Are shower requirements like minimum parking requirements

In the on-going argument between Randal O'Toole and Donald Shoup about parking minimums and the high price of free parking, O'Toole asks if DC's zoning shower requirement unfairly subsidizes cycling.

Cato is currently expanding its building and I understand it is installing showers for cyclists, as required by DC zoning codes, and is not providing a cash-out option for cyclists (or other employees) who do not plan to use those showers. As a cyclist, I’ll probably use those showers from time to time on my visits to DC. Perhaps someday Dr. Shoup and I will write a paper titled, “The High Cost of Free Showers.”

There are some key difference of course. Both DC and the federal government have stated goals to reduce the number of miles driven and encourage more people to bike to work. It's reasonable to "subsidize" things you want to encourage. It is unreasonable to subsidize behavior - like driving - while simultaneously trying to encourage people to not do that behavior.

And the decision to require showers was not made in a vacuum. The fact is that driving and parking are heavily subsidized, so this zoning requirement balances the field. If all free parking were taken away and we charged a price for gasoline that captured all the negative externalities, we wouldn't need to require showers, because so many employees would demand them.

Comments

[j]

I am a cyclist, I love to cycle. I wish more people would bike in the city, I support cycling infrastructure as part of the necessary expenditure of municiple governments. But, on the other hand, continual burdens on business is only going to continue slow growth. I don't know how this particular law impacts the cost of doing business in the district, but we learned the lessons of excessive burden on the private sector in the 80's. Encourage growth, then all the other nice things follow.

[MB]

"Encourage growth, then all the other nice things follow."

See, for example, China!

[j]

Its not a political issue, Bill Clinton understood this. Even the current administration wants to join the party at the moment. 'A rising tide lifts all boats'...I believe that was Kennedy, no?

[Early Man]

I hope Randal O'Toole does give the putative "high cost of free showers" a serious look. I think he would find they are a huge bargain. Unlike a car space that takes up substantially more real estate to be used by one person for the entire day, a shower can easily service a number of cyclists, along with joggers and people who need to feel clean after meeting with lobbyists, Congress-critters, and other occupational hazards here in DC.

[Joe D]

When my employer was building new office space, he looked into a shower for his (then) only cycle commuter (me). The deal-killer was the liability insurance; without that, he'd have had it built. So everybody put up with the smell of sweat and wet wipes.

[SJE]

I think O'Toole shouldn't be dismissed on this. However, what is the cost of a shower versus a parking space? If a shower gets 10 people to bike and costs 3x a parking space, then a shower is a bargain. Many law offices like having a shower so that people who are working long hours can freshen up: its not just a bike thing.

[Brendan]

Our new office in a new DC building has 2 showers for a staff of 90, 10 of which are regular bike commuters.

However, they're the only showers in the building and only 2 other people from other floors have asked to use them. So those numbers aren't great.

[nookie]

Like usual, you are comparing an apple to an orange to make a point.

Firstly, there is nothing free or subsidized about private underground parking. The structured parking is a cost that is usually 100% borne by the developer/individual building the building.

This zoning ordinance has nothing to do with street parking so I am not even sure why you mention it.

Secondly, the people that might decide to bike to work given this option, are ones already within a reasonable comutting distance for a recreational biker (~7-8 miles), i.e. well within the bounds of the prime exising public transportaion network (metrorail/metrobus)with overlapping public transport options available to them. It isn't like someone who commutes from PWC or Fairfax every day is going to now decide to bike.

Thirdly, someone already mentioned the liability insurance add-on requirement, which is by no means cheap and is a life-long cost. The 50K sq/ft threshold is pretty low too. 50K is a pretty small commercial builing downtown, making it harder for the builder to disperse the costs.

A typical parking space is 162 sq/ft. (9x18). Having to build two (one per gender) ADA compliant shower facilities takes up atleast twice that amount, or one space per shower. Considering those structured parking spaces are already ~$40K a piece, by the time you build out the actual shower facilities (add ~15 K), you've sacrificed a parking spot for a pretty small, one gender shower facility that costs 55K.

Having said all that, if the individual tenant(s) of the space want to build there space out to include a shower for their specific employees, I wouldn't mind DC offering some sort of financial incentive for them to do so, but lumping it into the general pot of expenses for anyone to do business in DC is detrimental to us all.

Poor school system and a much higher taxation rate aside, expensive commercial space in DC (literally twice what it costs just a few miles away in Arlington and Bethesda and ~2.5 times the cost of tysons etc) probably ranks 3rd, if not 2nd as to the reasons why companies locate outside of the District rather than in it. Every little blanket cost like this just worsens the problem.

[SJE]

Nookie: the debate has been about MANDATORY parking requirements which are in excess of what the free market would provide, and are not limited to DC. Personally, I would like there to be no regulatory subsidies for parking or showers and let the market decide.

[washcycle]

Nookie, it's not my comparison, it's O'Toole's. But they are both zoning requirements. Requiring builders to put in more parking than they otherwise would have lowers the cost of parking/driving and is therefore a subsidy.

the people that might decide to bike to work given this option, are ones already within a reasonable comutting distance for a recreational biker This is wrong, but even if it were true, so what?

those structured parking spaces are already ~$40K a piece, by the time you build out the actual shower facilities (add ~15 K), Based on previous discussions with you, what I see here are a bunch of numbers nookie made up. While I'm unsure of your point (I'm gussing it has to do with the cost of this zoning requirement) unless you can cite somthing stating (1) the change in cost for building an office building due to this req. and (2) the change in value of a building in compliance with it, I'm not inclined to pay attention.

expensive commercial space in DC probably ranks 3rd...as to the reasons why companies locate outside of the District rather than in it. Since price is a response to demand, your point is that so many people want their office space here (high price) and that's why no one wants their office space here. No one goes to Coney Island either, it's too crowded.

[James]

Nookie: I think you underestimate the distance commuters are willing to ride. My wife, one of her co-workers, a neighbor, and myself all bike commute to work from Falls Church into DC (or Reston in my case). Any one of the 4 commutes end up being almost 15 miles each way.

[Geof Gee]

It might unfairly subsidize cycling. But the more general complaint is that cycling is being scrutinized here while the subsidies for driving are being overlooked.

@nookie ... The Shoup/O'Toole argument is about mandatory parking-space requirements. Why the incidence would entirely fall on developers while cycling requirements are borne by us all? They both distrupt market-driven incentives.

http://tinyurl.com/2ejeddb

[Andy]

Generally, I hate subsidies. Where I think they make good sense though, is when they push us to make better decisions. If employees had the choice of paying for parking, or given access to a shower and secure bike parking, even if the bike scenario costs more, it's a benefit to everyone. Less emissions, congestion, more exercise, etc. Tax the bad, incentivize the good.

[Thrillhouse]

I ride in from Glenmont twice a week. We've got two showers (that I know of) in a building that probably has 400-500 people working in it. The bike racks generally fill up, but it's rare that I see another person in the locker room, meaning the other bikers aren't riding very far.

Here's the distances I travel to work at Metro Center:

- 11.7 miles by car

- ~14 miles if I take Sligo Creek Parkway to Colesville Rd. through downtown Silver Spring to 14th St. Takes about 1:15.

- ~22 miles if I take Beach Dr./Rock Creek Park Trail. Takes about 1:50

- ~21 miles if I take Beach Dr./Capital Crescent Trail. I forget how long it takes.

Granted, I don't ride home. When I show up at work before 7 a.m., I don't feel guilty hopping on the Metro at 3:59.

[nookie]

Washcycle,

I know it is simply easier for you to ignore factual data that debunks a point you are making by simply attacking the messenger, but sticking your head in the sand is a pretty childish way to go, considering these costs are widely documented.

Don't believe me? Fine, I suggest you meander over to GGW which you frequent and read the below article by Alpert acknowledging the cost of structured parking for this particular project to be 42K/per.

And listen, I am sure there are some uber bikers out there who bike 25-30 miles each way into town, but that isn't the general (I said recreactional) biker and we all know it. We also all know biking is a weather/seasonal thing as well. In the summer, I see half a dozen bikes parked in the buildings bike rack on a daily basis. Through the winter months, weeks will go by when there isn't a one. Ditto on bad weather days. Yes, I am sure someone will chime in and say they bike 20 miles each way every day, regardless of weather, but again we all know thats a minority.

http://greatergreaterwashington.org/post.cgi?id=636

I am also not getting the distinction between mandatory and not. Developers build the parking garages beneath their buildings, yes because they have to as a requirement to the zoning ordinance, but with the assumption that it is a future source of revenue. I don't know one building downtown that lets people park in it for free, either during business hours, or after hours.

At ~40K per space and a $20 dollar per day averaged cost per space, it takes ~5.4 years of steady usage to pay that space off. Now there are other considerations, (additional night revenue, days where the specific space isn't rented etc), but the original cost to the builder can be amortized generally over ~6-7 years. After that, the parking is simply an atm for the buildings owner.

The room lost to showering facilities not only adds in extra upfront construction costs than does parking, and long term liability costs, but is a non-revenue use of square footage.

[Fred]

So if we are going to eliminate zoning subsidies for cyclists, why not eliminate them for automobiles?

[nookie]

What zoning subsidy for automobiles?

[Chris]

The requirement is a shower stall per 50,000 square feet, and unless I'm reading it wrong, it's not a requirement for buildings smaller then that. This doesn't seem particularly burdensome to me. In fact, a lot of office buildings downtown already have shower stalls someplace in the building that people just don't know about.

[SJE]

Nookie: a minimum parking requirement that is in excess of the market rate is a subsidy. Just as a shower stall in excess of needs.

[Jim Titus]

Doesn't that depend on who pays? If employers are providing the shower but neither charging for it nor reporting it as taxable income to those who take the shower, then that is a tax subsidy. If they do report it as taxable income to the shower taker, it is not a tax subsidy (though it would be in effect a government directive to increase the compensation of one class of employees compared to what it would otherwise be.) If on the other hand, the building owner opens a public bath and charges market rate, it would be more like the mandatory parking--no subsidy, no favored class of employees.

We do not have alot of cyclists taking baths in fountains, reflecting pools, or muddy tidal beaches, so there is not a real concern that new buildings will place additional stresses on free bathing opportunities that must be offset by more showers. Unlike the typical mandatory parking for new stores etc. where planners accept the reality as it is and just try to prevent new construction from stressing the system further.

So to me the answer is "not really" unless people start opening up public baths. (That would be a way to bring the small buildings into the system with a payment-in-lieu.) Mandatory showers are different from mandatory parking because the parking is looking at parking supply and demand for a neighborhood while the showers are looking just at the building users. Usually.

So I say: Showers are great, long live the subsidy! Even if people are not bike commuting, there are many other uses. The showers at my office saved me many trips home before going out on Friday night.

[washcycle]

Nookie, I know it is simply easier for you to ignore factual data that debunks a point you are making You didn't present any facts - or at least nothing verifiable. And even that analysis doesn't back up your claim about how quickly a parking space can earn a positive return. Not that that is important to the issue at hand. The price of the parking space is only part of your claim. You also claimed that a shower and changing room costs the same as a parking space + $15,000 - a claim I find dubious based on the methodology. what I'd like to know is (a) the additional cost of meeting the shower/changing room requirement (b) the added value of a building with a shower/changing room.

I also still contend that how many people bike to work and when is a moot point.

I am also not getting the distinction between mandatory and not. Developers build the parking garages beneath their buildings, yes because they have to as a requirement to the zoning ordinance, but with the assumption that it is a future source of revenue. That's intuitively wrong. Let's divide spaces up in to two groups - those they would build without a minimum and those they would build to meet the minimum. If all the spaces fall into the first group, then there is no need for the minimum, but considering how often developers ask for a variance on this requirement that is clearly not the case. It's the spaces in the second group that we're calling mandatory, because those spaces are being built primarily to meet the requirement. It may be that some/all of these spaces will earn a profit (though so unlikely as to be nearly impossible). But that profit is probably below the ROI that developers seek. So that money could have been allocated elsewhere to a more profitable endeavor and as such is a subsidy.

I don't know one building downtown that lets people park in it for free, either during business hours, or after hours. It doesn't have to free, just below the market rate in a free market without parking minimums.

All of which is kind of off the subject. The question is does a shower/changing room requirement constitute a subsidy to cyclists in the same way that a minimum parking requirement subsidizes driving. And if so, is it bad.

[J]

Does the zoning that requires a shower allow for building developers to partner with a nearby development?

For example, it might be cost effective to give employees shower passes at a nearby gym.

[Michael H.]

Not all gyms have shower-only options.

The point about showers being used for reasons other than post-cycling is a good one. Many people work long hours downtown at the law firms, lobby firms, etc. A shower would benefit employers and employees in crunch situations (all-nighters) because the employees would not have to drive/bike all the way back home and then come back early in the morning on these days. That would save significant time, time that employees could use to either nap or work additional hours.

If someone has a meeting with a client after one of these marathon sessions, a shower would also be useful.

As for judging the number of bike commuters by how full the bike racks are, that is a flawed method of measuring bike commuting. Many people bring their bikes with them into their offices or into separate storage areas because they don't trust bike racks. Bikes were stolen from the bike rack in the parking garage in my building earlier this year.

Personally, I don't like leaving my bike in the rack and I definitely don't leave it locked up outside on the sidewalk. I always bring it up to the office. I see other people do the same thing.

[J]

Michael has a point. People I know with folding bikes place them under their desk, not in the garage.

[SJE]

Everyone I know with a decent bike puts them in their office if they can.

[Dr Pangloss]

O'Toole is like a one man cottage industry of hackitude. He's worth reading only in the sense that *anything* he writes must be the exact opposite of the truth.

[Dr Pangloss]

@Michael,

As for judging the number of bike commuters by how full the bike racks are, that is a flawed method of measuring bike commuting. Many people bring their bikes with them into their offices or into separate storage areas because they don't trust bike racks. Bikes were stolen from the bike rack in the parking garage in my building earlier this year.

Thanks for this. The point is so obvious, it didn't even occur to me at first. Before I began working from home full-time, I was a 24/7/365 bike commuter. Not once did I lock my bike to an outdoor bike rack.

Not once.