense. They’re right wing in the original sense of being conservatives that support existing forms of privilege and authority.

      A more meaningful divide in local government is between those who support progress and change, and those who support the status quo. Many nominally “left wing” councillors are in the status quo camp (Mike Lee, Cathy Casey, Wayne Walker) which is why they frequently vote the same as Quax, Brewer, and Wood.

      1. Exactly Frank. Left/Right politics is not the only way to characterise our political divisions. I think progressives versus conservatives is a more relevant description of the current state of politics in NZ, especially on the issues we discuss here -transport, housing affordability, urbanism, agglomeration economics etc.

        1. Completely agree. But there does seem to be more progressives on the left wing than the right for national politics (not necessarily for council).
          Why isn’t there a progressive party? Maybe Labour needs to reshape itself that way.

        2. Yes I agree – the lack of a smart centre party has IMO bedevilled NZ politics for a long time. I believe UF had the dream of occupying this ground …

          Although some might argue that National and Labout are already centrist enough?

          But as you note that seems to leave both National and Labour cover too many bases, e.g. economic liberals, social conservatives, rural interests, workers, urban liberals etc.

  3. Re the good Publicans of ChCh, they can of course apply for a resource consent to operate their ‘new’ business outside of the limits set by the District Plan rules.

    The issue for them is that when they apply for a Liquor Licence one of the prerequisites for the Licencing Authourity to grant it is that they must have certification from the Local Authority that the premises comply with both the Building Code and the relevant District Plan. No bad thing.

    I can only presume (given the context in the article) the CCC is legally unable to issue either a Certificate of Compliance or an Existing Use Rights declaration under the RMA (certifying the activity is a Permitted activity or is deemed to have existing use rights respectively, as, according to the current plan rules they need more carparks (and no doubt other things) and does not have existing use rights as its not existing its new via a change of use from a garden centre.

    Your key issue is that they shouldn’t have to comply with a rule necessitating more carparks of course, but i suspect that the article doesn’t give the whole story. (Surprise!)

    1. Why are the plans so strictly adhered to? Why aren’t they more a set of guidelines that the council can overrule whenever they feel fit?
      For example, I’m about to extend our house and we have slight height to boundary issues. Any moron can see that the issue isn’t going to effect the neighbour (the house will still be lower than the fence!), and the Unitary plan which is about to be passed will almost certainly allow for our development (and a lot higher). So why can’t the council just make a common sense exception rather than us having to apply for RMA?

      1. Because that is not the law. The RMA works through a graduated process – if you comply then no issue, if you kinda comply then a small resource consent, if you don’t really comply then a big resource consent, if you are doing something unheard of then a massive resource consent, and if you do something banned then you need to change the plan (7ish years of listening to Dave Dobyn singing about waiting…). You are in the ‘kinda comply’ category by the sounds of it.

        The plans are the plans. You can’t give discretion to ignore the rules. Doing so creates too many opportunities for dodgy behaviour. Frustrating? Yes. Good for the rule of law? Hell yes.

        1. Unfortunately the RMA doesn’t seem to “work” when it comes to urban areas. There’s a myriad of reasons why, e.g. political economy, professional incentives, poorly-designed consultation, dispersed benefits/concentrated costs etc.

          Personally, given all of those inter-locking issues I think it’s time we ditched most of the trappings of our current planning system in Auckland and went back to public policy first principles: 1) What are we trying to achieve and 2) what is the best way to achieve it?

          An intermediary step could be a series of NPS which effectively meant “RMA? Yeah-nah in urban areas”. More specifically, these NPS could be designed to ensure that only those activities which had demonstrable negative impacts on health and well-being, e.g. noise and emissions to noise/water/air, should be precluded from being able to happen as of right. This would mainly apply to industrial activities, rather than residential. Of course, if a particular development has implications for infrastructure then those costs should be worked through with the applicant. And if the constraints are really binding then maybe they do get turned down …

          Otherwise “live and let live” should apply in cities IMO. Mind you then we’d have a chronic over-supply of planners … poor poppets.

        2. However from a more philosophical point of view I could easily point out a million potential negative effects from potential developments. No man is an island and all that.

          My trudging to the bus stop at 5:27am in the morning, for example, probably creates noise and so forth. It’s very hard to imagine how any development of any sort doesn’t create negative effects (it may create a larger number of positive effects, of course). Houses block light, adjust wind patterns etc (think of that hotel in Las Vegas that created a death-ray solar reflection).

          If the rule was “first, do no harm” then nothing could ever be built.

        3. no, I apply the “first do no harm” rule to the regulator.

          That is, people should be able to engage in their daily activities largely unfettered unless the regulator can demonstrate that allowing them to do so would be harmful to society as a whole.

          In the case of your walk to the bus stop, I agree: Every action could be construed to have negative external impacts. Whether or not this warrants regulatory intervention or not is the key question. And my answer to that question is that we shouldn’t intervene with regulation unless we have clear evidence that doing so will make society better off in a net sense (costs and benefits, however measured).

      2. Well, thats exactly what they are. To go beyond what the rules allow as a permitted activity, requires a resource consent. Most councils process hundreds or thousands of them a year.
        The RMA is based on a presumption of process delivers good results (people having a say in what effects them will lead to better environmental outcomes). As setting the rules is a public process, there must be a ‘public process’ for dealing with exceptions. This is the consent application process which is laid out by law (i.e. the council may not flout the law just because Mr Jones thinks it would save him some paperwork, even if he pays his rates dont you know).
        The vast majority of consent applications are processed without public notification, (arguably) suggesting that most councils do take a ‘common sense’ approach to them.

        1. But they charge you $2500 as well as filling out a whole lot of paper work to apply that common sense.

        2. $2500 deposit. I got a bill of another $900 at the end of my application for a minor house extension. I’m in a heritage area, but I’m also the third house down a long driveway and the house was built in the 70’s. Took them about 20 chargeable hours to work out that would be ok. Then to add insult injury someone turned up announced today to check “compliance”. Given we’ve only just poured the foundations I’m not sure what he thought he was going to see. Apparently he took special interest in a pile of dirt. And this is for a limited discretionary consent.

      3. That’s what the resource consent is for, to allow the appropriate person to determine that there will be no negative effects. That is the process by which common sense exceptions are made. If you’ve already got the plans for building consent, resource consent won’t cost much more for a single issue like that. Why don’t you just change your plans to comply? Then you won’t need a resource consent.

        1. Yes we have changed our plans to a much less optimal layout to avoid it.
          But it is quite obvious that the only people affected would be my neighbours – shouldn’t I just be able to include a signed letter from them that they don’t care with my consent application? Why charge me $2500? And what’s it got to do with the environment?
          Why are councils allowed to apply ridiculously low height to boundary rules and then charge everyone $2500 to build anything semi reasonable?
          Our existing house built in the 50’s when they did use common sense would now be about 100% over the current height to boundary limits.

        2. Your supposition requires that sense is common. Anyway, Im not disagreeing with you just explaining why things are the way they are.

          Im sure based on this experience Im sure you will take a much more active interest in the public process used to set the limitations on residential development so that the net welfare of building extenders is not negatively impacted by faceless bureaucrats applying the law as its written without fear or favour.

          You may also be interested that the Governments current proposals for amendments to the RMA involve reducing compliance costs by reducing the need for pesky consultation and discussions.
          One of these proposals is that where all affected parties approvals is obtained that the consent is effectively a rubber stamp for situations of the type you describe.

          However, the PAUP rules may also be overridden by set of national ones which may not necessarily be a generous as are proposed. (tho i would imagine the NES would say “or which ever are the least restrictive”)

    2. Setting aside the messy interactions between multiple regulatory processes, there’s an enormous elephant in the room: Why would any sane regulator want bars to make it easier for people to drive drunk?

    3. You are correct in that the article doesn’t quite cover the whole story. It’s my local pub, and as I see it:
      1. It’s been functioning just fine for the 15 months I’ve lived around the corner without any minimum parking requirements. Why change now?
      2. Because, allegedly, a local council planning officer couldn’t get a park outside one Sunday evening.
      3. Not -at all – due to the other pub a few doors down.
      4. Or due to the fact that this is a cyckist’s pub! They finish a day at the national downhill tracks at bowenvale valley nearby; of road biking over the summit road!
      5. And in any event, the council has now downgraded the requirements to 39 parks( I think they have 18)
      6. I’m calling the various place makers comments elsewhere as well – the premises were – until 18 months ago- a garden shop, with 18 car parks. Doesn’t seem to have held it back for the past 30 odd years.

      MPRs strangle development. Even living in the CarParkCity, they make for a rubbish urban outcome.

  4. Personally I think minimum parking restrictions are ridiculous.

    If a business owner wants to run a business with no carparks then good luck to them. Likewise if a business owner wants to build 10,000 carparks then good luck to them as well.

    Space has a value and ultimately the most economic use of that space will prevail in a free market as a buyer who can make more economic return on said space will be able to justify a higher price.

    The less bureaucracy involved the better the outcome.

    1. Good point Matthew. However what often ends up happening is that customers will park on one property and shop next door if there aren’t enough carparks. Also the disabled need to have them for access (albeit the current ratios are far too high as there are always plenty of spare disabled parks).
      Some places do need minimum requirements but these could be reduced. Others don’t need them.

      1. First issue: Identifying that an activity (e.g. development) may have a negative impact (e.g. spillover parking) is necessary but not sufficient to justify regulatory intervention to address that impact.

        Second issue: The effects you have identified are relatively small compared to the costs of MPRs. Moreover, the costs of MPRs are higher than other potential responses, e.g. parking management.

        Conclusion There is no evidence to support your suggestion that “some places do need minimum parking requirements”. And when I say *none* I actually mean it – I’ve looked quite hard and couldn’t find any (NB: If you know of any please let me know!). I think this is extraordinary: In the time that minimums have existed, no one has published research which suggests their benefits exceed their costs …

        1. So people buying 20kg bags of concrete from Placemakers should just walk?
          Just sling a rug or chest of drawers over your shoulders?
          Just walk around with a tv?

          No of course not! The key is to balance the need for parking without encouraging people who don’t need parking to drive rather than walking/cycling/bus/train etc. Perhaps some form of validated parking might be of use in more places… discourages people who are just killing time etc from driving and leaving the carparks for people who are actually buying stuff.

          This is of course referring to the suburban context. I don’t think anyone is suggesting we need to have large minimum parking requirements in the city.

        2. How about this idea Bruce…
          – Companies build however many carparks they need
          – If someone uses company X’s carpark to shop at company Y (which hasn’t built any carparks)
          – Then company X can seize the vehicle or crush it or tow it or charge the owners with trespass

          Plenty of potential regulatory options 🙂

        3. Bruce,

          Did you know Placemakers not only has carparks, it also has (at least at the one I go to) a place you can drive through to load up your vehicle – and they even have free trailers you can use to take home your scoria. I can only assume the council has minimum trailer requirements, but haven’t been able to find any reference to them online*. But there must be right, or else I would have been shovelling the scoria into the backseat of my car? (“mind your hands, my daughter, I’ll just pile it up around your legs!”)

          *I lied. I didn’t even look.

        4. Its horrible, there is no regulation to force Kmart to build enough sales registers so they only built enough to serve their customers

        5. Early Commuter: Existing legislation allows you to impound/tow vehicles parked on your land, provided that you put up a sign which clearly states the conditions under which people can/can’t park. So really we have all the legislative tools we need. And we also have the technology now to manage parking facilities very efficiently.

  5. “carparks, at a cost of $30-50,000 apiece”

    How do you arrive at this figure? I know they sell for more than this, but I doubt it costs that much to build.

    FWIW I don’t mind if there are MPR’s or not, since the market will construct a carparking building elsewhere if there is demand. I’ve observed that some unleased commercial buildings on Hobson St have been converted into carpark floors.

    1. I don’t know about $50k, but $30k seems about right for the typical cost per parking space in a multi-storey structure. Structural floors don’t come cheap and you also have to factor in the space needed for the accessways, ramps, etc.

    2. 2000 carparks underneath the Downtown development would almost certainly cost a good deal more than 50k each. Can you imagine the excavation, containment and waterproofing costs of that? Alternatively they could wipe out the lease income of many floors of the tower in order to put in floor after floor of parking spaces and ramps…. to then still have the same GFA for lease afterwards the tower would have to be what 50, 60, 70 stories high? What would that cost? 50k is usually quoted for underground urban parking. I can’t see how these could be that cheap.

      The cost burden on the city of the driving such parking would then induce would also be high; but that would be borne by us, not the developer.

    3. Maybe one solution is to ensure all new buildings have no carparks at all, and instead leave that for standalone dedicated carparking buildings. That would ensure people needing carparks pay the true cost for that structure (including running costs, etc), without being subsidised by commercial tenancies.

    4. $30-50k was a bit of a back of the envelope estimate. But John took a look at this previously and came to a pretty comparable range.

      In the US, underground carparks cost an average of US$34,000, and aboveground spaces cost an average of US$24,000. Factoring in exchange rates (1.48 NZD/USD today) and the fact that construction is generally more expensive in NZ, you get something similar.

  6. OK so to paraphrase your argument Peter- “It would be absurd to require parking for a CBD tower block at the suburban rates, therefore it would be absurd to require parking for suburban development at the suburban rates.” I wonder if perhaps you missed the point somewhere?

    1. This isn’t how I read the post at all. Seems to me that Peter is questioning why MPR’s exist in any form, considering the costs that they burden developers with. What sense does it make for the council to tell a business or homeowner how many carparks they need? Let them make the decision for themselves in the market .

      Even in a suburban setting, MPRs still take choice away from landowners. If developers choose not to provide parking (in order to cut their costs), then the market will either vindicate or rebuff that decision. Removing MPRs allows landowners to provide what parking is needed, rather than what is mandated. Peter uses an example of a suburban business losing its’ viability due to nonsensical MPRs as an example of this.

      1. Yes I am sure all of the $2 shops that have been priced out of traditional centres will be looking forward to their chance to flourish. As for Peter’s argument he has applied parking rates that I don’t think have ever been used in the CBD (at least not in my memory) and applied them to a tower building in a way they were never used to prove they were not appropriate there.

        1. You are only arguing a question of scale – “how bad is it really?” The thing about regulation is it is actually supposed to mitigate a harm or externality and provide benefits that outweigh the costs of the regulation. Just because it might not be quite as bad as Peter makes out does not take anything away from his argument that MPRs are absurd and costly.

        2. I am interested in any argument he puts forward. But arguing against MPRs using them in a way they are not used is like arguing concrete is a bad just because you cant make life jackets out of it.

        3. I think you’re missing the point:
          – MPRs have REALLY REALLY negative impacts in medium to high density urban environments; and
          – MPRs have REALLY negative impacts in low to medium density urban environments.

          No more, no less!

        4. Good point Stu. But I dont remember a time we have applied them to the inner CBD. We have had maximums since at least 1987. And while they create costs in the lower density areas they also have a benefit. The areas actually work. If you only looked at negatives you would throw out side yards, stormwater rules, view shafts, heritage buildings, tree protection, activity status, urban design rules and all the rest of town planning. They all result in costs but we do them because they also have benefits.

    2. If you read all the way down to the end of the post, you’ll see that I also provided an example where MPRs applied in a suburban context made it impossible to operate a business.

      One important point I’d make is that even if there is a case for MPRs *in principle*, it would be extremely difficult or even impossible to justify any *particular* parking ratio. That’s because there is significant variation in vehicular trip generation rates for comparable facilities.

      Meanwhile, parking ratios tend to be set at the upper end of the distribution of measured demand for free parking – which means that they will *inevitably* have significant costs for a large number of businesses. This is a well-documented statistical fact – go take a look at chapter 2 of Donald Shoup’s book on the subject.

      1. I accept they are almost always overcooked by over-eager Council staff. But I would rather the right thing was done badly than the wrong thing done well. The inconsistency I cant get my head around on these pages is the argument that residential developers should mitigate their effects by building every road imaginable and the cost of that is ok but retail developers shouldn’t be expected to build parking to meet the demand they create in the small centres as the cost of that is a tax that damages business. Does St Donald The Cyclist comment on that?

  7. The great thing about minimum parking rates is they are completely made up. 1 car park per 18 sq m retail space? Says who?

    A clothes store might squeeze many people in. Yet a lawn mower store might be larger but with few customers. That’s what I dislike about these numbers, they’re completely arbitrary as to the true needs of the tenant.

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