By Melanie Curry, February 14, 2014
With today’s deadline looming for comments on new rules governing the
way the state analyzes transportation planning impacts, many
transportation planners and engineers remain confused about what the new
rules might mean while others join advocates in hoping that new rules
will create better projects.
SB 743, signed into law last year, removes traffic Level of Service
(LOS), a measure of traffic congestion, from the list of environmental
impact metrics that have to be used under the California Environmental
Quality Act when planning development and transportation projects. The
Governor’s Office of Planning and Research (OPR) has to decide on a
substitute for LOS that more broadly measures a project’s transportation
impacts. Although SB 743 says LOS must be replaced in dense urban areas
with robust transit access, OPR can also decide to apply that new
metric everywhere in the state.
Focusing on LOS has severely hindered the expansion of bike lanes in
California, including a lawsuit that delayed San Francisco’s bike plan
for years because it might delay car traffic. Critics of LOS have long
argued that using a metric that solely measures the movement of cars,
rather than the movement of people, makes for an inefficient
transportation system and requires costly measures to “mitigate” LOS
“CEQA rules were so backward that you had to analyze the
environmental impact of replacing a ‘car’ lane with a bike lane but you
could remove a bike lane to add a car lane with no analysis required
whatsoever,” said Dave Snyder, executive director of the California
“It’s not just for bikes, either, but for any street improvement that
involves reducing car capacity,” he added, “which is to say transit
lanes, sidewalk bulbouts, or all manner of changes that make a place
more livable, safer, and more prosperous, if a bit more congested with
Another example would be converting a mixed traffic lane to a
bus-only lane. In the past couple of years, there has been a debate in
Los Angeles over expanding the Wilshire Bus Only Lane. Studies showed a
net increase in vehicle congestion in the remaining mixed traffic lanes
with a major reduction in travel time for buses. More people ride the
bus on Wilshire Boulevard than drive, but that didn’t stop opponents of
the bus line from charging that the project was bad for commuters.
Rebecca Long, senior legislative analyst at the Bay Area’s
Metropolitan Transportation Commission, says that by focusing on LOS,
transportation analysis has often undermined environmental goals.
“Congestion itself is inevitable,” she points out. “And it has some
positive effects, like getting people to take transit” rather than
driving, thus reducing per capita emissions.
Which is not to say removing the LOS standard for state environmental review is a universally popular idea.
Streetsblog reached out to planners throughout the state, in cities
and counties, and found uncertainty and some confusion about what the
new law and the proposed rules might mean for them.
Speaking off the record, because their departments have not yet
determined their official responses to OPR’s request for comments, they
expressed concerns about how jurisdictions will determine traffic impact
fees — an important source of funds — if not through LOS, and about how
transit planning can take into account impacts on vehicle traffic.
However, none of these uses of LOS are affected by SB 743 or the
state’s proposed CEQA changes. Martin Engelmann, deputy executive
director of Planning at the Contra Costa County Transportation
Authority, pointed out that LOS is still required under the state’s
congestion management laws and that many general plans and zoning
regulations include LOS standards. “It’s not like LOS is going to
disappear — it will just not be used for a threshold of significance
Englemann dismissed the widely expressed concern that focusing on LOS
necessarily leads to wider, faster roads. “In many places, it’s not
even possible to widen roads,” he said, “so mitigations might include
shuttle buses or multimodal efforts or any number of other things.”
Another objection that some planners have to requiring LOS analysis
is that the process is cumbersome and often produces inaccurate results.
Reams of data are required by LOS models, and the process includes many
steps to reach a precise number. While the number may be precise, the
assumptions in the underlying data are allowed to have a very high error
Some planners think that measuring vehicle miles traveled (VMT) would
uch simpler and produce a more accurate calculation, especially
with recent technologies. Measuring VMT would be a more appropriate way
to analyze bicycle improvement projects that reduce vehicle miles
traveled “even if [they] increase automobile congestion,” according to
the California Bicycle Coalition’s official response to the OPR.
Official comments are due by the end of today to: firstname.lastname@example.org