G.B. Arrington - Comments

The question of whether FTA requires 1 for 1 replacement parking when a joint development project uses a park-n-ride as a development parcel has caused much confusion in the industry. FTA is to be applauded in seeking to provide more clarity and making it clear that 1 for 1 replacement is not required. Part of what the industry is looking for is the ability to leverage the value of transit to reshape land use. As systems mature that means it may be appropriate and necessary to eliminate transit parking in a situation where the ridership forecasts used to justify the original transit investment have been exceeded and the elimination of parking would not result in lower net ridership than the forecasts used to justify the investment. Eliminating parking allows systems to mature and change their mode of access over time as transits mode share increases in part from reshaping land use in a transit-supportive manner. The Rosslyn Ballston Corridor is an example of this evolution. Unfortunately in addressing replacement parking FTA staff seems to have taken a narrower view that locks in historic the automobile dependence of many systems and does not recognize the transformative power of transit + supportive public policy to reshape land use. The narrow standard of measuring if the Joint Development project produces more ridership than the displaced parking unfortunately locks in the auto-dependence many systems are seek to overcome. The costs of structured replacement parking is a major financial deterrent to the viability of joint development projects and an unnecessary transfer of resources to subsidize automobile access to transit at the expense of investing in more resilient outcomes. If the original ridership forecasts have been exceeded even with the elimination of a park-n-ride FTA should be unambiguous – no replacement parking is required.