Petition Record on Parking Rate Hikes at Shuidui Parking Garage, Tamsui District Office

In the Tamsui district, there is a public parking facility: the “Shuidui Parking Garage.” Previously, the monthly rental fee was NT$2,300 per month, or NT$6,000 when paid quarterly—effectively NT$2,000 per month. In Tamsui, a suburb situated over 20 kilometers away from central Taipei, this was considered a reasonable price point.

Then one day, the parking attendant notified me that another property management firm had won the public tender and taken over facility operations (yes, the notorious Build-Operate-Transfer / outsourcing model). Immediately, the monthly rate was hiked on the spot to NT$2,800 per month, or NT$7,500 quarterly. Overnight, the effective monthly rent escalated from the lowest NT$2,000 directly to NT$2,800—a steep gap of NT$800. And this drastic markup occurred purely because of an operator handover, without a single upgrade to hardware, software, or facility infrastructure!

I have always operated under the banner of reason and logic. If a new management company introduced upgraded software, state-of-the-art access equipment, or improved service standards, that would provide reasonable grounds to discuss a price revision.

Instead, the newly contracted vendor operated entirely upon the pre-existing infrastructure, merely changing the middleman collecting the fees (the highest tier remained the Tamsui District Office, while on-site attendants were grandfathered in). Why should an administrative intermediary suddenly demand significantly more money from residents?

Consequently, I dispatched formal petition letters to the local municipal office, urging them to prioritize citizen welfare. Below are two official petition correspondences exchanged with the Tamsui District Office (formerly the Tamsui Township Office). The complete official documents are reproduced below with personal names redacted to safeguard individual privacy.

The correspondences transcribed below are documented factually without subjective commentary, allowing readers to judge the merits freely. Relevant statutory articles are attached at the conclusion for reference.

Citizen Petitions Against the Parking Fee Increase

This was my initial petition letter, submitted through the New Taipei City (formerly Taipei County) Mayor’s Mailbox [1]. The management company cited in the complaint is a major property management conglomerate operating municipal parking lots across multiple counties and cities. I conducted specific research into their pricing strategies across other jurisdictions to present to government authorities for comparative evaluation.

First Petition Subject: “Shuidui Parking Garage”

Petition Submission Date: 2010-10-30 02:00:36

Case Reference Number: 1010300001

Petition Content: The new management contractor is charging exorbitant fees—an increase of NT$500 per month over the previous rate, which is completely unreasonable! All software, hardware, and structural facilities were already completed under previous administration. Raising prices out of thin air like this is utterly unjustified. Even in Xinzhuang, where this management company is headquartered and parking facilities sit along major traffic arteries, monthly fees are only NT$3,000. Yet charging NT$2,800 in a residential locale like Shuidui clearly takes unfair advantage of Tamsui residents. We request the mayor to uphold fairness. The local office has a duty to protect local residents’ rights!

Official Disposition:

Thank you for your valuable feedback, esteemed resident. This office hereby clarifies as follows:

1. Regarding your petition concerning the rate increase at the Shuidui Multi-Story Parking Garage: Pursuant to Article 3 of the Taipei County Public Parking Lot Management Self-Governance Ordinance, “The benchmark pricing for monthly passes shall be calculated based on the hourly rate multiplied by twenty-five days multiplied by eight hours. However, discounts may be granted considering local parking supply and demand conditions; private operators commissioned to manage parking lots shall submit any adjustments to monthly pass rates in advance to the competent authority for approval.” The hourly rate applicable to this parking facility is NT$20 per hour, establishing a statutory benchmark price of NT$4,000 per month. If an operating vendor adjusts the monthly pass price above NT$4,000, prior approval from the supervisory authority is required.
2. The new operator’s adjustment of the monthly pass rate to NT$2,800 does not violate the provisions of Article 3 of the Taipei County Public Parking Lot Management Self-Governance Ordinance. Insofar as the operator’s pricing does not breach relevant regulations, this office possesses no legal authority to intervene.
3. Thank you for your continued concern for municipal affairs. We wish you good health and every success.

Tamsui Township Office, Construction Section, XXX Respectfully

Processing Date: [2010-11-08 14:19]

Let us summarize the gist of this first official reply: the Construction Section claimed that under Article 3 of the ordinance, as long as the monthly fee does not exceed NT$4,000, no supervisory approval is required.

However, in citing the ordinance, the Construction Section deliberately dodged the crucial condition explicitly stated in the statutory text: “Private operators commissioned to manage parking lots shall submit any adjustments to monthly pass rates in advance to the competent authority for approval.”

Do you see the sleight of hand? The Construction Section told citizens that approval is only required when fees exceed NT$4,000, conveniently concealing the fact that any price adjustment, regardless of amount, legally requires advance administrative review and approval.

Civil servants capable of such disingenuous legal gymnastics would truly thrive as manipulative politicians or adversarial litigators; remaining modest civil servants seems almost a waste of their talents.

In other words, this unilateral rate hike can practically be construed as having been sanctioned and facilitated by the municipal authority itself.

Therefore, I followed up with a second petition letter.

Second Petition Subject: “Re: Case Reference Number 1010300001 Official Response”

Petition Submission Date: 2010-11-08 20:21:26

Case Reference Number: 1011080039

Petition Content: Your Construction Section replied stating that “The new operator’s adjustment of the monthly pass rate to NT$2,800 does not violate the provisions of Article 3 of the Taipei County Public Parking Lot Management Self-Governance Ordinance. Insofar as the operator’s pricing does not breach relevant regulations, this office possesses no legal authority to intervene.” However, upon review of the ordinance, Section 3 of the Schedule attached to Article 3 explicitly specifies: ”…However, discounts may be granted considering local parking supply and demand conditions; private operators commissioned to manage parking lots shall submit any adjustments to monthly pass rates in advance to the competent authority for approval.” Consequently, any price adjustment by the management company must be submitted to the supervisory authority for approval in advance. Article 2 of the same ordinance designates the Township Office as the competent authority. Yet, your office claimed in the previous letter that you have no authority to intervene. Does this imply that your office has neglected its statutory supervisory obligations, or did the management company fail to notify your office to seek required approval for its proposed rates? I am deeply concerned that either your office or the contractor may have violated the Administrative Procedure Act, and urge you to investigate thoroughly.

Official Disposition:

Thank you for your valuable feedback, esteemed resident. This office hereby clarifies as follows:

1. Regarding your petition regarding the follow-up to Case Reference Number 1010300001 and your queries on Article 3 of the Taipei County Public Parking Lot Management Self-Governance Ordinance: Upon review, the clause “if an operating vendor adjusts monthly passes…” in Article 3 refers to situations where the adjustment exceeds the benchmark specified in this Article (in this case, NT$4,000/month), which requires prior approval from the supervisory authority.
2. Because the new operator’s adjusted monthly pass fee of NT$2,800 does not violate Article 3 of the Taipei County Public Parking Lot Management Self-Governance Ordinance, this office has accepted it for official record (filed for reference).
3. Thank you for your continued concern for municipal affairs. We wish you good health and every success.

Tamsui Township Office, Construction Section, XXX Respectfully. Processing Date: 2010-12-10 13:37

Did I not remark earlier that this Construction Section official was born to be a politician? His ability to fabricate statutory interpretations out of thin air is truly jaw-dropping.

The verbatim text of Section 3 of the Schedule to Article 3 reads: “The benchmark pricing for monthly passes shall be calculated based on the hourly rate multiplied by twenty-five days multiplied by eight hours. However, discounts may be granted considering local parking supply and demand conditions; private operators commissioned to manage parking lots shall submit any adjustments to monthly pass rates in advance to the competent authority for approval.”

The full text of Article 3 states: “Public parking lots may have their rate categories, collection methods, operating hours, designated locations, eligible vehicle types, and payment deadlines determined and announced by the County Government based on differences in zone, traffic volume, and time periods; and progressive, discounted, or differentiated rates may be applied based on special circumstances. The aforementioned fee rates shall adhere to the attached Schedule.”

Neither Article 3, Section 3 of the Schedule, nor the entire body of the ordinance contains the phrase concocted by the official: “if an operating vendor adjusts monthly passes [beyond benchmark]…”. One cannot help but wonder what statutory basis this official was relying upon—other than going out of his way to help the private vendor bypass public oversight.

Looking at Section 3 of the Schedule, the benchmark formula and the provision requiring approval for rate adjustments are separated by a period. Grammatically and legally, these two distinct clauses are independent sentences; there is no conditional prerequisite stipulating that “approval is only required if the rate exceeds the benchmark.” The Construction Section clearly realized this vulnerability, which is why in point 2 of the second reply they hastily added the phrase "**this office has accepted it for official record**", engaging in the ultimate game of bureaucratic semantics.

Statutory References

Taipei County Public Parking Lot Management Self-Governance Ordinance

• Article 1: This Ordinance is formulated to strengthen the management and operation of public parking lots, enhance traffic flow, and improve public traffic order.
• Article 2: The competent authorities for public parking lots are as follows:
  1. For on-street parking lots: Taipei County Government (hereinafter referred to as the County Government).
  2. For off-street parking lots owned by Taipei County (hereinafter referred to as the County): the County Government or its subordinate agencies; for off-street parking lots owned by rural townships, urban townships, or county-administered cities: the respective township or city offices.
• Article 3: Public parking lots may have their rate categories, collection methods, operating hours, designated locations, eligible vehicle types, and payment deadlines determined and announced by the County Government based on differences in zone, traffic volume, and time periods; and progressive, discounted, or differentiated rates may be applied based on special circumstances. The aforementioned fee rates shall adhere to the attached Schedule.
• Article 4: The following vehicles parked in on-street parking spaces for official duty execution shall be exempt from parking fees:
  1. Official vehicles of the County Government and County Council, and vehicles issued official parking permits.
  2. Vehicles operated by uniformed volunteer police, volunteer traffic officers, volunteer firefighters, and civil defense personnel.
• Article 5: Vehicles operated by or transporting persons with disabilities parked in on-street parking spaces shall be exempt from fees. When parked in public off-street parking lots, such vehicles are limited to one free session per day up to three hours; parking exceeding three hours shall be charged at half the standard rate.
• Article 6: For vehicles parked in on-street parking lots where payment is not made within the deadline, the competent authority shall notify the driver via ordinary mail to pay within seven days, plus an administrative fee of NT$15. If overdue, notification shall be sent via registered mail to pay within seven days, plus an administrative fee of NT$50. Continued default will result in penalties pursuant to Paragraph 2, Article 56 of the Road Traffic Management and Penalty Act and recovery of owed fees.
• Article 7: For vehicles parked in the same public off-street parking lot exceeding seven days without payment, the supervisory authority shall issue a written notice instructing the owner to retrieve the vehicle and pay outstanding fees within a specified deadline. If identification is difficult due to missing, forged, altered, or canceled license plates, the vehicle engine number may be inspected to ascertain ownership prior to notification.
• Article 8: Vehicles parked in on-street parking spaces shall not exhibit the following circumstances:
  1. Unregistered plates, or use of forged, altered, canceled, or other vehicles’ license plates.
  2. Remaining parked within a 100-meter radius segment exceeding 15 days without fee settlement.
• Article 9: Citizens may apply to the competent authority for revocation of on-street parking spaces or change of use. Application procedures, eligible categories, fees, and related matters shall be prescribed separately by the County Government.
• Article 10: Public parking facilities assume no custodial responsibility for parked vehicles or personal property inside; provided, however, that this limitation does not apply if damage, loss, or theft is attributable to the negligence or liability of the facility operator.
• Article 11: Parking in designated public off-street accessible parking bays without a valid disability identification permit shall incur a fine between NT$600 and NT$1,200. In case of violation of Article 8, the authority may direct the driver or engage private towing contractors to relocate the vehicle to a designated impound lot.
• Article 12: Vehicles relocated by towing contractors pursuant to the preceding Article shall be released upon verification of ownership and payment of towing fees, storage fees, accrued parking charges, and fines. Towing and storage fees shall be charged pursuant to Articles 7 and 8 of the Taipei County Self-Governance Ordinance for Handling Vehicles Obstructing Traffic.
• Article 13: The County Government may assess utilization rates and local parking demands every six months. If the average occupancy rate during charged hours exceeds 80% or falls below 50%, rate categories and charging hours may be adjusted or suspended accordingly upon public notice.
• Article 14: This Ordinance shall come into force on the date of promulgation.

Schedule

Schedule Notes

1. Fee rate categories are classified into six grades: A, B, C, D, E, and F.
2. Rates in Classes E and F apply exclusively to motorcycles parked in public parking lots; all other classes apply to passenger cars. Large vehicles and automobiles complying with Article 3 of the Taipei County Vehicle Advertising Display Management Self-Governance Ordinance shall be charged double the passenger car rate.
3. The benchmark pricing for monthly passes shall be calculated based on the hourly rate multiplied by twenty-five days multiplied by eight hours. However, discounts may be granted considering local parking supply and demand conditions; private operators commissioned to manage parking lots shall submit any adjustments to monthly pass rates in advance to the competent authority for approval.
4. Vehicles utilizing monthly passes shall park on a first-come, first-served basis without designated or reserved spots.
5. Per-session billing does not offer monthly passes (except for motorcycles).
6. Per-session parking is valid only for the calendar day, where “per session” denotes each individual vehicle entry.
7. For hourly on-street parking, durations under one hour are charged as one full hour. For hourly public off-street parking, durations under one hour are charged as one hour; for parking exceeding one hour, fractions under 30 minutes are charged as half an hour, while fractions exceeding 30 minutes are charged as one full hour.
8. All monetary units in this schedule are in New Taiwan Dollars (NT$).

Extended Reading

1. If you plan to file a citizen petition or complaint against government administration, always submit it through the uppermost tier of the petition portal. Avoid sending queries solely to grassroots departments—especially those that only provide a bare email address and expect you to write them directly, as complaints can easily be buried. In this scenario, the supervisory body above the Tamsui District Office is the New Taipei City Government, and the superior executive body above New Taipei City is the Executive Yuan of the Republic of China. Submitting via the central government’s Executive Yuan Citizen Mailbox ensures genuine accountability.
2. First revision on December 18, 2014, updating administrative titles from Tamsui Township Office to Tamsui District Office following municipal restructuring.