By Damien Newton and Melanie Curry, August 7, 2014
Vehicle Miles Traveled in California has been on the decline for a
couple of years. Changes in how the state manages transportation changes
promise to drive it even lower.
Ding, dong…LOS is dead.
At least as far as the state of California is concerned.
Level of Service (LOS) has been the standard by which the state
measures the transportation impacts of major developments and changes to
roads. Level of Service is basically a measurement of how many cars can
be pushed through an intersection in a given time. If a project reduced
a road’s Level of Service it was considered bad — no matter how many
other benefits the project might create.
Now, thanks to legislation passed last year and
a yearlong effort by the Governor’s Office of Planning and Research
(OPR), California will no longer consider “bad” LOS a problem that needs
fixing under the California Environmental Quality Act (CEQA) . This
won’t just lead to good projects being approved more quickly and easily,
but also to better mitigation measures for transportation impacts.
Late yesterday, OPR released a draft of its revised guidelines [PDF], proposing to substitute Vehicle Miles Traveled (VMT) for LOS.
In short, instead of measuring whether or not a project makes it less
convenient to drive, it will now measure whether or not a project
contributes to other state goals, like reducing greenhouse gas
emissions, developing multimodal transportation, preserving open spaces,
and promoting diverse land uses and infill development.
“This is exciting,” said Jeffrey Tumlin,
principal and director of strategy at Nelson\Nygaard. “Changing from
LOS to VMT does away with a contradiction that applicants currently
face under CEQA. The contradiction between the state’s greenhouse gas
reduction requirements and the transportation analysis requirements is
This revision in state law promises many positive changes.
The most obvious one is that sponsors of projects that aim to reduce
car dependency will no longer have to spend time and money measuring
their potential to delay cars. VMT is easier and faster to estimate, and
it produces a measure of a project’s effect on overall travel, rather
than just focusing on delay caused to cars at certain intersections.
In an extreme example of LOS wreaking havoc, a lawsuit in 2009 forced San Francisco to spend more money studying the traffic impacts of its bike plan than it will take to completely implement it.
Such a study will no longer be necessary.
But perhaps a larger change will be what kind of development the law
now encourages. When the state measured transportation impacts of a
project based on car delay, it was fighting against its own
environmental goals. Using LOS, it was easier and cheaper to build
projects in outlying areas where individual intersections would show
less delay resulting from new development. At the same time it was much
harder and more expensive to build in dense areas where there was
already a lot of traffic, and where measured LOS impacts would require
expensive mitigations or reduced project size — but also where higher
density would make transit, walking, and bicycling more viable
Now, projects that are shown to decrease vehicle miles traveled — for
example, bike lanes or pedestrian paths, or a grocery store that
allows local residents to travel shorter distances to shop — may be
automatically considered to have a “less than significant” impact under
Another change will come in how developments mitigate their
transportation impacts. In many urban areas, under LOS analysis the only
way a development could lessen its impact would be to slim the sidewalk
and widen the roadway. This was particularly frustrating along major
bus routes or near rail transit stations, or anywhere bicyclists wanted
to travel safely.
Under the new rules, the hypothetical development would instead be
able to mitigate transportation impacts by funding better transit,
creating better access to transit, building better pedestrian
facilities, or a host of other improvements that would actually improve
The change in law does not require individual cities and local
governments to change the way they analyze traffic impacts for other
purposes, although some cities have already been working on more creative analysis than LOS.
While the change from LOS to VMT is clearly a good one in many
respects, many of the state’s most progressive transportation leaders
hope this is just the first step towards more progressive transportation
planning in the state. In her confirmation hearings,
incoming Los Angeles Department of Transportation General Manager
Seleta Reynolds argued that when projects are analyzed, they should be
scored on their value in creating a stronger community by providing
better housing, cleaner air, more transportation options, or something else.
Tumlin agrees. “Ultimately, what we need is a process and tool to
help us imagine what a better California would look like and what we
would need to move toward that vision,” he said. “Even with these
improvements, CEQA can’t do that.”
The proposed guidance must still go through a formal rulemaking
process, which may involve further revisions. OPR welcomes public
comments on the draft. Send them by 5 p.m., October 10, to: