PARKING FACILITY PRICING STRATEGY STUDY

MASSACHUSETTS BAY TRANSPORTATION AUTHORITY SUBMITTED ON THE 12TH DAY OF APRIL, 2016

SUBMITTED TO: RONALD ROSS DIRECTOR OF PARKING MASSACHUSETTS BAY TRANSPORTATION AUTHORITY 10 PARK PLAZA, SUITE 5750 BOSTON, MA 02116

ARCHITECTS ENGINEERS PLANNERS

RESTORATION ENGINEERS SUBMITTED BY:

PARKING CONSULTANTS 18 TREMONT STREET, SUITE 300 BOSTON, MASSACHUSETTS 02108 (617) 778‐9882 / (617) 778‐9883 (FAX) ARCHITECTS STRUCTURAL ENGINEERS PLANNERS PARKING CONSULTANTS RESTORATION ENGINEERS GREEN PARKING CONSULTING

PARKING FACILITY PRICING STRATEGY STUDY

PREPARED FOR RONALD ROSS, DIRECTOR OF PARKING

BOSTON, MASSACHUSETTS

TABLE OF CONTENTS

1. EXECUTIVE SUMMARY ...... 1 2. INTRODUCTION ...... 2 3. FIELD OBSERVATIONS ...... 3 Weekday Occupancy ...... 3 Weekend Occupancy ...... 7 Current Rates ...... 10 Conclusions ...... 13 4. IMPACT FACTORS ...... 14 Transit Fares ...... 14 Theory of Management by Pricing ...... 15 Parking Elasticity ...... 16 Fuel Cost ...... 16 Congestion ...... 18 Future Development ...... 18 5. IMPACT MODELLING ...... 24 Methodology ...... 24 Status Quo Scenario ...... 24 Realistic Scenarios ...... 25 Optimal Scenario ...... 26 6. CONCLUSIONS/ RECOMMENDATIONS ...... 28 7. APPENDICES...... 29

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1. EXECUTIVE SUMMARY

(Author’s Note: To ensure a comprehensive review of observations, findings, analysis and recommendations, an Executive Summary has been purposefuly omitted from the draft document. Pending comments and review from the Client, a draft Executive Summary will be developed and issued for review after the working session. A revised version of the document will be included in the final report.)

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2. INTRODUCTION

The Massachusetts Bay Transportation Authority (MBTA) is the fifth largest transit system in the United States, servicing 175 member cities and towns over a 3,200 square mile area containing over 4.7 million residents. In Fiscal Year 2014, it was estimated that the system supported 1.3 million trips each day and 400 million boardings for the year.

There are a total of 141 total parking facilities serving MBTA stations and terminals. Of these, the MBTA controls pricing at 101 facilities. Pricing at these facilities can range from as little as $4.00/day up to $27.00/day or $70.00/month up to $400.00/month; ten percent (10%) of MBTA parking facilities are completely free of charge.

The MBTA retained DESMAN to perform a study of current pricing for MBTA parking facilities and return with recommendations for price adjustments reflective of current and future conditions. The MBTA also asked DESMAN to recommend a strategy for future pricing adjustments consistent with the agency’s goals and objectives.

As part of this engagement, DESMAN reviewed current conditions in place at every station with parking, collecting data on utilization of a typical weekday and weekend day and current rates, as well as information on the utilization and rates of other facilities competing for MBTA riders. DESMAN also evaluated the area in a 500’ radius of each station to gain an understanding of parking supply and demand dynamics in each area and how those might change in the foreseeable future. Finally, DESMAN reviewed operations at each station and, where appropriate, made recommendations for improving efficiencies or revenue capture.

As part of our approach, DESMAN reviewed the MBTA’s history of parking rate and fare adjustments to gain an understanding of how parking and ridership correlate. DESMAN also searched for research quantifying the impact of fuel prices and congestion on mode choice on mode choice in an attempt to quantify how rising gas prices and increasing commute times might drive MBTA ridership and, as a result, parking demand at the various facilities included within the review.

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3. FIELD OBSERVATIONS

The following section provides an overview of the observed field conditions at the MBTA parking facilities included within the study.

3.1 Weekday Occupancy

In order to measure utilization at parking facilities servicing MBTA stations, DESMAN personnel confirmed the inventory of parking spaces in designated facilities and conducted parking occupancy counts on representative weekdays.

Based on our experience and input from MBTA administrators, DESMAN assumed that large part of the users who park at the lots and garages adjacent to MBTA stations will be in place before 9:00 AM. This assumption was predicated on the observation that a majority of riders are daily commuters who must be on their way into Boston by this time in order to reach their destination before the start of the business day. Similarly, the majority are not likely to return to their car before 3:00 PM or later.

Based on these assumptions, DESMAN executed occupancy counts between 9:00 AM and 3:00 PM on representative weekdays. Parking utilization counts were performed during the weeks of February 15th, February 22nd and February 29th, 2016. Occupancy counts performed the week of February 15th, a school vacation week throughout much of Massachusetts, were checked against conditions the following week and adjusted as necessary to reflect typical weekday conditions. At each of the 141 stations identified by the MBTA, DESMAN counted the number of vehicles parked in each facility to calculate the space utilization. The results of the weekday inventory and utilization surveys are presented Figures 1 and 2 on the following pages.

Figure 1: Observed Weekday Occupancy along MBTA Subway, Bus and Ferry Service Lines

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Figure 2: Observed Weekday Occupancy along MBTA Commuter Rail Service Lines

Source: DESMAN

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Figure 3: Observed Weekday Parking Utilization along MBTA Commuter Rail Service Lines

Source: DESMAN

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As shown in Figure 3, on the prior page, and Figure 4, below, DESMAN divided the parking facilities into three categories depending on the observed level of utilization: facilities experiencing level of utilization of 85% and higher (highlighted in red); facilities with level of utilization between 60% and 85% (highlighted in yellow); and underutilized facilities running at 60% of capacity or less (highlighted in green).

Figure 4: Observed Weekday Utilization along MBTA Subway, Bus and Ferry Service Lines

The first category highlighted in red is comprised of 59 highly utilized facilities that are operating near capacity. These include Wonderland, most of the Red and Orange Line stations, the Green Line stations closest to downtown Boston along the subway lines. It is DESMAN’s theory that Wonderland, a terminal station located in Revere, supports a large commuter population from the North Shore of Boston who elect to drive and park at the location each day to access the higher frequency of service afforded by the subway as opposed to the commuter rail servicing their home community. Similarly, the Red Line stations offer access to higher frequency service for commuters coming from the South Shore and the communities north and northwest of downtown Boston as well as easy access on and off major highways. High utilization along Green Line stations appears to be a function of limited capacity at those locations.

For commuter rail stations servicing South Shore communities, select stations along the Greenbush, Kingston/Plymouth, and Providence/Stoughton were highly utilized, but as a general rule these pockets of elevated demand were located between stations with excess capacity. Along the Franklin line, four of the eleven stations surveyed ran at over 85% capacity and on the Needham line, four of the seven stations with parking were running near or at capacity. While unsubstantiated, DESMAN believes the lower levels of utilization at the majority of stationsalong the Greenbush, Kingston/Plymouth and Providence/Stoughton lines is driven in part by commuters bypassing these locations in favor of the Red Line stations a Braintree and Quincy Adams, which offer easy highway access and higher rates of service.

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The communities serviced by the Franklin and Needham Lines do not have the same ease of highway access to high‐frequency lines, so the stations along these routes experienced higher utilization in general.

Along the lines serving communities west and north of downtown Boston, the Newburyport/Rockport and Haverhill Lines appeared to only expereince high utilization in stations with limited capacity. Along the Lowell Line, five of the seven stations with parking were highly utilized, although with the exception of North Billerica, this again appeared to be a function of limited capacity. In the case of North Billerica, DESMAN believes that the ease of access to I‐495, Route 3 and I‐93 makes this facility a favorite of daily commuters coming from communities in Middlesex County and southern New Hampshire. For stations along the Fitchburg Line, high utilization similarly was noted at stations with very limited capacity or those closest to major arterials like I‐495 and Route 2. Only the Framingham/Worcester Line appeared to be highly utilized along much of its length, with nine of fourteen stations running at 85% or higher utilization, including several with parking capacity in excess of 200 spaces.

These parking locations are experiencing high levels of demand despite the current pricing and are likely to cause spillovers into adjacent streets or other facilities within close proximity of the station, potentially creating conflicts with the community in which these stations are located. DESMAN belives that increasing parking rates at these facilities could shift the demand to other locations, creating a margin of capacity for non‐commuters seeking to utilize MBTA service. This shift in demand to lower utilized facilities with increase the efficiency of the operations and revenue as well as customer satisfaction.

Those facilities highlighted in yellow represent 38 facilities with moderate levels of occupancy ranging from 60% to 85%. At these facilities DESMAN observed a balanced combination of parking demand and parking supply. Parking at these locations retains enough customers on the weekday to generate reasonable revenue and yet leaves enough of available capacity to accommodate non‐commuters. DESMAN considers this category as having an optimal price structure.

The remaining 43 stations shown in green, experience low levels of parking utilization and can be considered as candidates for price reductions in attempt to attract demand from overutilized facilities along the same service lines or serving the same constituency. As a general rule, these facilities were located in areas which were hard to access from major highways or competed against subway stations offering greater frequency of service, making them less attractive to daily commuters.

3.2 Weekend Occupancy

At the MBTA’s request, DESMAN also performed occupancy counts on a representative weekend day between 9:00 AM and 3:00 PM. These counts represented an additional service outside DESMAN’s original scope, so these counts were performed during the weekends of February 27th and March 4th, after mucg of the weekday observations were complete. Similar to the weekday occupancy surveys, at each facility visited, DESMAN personnel recorded the number of vehicles parked in designated parking spaces and those parked illegally.

As a general rule, weekend occupancy was extremely low, with only three facilities across the entire system achieving 50% of greater utilization. The summary of weekend occupancy and utilization surveys is presented on the following pages as Figures 5 and 6.

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2,800 Figure 5: Observed Weekend Occupancy along all MBTA Services Li2,700 nes 2,600 Inventory Occupancy

2,500

2,400 2,300

2,200 2,100

2,000

1,900

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1,700

1,600

1,500

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1,300 1,200

1,100 1,000

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200 100

0 Eliot Ayer Lynn Salem Butler Natick Halifax Lowell Sharon Milton Shirley Hersey Hanson Lincoln Waban Rowley Norfolk Alewife Ipswich Grafton Endicott Franklin Ashland Reading Islington Walpole Concord Andover Hastings Bellevue Readville Brockton Cohasset Abington Montello Whitman Bradford Highland Haverhill Campello Savin Hill Rockport Attleboro Ri verside Plymouth Waltham Braintree Mansfield Fitchburg Lawrence Hyde Park

Route 128 Lechmere Mattapan Fairmount Stoughton Wakefield Wollaston Woodland Greenbush Oak Grove Providence Gloucester Wellington Ballardvale Forest Hills Montserrat Beachmont Auburndale Wilmington Bridgewater Greenwood Newtonville Manchester West Natick South Acton Swampscott Wedgemere Wonderland Framingham Ch estnut Hill Wyoming Hill North Quincy Newburyport Kendal Green Westborough West Newton North Beverly Canton Center North Scituate West Roxbury Beverl y Farms West Concord Beverly Depot Quincy Center West Hingham Suffolk Downs North Billerica Southborough Quincy Adams Wellesley Hills Orient Heights West Medford Malden Center Sullivan Square East Weymouth South Attleboro Norwood Depot Canton Junction TF Green Airport Wellesley Farms Watertown Yard West Gloucester Norwo od Central Kingston/Route 3 South Weymouth Wellesley Square Brandeis/Roberts Worcester/Union Roslindale Village Wickford Junction North Leominster Needham Heights North Wilmington Hingham Shipyard Melrose Highlands Nantasket Junction Dedham Corporate Needham Junction Winchester Center Anderson/Woburn Holbrook/Randolph Hamilton/Wenham Littleton/Route 495 Melrose/Cedar Park Forge Park/Route 495

Pemberton Point, Hull Middleborough/Lakeville Source: DESMAN Weymouth Landing/East Braintree

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Figure 6: Observed Weekend Utilization

South Station 35% Weymouth Landing/East Braintree 1% East Weymouth 2% West Hingham 4% Nantasket Junction 1% Cohasset 2% North Scituate 3% Greenbush 1% South Weymouth 1% Abington 1% Whitman 0% Hanson 1% Halifax 2% Plymouth 0% Kingston/Route 3 1% Holbrook/Randolph 1% Montello 2% Brockton 1% Campello 1% Bridgewater 3% Middleborough/Lakeville 4% Route 128 18% Canton Junction 4% Canton Center 3% Stoughton 3% Sharon 4% Mansfield 6% Attleboro 0% South Attleboro 4% Providence 42% TF Green Airport 0% Wickford Junction 2% Fairmount 0% Readville 1% Hyde Park 3% Endicott 16% Dedham Corporate 1% Islington 0% Norwood D epot 1% Norwood Central 1% Walpole 0% Norfolk 1% Franklin 2% Forge Park/Route 495 2% Roslindale Village 3% Bellevue 5% Highland 7% West Roxbury 18% Hersey 0% Needham Junction 2% Needham Heights 3% North Station 42% New tonville 47% West Newton 6% Auburndale 0% Wellesley Farms 12% Wellesley Hills 22% Wellesley Square 7% Natick 75% West Natick 15% Framingham 21% Ashland 1% Southborough 7% Westborough 2% Grafton 6% Worcester/Union 10% Waltham 42% Brandeis/Roberts 29% Kendal Green 37% Hastings 17% Lincoln 3% Concord 22% West Concord 14% South Acton 2% Littleton/Route 495 8% Ayer 50% Shirley 0% North Leominster 0% Fitchburg 5% West Medford 35% Wedgemere 3% Winchester Center 9% Anderson/Woburn 1% Wilmington 3% North Billerica 2% Lowell 13% Wyoming Hill 0% Melrose/Cedar Park 12% Melrose Highlands 16% Greenwood 9% Wakefield 22% Reading 38% North Wilmington 15% Ballardvale 12% Andover 3% Lawrence 2% Bradford 9% Haverhill 3% Lynn 8% Swampscott 3% Salem 8% Beverly Depot 18% Montserrat 7% Beverly Farms 8% Manchester 6% West Gloucester 5% Gloucester 8% Rockport 9% North Beverly 7% Hamilton/Wenham 2% Ipswich 8% Rowley 0% New buryport 8% Watertown Yard 6% Pemberton Point, Hull 0% Hingham Shipyard 0% Lechmere 16% Chestnut Hill 30% Eliot 36% Waban 18% Woodland 15% Riverside 36% Forest Hills 12% Sullivan Square 86% Wellington 15% Malden Center 43% Oak Grove 25% Mattapan 6% Milton 11% Bu tler 16% Savin Hill 13% Braintree 9% Quincy Adams 5% Quincy Center 0% Wollaston 5% North Quincy 7% Alewife 25% Orient Heights 18% Suffolk Downs 14% Beach mont 8% Wonderland 14% 0% 5% 10% 15% 20% 25% 30% 35% 40% 45% 50% 55% 60% 65% 70% 75% 80% 85% 90%

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DESMAN estimates that the revenue generated from the parking facilities during the weekends may be lower than the annual cost of parking enforcement. If so, this might serve as an incentive to make parking at the MBTA facilities free on weekends.

3.3 Current Rates

As a part of the analysis, DESMAN recorded current parking rates at each of the 140 commuter rail, rapid transit, bus, and ferry terminals identified by the MBTA. It is to be mentioned that out of 140 facilities factored in the analysis, MBTA has control over 96 parking facilities and has an exclusive right to charge for parking and change parking fees as they see fit. The remaining facilities are operated by the towns or other public transit agencies, which have full control of revenue collection and parking rates at those locations.

The median rate to park at a station serviced by subway, bus or ferry is $5.00, as shown in Figure 7.

Figure 7: Daily Parking Rates at MBTA Stations along Subway, Bus or Ferry Service Lines

Some of these stations offered graduated rate scales, such as Wonderland, where the daily rate increased if the parker stayed over 12 hours or for more than one day, but the majority were flat rates for up to 24 hours. Most of the garages operated on a pay‐on‐foot format within a gated system, while lots operated as pay‐at‐exit, pay‐on‐entry or pay‐by‐phone.

Commuter rail stations operated at median rate of $4.00 per day, as shown in Figure 8 on the following page, with some variation according to the managing agency and the location of the facility.

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Figure 7: Daily Parking Rates at MBTA Stations along Commuter Rail Service Lines

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Figure 8: Monthly Parking Pass Rates at MBTA Stations

South Station Weymouth Landing/East Braintree East Weymouth West Hingham Nantasket Junction Cohasset North Scituate Greenbush South Weymouth Abington Whitman Hanson Halifax Plymouth Kingston/Route 3 Holbrook/Randolph Montello Campello Bridgewater Middleborough/Lakeville Canton Junction Canton Center Stoughton South Attleboro Providence TF Green Airport Fairmount Readville Hyde Park Dedham Corporate Islington Norwood Depot Norwood Central Walpole Norfolk Franklin Forge Park/Route 495 Roslindale Village Bellevue Highland West Roxbury Hersey Needham Junction Needham Heights North Station West Newton Auburndale Natick Framingham Ashland Southborough Westborough Grafton Concord West Concord Littleton/Route 495 Ayer North Leominster Winchester Center Wilmington Wakefield Reading Ballardvale Andover Lawrence Bradford Haverhill Swampscott Montserrat West Gloucester Gloucester North Beverly Hamilton/Wenham Rowley Newburyport Hingham Shipyard Watertown Yard Oak Grove Milton Butler Braintree Quincy Adams

$0.00 $50.00 $100.00 $150.00 $200.00 $250.00 $300.00 $350.00 $400.00 $450.00

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DESMAN found thirteen facilities providing free daily parking: Ayer, Beverly Farms, Concord, Endicott, Hastings, Ipswich, Kendall Green, Manchester, North Wilmington, Pemberton Point, Hull, Rockport, Shirley, and Wickford Junction. Only at three facilities ‐ all garages in urban centers (North Station, South Station and Providence Station) ‐ charged daily rates above $20. Selected facilities provide different pricing for regular parkers, commuters and residents (Lawrence) or are only available for residents via monthly permits (Natick and Winchester Center). As with the subway stations, the garages operated as pay‐on‐foot, gated systems. All of the surface lots directly controlled by the MBTA used pay‐by‐phone exclusively for revenue collection, while some of the facility owned or controlled by other agencies still used honor boxes, multi‐space and/or single‐space meters.

DESMAN identified a total of 82 stations, shown in Figure 8 on the prior page, which offer some form of monthly parking pass, including five subway stations, a bus station, a ferry terminal, three stations in urban centers, and 72 commuter rail stations located in suburban communities. Rates for the urban stations were the highest, reflecting the conditions of the surrounding downtown market, rather than those along the transit line. Passes for highly utilized subway stations were also steep relative to commuter rail stations. The majority of commuter rail stations controlled and managed by the MBTA charged $70.00 per month for a pass, while those parking facilities managed by other public agencies typical charged less, although some of these limited pass sales exclusively to residents.

3.4 Conclusions

Parking industry best practices hold that parking rates should be set relative to the utilization of a facility, with the target of such practices being to maintain high levels of utilization and still preserving some capacity for discretionary users or unusual events. The practice of ‘value’ pricing assigns a higher rate to those facilities running at or near capacity under the premise that the rate of utilization demonstrates the relative value of accessing the facility to the wider market.

Field observations show a widely varied rate of utilization across the system, but pricing appears to be largely universal for both daily and monthly parkers, with only slight variations for those facilities with the highest utilization. While there appears to have been attempt to introduce value pricing to some of the subway stations, which offer a greater frequency of service than commuter rail lines and therefore should command a higher price, commuter rail stations appear to be largely priced the same regardless of utilization. The sole exception to this practice appears to apply to those facilities outside of the MBTA’s influence to set pricing and all of these are actually priced lower than the MBTA’s current standards.

Based on this, DESMAN believes that part of any future strategy must include setting pricing at each facility relative to its historical rates of utilization. In the next section, DESMAN will explore conventional wisdom and best practice within the parking industry for setting rates relative to utilization as well as other factors.

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4. IMPACT FACTORS A number of factors impact the volume of vehicles parking at the MBTA’s subway and commuter rail stations and bus and ferry terminals and, as a result, the amount of parking revenue that can be generated. Obviously, the number of riders using the transit system is the primary factor affecting parking revenue generation. Of the total population of transit users, some portion will never arrive at a station or terminal via personal vehicles and will not generate any parking demand. However, of the portion of the transit user population that does regularly or occasionally drive and park at a station, several factors affect if those users will continue to park in the future. The costs associated with the vehicle trip, mainly the price of parking, have an impact, as does the amount of time it takes to get to the station. If any of these factors change in the future, it will impact the number of current transit users who park who choose to do so in the future.

Another factor considered by daily commuters and occasional riders is the ease with which one can find an open space at a given station and reliability that capacity will be available on a day‐to‐day basis. Development of new land uses, at the station itself or within the immediate area, can influence availability. This component of parking demand can come from either the developments themselves, such as shoppers or restaurant‐goers who need to park short‐term, or from transit users who previously parked in facilities that were eliminated in order to make way for development.

4.1 Transit Fares As part of the analysis into the impacts of the upcoming MBTA fare increases, it was determined how many riders are expected to be lost from each mode of transit. Table 1 presents the estimates of lost ridership for each mode as presented in the report “Potential MBTA Fare Changes in SFY 2017 Final Option: Impact Analysis”.

Table 1: Estimates of Annual Ridership Impacts (Unlinked Passenger Trips)

# Change % Change Existing MODE in in Ridership Ridership Ridership Bus 119,200,567 -1,603,262 -1.35% Heavy Rail 188,679,222 -3,111,620 -1.65% Light Rail 46,416,326 -796,979 -1.72% Commuter Rail 31,360,888 -370,947 -1.18% Ferry 1,181,046 -25,933 -2.20% Source: Boston Region Metropolitan Planning Organization

In addition to the ridership impacts presented in the above table, the analysis also made an assumption related to the impact on parking revenue of the upcoming fare increases. Per the impact analysis, it is anticipated that parking activity (revenue) will decrease by 0.94% in fiscal 2017.

Despite the fact that a decrease in parking activity of 0.94% is expected as a result of the impending fare increases, for the purposes of the parking revenue model, DESMAN chose instead to use the noted ridership change assumptions in order to model future parking revenue. In our opinion, if ridership decreases by the assumed volumes noted in the above table, it is logical to assume that parking activity

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will decrease proportionally – there does not seem to be any research which indicates that parkers will be less impacted by the fare increases than non‐parkers. Additionally, assuming more significant negative impacts to parking activity in the revenue model than are assumed in the fare increase analysis should ensure that the parking revenue model remains conservative.

4.2 Theory of Management by Pricing One of the most common principles in parking is that people’s parking behaviors can be influenced by pricing. Instead of designating where particular groups of people are permitted to park, parking spaces should be properly priced in order to distribute parkers in a way that all parking spaces within a system are well utilized. This practice is explored in great detail and championed in Dr. Donald Shoup’s The High Cost of Free Parking. This seminal work is considered one of the cornerstones of smart urban planning and Dr. Shoup, recently retired from the University of California at Los Angeles, is considered one of the leading authorities on sustainable parking policies.

Within The High Cost of Free Parking, Shoup notes that, based on industry research, a parking facility or system operates at maximum efficiency when its utilization peaks at no more than 85% of its capacity. At facilities where utilization peaks at over 85%, drivers searching for the last few open spaces experience substantial delays and frustration. This influences their perception of the experience, as well as their decision to patronize the facility at a later date, very negatively, which in turn drives down patronage of area businesses and services, including transit ridership.

Shoup argues that prices should be increased in order to move parkers from that facility to a facility which is cheaper and less well utilized. Conversely, underutilized facilities should have their prices decreased in order to draw more parkers. Changing prices can shift parkers who are more price sensitive to less utilized facilities that may be less conveniently located, freeing space in the most convenient facilities and making them more operationally efficient.

On a broad scale, this was the intent of the first Parking Freeze instituted in the City of Boston in the 1970’s. The intent of capping the number of publicly accessible parking spaces in downtown was expressly to reduce the number of commuters driving into the city each day, thereby decreasing automotive emissions. But, by capping the supply of a public good and still allowing demand, in the form of new buildings and institutions, to grow, the City also set economic conditions highly conducive to inflation of parking rates across the area. Access Boston 2000‐2010, the City of Boston’s last major transportation planning effort, found that the cost of off‐street parking had doubled between 1980 and 2000. Today, when commuters are deciding whether to drive into Boston or take the T, one of the factors influencing in that decision making process is the difference in cost between rail fare and parking at a T station and the $24.00 to $45.00 they will be charged to park in a downtown garage.

Setting the price of a parking asset relative to demand has been recently recognized and extolled as “demand responsive” pricing by many planners, but economists know the practice as classic supply and demand economics and note that the practice has been in place since private companies started charging for parking. Review of parking rates for commercial garages in downtown Boston over the years has revealed that a majority of parking operators charge lower rates for nights and weekends than weekdays, as demand is decreased at these times. Inversely, special event parking rates are generally higher than weekday rates to capitalize on the influx of unusually high demand triggered by the event.

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4.3 Parking Elasticity Elasticity in economics is defined as the measure of responsiveness of demand and supply of a good or service to an increase or decrease in its price. If the demand for a particular product or service increases or decreases with changes in pricing, the demand for the product or service is judged to be elastic. If the demand for the product or service does not change substantially with changes in price, the product or service is determined to be inelastic.

After an exhaustive search, DESMAN was unable to locate a predictive model for parking elasticity. The majority of research done of the topic has been case studies within contained environments such as corporate campuses1 or universities2 or studied the impact of introducing fee‐for‐use parking into formerly free parking environments3. While informative, these studies are not germane to this engagement, which seeks to measure price elasticity for parking at commuter rail stations relative other stations along the same line, within the system and relative to the larger metropolitan market.

Studies of historical parking revenues at MBTA stations before and after recent price changes show only marginal reductions in utilization associated with the rate change and no discernable shift in utilization between service lines or facilities along the same line. While this likely does occur in a limited number of cases, a review of data provided by the MBTA for this study does not indicate a material impact on parking demand. As such, DESMAN assumed that any changes in parking demand would be proportionate to changes in transit ridership as outlined in the most recent analysis of potential fare increases.

4.4 Fuel Cost At the outset of the engagement, it was DESMAN’s hypothesis that the cost of fuel might have significant impact on commuter’s mode choice, which would in turn influence parking demand at MBTA stations. DESMAN consulted several resources on this topic, including the following:

 Hongwei Dong, Linking Oil Prices, Gas Prices, Economy, Transport, and Land Use: A Review of Empirical Findings, Portland State University, January 2015.  Hiroyuki Iselki and Rubaba Ali, Net Effects of Gasoline Price Changes on Transit Ridership in U.S. Areas (MTI Report 12‐19), Mineta Transportation Institute, December 2014  Ashley Raye Haire, A Methodology for Incorporating Fuel Price Impacts Into Short‐Term Transit Ridership Forecasts, University of Texas at Austin, May 2009  Kevin Washbrook, Wolfgang Haider and Mark Jacard, Estimating Commuter Mode Choice: A Discrete Choice Analysis of the Impact of Road Pricing and Parking Charges, Simon Fraser University, 2006

1 Richard H. Pratt (1999), Traveler Response to Transportation System Changes, Interim Handbook, TCRP Web Document 12, DOT‐ FH‐11‐9579.

2 Moshe Farber & Erin Weld (2013), Econometric Analysis of Public Parking Price Elasticity in Eugene, Oregon University of Oregon Department of Economics, June 13, 2013.

3 Comsis Corporation (1993), Implementing Effective Travel Demand Management Measures: Inventory of Measures and Synthesis of Experience, USDOT and Institute of Transportation Engineers

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 William P. Nowak and Ian Savage, The Cross Elasticity Between Gasoline Prices and Transit Use: Evidence From Chicago, Transport Policy, Volume 29, pages 38‐45, 2013

This was a reasonable concern, as fuel prices have been steadily declining for the last two years. Should fuel prices rebound, which they have historically done as shown in Figure 9 on the following page, this could potentially improve transit ridership and parking demand at MBTA stations.

Figure 9: Historical Fuel Prices (2006‐2016)

As a general rule, all the resources consulted found that rising fuel prices do drive transit ridership, although the proportion of impact varied widely between studies. However, the general consensus was that ridership among daily commuters was generally inelastic in relation to fuel pricing. In other words, a periodic reduction in fuel prices does not generally cause the majority of commuters to switch to driving over transit usage, if they are already transit riders. In the short‐term, commuters who are currently driving may temporarily convert to transit riders if fuel prices increase significantly in a short time span. Definitions of the degree of increase and time period varied between works, but as a general rule it appears that the cost of fuel must rise by at least $1.00 within a six‐month period to have a significant influence on mode choice.

Additionally, all the works consulted noted that the impact on mode change was likely to be only in the short‐term as most users impacted significantly enough to shift mode to reduce commuting costs were also likely to look at moving the location of their home or job or converting to a more efficient vehicle as a longer term solution. Finally, several authors cited the fact that an increase in fuel prices typically impacts other aspects of the economy, including employment and that in the long term, increases in unemployment would most likely offset any gains in transit usage by daily commuters.

As the cost of fuel was at a five‐year low at the time that field observations were executed, DESMAN would anticipate that any precipitous escalation in fuel prices could only drive up parking demand and

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revenues at MBTA stations in the short‐term and support any recommended rate increases in the longer term.

4.5 Congestion DESMAN was unable to locate any resource which could reliably forecast changes in transit ridership relative to the degree of congestion on arterial roadways feeding into an urban center. DESMAN understands there is a relationship between the number of persons electing to drive into work each day and the amount of ‘friction’ or congestion along their travel path from conversations with private parking facility managers active before and after the opening of the “Big Dig”. Most parking managers reported a 5‐10% increase in utilization within 30 days of opening the tunnel, which resulted in faster travel times to downtown Boston from outlying suburbs. Anecdotal evidence from commuters interviewed at this time suggests that this increase in parking demand was driven by former transit riders converting to drivers when travel times and conditions improved.

Travel times, impacted by congestion in part, into downtown Boston have been on the increase, as reported by the U.S. Census Bureau and shown in Figure 10.

Figure 10: Reported Average Travel Times to Work for Boston, MA

DESMAN believes that congestion along arterials, as measured by average travel times, does influence mode choice, but cannot reliably quantify this impact at this time. As such, while these conditions were considered a supporting factor in considering any rate increase, they were calculated as driver.

4.6 Future Development The following section details emerging developments planned near MBTA stations with parking which may impact future conditions.

4.6.1 One Boston Way Development ‐ Newburyport, MA In 2013, commercial real estate developer MINCO Development Corporation acquired the property owned by the MBTA at 1, 4, 6, and 8 Boston Way in Newburyport, MA. MINCO Corporation proposed smart growth initiative to create a walkable, vibrant neighborhood in Newburyport, MA, by redeveloping an underutilized MBTA Parking Lot C adjacent to the MBTA Commuter Rail station.

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The Newburyport 2014 Master Plan includes a proposal to develop 22,000 gross square feet structure, consisting of 84 apartments and approximately 2,500 square feet comprised of shared office space and resident amenities.

The development will be supported by an underground parking garage with capacity of 53 spaces and 79 surface spaces, DESMAN projects the structure will generate demand up to 89 parking spaces on an average weekday4, which will be supported by the planned parking component despite the displacement of Parking Lot C. DESMAN does not project this project will have significant impact on parking supply and demand dynamics in the area

4.6.2 North Common Estates ‐ Mansfield, MA This project by residential developer Marco Crungale, a mixed‐use development to be constructed in vicinity of Mansfield Commuter Rail Station, was approved by the Planning Board on July 22, 2015. The project calls for two, four‐story buildings, containing approximately 7,000 square feet of retail space and 87,880 square feet of residential space with a total of 81 living units. The development is projected to revitalize the area and boost local economy by attracting more businesses and residents. The developer is aiming to attract a restaurant to the rounded corner of the structure that will be facing the MBTA station. A total of 142 parking spaces would be provided at the rear part of the building.

To estimate the parking demand generated by new residential component of 81 living units, DESMAN applied the base demand ratio of 1.46 cars per dwelling unit and found an average weekday parking demand for 118 parking spaces. Similarly, for the proposed 7,000 SF of retail (Fine/Casual Restaurant) space on the first floor of one of the buildings, DESMAN applied a basic demand ratio of 15.25 spaces/ 1000 SF to render an average weekday parking demand for 106 spaces for retail/dining component of the project. The demand estimates indicate that the parking supply for the project will be able to accommodate the new parkers from both residential and retail components of the development, so DESMAN assumed this project would have no impact on the parking dynamics at the station.

4 Demand based on 84 dwelling units with an average 1.46 vehicles per unit ratio (Institute of Transportation Engineers Parking Generation: 3d Edition) adjusted by 72.5% drive rate (based on US Census Bureau estimate per car, truck or van drivers in Newburyport, MA, commuting to work alone).

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In October, 2015, the Town of Mansfield was awarded more than $2 million in grant money to improve traffic operations around its downtown commuter rail station. The planned investment will purportedly create 18 new parking spaces for downtown business and allow for additional commuter rail parking. This will help accommodate more MBTA parkers and minimize the overflow of demand from the proposed mixed‐use development, if such occurs.

4.6.3 The Commons at Forest Hills – Jamaica Plain, MA The Commons at Forrest Hills is a first step in transforming the post‐industrial site which was used as a petroleum product distribution depot into a green and resident‐ friendly community. Currently in construction, the project envisions 280 rental apartments, 7,960 sq. ft. of commercial, retail and amenity space and 169 resident vehicle parking spaces.

Using a basic demand ratio of 1.46 cars per living unit5, adjusted by 39.1% drive rate6, DESMAN calculated the demand for 159 parking spaces generated by the residential component of the project. Similarly, DESMAN applied a ratio of 15.25 parking spaces/1000SF of retail space7 and adjusted that by a 39.1% drive rate to estimate an average weekday demand for 47 parking spaces from commercial retail space.

According to the BRA records, one of the project’s main objectives is to leverage the proximity to MBTA station, reducing automobile dependency and attracting young professionals from downtown who are used to commuting, do not require parking and do not mind a short walk from the train station to their house. As a result, DESMAN believes this project could have a nominal impact on parking conditions at the adjacent Orange Line stations. While the targeted potential residents might not have profound impact on parking demand, DESMAN anticipates that 169 resident parking spaces included in the project may not be adequate to service the development fully occupied with private and commercial/retail tenants. As a result, adjacent parking facilities, including MBTA station parking lot, may experience an overflow of parking demand from residents and visitors of the Commons at Forest Hills.

4.6.4 Waterfront Square Revere Beach – Revere, MA Eurovest Development has committed to transforming beachfront area adjacent to Wonderland MBTA station into a 1.3 million sq. ft. vibrant community with state‐of‐art landscape and public infrastructure. As a part of this TOD, large commuter parking lots around Wonderland are proposed to be redeveloped

5 Institute of Transportation Engineers Parking Generation: 3d Edition

6 Based on US Census Bureau estimate per car, truck or van drivers in Boston, MA, commuting to work alone.

7 Institute of Transportation Engineers Parking Generation: 4th Edition

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into residential, retail, restaurant, hotel, entertainment and office space, displacing as many as 800 existing parking spaces and roughly 600 daily commuters.

Source: Waterfront Square at Revere Beach by Eurovest Development, Inc.

The new Wonderland Multi‐Modal Center and the 1,465‐car parking garage are already complete. The project’s Master Plan also includes 901 multifamily residential units, a 120‐200 key hotel, a 165,000 sq. ft. office building, and up to 80,000 sq. ft. of retail space, all of which are expected to drive new parking demand in the area and impact availability in the Wonderland Garage.

Large displacement of parking spaces and increased demand for parking from the emerging developments around Wonderland will create opportunity for generating additional revenue through higher parking rates. DESMAN observed that Wonderland garage and surface parking lot adjacent to the Transit Center are currently experiencing 77% weekday utilization. With new developments underway, the garage will not be able to accommodate the demand from new residents/hotel guests/ office workers and visitors unless the MBTA management converts to higher rate structure, providing incentive for North Shore commuters to use the commuter rail stations in their communities.

4.6.5 Readville Yard 5 Industrial Redevelopment Project – Hyde Park, MA In 2014, First Highland Management and Development Corporation proposed to redevelop an underutilized rail yard within a short walk of MBTA into a light industrial, manufacturing and office space that would enhance infrastructure and boost local economic development. A mixed‐use development will include construction of 6 buildings (A,B,C,D,E, and F) of various sizes and use, totaling approximately 375,000 sq. ft. The Project will contain approximately 333,000 sq. ft. for light‐industrial and manufacturing buildings A through E, and approximately 42,000 sq. ft. for office building F. The project will provide 250 parking spaces.

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Source: Boston Redevelopment Authority

Based on assumption of light‐industrial space taking up to 166,500 sq. ft. and employment space conversion factor of 800 sq. ft./employee, employment capacity in light‐industrial component of the project is 208 employees, capable of generating an average weekday demand of 132 parking spaces.8 Similarly, using the base ratio of 1.18 spaces/1000 sq. ft. of manufacturing space9, DESMAN calculated that 166,500 sq. ft. of manufacturing space is projected to need up to 148 parking spaces on an average weekday, while office space component will require up to 108 parking spaces10. In total, the facility will need up to 388 parking spaces to accommodate its employees on an average weekday.

Adjusting for the employees who will use bicycle parking (approximately 2.4% of commuters use bicycle to get to work in Boston), DESMAN anticipates the overflow demand of up to 129 spaces into the adjacent MBTA parking lot on an average weekday.

4.6.6 Orient Heights Redevelopment Project – East Boston, MA On February 2, 2016, Trinity Financial submitted a letter of intent to redevelop public housing area in Orient Heights into an urban community with new market rate units, community center, Public Park and

8 Based on a ratio of 0.85 spaces/employee (Institute of Transportation Engineers Parking Generation: 3d Edition) and adjusted by 75.3 % drive rate ( US Census Bureau).

6 Institute of Transportation Engineers Parking Generation: 3d Edition.

7 Based on a ratio of 3.44 spaces/1000 sq. ft. (Institute of Transportation Engineers Parking Generation: 3d Edition) and adjusted by 75.3 % drive rate ( US Census Bureau).

8Where We Ride: Analysis of Bicycle Commuting in American Cities, The League of American Bicyclists, 2014.

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improved traffic connectivity. Starting in fall 2016, Trinity Financial intends to demolish 331 existing public housing units and construct 373 new units in two‐five story buildings. Although the letter of intent does not specify the amount of planned parking supply, it states that the project will create a combination of on‐street and off‐street parking to accommodate new tenants.

New developments in Orient Heights are continuing to absorb existing parking, while housing in East Boston is at an all‐time high for demand. Considering that the project will revitalize the neighborhood and make it more appealing for local businesses and new tenants, DESMAN anticipates increasing demand for parking spaces in the area. MBTA parking lot at Orient Heights station has the potential to capture some of the overflow demand from the development once it is complete.

4.6.7 The Residences at 1181 Bennington Street ‐ Revere, MA In May, 2015, a local developer Velkor Realty Trust has proposed to replace Orient Heights garage and auto repair shop at 1181 Bennington Street with a new four story apartment building. Conveniently located a short walk away from Suffolk Downs MBTA Station, the project will qualify as a Transit Oriented Development and will construct 44 residential units along with 44 parking spaces in the garage beneath the building.

The final planned parking supply for the project may be inadequate to support the parking demand. Project review estimates indicate that the building will require at least 79 parking spaces11. Accounting for scale of this development and demand for parking spaces it is expected to generate, DESMAN anticipates the demand for parking spaces to spill over into 110‐spaces parking lot at Suffolk Downs MBTA station that is currently running at 46% utilization on an average weekday.

11 Calculation is based on a ratio of 2.0 spaces/unit above 10 units (37 market rate units x 2.0=74 spaces) and a ratio of 0.7 spaces per affordable units (7 affordable units x 0.7=4.9 spaces). (Application for Article 80 Small Project Review, BRA, May 19, 2015).

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5. IMPACT MODELLING

5.1 Methodology In order to develop projections of potential future revenue generation under various parking rate scenarios, it was necessary to use the factors described above, along with assumptions about longer‐term ridership growth. Historical revenue and transaction figures were used as a baseline for the future performance of the system. Historical parking revenue data for the facilities owned/controlled by the MBTA was gathered for FY11 through YTD FY16 and summarized on a monthly basis. With only six months’ worth of FY16 revenue data available, the FY16 revenue was annualized based on the historical pattern of revenue generated in the first six months of the year versus the second six months – roughly a 50/50 split.

Onto the historical figures were layered the anticipated ridership impacts from the recently‐approved fare increases in order to determine the anticipated number of MBTA riders and, in turn, the number of riders using the MBTA’s various parking facilities. From there, we developed a series of rate recommendations and made some assumptions as to the effect of parking price elasticity on the demand for parking.

5.2 Status Quo Scenario The “Status Quo” scenario was developed in order to demonstrate the anticipated parking revenue generated if the current parking rates are maintained. In this scenario, the only variable affecting parking revenues is the effect of the upcoming fare increases. By projecting the “status quo” parking revenues, we are then able to determine an approximate number of parkers at each station that can be inserted into each of the subsequent parking revenue scenarios.

As discussed previously, instead of decreasing FY17 parking activity by the 0.94% presented in the Impact Analysis, the “Status Quo” model applies the ridership decrease assumptions for each mode split to each station, as applicable. For stations that largely serve commuter rail customers, a factor of ‐1.18% was applied; for primarily subway stations, the “Heavy Rail” factor of ‐1.65% was applied; for the Green Line (light rail), a ‐1.72% factor was applied, and; for stations serving a combination of modes, the factors were averaged together, excluding bus. For two stations with both commuter rail and express bus service, Brandeis/Roberts and West Newton, the bus factor of ‐1.35% was averaged together with the commuter rail factor. These were the only stations where, according to the MBTA, a significant number of bus passengers may drive and park at the associated MBTA parking facilities.

Using the lost ridership estimates provided by the MBTA, FY17 parking revenue was estimated based on a scenario in which parking rates would not change. Revenues in FY18‐FY21 were then projected based on assumed ridership growth averaging 1% annually over each of those years (this ridership growth factor was an assumption made by DESMAN as no better estimate was available at the time of this report).

Under this scenario, FY17 parking revenue from all sources is projected to be approximately $47.4MM, increasing to $49.3MM in FY21. A more detailed summary of the anticipated revenue generated in this scenario, as well as the subsequent scenarios, is presented later in Table 2.

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5.3 Realistic Scenarios With the “Status Quo” scenario establishing the anticipated number of parkers that would continue to park in MBTA facilities given the upcoming fare increases and no parking rate increases, it is time to create revenue projections for a number of “Realistic” scenarios. As the name implies, the rates in the “Realistic” scenarios are what we think the MBTA may be able to implement with moderate public pushback and only minimal loss of customers.

In each of the below scenarios, at the facilities observed to have peak utilization of 85% or higher, a $1‐ $2 increase in the Daily Rate was modeled ($1 at facilities currently charging $4 per day and $2 at facilities currently charging more than $4 per day). Once the Daily Rate was established, the increase in the Monthly Rate was determined by multiplying the Daily Rate by 17.5 and rounding to a logical whole dollar amount – the 17.5 times multiplier was based on the current relationship between the $4 Daily Rate and the $70 Monthly Rate.

For each scenario, a group of facilities within a certain peak utilization range were assumed to maintain their current parking rates – these will be described in more detail, below.

Finally, each scenario assumed that the facilities whose peak utilization did not reach a certain threshold would have their Daily and Monthly parking rates reduced, both to draw parkers away from over utilized facilities and to give the MBTA a positive public relations talking point.

All parking rate changes were assumed to take effect as of January 1, 2017, in order to give the MBTA’s customers time to adjust to the upcoming fare increases.

5.3.1 60% Scenario As with each of the “Realistic” scenarios, rates at the facilities with peak utilization at or greater than 85% were increased in the “60% Scenario”. The $1 and $2 increases in Daily Rates were paired with $20 increases in Monthly Rates.

At the parking facilities with observed peak utilization ranging from 60% to 84%, the current parking rates were maintained.

The 25 parking facilities with observed peak utilization under 60% had their Daily Rates lowered by $1 and their Monthly Rates lowered by $15, again to try and preserve the current Monthly/Daily ratio.

Price elasticity factors, based on parking industry best practices and data provided by the MBTA, were then applied to each parking facility based on the proposed rate change. Ultimately, the price elasticities used in this model are actually more aggressive than the factors commonly used in the parking industry. Typically, a price elasticity of 0.30 is used when describing the effects of a 100% increase in price. This model assumes a 0.30 elasticity applies when prices are increased by 50% or more. Lower elasticities were assumed for lesser rate increases (ranging from ‐0.05 to ‐0.30). Additionally, at the facilities where parking rates were decreased, the elasticity factor was set to reflect the potential shift of parkers from the higher‐ cost facilities to these lower‐cost facilities.

As in the “Status Quo” scenario, after FY17, the only factor affecting revenue is anticipated annual ridership growth, currently assumed at 1% per year.

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Under this scenario, FY17 parking revenue from all sources is projected to be approximately $50.0MM, increasing to $54.8MM in FY21. A more detailed summary of the anticipated revenue generated in this scenario, as well as the subsequent scenarios, is presented later in Table 2.

5.3.2 50% Scenario In the “50% Scenario”, rates at the facilities with peak utilization at or greater than 85% were increased. At the parking facilities with observed peak utilization ranging from 50% to 84%, the current parking rates were maintained. The 18 parking facilities with observed peak utilization under 50% had their Daily and Monthly rates lowered. After FY17, the only factor affecting revenue is anticipated annual ridership growth of 1% per year.

Under this scenario, FY17 parking revenue from all sources is projected to be approximately $50.1MM, increasing to $55.0MM in FY21.

5.3.3 40% Scenario In the “40% Scenario”, rates at the facilities with peak utilization at or greater than 85% were increased. At the parking facilities with observed peak utilization ranging from 40% to 84%, the current parking rates were maintained. The 11 parking facilities with observed peak utilization under 40% had their Daily and Monthly rates lowered. After FY17, the only factor affecting revenue is anticipated annual ridership growth of 1% per year.

Under this scenario, FY17 parking revenue from all sources is projected to be approximately $50.2MM, increasing to $55.2MM in FY21.

5.3.4 30% Scenario In the “30% Scenario”, rates at the facilities with peak utilization at or greater than 85% were increased. At the parking facilities with observed peak utilization ranging from 30% to 84%, the current parking rates were maintained. The eight (8) parking facilities with observed peak utilization under 30% had their Daily and Monthly rates lowered. After FY17, the only factor affecting revenue is anticipated annual ridership growth of 1% per year.

Under this scenario, FY17 parking revenue from all sources is projected to be approximately $50.2MM, increasing to $55.2MM in FY21.

5.4 Optimal Scenario The process for creating the “Optimal” scenario was the same as that for the “Realistic” scenarios, except for assumptions about rate changes. The parking rates in this scenario are what would be recommended to maximize revenue and effect behavior changes, if public relations considerations were not a factor.

The “Optimal” scenario assumes that rates any facility less than 60% utilized would not change, at facilities that were 60%‐84% utilized, the Daily Rate would increase by $1 and the Monthly Rate by $20 and at facilities at 85% utilization or above, the Daily Rate would increase by $2 and the Monthly Rate by $35. These rate changes are aimed at affecting the greatest influence on parker behavior by pricing some users out of the most highly utilized facilities, while also generating the greatest amount of revenue.

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Under this scenario, FY17 parking revenue from all sources is projected to be approximately $51.5MM, increasing to $57.9MM in FY21.

Table 2 – Summary of Projected Revenue from Various Modelling Scenarios

PROJECTED PROJECTED PROJECTED PROJECTED PROJECTED SCENARIO FY 2017 FY 2018 FY 2019 FY 2 02 0 FY 2021

STATUS QUO 47,406,247 47,880,309 48,359,113 48,842,704 49,331,131

REALISTIC (60%) 50,016,679 53,150,481 53,681,985 54,218,805 54,760,993

REALISTIC (50%) 50,116,146 53,351,404 53,884,918 54,423,767 54,968,004

REALISTIC (40%) 50,230,434 53,582,266 54,118,089 54,659,270 55,205,862

REALISTIC (30%) 50,249,986 53,621,761 54,157,979 54,699,558 55,246,554

OPTIMAL 51,510,483 56,167,966 56,729,646 57,296,942 57,869,912

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6. CONCLUSIONS/ RECOMMENDATIONS

The MBTA should consider a modest rate increase for facilities operating at 85% or greater utilization in the near future, if only to create a cushion of capacity against discretionary riders arriving later in the morning to overused facilities. However, on the heels of the most recent fare increase, DESMAN would recommend holding off on implementing rate changes until at least six months after the fare increases are implemented, for fear of alienating already disenfranchised riders.

Additionally, DESMAN strongly recommends the MBTA consider one of the “realistic” scenarios, which pairs strategic rate increases in high demand facilities with proportionate rate reductions in underused facilities. While this will temper any financial gain from instituting changes, DESMAN believes it will be better received by the general public than a wholesale increase in prices.

Similarly, if the cost/benefit of collecting for parking on weekends in commuter rail stations does not indicate a net positive result, DESMAN would recommend the MBTA consider terminating this practice when any rate increases are implemented.

For those facilities adjacent to emerging developments, DESMAN would recommend the MBTA begin performing periodic occupancy counts to monitor utilization in these facilities and consider a policy of adjusting the parking rate by $1.00 increments for every 5‐10% increase in typical utilization in order to maintain a target utilization threshold of 85%.

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