PARKING CASH OUT

 

 

 

Donald C. Shoup

Department of Urban Planning

University of California, Los Angeles

Los Angeles, CA 90095-1656

shoup@ucla.edu

 

Funded by Year 13 Research Grant

 


PARKING CASH OUT

 

EXECUTIVE SUMMARY

 

Employer-paid parking is the most common fringe benefit offered to workers in the US, and 95 percent of American automobile commuters park free at work.  Free parking at work amounts to a matching grant for commuting by car: employers pay the cost of parking at work only if commuters are willing to pay the cost of driving to work.  Commuters who do not drive to work do not receive an equivalent subsidy.  This matching-grant feature of employer-paid parking helps to explain why 91 percent of commuters drive to work, and why 91 percent of their cars have only one occupant.

Many solo drivers who park free at work would drive to work alone even if they had to pay for their parking.  But some of them would carpool, ride public transit, walk, or bike to work if they had to pay to park; these commuters drive to work because they can park free.  Case studies and statistical models suggest that employer-paid parking increases the number of cars driven to work by 33 percent when compared with driver-paid parking.

A few employers offer commuters the option to take the cash equivalent of any parking subsidy offered.  Offering commuters the choice between a parking subsidy or its cash equivalent shows that even free parking has an opportunity cost—the foregone cash.  The option to “cash out” raises the effective price of commuter parking without charging for it.  Commuters can continue to park free at work, but the cash option also rewards commuters who carpool, ride public transit, walk, or bike to work.

Parking cash out does not prevent commuters from driving to work whenever they want, because firms can offer the cash-out option on a daily basis.  For example, consider the case of a firm (described in Chapter 23) that estimates its cost to provide commuter parking is $3 per space per day.  The firm offers all employees free parking, but also offers them a credit of $3 on any day they arrive at work without a car.  Therefore, commuters can either park free or take the cash value of the free parking, and they can make different choices on different days.  Although everyone can park free at work, commuters who drive to work alone forfeit $3 a day.  The daily cash option therefore encourages everyone to consider choosing the alternatives to solo driving whenever possible.


This daily cash-out arrangement is simple, fair, and flexible for both the firm and its employees.  Another important advantage is that all employees are automatically enrolled in the program even if they usually drive to work solo.  Every employee can earn a $3 bonus on any day simply by showing up at work without a car.  Rather than charge commuters for parking, the firm pays them for not parking.  Although this arrangement seems uncommonly generous to commuters who do not drive to work, it merely levels the playing field among modes, and it does not favor the alternatives to solo driving.  Offering the same subsidy to all commuters is unusually generous to nondrivers only because most firms offer them nothing.

 

CALIFORNIA’S PARKING CASH-OUT LAW

California law requires many employers to offer parking cash out if they subsidize commuter parking in spaces they rent from a third party, and the evidence suggests that parking cash out produces significant benefits.  Case studies in Southern California found that the commuters’ solo-driver share fell from 76 percent before employers offered parking cash out, to 63 percent afterward.  For every 100 commuters, parking cash out induced 13 solo drivers to shift to another mode.  Of the 13 former solo drivers, 9 joined carpools, 3 began to ride public transit, and one began to walk or bike to work.  Three times more commuters switched to carpools than to public transit, which shows that parking cash out can reduce solo driving to work even where public transit is not available.  By encouraging carpools, parking cash out takes advantage of many empty seats in cars already on the road to work.

These substantial reductions in solo driving reduced vehicle travel by 652 vehicle-miles traveled to work per employee per year.  This reduction in vehicle travel saved 26 gallons of gasoline per employee per year.  Finally, the reduction in fuel consumption for commuting reduced CO2 emissions by 367 kilograms per employee per year.    Because American motor vehicles consume one eighth of the world’s total oil production, and because commuting to work accounts for about 16 percent of total oil consumption in the US, parking cash out has significant potential to reduce total oil consumption and carbon emissions.  In 2001 the US imported $104 billion of petroleum, which accounted for 8 percent of total imports and 29 percent of the nations’s balance of trade deficit.  A reduction in the domestic demand for gasoline can therefore significantly reduce both petroleum imports and the balance of trade deficit.  Quite aside from this financial benefit, reduced petroleum imports will also increase national energy independence.


Parking cash out increased the employers’ costs by only $2 per employee per month because they saved almost as much on parking as they paid in cash to commuters.  Federal and state income tax revenues rose by $65 per employee per year because many commuters voluntarily traded their tax-exempt parking subsidies for taxable cash.  Employers praised parking cash out for its simplicity and fairness, and said that it helps to recruit and retain employees.  In summary, parking cash out provides benefits for commuters, employers, taxpayers, and the environment.  All these benefits result from subsidizing people—not parking.

Parking cash out also eliminates any unintended bias inherent in employer-paid parking.  Women and minorities are less likely than other commuters to drive to work solo, and more likely to ride transit.  For example, 78 percent of white commuters drive to work solo, and only 2 percent ride public transit, while only 58 percent of black commuters drive to work solo, and 16 percent ride public transit.  Because parking cash out gives an equal benefit to commuters regardless of their mode choices, it eliminates inadvertent discrimination based on gender, ethnicity, or any other demographic variable, and avoiding bias in transportation policy is simple transportation justice.  Because commuting to work accounts for almost one third of all automobile travel in the US, and because employer-paid parking is a tax-exempt fringe benefit, parking cash out promotes equity in both transportation and taxation.

 

EMPLOYER-PAID PARKING AS A TAX-EXEMPT FRINGE BENEFIT

Because employer-paid parking is a tax-exempt fringe benefit, the federal government subsidizes solo driving to work.  To solve this problem I have proposed two simple amendments to the tax code: (1) require parking cash out as an alternative to employer-paid parking, and (2) allow the inclusion of employer-paid parking in cafeteria plans for tax-exempt fringe benefits.

 

(1)  Require Parking Cash Out as a Condition for Tax Exemption

First, parking cash out can be required by putting a condition on the tax exemption for  parking subsidies.  Employer-paid parking should be a tax-exempt fringe benefit only if an employer offers commuters the option to cash it out.  The non-italic text quoted below is the Internal Revenue Code’s existing definition of employer-paid parking that qualifies for a tax exemption; the italic text is the proposed amendment.

Section 132(f)(5)(C): Qualified parking – The term “qualified parking” means parking provided to an employee on or near the business premises of the employer . . . if the employer offers the employee the option to receive, in lieu of the parking, the fair market value of the parking.


If this proposed amendment is adopted, employers will choose whether their parking subsidies are tax exempt.  The cash-out requirement can be interpreted as a test that an employer’s  commuter transportation policy must pass.  Any policy will pass this test if it subsidizes the alternatives to driving to work alone (such as transit, walking, cycling, or carpooling) as much as it subsidizes parking at work.  A policy will fail this test only it if subsidizes parking more than the alternatives.

If an employer offers commuters a fair deal—free parking or its fair market value—the free parking will remain a tax-exempt fringe benefit.  Commuters will be able to convert the tax-exempt parking subsidy into a tax-exempt transit subsidy, or to pay income taxes on the parking subsidy’s cash value and use the after-tax cash for any purpose they choose.  But if an employer offers commuters an unfair deal—free parking without the option to choose its fair market value—the subsidy does not merit tax exemption.  This minor amendment to the tax code will give commuters more choices and it will reduce the economic and environmental costs of employer-paid parking.  Commuters who cash out their parking subsidies will reduce traffic congestion, energy consumption, and air pollution.  The amendment will also significantly increase income tax revenues from commuters who voluntarily choose taxable cash in lieu of tax-exempt parking subsidies.

 

(2) Include Parking in Cafeteria Plans

Second, cafeteria plans for fringe-benefits permit employees to select among one or more non-taxable benefits or taxable cash, so each employee can design his or her individual fringe-benefit plan.  Nevertheless, a quirk in the Internal Revenue Code excludes employer-paid parking from these cafeteria  plans. The text quoted below is the Internal Revenue Code’s existing definition of cafeteria benefit plans that qualify for a tax exemption; the proposed amendment is to delete the italic text.

Section 125(a): Cafeteria plans – No amount shall be included in the gross income of a participant in a cafeteria plan solely because, under the plan, the participant may choose among the benefits of the plan.

Section 125(f): Qualified benefits defined – For purposes of this section, the term “qualified benefit” means any benefit which . . . is not includible in the gross income of the employee by reason of an express provision of this chapter (other than section . . . 132).


Because “other than section 132” here refers to the tax exemption for employer-paid parking, the tax code prevents employers from allowing commuters to give up free parking in exchange for health insurance or any other tax-exempt benefit offered in a cafeteria plan. Therefore, deleting the words “other than section 132” from Section 125(f) will allow employers to offer commuters the option to take other tax-exempt fringe benefits in lieu of free parking at work.  Why not allow commuters  to choose health insurance in lieu of free parking at work?  This offer will increase the after-tax opportunity cost of the free parking, and it will thus reduce solo driving to work.  It will also increase the number of employees with health insurance, and it will improve employers’ fringe benefit packages at no cost to the employers.

 

CONCLUSION

The tax exemption for employer-paid parking should be amended in two ways.  First, employer-paid parking should qualify as a tax-exempt fringe benefit only if the employer offers commuters the option to take cash in lieu of the parking itself.  If an employer wants to offer free parking without the option to cash it out, the parking subsidy should not be tax-exempt.  Second, employer-paid parking should qualify for inclusion in cafeteria benefit plans.  Employers should be able to offer commuters the option to trade away free parking in exchange for other tax-exempt fringe benefits.  These two tax reforms will give commuters more choices and will significantly reduce the economic and environmental costs of employer-paid parking.  Commuters who trade away their parking subsidies will reduce traffic congestion, air pollution, energy consumption, and the risk of global warming.  Commuters who voluntarily choose taxable cash in lieu of tax-exempt parking subsidies will also increase income tax revenues.  Requiring employers to offer commuters the option to cash out their tax-exempt parking subsidies, and allowing employers to offer commuters the option to choose other tax-exempt fringe benefits in lieu of free parking will reduce traffic congestion, conserve gasoline, improve air quality, reduce the risk of climate change, increase tax revenues without increasing tax rates, and increase employee benefits without increasing employers’ costs.

Two minor tax reforms can provide all these economic and environmental benefits simply by allowing commuters to choose how they wish to spend their own income.

 


PUBLICATIONS

Donald Shoup, “Parking Cash Out,” in Managing Commuters’ Behaviour, a New Role for Companies, Report of the Hundred and Twenty First Roundtable on Transport Economics, Paris: European Conference of Ministers of Transport, 2002, pp. 41-173.

 

Shoup, Donald C., "In Lieu of Required Parking," Journal of Planning Education and Research, Vol.18, pp.307-320.

 

Shoup, Donald C., and Jeffrey Brown, "Pricing Our Way Out of Traffic Congestion: Parking Cash-Out and HOT Lanes," California Policy Options 1998, Mitchell, J.B. and Mary Richardson, eds., The School of Public Policy and Social Research, UCLA and The UCLA Anderson Forecast.