More than three dozen Congressional Democrats, led by Oregon Sen. Ron Wyden, are hoping to help revive a landmark lawsuit against the U.S. government by 21 young Americans – including 11 Oregonians – over continued federal support for fossil fuel production and a failure to urgently mitigate the worst effects of climate change, violating the plaintiffs’ right to a livable environment.

The case, Juliana v. United States, was first filed in the U.S. District Court in Eugene nearly 10 years ago. At the time, the youth behind the suit were between eight- and 18-years old. It has not gone to trial following pressure from three presidential administrations, which asked the court multiple times to have the case dismissed.

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Charlotte Shuff and Jennifer Hill-Hart, June 20, 2024,  CUB Energy Policy Conference

Last year, regulators found that Pacific Power did not have a plan to meet emission reduction requirements. Now, the utility has doubled down on its faulty plan. This time, it has moved further away from meeting clean energy goals cemented in Oregon law.

As we review the updated Clean Energy Plan for Oregon’s second-largest electric utility, CUB and other advocates are pushing for improvements. Recently, CUB joined the Sierra Club, Green Energy Institute, and other advocacy groups calling for regulators to take strong action against Pacific Power.

CUB would like to extend a huge thank you to Sierra Club’s Staff Attorney, Rose Monahan, for leading the charge in addressing Pacific Power’s faulty plan. Her analysis of the updated Clean Energy Plan has brought to light deep issues of reaching clean energy targets. She also brought in many community organizations to this advocacy work. Thank you for your hard work, Rose!

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Rewiring America has established a webpage that provided tips on federal incentives and rebates to help folks electrify their homes.   Information is available for state rebates and incentives when that is available. Currently, Oregon’s Department of Energy is compiling this information for Oregon.  This website will link to that when it’s available.

Alan. R.P. Journet Ph.D.
Cofacilitator
Southern Oregon Climate Action Now
Facilitator SOCAN Medford Climate Action Team
7113 Griffin Lane
Jacksonville
OR 97530-9342
alan@socan.eco
541-301-4107
June 18th 2024

Mayor Sparacio and members of the Medford City Council

Reference: Minimum Parking Requirements

Colleagues:

I write in relation to city consideration of Minimum Parking Requirements (MPRs) as cofacilitator of Southern Oregon Climate Action Now (SOCAN https://socan.eco) and especially as facilitator of SOCAN’s Medford Climate Action Team.

Economic Considerations and Current Trends:

My most interesting discovery in researching this issue was that, according to Shoup (1999) it is unclear how the concept of Minimum Parking Requirements entered the Planning arena, and additionally, because theory and data play such a small role in determining which specific MPRs will be applied in any given situation, the requirements ultimately imposed often appear foolish. This author also argues that MPRs inflate trip generation rates and that a better alternative would be to allow pricing (i.e., the free market) to do the planning.

Quednau (2018) identified three arguments against the principle of MPRs:

  1. From a financial perspective, they undermine financial productivity and prosperity.
  2. They serve as a problem for small business owners, homeowners, developers and renters.
  3. A result of MPRs is that cities become encumbered by empty space that is inadequately used.

By noting that if one enters a city on Black Friday, the day when one would expect the maximum number of parking spaces to be needed there remain abundant spaces unoccupied, Quednau (2018) exemplified the last item,

Spivak (2022) discussed the benefits to eliminate MPRs and illustrated this with an example of how an Olive Garden management team in Auburn, Maine was prevented from buying and expanding to occupy a closed Ruby Tuesday’s site when MPRs were in place because they would have had to generate more parking spaces. However, when the MPRs were removed, they were able simply to buy the site and expand into a current parking lot and thus open for business without being thwarted by issues related to lack of parking. In discussing the elimination of MPRs, Spivak (2022) offered the summary that: “In the smallest of towns and the biggest of cities, these new zoning reform policies that abridge MPR help boost small businesses, promote housing development, and put people over parking.”

In discussing ‘The Pseudoscience of Parking Requirements.,’ Shoup (2020) suggested that cities:

  • Remove off-street parking requirements. This would allow free market considerations by developers and businesses to decide the number of parking spaces they should provide to customers.
  • Charge the right prices for on-street parking. The suggested criterion is the lowest prices that would leave one or two vacant spaces on each block. This ensures there will be no parking shortages. Thus, supply and demand control the price to be charged.
  • Spend the income from parking fees to improve public services on the metered streets since the use of the funds to improve on-street parking will make the policy more popular.

The evidence suggests that Minimum Parking Requirements are of questionable value and that residents and the local economy would be better served if these requirements were eliminated completely. It is argued that the free market should be allowed to determine how many parking spaces will be required for any given structure.

In discussing the impact of Minimum Parking Requirements on affordable housing, Lehe (2018) indicated that MPRs (1) on average add $200 to rental housing because the cost of parking is bundled with the residence itself. Meanwhile the cost of a condo is elevated by $43,000 for the same reason, and (2) encourage larger units rather than relatively small units. Clearly, these outcomes contribute to the unavailability of affordable housing for low-income residents; they do not solve the housing crisis.

Environmental Considerations:

As identified in the Medford Climate Change Adaptation and Resilience Plan (CCARP, 2024), one of the compounding influences exacerbating the impact of global warming on Medford is that this city, like others, is an Urban Heat Island which means that the city experiences summer temperature substantially greater than the surrounding rural area. This, of course, would also occur in the absence of global warming. Yale (2018) reported that “urban centers can be an average of 5 degrees hotter than the surrounding rural areas (though not stated, this is presumably in Fahrenheit).” This phenomenon occurs because incoming solar radiation, mainly that in the shorter visible light range, contacts the concrete and tarmac and is converted into longer wavelength heat energy. Thus, these surfaces can heat to temperatures far greater than the local atmosphere. Although it is sometimes claimed that sidewalks can become so hot one could fry an egg on them, this is unlikely because although the concrete temperature might reach 145⁰F, the temperature required to fry an egg is 158⁰F (McMurtrie and Martin 2022). This is why it can be painful for us and our pets to walk barefooted on concrete on a hot sunny day. This absorbed heat is then radiated back into the atmosphere warming the city. This is the reason that solar ovens are so effective, and our cars can become unbearably hot when left in the sun. Light wavelengths pass through the windows substantially undiminished but heat wavelengths do not pass out anywhere near as effectively; thus, solar ovens and our cars heat up when left in the sun.

Unsurprisingly, infrastructure is the leading contributor to the Urban Heat Island Effect, especially roofs and parking lots (Yale 2018). Roofs, conceivably, could be painted lighter colors to reflect the incoming visible wavelengths of solar radiation, but this solution would potentially be blinding if applied to parking lots. It is also noteworthy that, as CCARP (2024) indicates, “People of color and low-income households are particularly vulnerable to the urban heat island effects….” The presence of vast expanses of little used parking lots thus contributes to the suffering of all residents and also imposes a measure of social injustice.

Stormwater run-off is an additional concern about the negative contribution of parking lots to cities. In rural regions, rainwater generally is absorbed by the soil and contributes to the productivity of the natural or agricultural communities. Stormwater in rural regions may cause flooding but does not contribute pollution to natural waters when it ultimately flows into creeks and rivers. Urban rainfall, however, fails to penetrate the ground because buildings, roads and parking lots constitute a barrier. This water simply flows into storm drains and ditches and thence either into the community wastewater treatment plant, potentially overloading the system, or, as in Medford, into neighboring creeks and thence rivers. If this water were moderate in volume and unpolluted, these would not necessarily be problematic outcomes. However, stormwater flowing from parking lots is generally polluted. As Waters et al. (2011) noted several years ago: urban run-off encounters debris and pollutants such as fertilizers and pesticides, pet waste, leaky car toxins, etc. as it flows through the urban environment. Greentumble (2016) also pointed out that parking lots are especially likely to contribute oil, grease, heavy metals and sediment. Indeed, EPA (2003) long ago identified a long list of pollutants from urbanization, pointing out that “These pollutants can harm fish and wildlife populations, kill native vegetation, foul drinking water supplies, and make recreational areas unsafe and unpleasant.”

In considering overall transportation policy ITDP (2022) argues that cities need to rethink parking. They particularly argue that “This history of parking minimums has ultimately driven down the cost of parking in many cities by providing an excess of free and low-cost parking space, compelling drivers to take more trips by car (even unnecessarily) with the assumption that there will always be a place to park.” They also note that: “the provision of expansive and low-cost parking serves to induce more driving and unsustainable uses of urban space…” and “parking space and storage also tend to be composed of unsustainable, resource-intensive, and non-porous materials (asphalt, concrete, gravel, etc.) that contribute to urban heat island effects and compound stormwater pollution and runoff.”

In terms of our collective contribution to the climate crisis, it’s important to acknowledge that the assessment of total greenhouse gas emissions from automobile use, whether the vehicle is powered by electric, internal combustion engine, or is a hybrid, should include emissions that result from the construction and maintenance of parking structures used by the automobile. Chester et al. (2010) assessed this several years ago and concluded that parking construction emissions: “constitute a significant portion of an automobile’s life-cycle emissions, ultimately increasing the total cost of driving.” This increased cost is not borne by the driver but is externalized to the community since community taxpayer dollars build and maintain the parking lots. This is exactly an example of what ‘externalizing costs’ means: the individual reaping the rewards (i.e., the driver) benefits, while others (i.e., community taxpayers) incur the cost.

Conclusions:

As I researched this topic, I included a search for ‘arguments in favor of Minimum Parking Requirements.’ Curiously, I found most of the hits actually either argued against MRPs or that MRPs are ‘a thing of the past.’ It is also worth noting that the Planning literature seems to focus purely on economic issues and undervalues the environmental costs and benefits of the options discussed.

The evidence suggests to me that Minimum Parking Requirements increase the required number of parking spaces well beyond that which is necessary, even on peak use occasions, cause economic harm to businesses, and simultaneously exacerbate the urban heat island effect and water pollution impacts of urban areas. Furthermore, if the city of Medford is serious about addressing the local housing crisis, it seems that removing MRPs would serve it well. MPRs also, evidently, increase the life cycle pollution emissions assessed for automobile travel.

It is worth noting that the arguments for abandoning Minimum Parking Requirements do not rely on the acceptance f climate science conclusions but rely on economics, restoring a free market approach, and minimizing the threats to city residents imposed by the urban heat island effect and the stormwater run-off.

I understand that some individuals are inclined a priori to be skeptical about repealing Minimum Parking Requirement rules in Medford for reasons seemingly unrelated to their value, but my reading of the evidence suggests abandoning MRPs would constitute a win-win-win-win action:

  • it would benefit the economy while promoting a free market solution to parking questions,
  • it would reduce the heat island effect thus benefitting all residents especially the more vulnerable,
  • consistent with the CCARP, it would contribute to the city’s commitment to undertaking steps that promote climate adaptation and resilience, and
  • it would reduce the rental and purchase price of new low-cost housing developments and thereby potentially put downward pressure on the rent and price of existing housing.

Literature Cited:

CCARP 2024 Climate Adaptation and Resilience Plan: Vulnerabilities. City of Medford Planning Department. https://www.medfordoregon.gov/files/assets/public/v/1/planning/documents/long-range/ccarp_final_122023.pdf

Chester M, Horvath A, Madanat S. 2010. Parking infrastructure: Energy, emissions, and automobile life-cycle environmental accounting. Environmental Research Letters 5 (3): 034001. https://iopscience.iop.org/article/10.1088/1748-9326/5/3/034001/meta

EPA 2003 Protecting Water Quality from Urban Run-off. United States Environmental Protection Agency https://www3.epa.gov/npdes/pubs/nps_urban-facts_final.pdf

Greentumble 2016 Environmental Problems with Parking Lots. Greentumble https://greentumble.com/environmental-problems-with-parking-lots

ITDP 2022 To Tackle Climate Change, Cities Need to Rethink Parking. Institution for Transportation and Development Policy. https://www.itdp.org/2022/09/20/to-tackle-climate-change-cities-need-to-rethink-parking/

Lehe L 2018 Minimum parking requirements and housing affordability. The Journal of Transport and Land Use 11 (1): 1309-1321. https://www.jtlu.org/index.php/jtlu/article/view/1340.

McMurtrie L,Martin S. 2022 Can you actually fry an egg on the sidewalk? Even in high heat, it’s tough. USA Today Network. https://www.usatoday.com/story/life/food-dining/2022/07/29/can-you-fry-egg-sidewalk-car/10048288002/ .

Quednau R. 2018 3 Major Problems with Parking Minimums. Strong Towns https://www.strongtowns.org/journal/2018/7/2/3-major-problems-with-parking-minimums

Shoup D. 1999 The trouble with minimum parking requirements. Transportation Research Part A; Policy and Practice. Science Direct  https://www.sciencedirect.com/science/article/abs/pii/S0965856499000075#:~:text=This%20foolishness%20is%20a%20serious,of%20not%20considering%20this%20cost

Shoup D. 2020 The Pseudoscience of Parking Requirements. Practice Parking Reform. Zoning Practice. https://parkingreform.org/wp-content/uploads/2023/03/APA_-Practice_Parking_Reform_February-2020.pdf

Spivak J. 2022 A Business Case for Dropping Parking Minimums. American Planning Association https://www.planning.org/planning/2022/spring/a-business-case-for-dropping-parking-minimums/

Waters S, Farrell-Poe K, Wagner K. 2011. When it Rains it Runs Off: Runoff and Urbanized Areas in Arizona. Arizona Cooperative Extension. https://extension.arizona.edu/sites/extension.arizona.edu/files/pubs/az1542.pdf

Yale K. 2018 Heat Island Effect: What You Need to Know.  Buildings. https://www.buildings.com/building-systems-om/roofing/article/10186046/heat-island-effect-what-you-need-to-know

 

Alan R.P. Journet Ph.D.
Cofacilitator
Southern Oregon Climate Action Now
alan@socan.eco
541-500-2331
June 25th 2024

 

Nicole Singh and DEQ Greenhouse Gas Program Staff:

I write again as cofacilitator of Southern Oregon Climate Action Now, an organization of some 2,000 Southern Oregonians who are concerned about the climate crisis and encourage state action to address it.  As rural and coastal Southern Oregonians, we live on the frontlines of the warming, reducing snowpack, heatwaves, drought and the increasing wildfire risk that these trends conspire to produce.  Because of this, we pay close attention to what is happening in Salem in terms of agency proposals.

I offer the following comments both in my capacity as cofacilitator of Southern Oregon Climate Action Now and my experience as a long-time university faculty member teaching ecology, conservation biology, environmental science and process of science.

I first wish to express appreciation to the DEQ staff for their efforts in developing the updated Climate Protection Program. Having noted that, I have three concerns about which, regrettably, I have no ready solutions.

  • My years of teaching ecology and conservation biology lead me to identify our need to address the climate crisis as falling under the same umbrella as our need to develop a sustainable lifestyle. All life on the planet, including future generations of humans, demand that we recognize a critical reality: we live on a finite planet with finite resources and a finite capacity to process our waste. Greenhouse gas emissions are, of course, among the waste production that our planet has a finite capacity to process. This reality instructs us that infinite economic growth, when it’s accompanied by expanding resource use and waste production, is impossible. This is relevant to the discussion of emissions assessment by EITE industries. We know that, to protect planetary life, we need at minimum to reduce emissions to net zero by 2050. This means industries, of whatever type, must reduce their total emissions. When we start discussing emissions reductions in terms of ‘emissions intensity’ per widget produced – or whatever, we have pulled the wool over our own eyes. A focus on emissions intensity rather than total emissions implies that we actually think infinite economic growth is possible since emissions intensity may well drop while total emissions are rising. This is almost inevitable if increasing productivity occurs. To be realistic, we need a program that demands any increase in productivity shall be accompanied by a sufficient emissions intensity decrease as to negate the impact of that increased productivity.

In terms of the next two items, I understand that DEQs hands are somewhat tied either by legislative action of legislative inactions.

  • Legislative action in Oregon has defined biofuels as zero emissions fuels even though this is not the case. This is because the production, processing and transmission / transport of the fuel requires energy the production of which results in greenhouse gas emissions. A Climate Protection Program that fails to account for those emissions is based on false accounting.
  • Legislative inaction or resistance has resulted in the DEQ not being authorized to assess fugitive emissions of greenhouse gases upstream from their final use and, especially, out-of-state. Again, a Climate Protection Program that pretends these upstream fugitive emissions don’t exist will inevitably fall short of achieving the emissions reductions it could achieve if these were included and reduced.

In the months following Governor Brown’s signing EO 20-04, we (SOCAN) engaged with the DEQ through its technology hearings and Rulemaking Advisory Committee hearings submitting substantial comments during that period. We were disappointed to learn of the judicial rejection of the CPP on a technicality and are now engaged again as the updated CPP is developed.

We strongly support DEQ’s effort to restore the Climate Protection Program and urge this be completed before the end of 2024 to allow the state to remain on track for achieving critical CPP goals. Every day of delay requires a program with a steeper emissions reduction trajectory if we are to achieve the same goals. By filing suit to undermine the CPP, presumably the plaintiffs made a wager after balanced the cost of their needing to undertake more rigorous reductions later against the potential financial benefit to them (and cost to society as a whole) of eliminating the program altogether. We encourage DEQ to retain the science-based trajectory of a 45% reduction in emissions by 2035 while retaining also the Community Climate Investment component as a route for benefitting Oregon communities through the investment of hundreds of millions of dollars.

We anticipate that the CPP will spur job growth, technological innovation, enhance public health in the state along with producing cleaner, cheaper, and improved transportation options.

Reducing fossil fuel combustion emissions through the Climate Protection Program, we suggest, will benefit workers and our economy providing reduced health care costs, reducing job-loss risk, and avoiding business closures while sustaining the state’s natural resources economy.

We object to the notion that the CPP should be compromised in any way by proposals arriving from the same sources who resisted throughout the previous RAC process, and who then engaged in a frivolous lawsuit that was only victorious on a technicality and which lacked any substantive justification.

I am confused by the assertion that the program does not allow offsets when the Community Climate Investments, as stated in 340-273-0900  Purposes of Community Climate Investments and Eligible Uses of CCI Funds, target:

“(2) A CCI entity may use CCI funds only for:

“(a) Implementing eligible projects in Oregon, which are actions that reduce anthropogenic greenhouse gas emissions that would otherwise occur in Oregon. Eligible projects include, without limitation, actions that reduce emissions in Oregon resulting from:

“(A) Transportation of people, freight, or both;

“(B) An existing or new residential use or structure;

“(C) An existing or new industrial process or structure; and

“(D) An existing or new commercial use or structure.”

Since these represent emissions reductions undertaken elsewhere than by the regulated entity, they are offsets.  Maybe, the statement should be that the CPP does not allow offsets except those covered by Community Climate Investment credits.

In terms of the proposed elimination of restriction on CCI entities allowing for-profit entities to become CCI entities I would like to endorse the reservations expressed by RAC member Lisa Arkin of Beyond Toxics. If for-profit entities are permitted, there should be a requirement that they are certified Benefit Corporations since such corporations include among their goals maintaining environmental protection and a social conscience. The notion that the CCI component should be undertaken by entities that solely have a profit-driven motive will direct funds away from the environmental and social justice projects defined as the targets of the Community Climate Investments and toward the benefit of corporate shareholders.

Many Oregon businesses and industries, fossil fuel marketers and utilities were responsible for ignoring the voluntary emissions reduction goals established in 2007. These businesses have necessitated the development of a Climate Protection Program.  We urge that DEQ hold them responsible for now engaging in sufficient emissions reduction to compensate for the problems and delays they have caused.

Respectfully Submitted

Alan Journet

7113 Griffin Lane
Jacksonville OR
97530-9342

The SOCAN May 28th General Meeting  presentation by Mel Martin from the Oregon Coalition for an Environmental Rights Amendment (OCERA) will be screened on RVTV M-F at 5pm for the next two weeks.

This is:

Ch182 on Spectrum
Ch 15 on Ashland Home Net

SOCAN Comments on the ODF Vision for Oregon’s Forests

 

Alan R.P. Journet Ph.D.
Cofacilitator
Southern Oregon Climate Action Now
alan@socan.eco
541-500-2331
June 2nd 2024

 

Oregon Board of Forestry

Oregon Department of Forestry

Reference: Vision for Oregon’s Forests

Chair Kelly and members of the Oregon Board of Forestry:

I write as cofacilitator of Southern Oregon Climate Action Now, an organization of some 2,000 Southern Oregonians who are concerned about the climate crisis and encourage state action to address it. As rural and coastal Southern Oregonians, we live on the frontlines of the warming, reducing snowpack, heatwaves, drought and the increasing wildfire risk that these trends conspire to produce. Because of this, we pay close attention to what is happening in state agencies that relates to climate and wildfire.

We are particularly interested in the incredibly important role that Oregon’s forests can play in terms of contributing to the state’s natural climate solutions by sequestering carbon. It is within this context that the Vision for Oregon’s Forests was reviewed.

I was delighted to see the statement (P. 1): “Forests are an integral part of the social economic and environmental fabric of our state…” included in the purpose. It would have been better, however, if this had been followed by recognition of ‘stabilizing our climate’ as one of the listed benefits since doing so would indicate that the authors acknowledge this as a priority. Indeed, this should probably be the first item listed since without a stable climate, “Clean air and water, sustainable forest products, biodiversity, public health and safety’ will all be severely compromised. Given that reality, stabilizing climate should be the highest priority.

It is also encouraging to see (P. 1) that “Policies will be responsive and adaptable to global and local climate change while mitigating threats to ecosystems, human health and safety, and economies.” However, this should be stated as occurring within the recognition that ‘climate smart’ management will be employed (see below for further comment on this concdern).

On face value, it is encouraging to identify (P.3) a shared vision of “Complex and resilient forest ecosystems that endure and adapt.” Regrettably, however, the climate envelope studies and projections of Rehfeldt and Crookston, as depicted on the Plant Species and Climate Profile Predictions website suggest the consequences of continuing our business-as-usual behavior of accelerating fossil fuel use and greenhouse gas emissions. These projections indicate that unless we globally divert the current climate trend, this will likely reduce the range of many ecologically and commercially important Oregon forest species and eliminate some from the state. Without elevating the role of our forests in combating climate change, our ability to maintain complex and resilient forest ecosystems seems like a challenge.

In terms of the strategies proposed (P.6) I was delighted to see “…extended rotations and increased retention of large legacy structures (live green trees, snags, and downed wood) during harvest activities.” This delight applies also, and critically, to “Encourage the development of complex, functional forests that sequester and store carbon.”

In terms of the “Priority: Addressing the Wildfire Crisis” (P. 10), it is somewhat disappointing to see the Goal as: “Prevent, suppress and mitigate wildfire to protect communities and expedite forest restoration activities that promote the adaptive capacity of Oregon’s forests.” As the subsequent narrative implicitly acknowledges, we live in a Mediterranean climate where the millennia of winter wet / summer dry seasonal cycles have generated forest communities that are fire prone, fire adapted and fire dependent. Instead of repeating the 20th Century refrain indicated in this goal of trying to prevent, suppress and mitigate wildfires, I would prefer to see a goal that focuses on ‘managing’ fire in our forests and promoting a regime that includes fire. The evidence suggests that the decades of fire suppression combined with climate transitions resulting from the Pacific Decadal Oscillation and global warming have contributed to the problem of increasing fire risk. I suggest that it would behoove ODF to acknowledge more explicitly the consequences of our Mediterranean climate and the need for managing fire to serve both forest and human community health rather than focusing on fire prevention and suppression. The subsequent list of strategies that include ‘prescribed fire’ suggests that ODF understands the need for fire in our forests though there seems to be little recognition that we should manage wildfire rather than merely and consistently prevent and suppress fire and then compensate by imposing prescribed fire often in seasons when historically it has been less prevalent.

It is gratifying to see that Climate Smart forestry is incorporated into the planning (P. 12).  However, it is a little disturbing that the basic literature on climate smart natural resource management is not included. Instead, ODF seems to have adopted its own definition of what comprises ‘climate smart’ management. Since there is a tendency for natural resource managers to claim that since they manage natural resources and they accept climate science, what they are doing must be climate smart. It would generate greater confidence if the literature listed below were referenced.

In this vein, I note that one of the basic tenets of climate smart management is recognition that future climate will be unlike past climates. Thus, seeking restoration to some prior species composition is not rational.

While I see reference to the need for public education, I would like to recommend that this be accorded greater emphasis. One of the greatest problems we have in discussing climate change and wildfire with the public is that there exists tremendous ignorance about the importance of fire in our forests and why our forests are fire adapted and fire dependent. This is compounded by a similar level of ignorance regarding climate change and how that is currently affecting fire risk and how ongoing climate change will only exacerbate the fire risk problem. The roll out of wildfire risk maps a year or so ago is a perfect example of how that level of public ignorance can lead to anger and rejection of rational proposals and arguments.

Respectfully Submitted

Alan Journet

7113 Griffin Lane
Jacksonville
OR 97530-9342

 

Suggested Examples of Climate Smart Literature:

Glick, P., B.A. Stein, and K.R. Hall. 2021. Toward a Shared Understanding of Climate-Smart Restoration on America’s National Forests: A Science Review and Synthesis. Washington, DC: National Wildlife Federation.  A 2021 update of the seminal Stein et al 2014 discussion

Schuurman, G. W., C. Hawkins Hoffman, D. N. Cole, D. J. Lawrence, J. M. Morton, D. R. Magness, A. E. Cravens, S. Covington, R. O’Malley, and N. A. Fisichelli. 2020. Resist-accept-direct (RAD)—a framework for the 21st-century natural resource manager. Natural Resource Report NPS/NRSS/CCRP/NRR—2020/ 2213. National Park Service, Fort Collins, Colorado.

Stein, B.A., P. Glick, N. Edelson, and A. Staudt (eds.) (2014). Climate-Smart Conservation: Putting Adaptation Principles into Practice. National Wildlife Federation, Washington, D.C.  One of the seminal papers that kick-started climate smart thinking.

Swanston, Christopher W.; Janowiak, Maria K.; Brandt, Leslie A.; Butler, Patricia R.; Handler, Stephen D.; Shannon, P. Danielle; Derby Lewis, Abigail; Hall, Kimberly; Fahey, Robert T.; Scott, Lydia; Kerber, Angela; Miesbauer, Jason W.; Darling, Lindsay; Parker, Linda; St. Pierre, Matt. 2016. Forest Adaptation Resources: climate change tools and approaches for land managers, 2nd ed. Gen. Tech. Rep. NRS-GTR-87-2. Newtown Square, PA: U.S. Department of Agriculture, Forest Service, Northern Research Station. 161 p.

LED Parking lot lights at Walmart Puerto Rico” by Walmart Corporate is licensed under CC BY 2.0.

Alan. R.P. Journet Ph.D.
Cofacilitator
Southern Oregon Climate Action Now
Facilitator SOCAN Medford Climate Action Team
7113 Griffin Lane
Jacksonville
OR 97530-9342
alan@socan.eco
541-301-4107
May 23rd 2024

 

Medford Planning Commission

Reference: Minimum Parking Requirements date (5-23-24) and DCA-24-032

Colleagues:

I write as cofacilitator of Southern Oregon Climate Action Now (SOCAN https://socan.eco) and facilitator of SOCAN’s Medford Climate Action Team in relation to city consideration of Minimum Parking Requirements (MPRs). Initially, I was relatively uninformed about this issue but have undertaken some research into the Planning literature and engaged in a little reflection. I offer the following thoughts.

Economic Considerations and Current Trends:

My most interesting discovery was that, according to Shoup (1999) it is unclear how the concept of Minimum Parking Requirements entered the Planning arena, and additionally, because theory and data play such a small role in determining which specific MPRs will be applied in any given situation, the requirements ultimately imposed often appear foolish. This author also argues that MPRs inflate trip generation rates and that a better alternative would be to allow pricing (i.e., the free market) to do the planning.

Quednau (2018) identified three arguments against the principle of MPRs:

  1. From a financial perspective, they undermine financial productivity and prosperity.
  2. They serve as a problem for small business owners, homeowners, developers and renters.
  3. A result of MPRs is that cities become encumbered by empty space that is inadequately used.

Quednau (2018) exemplified the last item by noting that if one enters a city on Black Friday, the day when one would expect the maximum number of parking spaces to be needed, there remain abundant spaces unoccupied.

Spivak (2022) discussed the benefits to eliminate MPRs and illustrated this with an example of how an Olive Garden management team in Auburn, Maine was prevented from buying and expanding to occupy a closed Ruby Tuesday’s site when MPRs were in place because they would have had to generate more parking spaces. However, when the MPRs were removed, they were able simply to buy the site and expand into a current parking lot and thus open for business without being thwarted by issues related to lack of parking. In discussing the elimination of MPRs, Spivak (2022) offered the summary that: “In the smallest of towns and the biggest of cities, these new zoning reform policies that abridge MPR help boost small businesses, promote housing development, and put people over parking.”

In discussing ‘The Pseudoscience of Parking Requirements.,’ Shoup (2020) suggested that cities:

  • Remove off-street parking requirements. This would allow free market considerations by developers and businesses to decide the number of parking spaces they should provide to customers.
  • Charge the right prices for on-street parking. The suggested criterion is the lowest prices that would leave one or two vacant spaces on each block. This ensures there will be no parking shortages. Thus, supply and demand control the price to be charged.
  • Spend the income from parking fees to improve public services on the metered streets since the use of the funds to improve on-street parking will make the policy more popular.

The evidence that I encountered suggests that Minimum Parking Requirements are of questionable value and that residents and the local economy would be better served if these requirements were eliminated completely. It is argued that the free market should be allowed to determine how many parking spaces will be required for any given structure.

In discussing the impact of Minimum Parking Requirements on affordable housing, Lehe (2018) indicated that MPRs (1) on average add $200 to rental housing because the cost of parking is bundled with the residence itself. Meanwhile the cost of a condo is elevated by $43,000 for the same reason, and (2) encourage larger units rather than relatively small units. Clearly, these outcomes contribute to the unavailability of affordable housing for low-income residents; they do not solve the housing crisis.

Environmental Considerations:

As identified in the Medford Climate Change Adaptation and Resilience Plan (CCARP, 2024), one of the compounding influences exacerbating the impact of global warming on Medford is that this city, like others, is an Urban Heat Island which means that the city experiences summer temperature substantially greater than the surrounding rural area. This, of course, would also occurs in the absence of global warming. Yale (2018) reported that “urban centers can be an average of 5 degrees hotter than the surrounding rural areas (though not stated, this is presumably in Fahrenheit).” This phenomenon occurs because incoming solar radiation, mainly that in the shorter visible light range, contacts the concrete and tarmac and is converted into longer wavelength heat energy. Thus, these surfaces can heat to temperatures far greater than the local atmosphere. Although it is sometimes claimed that sidewalks can become so hot one could fry an egg on them, this is unlikely because although the concrete temperature might reach 145⁰F, the temperature required to fry an egg is 158⁰F (McMurtrie and Martin 2022). This is why it can be painful for us and our pets to walk barefooted on concrete on a hot sunny day. This absorbed heat is then radiated back into the atmosphere warming the city. This is the reason that solar ovens are so effective, and our cars can become unbearably hot when left in the sun. Light wavelengths pass through the windows substantially undiminished but heat wavelengths do not pass out anywhere near as effectively; thus, solar oven and our cars heat up when left in the sun.

Unsurprisingly, infrastructure is the leading contributor to the Urban Heat Island Effect, especially roofs and parking lots (Yale 2018). Roofs, conceivably, could be painted lighter colors to reflect the incoming visible wavelengths of solar radiation, but this solution would potentially be blinding if applied to parking lots. It is also noteworthy that, as CCARP (2024) indicates, “People of color and low-income households are particularly vulnerable to the urban heat island effects….” The presence of vast expanses of little used parking lots thus contributes to the suffering of all residents and also imposes a measure of social injustice.

Stormwater run-off is an additional concern about the negative contribution of parking lots to cities. In rural regions, rainwater generally is absorbed by the soil and contributes to the productivity of the natural or agricultural communities. Stormwater in rural regions may cause flooding but does not contribute pollution to natural waters when it ultimately flows into creeks and rivers. Urban rainfall, however, fails to penetrate the ground because buildings, roads and parking lots constitute a barrier. This water simply flows into storm drains and ditches and thence either into the community wastewater treatment plant, potentially overloading the system, or, as in Medford, into neighboring creeks and thence rivers. If this water were moderate in volume and unpolluted, these would not necessarily be problematic outcomes. However, stormwater flowing from parking lots is generally polluted. As Waters et al. (2011) noted several years ago: urban run-off encounters debris and pollutants such as fertilizers and pesticides, pet waste, leaky car toxins, etc. as it flows through the urban environment. Greentumble (2016) also pointed out that parking lots are especially likely to contribute oil, grease, heavy metals and sediment. Indeed, EPA (2003) long ago identified a long list of pollutants from urbanization, pointing out that “These pollutants can harm fish and wildlife populations, kill native vegetation, foul drinking water supplies, and make recreational areas unsafe and unpleasant.”

In considering overall transportation policy ITDP (2022) argues that cities need to rethink parking. They particularly argue that “This history of parking minimums has ultimately driven down the cost of parking in many cities by providing an excess of free and low-cost parking space, compelling drivers to take more trips by car (even unnecessarily) with the assumption that there will always be a place to park.” They also note that: “the provision of expansive and low-cost parking serves to induce more driving and unsustainable uses of urban space…” and “parking space and storage also tend to be composed of unsustainable, resource-intensive, and non-porous materials (asphalt, concrete, gravel, etc.) that contribute to urban heat island effects and compound stormwater pollution and runoff.”

In terms of our collective contribution to the climate crisis, it’s important to acknowledge that the assessment of total greenhouse gas emissions from automobile use, whether the vehicle is powered by electric, internal combustion engine, or is a hybrid, should include emissions that result from the construction and maintenance of parking structures used by the automobile. Chester et al. (2010) assessed this several years ago and concluded that parking construction emissions: “constitute a significant portion of an automobile’s life-cycle emissions, ultimately increasing the total cost of driving.” This increased cost is not borne by the driver but is externalized to the community since community taxpayer dollars build and maintains the parking lots. This is exactly an example of what ‘externalizing costs’ means: the individual reaping the rewards (i.e., the driver) benefits, while others (i.e., community taxpayers) incur the cost.

Conclusions:

As I researched this topic, I included a search for ‘arguments in favor of Minimum Parking Requirements.’ Curiously, I found most of the hits actually either argued against MRPs or that MRPs are ‘a thing of the past.’ It is also worth noting that the Planning literature seems to focus purely on economic issues and undervalues the environmental costs and benefits of the options discussed.

The evidence suggests to me that Minimum Parking Requirements increase the required number of parking spaces well beyond that which is necessary, even on peak use occasions, cause economic harm to businesses, and simultaneously exacerbate the urban heat island effect and water pollution impacts of urban areas. Furthermore, if the city of Medford is serious about addressing the local housing crisis, it seems that removing MRPs would serve it well. MPRs also, evidently, increase the life cycle pollution emissions assessed for automobile travel.

It is worth noting that the arguments for abandoning Minimum Parking Requirements do not rely on the acceptance f climate science conclusions but rely on economics, restoring a free market approach, and minimizing the threats to city residents imposed by the urban heat island effect and the stormwater run-off.

I understand that some individuals are inclined a priori to be skeptical about repealing Minimum Parking Requirement rules in Medford for reasons seemingly unrelated to their value, but my reading of the evidence suggests abandoning MRPs would constitute a win-win-win-win action:

  • it would benefit the economy while promoting a free market solution to parking questions,
  • it would reduce the heat island effect thus benefitting all residents especially the more vulnerable,
  • consistent with the CCARP, it would contribute to the city’s commitment to undertaking steps that promote climate adaptation and resilience, and
  • it would reduce the rental and purchase price of new low-cost housing developments and thereby potentially put downward pressure on the rent and price of existing housing.

Literature Cited:

CCARP 2024 Climate Adaptation and Resilience Plan: Vulnerabilities. City of Medford Planning Department. https://www.medfordoregon.gov/files/assets/public/v/1/planning/documents/long-range/ccarp_final_122023.pdf

Chester M, Horvath A, Madanat S. 2010. Parking infrastructure: Energy, emissions, and automobile life-cycle environmental accounting. Environmental Research Letters 5 (3): 034001. https://iopscience.iop.org/article/10.1088/1748-9326/5/3/034001/meta

EPA 2003 Protecting Water Quality from Urban Run-off. United States Environmental Protection Agency https://www3.epa.gov/npdes/pubs/nps_urban-facts_final.pdf

Greentumble 2016 Environmental Problems with Parking Lots. Greentumble https://greentumble.com/environmental-problems-with-parking-lots

ITDP 2022 To Tackle Climate Change, Cities Need to Rethink Parking. Institution for Transportation and Development Policy. https://www.itdp.org/2022/09/20/to-tackle-climate-change-cities-need-to-rethink-parking/

Lehe L 2018 Minimum parking requirements and housing affordability. The Journal of Transport and Land Use 11 (1): 1309-1321. https://www.jtlu.org/index.php/jtlu/article/view/1340.

McMurtrie L,Martin S. 2022 Can you actually fry an egg on the sidewalk? Even in high heat, it’s tough. USA Today Network. https://www.usatoday.com/story/life/food-dining/2022/07/29/can-you-fry-egg-sidewalk-car/10048288002/ .

Quednau R. 2018 3 Major Problems with Parking Minimums. Strong Towns https://www.strongtowns.org/journal/2018/7/2/3-major-problems-with-parking-minimums

Shoup D. 1999 The trouble with minimum parking requirements. Transportation Research Part A; Policy and Practice. Science Direct  https://www.sciencedirect.com/science/article/abs/pii/S0965856499000075#:~:text=This%20foolishness%20is%20a%20serious,of%20not%20considering%20this%20cost

Shoup D. 2020 The Pseudoscience of Parking Requirements. Practice Parking Reform. Zoning Practice. https://parkingreform.org/wp-content/uploads/2023/03/APA_-Practice_Parking_Reform_February-2020.pdf

Spivak J. 2022 A Business Case for Dropping Parking Minimums. American Planning Association https://www.planning.org/planning/2022/spring/a-business-case-for-dropping-parking-minimums/

Waters S, Farrell-Poe K, Wagner K. 2011. When it Rains it Runs Off: Runoff and Urbanized Areas in Arizona. Arizona Cooperative Extension. https://extension.arizona.edu/sites/extension.arizona.edu/files/pubs/az1542.pdf

Yale K. 2018 Heat Island Effect: What You Need to Know.  Buildings. https://www.buildings.com/building-systems-om/roofing/article/10186046/heat-island-effect-what-you-need-to-know

Southern Oregon Climate Action Now part of coalition to put amendment before voters

Tony Boom, May 28th 2024, RV-Times

Southern Oregon Climate Action Now has joined a coalition that seeks to add an environmental rights amendment to the state constitution though a vote of the people.

“Many people haven’t heard of this idea and don’t understand why it is necessary,” said Alan Journet, co-facilitator of SOCAN.

Journet said government has a responsibility to manage natural resources such as air and water for current and future generations in a public trust doctrine, he said.

Mel Martin of the Oregon Coalition for an Environmental Rights Amendment strategy committee will talk about the effort and explain the need for action in a public meeting at 6 p.m. Tuesday, May 28, in the Medford library, 205 S. Central Ave.

Peter Fargo, a spokesperson with OCERA, said, “We are forming the coalition. We are reaching out to interested partners across the state. We are just getting started.

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The legal and moral case for holding companies accountable.

Vermont’s House and Senate have approved a bill that would make fossil fuel companies financially liable for their carbon pollution and its role in the climate crisis. Lawmakers pointed to consequences of these carbon emissions, like the flood in July 2023 that put parts of the state capital underwater for weeks and caused over a billion dollars in damage.

The bipartisan bill is known as the Climate Superfund Act because it demands that fossil fuel companies cover at least part of the growing costs of climate change. Similar bills are being considered in New York, Massachusetts and Maryland, but Vermont is the first state to pass this kind of legislation. The bill passed with a supermajority, enough to override a potential veto. It is now headed to Governor Phil Scott’s desk.

Living on Earth spoke with Pat Parenteau, former EPA regional counsel and emeritus professor at Vermont Law and Graduate School, to unpack the details. This interview has been edited for length and clarity.

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