An Assessment of the Expected Impacts of City-Level Parking Cash-Out and Commuter Benefits Ordinances
Appendix A. Implementation Resources
While there is some guidance related to parking cash-out implementation strategies, much of that guidance is limited to providing advice for programs run by individual employers and not to municipalities attempting to implement broader policies. A major implementation hurdle at the municipal level, however, may be employer buy-in and compliance resistance. Being able to convey implementation strategies and benefits for employers is thus valuable for policy makers considering city-level ordinances.
One of the most comprehensive guidance documents available, the Federal Transit Administration’s (FTA’s) published “TDM Status Report: Parking Cash Out” (1994) notes a diverse array of considerations related to implementation applicability, policy development, program exemptions, enforcement, costs, and benefits. Some highlights include:
- The potential for parking cash-out alone to achieve significant impacts is dependent, in part, on the degree of employer-subsidized parking in an area. That is, where there is more subsidized parking, a larger proportion of employees would be eligible for parking cash-out (and subsequently take the cash). As explored with some scenarios in this FHWA study report, parking cash-out for employees with parking subsidies may be combined with other commuter benefits policies (i.e., pre-tax transit benefits) for employees without parking subsidies, increasing potential effectiveness.
- The structure of leased parking in an area is also key to consider. Parking costs may be lumped into employers’ building leases (which may be non-negotiable), or parking may be leased separately. In the latter case, employers often could offload spaces that commuters choose to stop using to cover costs associated with providing parking cash-out.
- With an ordinance, employer impacts may vary based on their existing benefits’ offerings, employer sizes, or parking lease versus ownership status. Note these topics are touched on in the discussion of results in this FHWA study report.
- Localities may wish to re-evaluate parking requirements for new commercial developments, given cash-out is expected to reduce parking demand.
- Monitoring and enforcement are critical in the implementation process. In the most limited form, this may involve posted notice of the policy, retained records of participating employees, and periodic checks for compliance. A more proactive approach might involve annual reporting requirements to be reviewed by the regulating jurisdiction.
A more recent report published by the U.S. EPA, “Parking Cash-Out: Implementing Commuter Benefits as One of the Nation’s Best Workplaces for CommutersSM” (2005) provides some additional information on parking cash-out and implementation:
- Complexities associated with implementing parking cash-out are usually experienced one-time only at a program’s onset, with employers modifying payroll systems to account for some employees taking additional taxable cash.
- A general step-wise framework for implementation is provided, geared toward employers, and its steps include: 1) analyze current parking conditions and policies, 2) determine how to structure a commuter benefits program, 3) obtain senior management approval, 4) work with payroll to set up appropriate payroll codes, 5) develop a process for employees to elect their commuter benefit, and 6) publicize and implement the parking cash-out program. Additional guidance on each step is provided. Municipalities considering an ordinance could provide context-sensitive modifications to this guidance to help employers with compliance.
FHWA’s “Non-Toll Pricing: A Primer” (2009) covers some additional implementation considerations, including how incentives may play a role in supporting employer buy-in and compliance with parking cash-out programs.