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Konsyumer Inc.

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September 27, 2019

Committee on Trade and

House of Representatives

Batasan Complex

Quezon City

Subject : Car Park Regulation


Laban Konsyumer Inc., a non
stock, non profit registered entity is an accredited consumer
organization of the Department of Trade and Industry and a full
term member of the Consumers International .

We submit our comments and
recommendations on various bill proposing regulations of the car
park business, namely HB 386,
450,506,1037,2125,2214,2923,3215,3262,3540,3559,4335 and 4621.

First, we propose that
Congress propose a broad policy that encourages the establishment
, operation , maintainance and security of the car park business
amidst the worsening conditions of vehicles that use the public
streets for parking .

Second, car park business
could start in the neighborhood barangays , villages and
subdivisions that will use vacant lots and premises as parking
spaces. Local ordinances can issue zoning guidelines of the
parking premises . The local barangays or an entrepreneur , can
operate , maintain and secure parking premises at terms and
conditions the concerned lot owners , Homeowner Associations ,
the public transport like jeepneys associations including
tricycles owners and drivers associations can agree with the local
executives . Buses normally enters into leases on vacant
premises as their parking terminals .

Third, in the cities ,
commercial and government centers , business should be encouraged
to establish and operate more private and commercial parking
structures on vacant premises at no cost to the local government
unit . The concerned local government unit should extend all
support to the entrepreneur entering the car park business.

Fourth , the applicable rates
and schemes proposed in the various bills can be harmonized .
There could be no one formula that fits all types of commercial
parking premises. Local government units that can afford to offer
discounts to parking fees for certain sectors of the society
should be allowed to do so but should not be mandated as such. We
are oppose to provide fines and penalties in the conduct of the
car parking business.

big operators of parking buildings in malls and other commercial
establishments, including hospitals , should provide disclosure
to Congress on whether their existing rates are subsidized by the
amounts they collect from their tenants. The disclosure is
relevant in the crafting of applicable rates on the matter .

Laban Konsyumer Inc. expresses our appreciation to the various
sponsors of the Bills for the opportunity to submit our comments
, as well as conveying our desire to continue our participation
in the deliberation of the various bills.

Very truly yours,

Victorio Mario A. Dimagiba, AB, LLB, LLM