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Change Needed to Align On-Street Parking Enforcement with City
Goals
OFFICE OF THE CITY AUDITOR
PERFORMANCE AUDIT
April 2021
Honorable Mayor and Members of the City Council:
This audit of on-street parking enforcement focuses on actions the
city could take to improve on-
street parking enforcement in downtown Kansas City, Missouri.
Downtown parking enforcement
is currently performed by the Kansas City, Missouri, Police
Department. In April 2018, the city
and the Board of Police Commissioners entered into a Memorandum of
Understanding (MOU)
with the intent to increase the level of parking control activities
and collaborate on parking
enforcement activities in the downtown area.
The Police Department is not meeting the staffing requirements
outlined in the MOU. Between
2018 and 2021, the department did not achieve the minimum 10
parking control officers (PCOs).
As of January 2021, only two PCOs are assigned in the downtown
area. KCPDs parking control
activities and strategies also do not support the city’s parking
and transportation strategies.
KCPD does not routinely meet with city departments to coordinate
downtown parking
enforcement. Without control over downtown parking enforcement, the
city cannot achieve its
parking and transportation goals. The city has invested millions of
dollars in downtown parking
structures that require coordination with on-street parking
enforcement to maximize their value.
We make a recommendation to explore returning downtown parking
enforcement to a city
department, outsourcing enforcement, or identifying other
enforcement options to align
downtown parking enforcement with city goals.
The draft report was sent to the city manager on March 29, 2021,
for review and comment and
his responses is appended. We also discussed our findings and
conclusions with the director of
public works and Police Chief. We would like to thank Police,
Public Works, and Municipal Court
management and staff for their assistance and cooperation during
this audit. The audit team for
this project was Terry Bray, Jonathan Lecuyer, and Nancy
Hunt.
Douglas Jones, CGAP, CIA, CRMA
City Auditor
21st Floor, City Hall
Kansas City, Missouri 64106 Fax: 816-513-3305
Change Needed to Align On-Street Parking Enforcement
with City Goals
Table of Contents
Introduction 1 Objective 1 Background 1
Parking Control Enforcement in Downtown Kansas City 1 On-Street
Parking 2 Off-street Parking 2 Parking Studies 2
Findings and Recommendations 3 Police Department Not Performing in
Accordance with Downtown Parking Enforcement MOU 3
Understaffing in Downtown Parking Enforcement Area 3 Inconsistent
Collaboration on Downtown Parking Enforcement Activities 4 KCPD
Parking Enforcement Strategy Not Focused on City Goals 4 New
Ordinance Changes Current Adjudication Process of Traffic
Violations 5
Recommendations 6
Appendix A: Objective, Scope and Methodology, and Compliance
Statement 7 Why We Did This Audit 7 Audit Objective 7 Scope and
Methodology 8 Statement of Compliance with Government Auditing
Standards 8
Appendix B: 2018 Memorandum of Understanding Between Board of
Police Commissioners and
City of Kansas City, Missouri – Downtown Parking Enforcement
9
Appendix C: City Manager’s Response 13
List of Exhibits
1
Introduction
Objective
downtown Kansas City, Missouri?
To answer the objective, we interviewed staff in the Police
and
Public Works departments, reviewed the Memorandum of
Understanding (MOU) between the city and Board of Police
Commissioners for parking enforcement services, examined city
parking studies, evaluated documents and data related to
parking
enforcement activities in downtown Kansas City, and reviewed
citywide goals related to parking and transportation.
We conducted this audit in accordance with Government
Auditing
Standards.
See Appendix A for more information about the audit
objective,
scope, methodology, and compliance with standards.
In conducting our audit work, we identified an issue related to
a
potential conflict between the Police Department’s written
policy
and Missouri state law. State law prohibits quotas for
traffic
violation citations and the written policy of Parking Control
Unit
establishes daily ticket issuance goals for Parking Control
Officers.
We communicated this information to the Police Chief in a
separate
memorandum.
Background
In the recent past, downtown Kansas City parking control
enforcement has been performed by the Public Works Department
or Kansas City, Missouri, Police Department (KCPD). Public
Works
was responsible for downtown parking enforcement in fiscal
years
2013 and part of fiscal year 2014. KCPD has been responsible
for
downtown parking control enforcement since November 2013.
After issuing an RFP, Public Works was prepared to enter into
a
contract to outsource on-street parking enforcement and meter
operations in January 2018. In April 2018, the city and the
Board
of Police Commissioners of Kansas City, Missouri, executed an
MOU
regarding parking enforcement activities in downtown Kansas
City.
(See Appendix B.)
Change Needed to Align On-Street Parking Enforcement with City
Goals
2
On-Street Parking
On-street parking is part of the city’s transportation system.
The
redevelopment of the greater downtown area has increased
demand for on-street parking which offers convenient, short
term
parking for restaurants, entertainment, retail customers, and
visitors. KCPD is responsible for enforcement of traffic,
parking
and vehicle laws of the city, turn-over of short term
on-street
parking spaces in support of businesses, and encourage long
term
parkers to use parking garages and other off-street
locations.
Off-street Parking
Off-street parking is defined as parking a vehicle anywhere but
on
the street, like in parking garages and lots. Our 2019 audit of
the
city’s investment in parking garages1 found that the city has
significant long-term financial commitments and obligations
through the ownership and support of parking garages in the
greater downtown area. Between 2007 and 2018, the city’s
general fund covered about $94 million of the $140 million in
debt
service payments for parking garages with city commitments.
In
addition, the city has financial responsibility for substantial
future
capital improvements.
Parking Studies
The city has had four parking studies conducted within the
last
eight years. These studies have focused on the downtown area
which includes the River Market, Crossroads, and Central
Business
District (downtown) areas.2
recommendations to improve long-term planning, operation,
maintenance, and governance of the public parking assets.
1 Parking Garage Investment Needs Planning, Coordination with
Transportation Goals, Kansas City. Missouri City
Auditor’s Office, March 2019. 2 Operational Parking Assessment,
Walter P. Moore and Associates, Inc., January 2012; River Market
Parking Audit,
Smart Growth America, November 9, 2016; Crossroads District Parking
Study, Walker Parking Consultants, July 28,
2017; Central Business District Parking Study, Walker Parking
Consultants, June 8, 2020.
3
Enforcement MOU
The city and the Board of Police Commissioners of Kansas
City,
Missouri, entered into a Memorandum of Understanding (MOU) in
April 2018 with the intent to increase the level of parking
control
activities and collaborate on parking enforcement activities in
the
downtown area.
The Police Department is not committing ten parking control
officers (PCOs) to the downtown area as required in the 2018
MOU. The MOU states that KCPD is committed to hire and
maintain a minimum of 10 full-time employees primarily
dedicated
to parking control activities within downtown Kansas City.
KCPD’s
Parking Control District maps show an increase in the number
of
PCOs starting in 2018 but staffing has steadily declined and
by
January 2021 show only two PCOs assigned to the downtown
area,
while other PCOs are assigned to patrol areas outside
downtown.
(See Exhibit 1.)
million appropriated for downtown PCOs. (See Exhibit 2.) The
requested budget for 2022 shows an increase in dollars from
previous year’s budget requests for the lowest number of PCOs
patrolling downtown. The MOU states the city is committed to
appropriating money to the Police Department for the total
costs
0
1
2
3
4
5
6
7
8
9
Change Needed to Align On-Street Parking Enforcement with City
Goals
4
dedicated to downtown parking control activities. Without the
minimum 10 PCOs dedicated to downtown parking control
activities, the department did not expend these funds in
accordance with the MOU and the city is not receiving the
services
it funded.
Actual
Inconsistent Collaboration on Downtown Parking
Enforcement Activities
The Police Department and city do not regularly meet to
coordinate
and collaborate on parking enforcement operations. The 2018
MOU established a Joint Advisory Committee, made up of
individuals appointed by the Chief of Police and the City
Manager,
to meet as needed to review, advise, and approve aspects of
downtown parking control activities. In 2019, city staff
reported
the Joint Advisory committee met initially, but that meetings
stopped occurring. Public Works staff stated that KCPD has
attended most of the more recent Parking Policy Review Board
meetings, but KCPD has not participated in the Administrative
Parking Tribunal meetings to discuss the costs of managing
parking
enforcement.
The MOU also stated the City Manager and Police Chief were to
meet semi-annually to discuss the progress of downtown
parking
enforcement. The former city manager reported that meetings
with the police chief did not occur. Without regular
participation
from KCPD, there is no collaboration on improving downtown
parking control and enforcement activities as intended by the
MOU.
KCPD Parking Enforcement Strategy Not Focused on City
Goals
The Police Department’s parking enforcement strategies do not
align with the transportation goals the city is trying to
achieve.
The city used parking studies to develop policies that focus
on
shifting long-term parkers to off-street locations. One of the
city’s
parking management goals is to improve garage utilization
with
increased parking enforcement and improved communication with
the public.3 KCPD’s Parking Control Unit does not focus on
the
3 Public Works Department Operations Division Business Plan
2016-18.
Findings and Recommendations
5
turnover of on-street parking in the downtown area but rather
on
the following parking control objectives and goals.
PCOs daily activities do not assist them in the enforcement
of
short-term parking violations. According to a KCPD Parking
Control Supervisor, PCOs do not follow defined enforcement
routes. For parking enforcement to be effective, the
enforcement
must be provided in a consistent and regular manner.
Enforcement routes must be done regularly enough to set the
expectation that those who stay over time in a time limited
space
will get a citation.
Without enough staff or a strategy focused on turning over
short-
term parking, many vehicles continue to park illegally with
no
consequence. A previous parking study and our observations in
June 2020 identified many illegally parked vehicles in the
downtown area.
Traffic Violations
downtown Kansas City. KCPD, as a law enforcement agency, is
tasked with the enforcement of traffic, parking, and vehicle laws
of
the city. Before the recent change parking violations were
treated
as criminal offenses and adjudicated through the city’s
Municipal
Court system. Failure to pay a parking ticket could result in
a
warrant for one’s arrest.
6. Parking Control Objectives
I. To keep the streets in Kansas City clear and passable from
illegally
parked vehicles impeding the flow of traffic
II. To assist Citizens when needed
III. To answer Calls for Service as soon as possible
IV. Tow vehicles obstructing traffic or abandon on city
streets
V. When possible educate citizens about parking ordinances
VI. If you see suspicious activity or bag – Report it immediately
to the
dispatcher
A. Watch II - Daily goal of 40 citations a day
a. This will vary with the # of 311 complaints you are
assigned
B. Watch III – Daily goal of 35 citations a day
a. Assist Traffic Personnel when needed at the Sprint Center or
any
other function occur Downtown
Source: Kansas City, Missouri, Police Department Parking Control
Unit Policies and
Guidelines 2019.
Change Needed to Align On-Street Parking Enforcement with City
Goals
6
In August 2020, the City Council passed Ordinance 200677,
which
established an administrative adjudication system for parking
tickets and other non-moving violations as of October 15,
2020.
An administrative tribunal under the supervision of the Parking
and
Transportation Commission is responsible for overseeing the
administration of parking tickets and other non-moving
ordinance
violations. Tickets for these violations are adjudicated by
the
administrative tribunal and are administrative citation fines.
City
staff is still determining how this change will operate, however
a
civilian board will oversee these in some manner, with no
warrant
issuance. Without a criminal offense or public safety element
associated with parking citations, the KCPD’s role as the
primary
enforcer of these violations may no longer be practical or
necessary in downtown Kansas City.
Recommendation To align downtown parking enforcement with city
goals, the city
manager should explore returning downtown parking enforcement
to a city department, outsourcing enforcement, or identifying
other
enforcement options.
enforcement to a city department, outsourcing enforcement, or
Compliance Statement
We conducted this audit of on-street parking control
enforcement
under the authority of Article II, Section 216 of the Charter
of
Kansas City, Missouri, which establishes the Office of the
City
Auditor and outlines the city auditor’s primary duties.
A performance audit provides “objective analysis, findings,
and
conclusions to assist management and those charged with
governance and oversight, with among other things, improving
program performance and operations, reducing costs,
facilitating
decision making by parties with responsibility for overseeing
or
initiating corrective action, and contributing to public
accountability.”4
The redevelopment of the city’s downtown area has increased
demand for parking. During times of peak demand, on-street
parking availability can be limited, which may affect access
to
businesses and jeopardize business viability. The city’s
parking
consultant noted, “Enforcement is the lynchpin for effective
parking
policies.”5
In 2018, the city and the Board of Police Commissioners of
Kansas
City, Missouri, entered into a Memorandum of Understanding
(MOU) to increase the level of parking control activities in
the
downtown area. The MOU committed KCPD to hiring and
maintaining a minimum of 10 full-time parking control
employees
primarily dedicated to parking control activities in the
downtown
area. These responsibilities would include, but not be limited
to,
issuing parking citations or warnings and ordering the towing
of
illegally parked vehicles. The city agreed to fund these
additional
positions from the Parking Garage Fund.
Audit Objective
• What actions could improve on-street parking enforcement
in downtown Kansas City, Missouri?
4 Comptroller General of the United States, Government Auditing
Standards (Washington, DC: U.S. Government
Printing Office, 2018), pp. 10, 11. 5 Crossroads District Parking
Study, Walker Parking Consultants, July 28, 2017, p.83.
Change Needed to Align On-Street Parking Enforcement with City
Goals
8
that included members of the Parking Policy Review Board
and the Parking and Transportation Commission, and a
small business owner to identify their concerns related to
on-street parking enforcement.
to identify recommended practices and study results for the
greater downtown, Crossroads, and River Market areas.
• Reviewing citywide goals, plans, and policies, and
Memorandum of Understanding (MOU) to identify the city’s
stated strategy and intent for on-street parking
enforcement in downtown area.
parking enforcement.
enforcement, Parking Control staffing levels, coverage
areas, and enforcement times to understand city on-street
parking enforcement operations.
Most of the fieldwork for this audit was conducted before the
start
of the pandemic.
Standards
accepted government auditing standards. Those standards
require
that we plan and perform the audit to obtain sufficient,
appropriate
evidence to provide a reasonable basis for our findings and
conclusions based on our audit objectives. We believe that
the
evidence obtained provides a reasonable basis for our findings
and
conclusions based on our audit objectives. No information was
omitted from this report because it was deemed confidential
or
sensitive.
In conducting our audit work, we identified an issue related to
a
potential conflict between the Police Department’s written
policy
and Missouri state law. State law (RSMo §304.125) prohibits
quotas for traffic violation citations and the written policy
of
Parking Control Unit establishes daily ticket issuance goals
for
Parking Control Officers. We communicated this information to
the
Police Chief in a separate memorandum.
Appendices
9
Between Board of Police Commissioners and City of Kansas
City, Missouri – Downtown Parking Enforcement
Change Needed to Align On-Street Parking Enforcement with City
Goals
10
Appendices
11
Change Needed to Align On-Street Parking Enforcement with City
Goals
12
Appendices
13