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TECHNICAL MEMORANDUM

DATE: Tuesday, June 15, 2021

TO: Tim Cummings, Director of Economic Development — City of Nashua

cc: dill Stansfield, Parking Manager; Amy DeRoche — City of Nashua

FROM: Andrew Hill, Senior Associate — DESMAN Design Management

PROJECT: Nashua Overnight Parking Study PROJECT #: 20-21100.00-3
RE: Draft Report (Revised)

In early 2021, DESMAN Design Management (“DESMAN”) was retained by the City of Nashua to engage
in a course of study to determine if the City's current policy of prohibiting overnight parking should be
revised and, if so, in what manner and to what extent. The following memorandum summarizes DESMAN’s
work to date on this engagement and recommendations.

EXECUTIVE SUMMARY

DESMAN did not find ground to recommend a bianket repeal of the existing regulations banning overnight
parking across the City of Nashua. However, we did find interest in establishment of permit programs
allowing for overnight parking specific neighborhoods in some wards within the City. After review of
practices employed in peer municipalities and parking industry best management practices, DESMAN
developed a proposed program for the establishment of parking permit zones within the City of Nashua.
This program hinges on citizens in an area who desire parking on public streets overnight to:

1) Demonstrate that the majority of households within the proposed area support the program;

2} Agree to core program rules which require streets to be cleared during snow emergencies and to
facilitate periodic trash collection and street sweeping;

3) Abide by all other existing regulations (i.e., daytime time limits, metering, etc.) prevailing on on-
street parking within their proposed zone as well rules specific to the proposed program;

4) Register their vehicles and maintain current registration and contact information with the City
when purchasing a permit;

5) Park only in areas within their zone deemed by the City to be able to safely allow for overnight
parking while maintaining clear and free passage for personal, emergency, and service vehicles
along the roadway;

6) Agree to limits on the number of permits issued in total and the number of permits allowed per
household to maintain a balance between legal on-street parking supply and the number of
permits issued;

7) Purchase permits annually at a cost per permit which allows the City to establish zones at no direct
to any constituent other than program participants and subsidize the cost to maintain on-street
parking areas within the zone;

Board of Aldermen Page 7
November 9, 2016

R-16-074
Endorsers: Mayor Jim Donchess
Alderwoman Mary Ann Melizzi-Golja
Alderman Richard A. Dowd
Alderman-at-Large Michael B. O’Brien, Sr.
RELATIVE TO THE TRANSFER OF $25,000 FROM DEPARTMENT #179 “LIBRARY,” ACCOUNT
CLASSIFICATION 51 “SALARIES AND WAGES” AND ACCOUNT CLASSIFICATION 52 “FRINGE
BENEFITS” INTO DEPARTMENT #183 “ECONOMIC DEVELOPMENT”
Given its second reading;

MOTION BY ALDERWOMAN MELIZZI-GOLJA FOR FINAL PASSAGE OF R-16-074
MOTION CARRIED

Resolution R-16-074 declared duly adopted.

R-16-075

Endorser: Alderman Richard A. Dowd

AUTHORIZING RELEASE OF A CERTAIN ACCESS EASEMENT OVER 482 AMHERST STREET
Given its second reading;

MOTION BY ALDERMAN DOWD FOR FINAL PASSAGE OF R-16-075
MOTION CARRIED

Resolution R-16-075 declared duly adopted.

R-16-076
Endorser: Mayor Jim Donchess
Alderman-at-Large Lori Wilshire
Alderman June M. Caron
Alderman Richard A. Dowd
Alderman Ken Siegel
Alderwoman Mary Ann Melizzi-Golja
Alderman-at-Large Michael B. O’Brien, Sr.
Alderman Tom Lopez
Alderman-at-Large Brian S. McCarthy
AUTHORIZING THE CITY OF NASHUA TO EXTEND AND AMEND THE LEASE FOR THE
HERITAGE RAIL TRAIL COMMUNITY GARDEN
Given its second reading;

MOTION BY ALDERMAN WILSHIRE FOR FINAL PASSAGE OF R-16-076
MOTION CARRIED

Resolution R-16-076 declared duly adopted.

Identify regulatory and product market considerations with “no improvements” alternatives over
the 20-year planning period. Meet with representatives of NHDES to assess regulatory concerns.
Meet with RMI and Casella to assess agronomic end-user concerns.

Summarize the necessary capital improvement needs to maintain the existing digester facilities
over 20-year planning period for this “no improvements” alternative.

Identify beneficial use and disposal options over the 20-year planning period with the “no
improvements” alternative.

E. Preliminary Screening of Drying Alternatives:

F.

1.

Determine desired throughput capacity, operating regime. Assess requirements for dewatered
cake storage and feed, drying process throughput, post-processing (finished product
characteristics), and dried product storage requirements.
Conduct a screening level evaluation of drying technology alternatives to process dewatered sludge
for disposal including:

i. Belt Dryer

ii. Rotary Drum Dryer (triple pass type)

iii. Indirect Dryer
Meet with firms that market dried biosolids (RMI, Casella, Synagro, New England Fertilizer) to
assess desirable and minimum acceptable product characteristics for each drying technology.
Obtain input on potential markets for the product from each technology and product storage
requirements. Meet with City landfill staff to assess characteristics to allow land filling and/or use
as daily cover.
Arrange site visits for City staff for 2 days to nearby drying facilities (rotary drum - GLSD, MWRA-
Quincy; paddle-type: Naugatuck, Waterbury, Springfield, other). Arrange one overnight site visit to
remote location to visit belt dryer installation(s}. The budget for this scope item shall include
$4,000 for non-labor travel expenses for Wright-Pierce and City staff.
Develop order of magnitude life-cycle costs for each drying technology option and assess options
for using hot water from CH&P generators and/or biogas as the hot source for the drying process.
A list of non-monetary factors will also be developed for these options as part of the cost-benefit-
risk analysis. Non-monetary factors will include regulatory requirements, equipment footprint,
public acceptance (odors, etc.}, characteristics of dried product, and impact on beneficial use and
disposal options.
Determine recommended technology based on cost and non-cost factors.
Evaluate beneficial use and disposal options with dried Class A product versus continuing with
existing facilities (Class B or less). Develop life cycle biosolids management cost comparison for
most likely beneficial use/disposal option with drying facility versus existing.
Summarize findings in a technical memorandum and submit to City staff for review. Hold meeting
with City staff to review comments and finding. Update technical memorandum based on
comments from City staff.

Preliminary Design Development

1.

Develop preliminary design documents (basis of design technical memorandum and process
drawings) for the recommended technology that includes sizing of drying system; sludge cake
conveying and storage; post processing and storage; and product off-loading.

Develop plan for providing an adequate level of odor control to avoid off-site odor impacts from
drying facility.

WRIGHT-PIERCE = 2 of 3

ing a Better Envi

8) Periodically certify that the majority of households within an established zone still support the
program.

Additional detail on this proposed program can be reviewed starting on page 14 of this document.
BACKGROUND

Per the City of Nashua’s Code of Ordinances, under Part Il (General Legislation), Chapter 320 (Vehicles and
Traffic), Article XIll (Night Parking), individuals may not park on City Streets for longer than two
consecutive hours between midnight (12:00 4AM} and 6:00 AM at any time without a permit. Discussions
with City staff indicate this ordinance was originally adopted in the 1930's as a public safety measure
against individuals parking outside private homes and businesses to observe those structures prior to the
commission of a crime. When initially enacted, this was a blanket prohibition across the entirety of
Nashua without exception.

Review of the City’s Code suggests that an amendment ({320-78.1) to this blanket prohibition was
introduced in 2013, allowing for overnight parking of private vehicles on selected city streets by permit
only. The Code indicates a maximum limit of 550 permits could be applied for and issued te residents
living at select addresses or streets where overnight parking by permit was authorized. Currently, there
are a total of forty defined areas on thirty-two streets where overnight parking by permit is allowed.

individuals wishing to receive a permit to park overnight on designated streets must prove residency on
one of the authorized streets or at twelve authorized areas as defined in the Code. There is no limit on
the number of permits a qualified resident can receive, but each permit must be specific to a private
vehicle registered to the place of residence; qualified residents may not purchase a permit for a
commercial or recreation vehicle or boat.

Permits cost $10.00 per year currently and allow the holder to park overnight in authorized areas where
parking is alowed and under conditions where parking is authorized. Permit holders may not park in areas
not designated for parking, may not park on the street during snow emergencies or when street
maintenance is scheduled, and may not remain in the same space for more than 48 consecutive hours. All
proceeds from permit sales are dedicated to covering the cost of the program first, with any surplus
revenues pledged to neighborhood improvements in the area where the program is executed. Violators
of the overnight parking regulations are subject to parking citation and associated fine of $25.00, which
increases to $35.00 if not paid within seven days of issue.

A search of news articles indicates that the question of overnight parking has consistently been debated
by residents and city leaders for well over a decade as Nashua has grown and increased in density,
especially in those neighborhoods closest to the downtown core. As DESMAN understands it, this study
was sparked by a request fram a member of the Board of Alderman asking for a third-party examination
of the policy in light of changes in residential dwelling and commuting patterns provoked by the COVID-
19 pandemic.

METHODOLOGY
DESMAN initiated our course of study with a series of structured virtual “Town Hall’ meetings with the

residents of each Ward within the City of Nashua. These meetings lasted between 60 and 90 minutes and
length and were conducted over a period of seven weeks in January, February and March of 2021.

Attendance at these meetings varied from just a handful of residents in some wards to upwards of eleven
residents in some of the wards closest to downtown. In addition, representatives from the Nashua
Department of Public Works, the Board of Alderman, the Parking Department, and Economic
Development were also on hand. These meetings were conducted as open forums during which residents
were encouraged to speak out about their concerns, desires, objections to and/or support for a change in
the current policy regarding Overnight Parking. Residents were also encouraged to ask questions of
DESMAN representatives, City staff, and Alderman and to react to conceptual scenarios regarding possible
changes to the policy.

DESMAN also met with representatives of the Nashua Police Department, Fire Department, Department
of Public Works, Parking Department, and Economic Development to discuss their perspective on any
potential change to current policy and how it could impact their respective missions and operations. These
interviews were conducted virtually in December 2020.

During the course of interviewing City staff, leaders, and Alderman and subsequent to concluding the
public forums, DESMAN also executed a course of study to examine best practices with regards to
overnight parking policy across the whole of the parking, transportation and mobility industry as well as
at specific municipalities deemed “comparable” to Nashua.

Based on this feedback, DESMAN prepared a set of recommended policy changes for consideration by
City staff and the Board of Alderman.

FEEDBACK FROM PUBLIC FORUMS
In total, DESMAN conducted a total of eleven forums; one for each ward and two supplemental meetings
to revisit issues and questions raised in Wards 3, 4 and 7 that could not be addressed in the original

meeting. A summary of attendance by meeting is provided in Table 1.

Table 1: Attendance by Ward for Public Forums

Attendees

Date Ward Residents Alderman Staff Total
1/14/2021 9 2 1 6 " 9
1/21/2021 8 3 1 6 "40
1/25/2021 7 6 1 7 "44
1/28/2021 6 g 1 7 46
2/1/2021 5 2 2 8 "2
2/4/2021 4 11 2 7 "20
2/8/2021 3 1 1 7 "49
2/11/2024 2 4 2 7 "43
2/18/2021 1 6 2 5 r 43
3/8/2021 4* 6 2 5 13
3/11/2021 3&7* 8 3 5 16
TOTALS 67 18 70 455

* Supplemental meeting to cover additional topics/issues

At least one Alderman was present for each meeting and five City staff members from Economic
Development, Parking and the Department of Public Works. The wards located the furthest from
downtown Nashua, in areas where residential density was lower and most single-family homes had
substantial driveways and often garages, generally attracted lower attendance and interest from citizens
than those closer to the downtown core, where off-street was not universally available with all residential
structures. Universal issues raised across all forums, in no particular order, included the foliowing:

* Lifting of the overnight parking ban could disrupt snow removal operations if the program is not
rigidly structured and enforced.

e =Any change in policy must account for reasonable setbacks from individual refuse containers for
each property, which require a minimum clearance of 2’ to any side of the container to allow
automated vehicles to safely grasp, lift, and empty the receptacles.

e =6Any privileges granted by a change in policy would not negate the requirement to clear streets to
allow for periodic sweeping and maintenance during the year.

« Any change in policy should be specific only to residents and their guests and should not be
extended to commuters, business owners, or others.

e Any change in policy which allows for overnight parking on public streets should be supported
with clear markings indicating where individuals can and cannot park. This includes minimum
setbacks from fire hydrants, driveways, crosswalks, intersections, etc.

¢ Any change in policy must take into account the geometrics (i.e., dimensions of width, length,
number of travel lanes, etc.) of the particular street(s) being considered and must accommodate
the safe and efficient passage of large emergency and municipal service vehicles.

Some residents in Wards 9, 8, 2, and 1 questioned the need for any change in policy, stating that most of
the homes in their neighborhoods had abundant off-street parking contained in driveways and private
garages. Those residents in these wards who spoke out in support of a change indicated that they were
advocating primarily for themselves and desired the ability to park on public streets overnight to
accommodate guests or members of their households who could not be parked in their existing driveways
or garages.

Within the other wards (3-7) there was a mix of sentiment, with some residents strongly in favor of a
change in policy and others equally strident in the opposition. Individual reasons for each perspective
varied, but in general, those individuals arguing in support of a change in policy did so due to the following
conditions:

® The properties they occupied and/or the properties within their neighborhood were constructed
prior to the proliferation of personal vehicles in the United States and as a result were not
equipped with off-street parking in match with today’s market standards.

« Many properties had adequate parking to support the needs of residents, but not necessarily their
guests. This issue has been augmented during the pandemic as many households experienced
college-age children returning home for remote learning unexpectedly.

e The property they lived in and/or an adjacent property had been converted from a single-family
home toa multiple unit property, inflating demand beyond the size of the parking supply provided
when the property was first constructed.

e The need for overnight parking was not a constant, but rather a transient issue experienced
primarily around the holidays when family from outside the city came to visit for several days.
During these times, the ability to park on the street would help alleviate demand for the limited
capacity contained within the resident's existing driveway, garage, and/or lot.

Those individuals living in the same wards who opposed any change to policy noted the concerns about
roadway width and geometrics and impacts on snow removal, street maintenance and trash collection
noted previously. In addition, these individuals submitted the following arguments:

e Zoning regulations are intended to assure adequate provision of parking to support any land use
and/or change in use of an existing building. If there is a problem with parking adequacy for a
particular property, it should be incumbent on the property owner or developer to provide
adequate capacity in an off-street facility.

e Opening up overnight parking at the curb does not guarantee the space(s) in front of an
individual’s house will be set aside for their exclusive use. The possibility does exist under such a
program that a stranger could be parked in front of your house overnight.

e The City already provides overnight parking options in their off-street facilities for those who have
a need.

e There may not be adequate capacity on public streets in some areas to accommodate all the
individuals seeking parking.

e Along some streets, there are no sidewalks, so pedestrians and bicyclists use the edge of the
roadway for travel. Parking vehicles on these streets overnight would force these individuals into
traffic during the morning hours when many residents run, jog, walk, etc.

As a general rule, all parties agreed that any change in policy could only occur within a structured
framework that required participants register their vehicles with the City and abide by a uniform set of
regulations (e.g., a permit program). By the same token, the majority of participants indicated they would
only support a program which was offered at no- or low-cost to participants, arguing that residents already
pay substantial property taxes.

BASIC PRINCIPLES AND BEST PRACTICES

The number of municipalities which offer unrestricted access to and use of curbside parking is dwindling
across the United States as towns and cities continue to grow and densify. This is a natural response to
increasing competition for a limited resource or public good. As first documented by British economist
William Forster Lloyd in 1833, any unregulated public resource unhampered by formal rules governing
access and use may become depleted when individual uses act in their own self-interest, rather than the
common good; this is known in the fields of economics, psychology, anthropology, sociology and urban
planning as ‘the tragedy of the commons’.

In the context of urban planning and municipal management, curbside parking is a public good provided
for the benefit of all constituents within a community, including residents, visitors, merchants, patrons,
workers, and others conducting themselves within that community. Curbside parking is, by its very
definition, a limited resource as only so many vehicles can be accommodated along public streets within
a defined area and, as often is the case, the land uses occupying that area generate parking demand in
excess of the parking capacity contained therein. Even when there is ample off-street parking within an

area, individuals will generally prefer to park on the street when possible as it often affords greater
proximity and line-of-site travel paths to most destinations than off-street options.

When the density of a community reaches a point where competition for curbside parking begins ta create
conflicts with various constituencies, municipal leadership typically begins to impose rules and regulations
to assure fair and equitable access to all constituents to this limited resource. These rules and regulations
often begin as time iimits imposed to assure reasonable turnover and availability of curbside parking ina
particular area during periods of heightened demand. As density continues to grow in the area and
competition increases, the community may migrate to a system of metering which places a financial cost
on accessing curbside spaces, further reinforcing the community's desire to create turnover of these
spaces by adding an entry cost (i.e., the meter fee) to a penalty {i.e., the fine for failing to pay the meter
and/or exceeding posted time limits or other regulations).

A community may also elect to manage and regulate access to and use of curbside parking through a
parking permit system. This system ailaws the municipal leadership to define who may use curbside
parking in a particular area under different conditions by requiring individuals wishing to park on the street
to register their vehicle with a public agency and abide by a particular set of regulations. These programs
provide a number of benefits which include:

1. Improving the effectiveness of parking enforcement. When a particular area is designated as
parking by permit only and participants are required to identify their vehicles in a prescribed
manner, it makes it much easier for parking enforcement officers to find unauthorized vehicles
and cite them.

2. Expediting communications between program participants and the municipality. By registering
for the program with the municipality, the individual participants provide current contact
information to the municipality which can speed communication when conditions occur which
may require clearing the streets within the area, such as snow emergencies or scheduled street
maintenance.

3. Improving security within the district. In addition to making it easier for parking enforcement
officers to identify scofflaws, parking permit programs also make it easier to identify individuals
parking in an area for reasons beyond evading parking regulations.

Most municipalities of any size or density which allow for overnight parking on public streets typically do
so within the framework of a parking permit program for the preceding reasons. These programs are often
structured as “Residential Parking Permit” (RPP) programs, but may go by other names as well. Some of
these programs require a permit to park on the street on a 24/7 basis, while others are only in effect
during overnight hours and/or weekends. The first type of program is common in areas that are comprised
solely of residential land uses while the second is more common where residential units share a district
with other land uses.

Parking permit programs may be established in areas adjacent ta commercial districts to prevent
individuals seeking to avoid time limits and/or meter fees imposed within those commercial districts from
migrating to the adjacent neighborhoods. Alternately, parking permit programs may be established in
commercial districts where time limits and/or metering are already in place, but may only be in effect
when active enforcement ends for the posted time limits and/or metering. In mixed-use neighborhoods
where residential is the dominant land use, but there are retail establishments and/or restaurants, it is

not unusual to find the area is subject to a fixed time limit, often 2-3 hours, or metering requirement
unless the vehicle has a permit.

As a general rule, only individuals meeting certain criteria can apply for and receive a permit. Most
commonly, the applicant must demonstrate proof of residency by providing mortgage documents, a lease
or rental contract, a property tax bill, a utility bill, or some of other defined proof that they reside within
the define parking permit area. Often applicants must also provide a copy of their vehicle registration to
prove it is garaged at their home address and legally registered to operate within the municipality and/or
state. Applicants are also asked to provide contact information such a home phone, cell phone, mailing
address and email address.

The decision on how many permits to allow an applicant and whether they will be subject to any kind of
fee is largely a political one, based on each community’s dynamics. In large urban centers like Boston with
a robust transit system, the municipality may elect to issue a permit to any individual meeting their
criteria, despite the fact are there a very limited number of curbside spaces available in each permit zone.
These permits may be offered to qualified applicants at no- or low-cost, but are in essence a ‘hunting
license’ within the district and not a guarantee of accommodation. In these instances, the leadership for
the municipality may elect to offer permits in excess of capacity without concern for impact as individuals
who cannot find an open space on the street can presumably be accommodated in one of many private
off-street commercial parking facilities in the area and/or elect to store their vehicle or get rid of it in favor
of alternative modes of transportation which do not require parking.

In smaller communities with lesser transit service, the municipality may limit the number of passes issued
to a prescribed limit in attempt to balance the number of permits against the curbside capacity within the
permit area. In these cases, the municipality may fix a maximum number of permits to be issued against
the judged capacity of a defined permit area or zone and distribute the permits to qualified applicants on
a first-come, first-served basis. Alternately, the municipality may limit the issuance of permits to X per
individual or household to maintain balance between supply and demand. These methodologies are most
common among municipalities which offer permits at no- or low-cost.

In more progressive communities, the municipality regulates the number of permits issued through
pricing structures. For example, Town X determines it can comfortably offer one space per household
within a defined parking permit zone, but only one addition space for every 5 households in the same
area. As a prescription of 1.2 permits per household is not achievable, the Town offers the first permit as
a universally accessible price for the community, but additional permits at an aggressively increased cost.
Under such a structure, any household who wants a permit can reasonably purchase the first one, but
each household must determine if the cost of additional permits is warranted. In this manner, the
municipality does not prescribe the number of permits per household, but rather allows households to
determine how valuable additional permits might be relative to their budget and means.

The City of Boston is currently considering such a structure, which would charge $25.00 for the first permit
and escalating costs of an additional $25.00 for each additional permit (e.g., $50.00 for the second, $75.00
for the third, etc.). The City of Fort Collins, Colorado has already adopted this structure, offering the first
permit for free to qualified applicants, but charging $15.00 for the second permit, $40.00 for the third,
$100.00 for the fourth, and $200.00 per permit for each vehicle thereafter.

Other communities, such as Portland, Oregon, control residential permit issue through pricing by setting
the cost per permit at a high-level, $180.00 per permit, but offering a lower cost, $60.00, to households

meeting the local definition of low income. Several cities have considered, but have not yet implemented,
a rate structure that applies a slide scale to the cost of each permit relative to the applicant's reported
income. A variation of this structure is in place at the University of Connecticut which charges employees
and faculty for annual parking permits based on income.

PRACTICES IN COMPARABLE COMMUNITIES

In conjunction with leadership in the Nashua Economic Development, DESMAN identified ten
communities which were considered comparable to Nashua and/or aspirational. In evaluating
communities, DESMAN considered factors such as population, population density, housing density,
median income and the percentage of workers reporting they drove alone each day (“driving share”.)
Three of the communities studied were in New Hampshire and six were located in New England states.
The communities studied are shown in Table 2.

Table 2: Comparable and Aspirational Communities Studied

City: Noshua Albany AnnArbor Concord Concord Manchester Meridian Portland Portsmouth Rochester West Hartford
State: NH NY Mi NC NH NH ID ME NK MN cT
Population: 88,815 97,889 117,082 91,980 43,244 112,673 101,905 66,735 21,778 145,557 63,063
Area: {sq mi) 31.73 21.94 28.79 63.54 63.90 34.94 34.03 69.44 16.82 55.69 22,30
Pop. Density: “2,719.9 4,506.84 4,297.59 1,517.13 688.30 3,406.59 3,360.74 3,059.92 1,400.28 2,146.69 2,888.90
Housing Units: 37,168 46,362 50,863 36,101 18,663 49,288 43,043 34,075 10,615 49,757 26,437

Housing Density: 1,202.8 2,166.40 1,824.70 568.16 252.07 1,493.60 1,206.08 1,581.60 678.90 893.46 1,385.52
Medianincome: $73,022 $45,500 $63,596 $83,957 $62,967 $58,227 $75,515 $56,977 $78,027 $73,016 $104,281
Driving Share: 80.1% 59.1% 53.2% 80.4% 79.5% 78.7% 82.0% 64.6% 74.7% 70.6% 82.9%

DESMAN initially evaluated each of these communities according to their basic policies regarding
authorization for overnight parking (“O.P.”). Specifically, BESMAN examined each community’s codes and
ardinances to determine of the municipality:

Had a blanket prohibition on overnight parking on public streets.

Allowed for parking on public streets during overnight hours by permit.

Had instituted a Residential Parking Permit (RPP) program to manage on-street parking.

Did not have any rules or regulations specific to the issue of overnight parking on public streets.

As shown in Table 3 on the next page of the ten communities examined only West Hartford, Connecticut
had a blanket prohibition on overnight parking including in their code of ordinances.

In Albany, New York, an individual can park for free on downtown public streets between 5:00 PM and
8:00 AM the follawing day on weekdays and all day on weekends and holidays, but must purchase permit
to park in one of the Albany Parking Authority’s off-street facilities.

While the other communities did not prohibit overnight parking per se, there were regulations within
each community’s codes regulating parking on-street in some manner. For example, Concord, New
Hampshire prohibited the parking of any commercial vehicle on public streets between midnight and 5:00
AM and required persona! vehicles parked on street to not stay in one place for more than 48 consecutive
hours. Rochester, Minnesota allows overnight parking on public streets without a permit, but requires
vehicles to park only on the even numbered side of the streets on even numbered days and the odd
numbered side of the street on odd numbered days between 2:00 AM and 3:00 PM from October 1 to
May 1 each year. The City of Manchester, New Hampshire has a code on their books which suggests that
overnight parking was banned on public streets until 2011, when the prohibition was rescinded.