CITY OF LOS ANGELES
INTER-DEPARTMENTAL MEMORANDUM
Date:
To:
June 8, 2021
Honorable City Council
c/o City Clerk, Room 395, City Hall
Attention: Honorable Mike Bonin, Chair, Transportation Committee
From: Seleta J. Reynolds, General Manager
Department of Transportation
Subject: EXPANDING AND BROADENING ECONOMIC HARDSHIP RELIEF PROGRAMS FOR
MOTORISTS WITH PARKING FINES
SUMMARY
This report summarizes the Los Angeles Department of Transportation’s (LADOT’s) findings to expand and
broaden economic hardship relief programs for persons who received parking fines (Council File 20-1365).
RECOMMENDATIONS
That the City Council, subject to approval of the Mayor:
1. DIRECT LADOT to increase the low-income installment payment plans qualifying criteria of
household income to 150% of the Federal Poverty Rate to expand access to the payment plans;
2. DIRECT LADOT to develop standards for a separate general installment payment plan that allows
any motorist to qualify, regardless of income; and
3. AUTHORIZE LADOT to continue the Unemployment Penalty Waiver and Citation Amnesty Programs
until December 31, 2021.
BACKGROUND
On October 15, 2020, LADOT resumed parking enforcement for most violations that City Council and the
Mayor suspended during the initial months of the COVID-19 pandemic. Several existing programs for
people experiencing economic hardship, including for people experiencing homelessness and low-income
households, were immediately available to assist motorists during the onset of the pandemic. To broaden
financial support for individuals experiencing hardship, LADOT, at the direction of the Mayor, implemented
three new equity-based parking citation relief programs:
1. Citation Amnesty Program - Grants motorists a one-time opportunity to reduce late fees owed on
parking citations over three years old.
2. Unemployment Penalty Waiver - Allows registered vehicle owners who lost their job during the
COVID-19 pandemic to have accrued parking citation penalties removed upon submission of proof
of unemployment benefits.
3. Early Pay LA - An incentive program that provides a $20 discount to those who make early citation
payments within 48 hours from the issuance date on eligible violations only.
The Honorable City Council -2- June 8, 2021
On October 21, 2020, City Council requested LADOT to report on expanding and broadening the economic
hardship relief programs for persons who received parking fines by examining economic hardship relief
programs offered by other agencies and their criteria used to qualify individuals. City Council requested
that the report include data on the number and percentage of applications for low-income payment plans
which the Department denied and reasons for the denial; the number of incomplete applications for low-
income payment plans; the number of late unpaid citations; and an estimate of the percentage of unpaid
citations due to economic hardship.
This report provides further detail and performance data for each financial relief program and proposes
new ways to expand the programs recommended for extension.
DISCUSSION
Existing Parking Relief Programs
Prior to the COVID-19 pandemic, LADOT provided economic relief programs geared towards alleviating the
financial strain of parking citation debt for disadvantaged residents. The programs included the Community
Assistance Parking Program (CAPP) and Installment Payment Plans (IPPs).
CAPP: A program for individuals experiencing homelessness. CAPP allows participants to reconcile parking
citations through volunteer community service or through enrollment in a homeless service program.
Through the three years of the program leading up to the end of April 2021, participants completed 18,400
of community service hours. This represents 1,325 vehicle plates and 4,462 citations, with a total amount
of $713,515 converted to community service hours.
LADOT continues to refine CAPP application procedures and broaden the outreach of the program. In
December 2020, LADOT added new ticket language to the bottom of every parking citation issued
informing those who are experiencing homelessness to inquire about the CAPP program. During the onset
of the pandemic, LADOT worked with various service provider agencies to offer virtual community service,
where individuals could satisfy their hours with online courses, training, and/or seminars.
IPPs: The City of Los Angeles offered parking citation payment plans for over 20 years for eligible low-
income individuals. In July 2018, LADOT expanded the IPPs to indigent and eligible low-income motorists
whose financial situation qualifies them under the guidelines in the Federal Register by the United States
Department of Health and Human Services under the authority of paragraph (2) of Section 9902 of Title 42
of the United States Code. Qualified individuals must fall within the monthly income of 125% or less of the
current poverty guidelines, and/or receive public assistance benefits. If qualified, a motorist may be eligible
for one of three available IPPs:
1. General IPP - Motorists may enroll at any point during the citation lifecycle. The amount due can
be paid in installments over a three-month period with a first installment of 60% of the total due,
followed by two installments of 20% of the total remaining.
2. Extended Low-income Plan (ELP) - Motorists with under $500 in base fines can pay monthly
installments over 24 months with no penalties or DMV restrictions.
3. Extended Low-income Plan Plus (ELP+) - Motorists with over $500 in base fines can pay monthly
installments over 24 months with no DMV restrictions.
Council directed LADOT to provide data on several metrics related to the existing installment payment
plans, as detailed below:
The Honorable City Council -3- June 8, 2021
1. The number and percentage of applications for low-income payment plans who are denied and the
reasons for the denial.
The Parking Violations Bureau received 8,913 applications in calendar year 2020. We denied approximately
18% or 1,643 due to ineligibility, mainly due to incomplete paperwork of the application, missed deadline
to apply (in January 2021, LADOT eliminated the deadline to further alleviate this burden), and income
requirements not met. LADOT does not track denials by category.
2. The number of incomplete applications for low-income payment plans.
The majority of denials reported by the Parking Violations Bureau are due to incomplete applications.
When an applicant is denied, a notice with information about eligibility and documentation requirements is
mailed to them and they are afforded an opportunity to reapply.
3. The number of late unpaid citations.
The total number of plans that defaulted in 2020 was 992 out of 2,463 total plans and the total number of
citations associated with those defaulted plans was approximately 4,667. Note that some payment plans
may have been partially fulfilled before the motorist defaulted on the plan.
4. An estimate of the percentage of unpaid citations that are due to economic hardship.
Motorists do not provide the City a reason why citations go unpaid. Therefore, LADOT cannot provide a
percentage of unpaid citations that are due to economic hardship.
Expanding the Parking Relief Programs
At the direction of the City Council, LADOT evaluated the effective reach of its parking fine relief programs
to see if there are additional motorists that should be eligible, but are unable to qualify under current rules.
As LADOT continues to improve and refine the installment payment plan options, the Department
exceeded State legislation requirements and eliminated the cutoff date to apply for an installment plan in
January 2021. Prior to the change, motorists had 60 days from the date of citation issuance or 10 days after
an administrative appeal, to apply for an installment plan. By eliminating the deadline, motorists no longer
forfeit their right to request an installment plan due to any hardships they might have been experiencing
that may have impacted their ability to apply in a timely manner.
We compared payment plans locally and among other metropolitan cities such as Chicago, Philadelphia,
San Francisco, and Washington D.C. Local cities either did not have substantially different payment plan
options or had more restrictive requirements. San Francisco has broader qualifying income levels for
participation. Qualified individuals in San Francisco must fall within the monthly income of 200% or less of
the current Federal poverty guidelines. As mentioned above, Los Angeles requires 125% or less of the
current Federal poverty level, which is based on the California Vehicle Code’s minimum required
qualification levels. San Francisco’s cost of living environment and median household income is far greater
than the City of Los Angeles (nearly 77% more), which could be the attributing factor for the increase.
Attached is a comparison chart of current qualifying income thresholds between the cities of Los Angeles
and San Francisco (see Attachment A).
To broaden participation rates, LADOT proposes increasing the monthly income criteria to 150% of the
Federal poverty level from the existing 125% of the Federal poverty level. By increasing the eligible income
The Honorable City Council -4- June 8, 2021
limits, more low-income motorists will be afforded the opportunity to qualify for an IPP. Attachment A
includes the proposed income levels at 150%.
The City of Chicago offers a Standard Non-Hardship Payment Plan for individuals, regardless of income
levels. LADOT considered a similar open enrollment program to expand the range of payment plan options
for qualifying motorists of any income level, with different qualifying factors and default outcomes (see
Attachment B). A key component of this program would be to enable autocharge payments to the
motorist’s credit or debit cards to reduce the default rate. To develop this program, LADOT must follow
National Automated Clearing House Association (NACHA) and Payment Card Industry (PCI) standards for
autopay enrollment requirements and develop necessary programming to process and track plans
accordingly. LADOT considers the Standard Non-Hardship Payment Plan as a longer term project to
account for program development, testing, and costs. Preliminary estimates from the City’s processing
agency are $75,000 to $100,000 for programming and development costs. LADOT could implement the
project with the release of a new citation processing Request For Proposals (RFP), which could affect cost
estimates. The anticipated release for the RFP is Fiscal Year (FY) 2022.
Currently, people can make payments for citations and payment plans online, via PayTix, in-person, by
phone, or by mail. PayTix is the mobile application provided by the Parking Violations Bureau. If
installment plan options expand to include motorists of any income level, LADOT will develop an RFP to
encourage a wide marketplace of payment apps.
In response to the economic fallout of the pandemic, LADOT launched the three previously mentioned new
parking relief programs to further assist motorists: Citation Amnesty Program, Unemployment Waiver
Program, and Early Pay LA. All three programs are set to expire on June 30, 2021.
1. Citation Amnesty Program – From August 2020 through April 2021, motorists paid a total of
$211,000 after LADOT waived late fees for citations older than three years. LADOT recommends
continuing this program until December 31, 2021 to further assist the public and LADOT’s effort to
address difficult-to-collect citations.
2. Unemployment Penalty Waiver – From October 2020 through April 2021, nearly 2,000 motorists
completed the waivers and were permitted to pay the base fine amount. LADOT reduced
approximately $200,000 in late penalty fines for those who qualified for the program. LADOT
recommends continuing this program until December 31, 2021. The unemployment rate in the City
of Los Angeles was 10.90% in April 2021. This exceeds the long-term average of 8.34% and
indicates an ongoing need to provide economic relief.
3. Early Pay LA – From November 2, 2020 to April 2021, Early Pay LA increased early payment by two
percent. In April 2021, the City discounted over $1.1 million for eligible citations. LADOT does not
recommend continuing this program beyond June 30, 2021. This program failed to increase the
amount of citations paid early and furthermore does not appear to have benefited anyone other
than those Angelenos who could already afford to pay their tickets. Further, the intended purpose
of the program was to allow a short term opportunity for motorists to transition from receiving no
citations for the specific violations during the relaxed enforcement period. The Department
transitioned to near-regular enforcement levels in October 2020.
LADOT’s parking payment relief programs are among the most progressive options available across the
country. In 2020, LADOT received the National Parking Association’s Innovative Organization of the Year
Award for parking initiatives benefiting low-income and economically disadvantaged motorists, including
those affected by the COVID-19 pandemic. LADOT continues to work closely with local community service
The Honorable City Council -5- June 8, 2021
providers and industry to bring innovative technologies to help people participate in payment plans to Los
Angeles, including convenient mobile application, streamlined eligibility process, options to manage and
track payments, and new payment methods.
FISCAL IMPACT STATEMENT
The City’s parking citation program is estimated to generate approximately $94 million in General Fund
revenue in FY 2021, which is a decrease of nearly $22 million or 19% compared to FY 2020.
The COVID-19 related parking relief programs resulted in citation discounts of approximately $1.5 million
($1.1 million for Early Pay LA; $200,000 for the Unemployment Penalty Waiver, and $200,000 for Citation
Amnesty) over the first eight months of implementation. At the current participation rates of these
programs, LADOT estimates a total revenue loss of $2.25 million this fiscal year. LADOT recommends
continuing the COVID-19 Citation Amnesty and Unemployment Payment Waiver Programs through
December 2021 and allowing the Early Pay Program to conclude on June 30, 2021.
LADOT recommends expanding the installment payment plan qualification requirements to 150% of the
Federal poverty level. Expanding requirements for installment payment plans will improve revenue
generation as data shows that existing payment plans with flexible options reduced default rates by nearly
75%. Increasing participation will extend revenue collection over a greater period of time.
Creating an installment payment plan for standard non-hardship motorists may increase revenue
generation because the requirement to establish auto payment will reduce the likelihood for default. The
cost to establish this program is between $75,000 and $100,000 for programming development costs. This
amount could vary depending on anticipated RFP responses from potential processing agency bidders in FY
2022. LADOT will develop a cost estimate and revenue impact related to creating a general installment
payment plan regardless of qualifying income and will consider requesting new resources for FY 2023.
SJR:JK:KH:mg
Attachments
Attachment A
Comparison between the cities of Los Angeles and San Francisco current qualifying income levels for
parking citation payment plans:
Los Angeles - 125%
San Francisco - 200%
# in
Household
2020 Monthly
Guidelines
2020 Annual
Guidelines
2020 Monthly
Guidelines
1
$1,329
$15,950
$2,127
2
$1,796
$21,550
$2,873
3
$2,263
$27,150
$3,620
4
$2,729
$32,750
$4,367
5
$3,196
$38,350
$5,113
6
$3,663
$43,950
$5,860
7
$4,129
$49,550
$6,607
8
$4,596
$55,150
$7,353
Proposed increase to qualifying income levels for parking citation payment plans:
Los Angeles - 150%
# in Household
2020 Monthly Guidelines
2020 Annual Guidelines
1
$1,595
$19,140
2
$2,155
$25,860
3
$2,715
$32,580
4
$3,275
$39,300
5
$3,835
$46,020
6
$4,395
$52,740
7
$4,955
$59,460
8
$5,515
$66,180
Attachment B
Online Payment Plans
ELP ELP+
*Open Enrollment
Standard Non-Hardship
Eligible Violations
All
All
All
Term
Up to 24 months
Up to 24 months
Up to 12 months
Qualifications
• Income: Less than 150% of the
Federal poverty rate (Link to table)
• Qualifying documentation (Link to
list)
• Base citation amounts must total
less than $501
• Income: Less than 150% of the
Federal poverty rate (Link to table)
• Qualifying documentation (Link to
list)
• Citation amounts must total more
than $501
• Income: Any
• Must provide credit card or debit
account for autocharge or auto ACH
payment
Enrollment Fee
$5
$5
$5
Down Payment &
Installments
• $20 Down Payment
• $20 monthly installment
• $20 Down Payment
• Balance/24 months
• Equal Payments: Total debt
divided by the number of months in
the plan;
• $20: If the amount above is greater
than $25, the minimum down
payment is $20;
• Custom: Any amount provided it is
greater than the amounts in options
(1) and (2).
Monthly Payment
Restriction
Monthly installment payment cannot be
less than $20
Monthly installment payment cannot be
less than $20
Monthly installment payment cannot be
less than $20
Attachment B
Online Payment Plans
ELP ELP+
*Open Enrollment
Standard Non-Hardship
Multiple Payment
Plans
No
No
No
Add Additional
Tickets to Existing
Plan
Yes
Can extend plan term when adding
tickets to a standard payment plan
Yes
Can extend plan term when adding
tickets to a standard payment plan
No
Consequences of
Default
• Prohibited from entering
another Early payment plan for
the same violations
• May become boot and/or
suspension eligible
• Penalties will be assessed if the
ticket is not paid in full
• One time monthly late
allowance, $5 fee to reactivate
• Prohibited from entering
another Early payment plan for
the same violations
• May become boot and/or
suspension eligible
• Penalties will be assessed if the
ticket is not paid in full
• One time monthly late
allowance, $5 fee to reactivate
• Default fee to account for
chargeback fee
• Citation penalties will be
reassessed
• May become boot and/or
suspension eligible
• One time monthly late
allowance, $5 late fee to
reactivate
Additional Benefit
• No penalty is assessed on
ticket(s) if you successfully
complete the payment plan
• May enter multiple Early
Payment plans if you received
additional tickets
• DMV Hold removal
• Will prevent booting
•
Penalties will be waived
• No penalty is assessed on
ticket(s) if you successfully
complete the payment plan
• May enter multiple Early
Payment plans if you received
additional tickets
• DMV Hold removal
• Will prevent booting
• Penalty 2 will be waived upon
full payment
• If only Penalty 1 is assessed, it
will be reduced by 40% upon
full payment
• Citations enrolled will be
suspended until payments are
complete
* Requirements for the Open Enrollment Standard Non-hardship are proposed guidelines. This proposal is subject to review and may
change after an extensive review by prospective parking citation processing agencies through the Request for Proposal process.