Karnataka’s Urban Development Department, through the Directorate of Urban Land Transport (DULT), has prepared a draft Parking Policy for Bengaluru city. Citizens can send their feedback on the policy to DULT until May 15.

DULT says the policy has been formulated to achieve the following goals in a systematic and time bound manner:

1. Move from chaotic parking to well-organised parking
2. Move from free parking to paid parking
3. Move from government-driven parking supply to market-driven parking supply and management
4. Move from passive and weak enforcement of parking regulations to active management of parking demand.

Comments on the proposed parking policy

• The policy aims to actually encourage private vehicles!

Bengaluru’s CMP (Comprehensive Mobility Plan) aims to increase the trip-share of PT+IPT* from the current 48% to 73%. This can be done only by developing a PT and IPT that is loved by the public to such an extent that they can readily give up the idea of possessing cars or two-wheelers. That means the PT and IPT must be safe, fast, reliable, cheap and comfortable.

At the same time, BBMP must make it difficult and painful to own and use private vehicles. This includes taxation, congestion charges, slower lanes and lack of parking slots. But the Parking Policy actually facilitates private transport by making parking slots available across the city at cheap rates, thus makes it harder for the public to switch to PT!

* PT=Public transport (BMTC buses, Metro, rail);
IPT=Intermediate Public Transport (auto, shared auto, taxi, shared taxi)

• The planning is done without any TDM data!

On the demand side, no TDM (Travel Demand Modeling) was done to find the parking demand for each TAZ (Traffic Analysis Zone)*. On the supply side, the policy assumes that the model is scalable, and any number of parking slots can be generated in the off-street category.

Thus, we do not have any reliable data for today, or projection for the future.

* The same Travel Demand Modeling can serve both CMP and the Parking Policy. (Actually the parking policy should be an integral part of the CMP).

• The policy does not anticipate the dilemma faced by car owners

Once the Parking Policy is put in motion, the city is going to have a huge number of vehicles that do not have a parking slot at all, and desperate owners will take up slots that are too far away to be of any use. In the long term, the only option left for them would be to sell the car.

But a glut of cars in the market will crash the prices. Thus car owners will not find this option palatable. A solution needs to be found for this.

• The implementation strategy is extremely poor

If PT+IPT are made popular first, people will easily give up personal vehicles, especially over a longer time-frame when choosing the next car/two-wheeler. But if the Parking Policy makes a dramatic entry first, people will think that BBMP is trying to snatch away their available parking slots. Commuters will hate this proposal of losing the parking that they took for granted for so long.

So, the situation calls for strengthening of PT+IPT long before imposing restrictions on parking. It also calls for a well-laid marketing campaign to popularize PT+IPT. (It should not be just empty slogans; the service must really reach fantastic levels, and win the hearts of citizens.) BBMP must identify an able administrator and give them free reign to achieve this.

• There is no leadership to drive this delicate change

After successfully implementing the PT+IPT, the PP (Parking Policy) can be introduced. Even at that stage, people would be asked to make sacrifices (though they have never been entitled to park on public roads). Such a programme can be successful only if a powerful and popular leader with a vision drives its implementation, without getting swayed by the criticism. This leader could be a BBMP Commissioner or a political leader. At present, the Parking Policy is not led by any such leader, and will definitely fail.

This calls for a dedicated authority (UMTA/BMLTA) with proper authority over mobility assets belonging to BMTC, BBMP, BDA, Metro, KSRTC, etc.

• Confusion between permit system and off-street parking

Page 16 para 5.5.5 states that the limited on-street parking is meant for short-term parking needs; and the long-term parking needs must be met through off-street parking. If this is the logic, then why do we need permits for on-street parking? It should be managed through pay-and-park!

• Revamp parts of the city before launching parking policy

Several areas of the old city (Avenue road, Chikkapet, Balepet, BVK Iyengar Road, SP Road, etc.) need urgent revamping for fire/life safety perspective rather than traffic management aspect.

1. Highly inflammable material is stored in cramped buildings with no ventilation
2. The buildings have narrow and steep staircases
3. The buildings have no fire exits. 
4. The roads are narrow, with cables strung across; which would prevent fire engines from coming. 
5. The lanes are blocked with wheelbarrows and cycle rickshaws. 
6. The footpaths are occupied by parked motorcycles. 
7. The area does extremely high-volume business. That means a huge crowd is attracted to these areas. The resultant dense crowds can only shuffle (as opposed to brisk walking).

When these areas are revamped, the parking needs of the area will change drastically. Therefore this should not be postponed till later.

• Shift the people hubs out of the city first

Large people and goods hubs need to be shifted out of the city, so that the traffic becomes decentralised (ref: 5.6.1). 

These centres include the Inter-State Bus Terminus (ISBT) at Majestic, City Market, the private bus station at Kalasipalya, Vegetable market at Kalasipalya, etc.

• Parking zones are too large!

The policy calls for parking zones of 2-10 sq km area, which means that the parking-to-work distance can be up to 5 km. This is too large. To manage this, define a maximum walking distance. But if the IPT facility is strong in the area, this hybrid model (“park and catch IPT”) can work.

• The parking-slot finder app must show taxi slots separately

Page 12 para 5.3.3.5 refers to a mobile app made by BBMP that shows the number of parking slots available in different parking lots in real time. Taxi operators must get a separate count for their own slot type.

• Variable price during the day (peak and off-peak)

According to Dr Donald Shoup, an urban planning professor at UCLA, parking prices must be kept variable (depending on the time of the day and place). Too low a price attracts too many users, whereas too high a price leaves the lot empty. Thus the goal is to maximise the price with near full occupancy.

• Ban the queues that build up on the road

Apart from regulating off-street parking, also ban the vehicle queues outside malls, tech parks, etc that routinely block traffic. They must upgrade their ticketing and security scanning process to prevent the queue from spilling on to the road. 

Most often, the solution is to shift the ticketing window farther inside the building, so that the queue can be accommodated within the premises.

• No parking near a junction

On page 12, in para 5.3.4, DULT must add: No parking should be allowed within 250 m of any Y-junction (split / merger) or a T-junction (even for a U-turn). This is to ensure that vehicles approaching the junction (of any type) have sufficient maneuvering space). For the same reason, autos waiting at the corner of a crossroad must be punished harshly.

• No parking near entry/exit gates of people hubs

On page 12, in para 5.3.4, add: No parking within 250 m of entrance/exit gates of major people hubs – tech park, mall, school, college, wedding hall. This is because often the queues at entry and exit gates of these places block one lane of the road. If parking is allowed, then totally two lanes would get blocked.

• Bar hawkers from parking areas

On page 11, DULT must add: No hawkers shall be allowed to occupy the space identified for parking.

• Specify the minimum guaranteed LOS

On page 12, para 5.3.3.2 states that parking must not impact vehicular or pedestrian movement. While this statement looks impressive, it means nothing. Over time, the situation would degrade, and yet it would not trigger corrective action.

DULT must specify the minimum guaranteed Level of Service (LOS) for both vehicles and pedestrians. If the actual LOS falls below this guaranteed limit, the parking provision must be removed.

• Charging of electric vehicles

It is projected that the future belongs to electric vehicles. But these vehicles cannot be charged fast. This problem can be solved if the vehicles can be charged while parked off-street.

Hence, in all off-street parking facilities, a certain number of slots must be reserved for charging of electric vehicles. (This calls for standardisation of charging connectors and charging current.)

• The formula for off-street parking is wrong

The parking would be occupied only for 16 hours every day. Therefore the formula calculates the hourly rate based on 16 hours/day instead of 24 hours/day. 

In addition, this formula has several other shortcomings: 

1. BBMP aims to recover the land cost in 30 years. But the land is not free. So the formula should recover its carrying cost.
2. The O&M costs would go up due to inflation. Therefore this component must be revised each year (typically it would rise by 8% each year). 
3. After 30 years, BBMP will have to demolish the aged building and construct a new one.  At that time, it will still have the land in its own possession. Therefore, the land should not be amortised over the next 30 years, but the NPV of the demolition cost should be considered.
4. The parking scheme as a whole must be financially self-sustained. So, it must generate enough revenues to enable BBMP to construct additional parking buildings every n years. At that time, the land prices would have gone up due to inflation and appreciation of land. This margin needs to be added.

• Revenues from this scheme can help make public transport self-financed!

Public transportation agencies (BMTC and KSRTC) have been in financial distress for a while. After the COVID-19 outbreak, their lack of revenue has made the situation extremely precarious.

Even if we assume that 5% of vehicles will use the permit system, BBMP will earn Rs 350 cr annually. And the remaining 95% of the vehicles are bound to earn money at a much higher rate. This amount is much more than the annual loss suffered by BMTC (Rs 200 cr). Thus our public transport can really afford to make a quantum leap based on this single source of finance

• Do not provide on-street parking if FAR or setback is violated.

The on-street parking permit scheme must not be extended to those who violated their FAR or setback limits. Similarly, illegal restaurants, gyms and offices set up in residential buildings require much more parking space. They also should not be facilitated by providing them with extra parking.

This scheme effectively extends the plot area at a throw-away price! Why encourage encroachment? Where is the punitive pricing? This is unfair to law-abiding citizens who provided for off-street parking within their plots.

If BBMP officials were responsible for sanctioning such faulty plans, they must be punished. Certainly BBMP is not duty-bound to honor such underhand deals.

• The permit is too cheap!

Ref page 12 para 5.4.5. Why is DULT giving away prime land as parking space at only 3% of the land price?

• How to decide whether a road carries only local traffic?

In page 13 para 5.4.4.1, it is difficult to assess whether a road carries local traffic or through traffic. If the road is part of a grid, it will always attract through traffic. The only exceptions are the blind alleys (with dead ends).

• Problems in permit system

In page 14, para 5.4.5, there are several issues:

1. What is the strategic purpose of having short-term permits? (ref: part c)
2. Why is a very meek approach being adopted? The roads belong to the public, and no one can encroach it. Therefore BBMP should be able to adopt a suitable pricing policy. But 3% of market land rate is just too low! (ref: part d)
3. Why is there a ceiling amount (ref: part d)? When the land prices are highly expensive, the slots also would be expensive. Why is there a need to subsidise the price of a slot?

• BBMP must finish its road inventory

In para 5.4.6.2, BBMP should also complete its road inventory, which is pending for a long time. This will give us an insight into which road takes up how much money in making and then annual upkeep.

• Why are we giving one year to vehicles without parking?

Legally, all vehicles are supposed to have off-street parking by default. The owners of vehicles that don’t have off-street parking would be waiting for almost a year, for the completion of the inventory of parking slots. At this time, why should we give them one more year to find a slot (ref: para 5.4.6.6, page15)?

Two more months are enough to know whether they would be able to get a parking slot.

• BBMP must solve the common area parking problem in apartments

The fight over scarce slots would re-open an old wound that is festering for long:

All apartments are supposed to have 10% of the total car slots for visitors. But in most cases, the builder has sold these slots to some of the owners illegally. These slots cannot be registered in the name of those “owners”, thanks to a protection provided in the KAOA.

When the new parking policy creates a shortage of on-road slots, the visitors coming to an apartment would have to be accommodated in the compound. However, since these slots are already claimed by some of the owners, the visitors cannot park their car inside the apartment. Thus they would have to park in the nearest public parking areas and take a taxi. Or come the whole way by taxi. This is going to create a huge fight.

• The implementation of the policy hinges on three unreliable partners!

The policy leaves a major part of implementation to BBMP, Traffic police and BMTC. However, the past track records of these three partners has been quite disappointing.

1. BBMP

The policy requires BBMP to keep a vigil and book violators of the Parking Policy (ref: 5.4.6.7, page 15). But this will not work out practically. Measures suggested in para 5.9.3.2 and para 5.9.3.3 can work only if BBMP has honest and diligent staff. But BBMP has an impressive track record of incompetence, such as the ineffective Sahaay helpline, or the dysfunctional Solid Waste Management programme, or the non-existent lake management. 

Thus there is no doubt that BBMP will make a mess of this nice-looking proposal also. 

First of all, BBMP does not have enough staff to keep a watch in all residential bylanes; especially after office hours. Second, there is a good chance that the offenders will pay a  bribe and continue violating the system.

Therefore, the implementation should be based on the principle of self-interest: Let the public use the app to capture a photo of the violation, and upload a complaint (ref: 5.4.6.8). The fine should be split 50-50 between BBMP and the initiator. This is a powerful motivation for everyone to keep the vigil, and keep the streets trouble-free.

It must be noted that a similar policy was proposed in 2012, and rejected by the BBMP council. This highlights the need for a framework that is mandatorily imposed on all ULBs: If left to the whims of councillors, some ideas will be shot down by vested interests.

It is also a fact that BBMP is duty-bound to implement the parking policy. When Metro was set up in 2017 as a Special Purpose Vehicle, one of the preconditions in its MoU was that all parking in the city would attract parking fees that are based on the market price, and would not be free. However, this condition is not met even after three years of Metro. A PIL has been filed in the Karnataka HC based on these MoUs. Thus BBMP cannot evade this issue any longer.

2. Traffic Police 

The policy wants the traffic police to monitor the traffic violation in parking. But the traffic police is stretched beyond its limits, and its current function is mostly limited to VIP bandobast. For example, out of 40,000 intersections in the city, 39,000 are totally unattended. 

At present, the traffic police are unable to catch people who drive on the other side of the road to jump a queue at a signal, or those who drive on the footpath. Given this pathetic performance, how can this policy rely on the traffic police?

3. BMTC

Even in case of BMTC, the CCTV cameras mounted for women’s safety are mostly stolen. Their much-touted programme of Bus Priority Lane failed due to poor planning. And the worst part is, BMTC has not learned lessons from that spectacular failure. So BMTC will not be able to participate in the multi-agency vigilance programme envisaged in the policy (Ref: para 5.9.3.3).

This will never work unless accountability is set up and people are punished for laxity or poor performance.

• Terms & Conditions need clarification

1. Is a permit linked to a particular vehicle? Can the owner park his other cars?
2. Can a permit for one car be used to park two two-wheelers?
3. Can anyone request for a permit without a vehicle?
4. Can the permit be transferred (sold) to others, or will they have to be surrendered?
5. When a permit is surrendered prematurely, will there be a refund?
   If yes, will it be pro-rata?
6. When a vehicle is transferred, what happens to the permit?
   (In most cases, the buyer is not a neighbour living in the same street!)

• Develop engineering standards for parking slots

In many multi-storeyed malls in Bengaluru, the entry and exit ramps are unsafe.

1. The width is too narrow; not comfortable for large vehicles like Innova
2. The slope is too high. The combination of slope and turning needs high driving skills.
3. The drivers have to stop at each floor to check if there is a free slot. All the following cars have to stop on the steep gradient and start on the incline. Many cars stall and roll backward. This is a dangerous situation for the cars that follow.

Suitable standards must be set to avoid such problems.

• Prevent harassment of innocent public

Sometimes the towing agency harasses innocent people who have parked their car in a legal place, by claiming that it was parked illegally somewhere else. Technological solution is needed to prevent such malpractices. 

• How to catch wilful violators

Some taxi drivers feign a fault in the engine by turning on the flashers (emergency lights) and/or opening the hood. But in reality they are waiting for their passengers. Make towing mandatory for such vehicles, to discourage this practice. 

At minimum, they must pay towing charges even if the vehicle is not actually towed to a garage.

• How to handle abandoned vehicles

Often the multi-storeyed parking slots are used for vehicles that are abandoned. These vehicles could have been used by criminals and dumped in such unattended places to avoid detection. Vehicles parked beyond a certain threshold must be removed and handed over to the police.

• Traffic police must have its own dumping yard

Often on-street parking is created by the police itself: It does not have a time-limit for storing damaged, stolen, seized or unclaimed vehicles. Over time, such vehicles go on accumulating at the police station. Finally they start making use of the nearby public roads to dump such vehicles (some of which are scrap, actually).

Similarly, the Traffic Police also has no storage space for their barricades and sign-boards. These are also dumped on the footpath.

A solution must be found to solve this perennial issue.

•  Misc suggestions

1. Ban entry of private passenger vehicles on busy commercial streets (e.g. Avenue road, BK Iyengar road, etc). Allow only pedestrians and goods vehicles.
2. For each high-density commercial place, provide a high-frequency shuttle to connect it with a public transport hub, from where connecting routes take the passenger across the city.
3. Vehicles needed to carry goods locally in commercial areas (e.g. hand carts, tempos, tricycles) must have exclusive parking slots at both ends.
4. Often vehicles wait in the main lane, waiting for a free slot. This must be banned, and violators must be punished heavily.
5. Rented scooters and motorcycles must be treated at par with private vehicles, as they are not NMT (Non-motorised transport).
6. Rented bicycles must be exclusively used for last-mile connectivity only. They must be banned on all major roads (arterial, peripheral). Provide exclusive parking for them.
7. At all places, the parking charges must be based on Fastag, so that all delays can be eliminated. (Security check is the sole delaying factor.)
8. On p12, in paragraph 5.3.3.3, add that the parking space may have to be modified to suit the parking/docking/charging needs of these vehicles.
9. The policy does not specify that on-street parking permits are locked to a particular vehicle, and cannot be used for any other vehicle.
10. Provide a special type of slot when a business uses multiple vehicles for delivery of goods (e..g. pizzeria). They may need a parking bay for a specified number of vehicles. This parking area would have clear marking for each vehicle (to prevent overcrowding and abuse).
11. In 5.7.2.2 data format, include total slots that are designed in a facility, and also slots that are unusable for any reason. Ideally, there should not be any unusable slots at all. Therefore any such slots must be investigated.
12. In 5.1.8 (page 7), calls for review of parking demand every 2-3 years. In government work, such long-term tasks are simply forgotten. Instead, it should be made annual.

In fact, the data is going to be huge, because it is real-time (e.g. BMTC produces 1 TB/day of data.) So there should be more frequent analysis to keep it simple (e.g. monthly). 

I also hope the revised version corrects  “disable parking slot” in para 5.7.3.8 to “parking slot for the disabled”.