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	<title>Comments on: CA Poised to Reform Auto-Centric Level of Service Environmental Rules</title>
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	<link>http://sf.streetsblog.org/2009/10/26/ca-poised-to-reform-auto-centric-level-of-service-environmental-rules/</link>
	<description>Covering San Francisco&#039;s livable streets movement</description>
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		<title>By: djconnel</title>
		<link>http://sf.streetsblog.org/2009/10/26/ca-poised-to-reform-auto-centric-level-of-service-environmental-rules/comment-page-1/#comment-52541</link>
		<dc:creator>djconnel</dc:creator>
		<pubDate>Tue, 03 Nov 2009 18:27:29 +0000</pubDate>
		<guid isPermaLink="false">http://sf.streetsblog.org/?p=72961#comment-52541</guid>
		<description>LOS ignores the feedback loop that less congestion -&gt; more driving -&gt; little change in congestion.  With this simple model, it&#039;s clear that the way to minimize environmental impact is to minimize LOS, not maximize.  The goal should be a car free city.</description>
		<content:encoded><![CDATA[<p>LOS ignores the feedback loop that less congestion -&gt; more driving -&gt; little change in congestion.  With this simple model, it&#8217;s clear that the way to minimize environmental impact is to minimize LOS, not maximize.  The goal should be a car free city.</p>
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		<title>By: Charles Siegel</title>
		<link>http://sf.streetsblog.org/2009/10/26/ca-poised-to-reform-auto-centric-level-of-service-environmental-rules/comment-page-1/#comment-50831</link>
		<dc:creator>Charles Siegel</dc:creator>
		<pubDate>Tue, 27 Oct 2009 16:43:32 +0000</pubDate>
		<guid isPermaLink="false">http://sf.streetsblog.org/?p=72961#comment-50831</guid>
		<description>Is there any group working to get cities to develop environmentally sound plans, such as the ATG that Andy mentions? 

This seems to give each jurisdiction lots of latitude, and many of them will probably adopt conventional plans focused on capacity, unless someone works hard against that. 

&quot;An applicable plan, ordinance or policy establishing a measure of effectiveness for the performance of the circulation system, taking into account all modes of transportation including mass transit and non-motorized travel and relevant components of the circulation system&quot; could be based on level of service, high average speed of vehicles, etc.  That could be considered a measure of effectiveness for cars and buses, and you could cover yourself on non-motorized transport by striping bike lanes.

I have no doubt that San Francisco will do better than this.  I also have no doubt that Pleasanton and Orange County will want to do no better than this.  (And, being from Berkeley, I have no doubt that Berkeley will argue about it for years before doing anything.)</description>
		<content:encoded><![CDATA[<p>Is there any group working to get cities to develop environmentally sound plans, such as the ATG that Andy mentions? </p>
<p>This seems to give each jurisdiction lots of latitude, and many of them will probably adopt conventional plans focused on capacity, unless someone works hard against that. </p>
<p>&#8220;An applicable plan, ordinance or policy establishing a measure of effectiveness for the performance of the circulation system, taking into account all modes of transportation including mass transit and non-motorized travel and relevant components of the circulation system&#8221; could be based on level of service, high average speed of vehicles, etc.  That could be considered a measure of effectiveness for cars and buses, and you could cover yourself on non-motorized transport by striping bike lanes.</p>
<p>I have no doubt that San Francisco will do better than this.  I also have no doubt that Pleasanton and Orange County will want to do no better than this.  (And, being from Berkeley, I have no doubt that Berkeley will argue about it for years before doing anything.)</p>
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		<title>By: CBrinkman</title>
		<link>http://sf.streetsblog.org/2009/10/26/ca-poised-to-reform-auto-centric-level-of-service-environmental-rules/comment-page-1/#comment-50801</link>
		<dc:creator>CBrinkman</dc:creator>
		<pubDate>Tue, 27 Oct 2009 14:12:37 +0000</pubDate>
		<guid isPermaLink="false">http://sf.streetsblog.org/?p=72961#comment-50801</guid>
		<description>&quot;Off-street parking requirements are a fertility drug for cars.&quot;  Donald Shoup has a great way with words, who can fail to understand this idea?</description>
		<content:encoded><![CDATA[<p>&#8220;Off-street parking requirements are a fertility drug for cars.&#8221;  Donald Shoup has a great way with words, who can fail to understand this idea?</p>
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		<title>By: lizonthebus</title>
		<link>http://sf.streetsblog.org/2009/10/26/ca-poised-to-reform-auto-centric-level-of-service-environmental-rules/comment-page-1/#comment-50721</link>
		<dc:creator>lizonthebus</dc:creator>
		<pubDate>Tue, 27 Oct 2009 03:45:10 +0000</pubDate>
		<guid isPermaLink="false">http://sf.streetsblog.org/?p=72961#comment-50721</guid>
		<description>Certainly a big step in the right direction; however, i agree with the concern&#039;s Andy raised. In order for a lead agency to avoid the LOS analysis, do they need to be within the jurisdiction of a progressive Congestion Management Agency that has thrown out traditional LOS measures? I thought counties that prepare Congestion Management Programs must have an auto LOS standard for highways and principal arterials, in addition to multi-modal standards? 

Yet, the Resources Agency&#039;s description of the intent to give discretion to lead agency&#039;s to choose their own methodology is heartening. And, Appendix G is just a list of criteria to consider. There&#039;s no requirement that each one must be studied.</description>
		<content:encoded><![CDATA[<p>Certainly a big step in the right direction; however, i agree with the concern&#8217;s Andy raised. In order for a lead agency to avoid the LOS analysis, do they need to be within the jurisdiction of a progressive Congestion Management Agency that has thrown out traditional LOS measures? I thought counties that prepare Congestion Management Programs must have an auto LOS standard for highways and principal arterials, in addition to multi-modal standards? </p>
<p>Yet, the Resources Agency&#8217;s description of the intent to give discretion to lead agency&#8217;s to choose their own methodology is heartening. And, Appendix G is just a list of criteria to consider. There&#8217;s no requirement that each one must be studied.</p>
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		<title>By: zsolt</title>
		<link>http://sf.streetsblog.org/2009/10/26/ca-poised-to-reform-auto-centric-level-of-service-environmental-rules/comment-page-1/#comment-50591</link>
		<dc:creator>zsolt</dc:creator>
		<pubDate>Mon, 26 Oct 2009 22:41:53 +0000</pubDate>
		<guid isPermaLink="false">http://sf.streetsblog.org/?p=72961#comment-50591</guid>
		<description>I like it. The cynic in me will wait to see what happens when the complicated language few now understand actually trickles down and becomes &quot;rubber-meets-the-road&quot; (excuse the pun) measures, over which drivers will of course get their panties in a bunch and show up to the various hearings with their pitchforks.

But, I like it.</description>
		<content:encoded><![CDATA[<p>I like it. The cynic in me will wait to see what happens when the complicated language few now understand actually trickles down and becomes &#8220;rubber-meets-the-road&#8221; (excuse the pun) measures, over which drivers will of course get their panties in a bunch and show up to the various hearings with their pitchforks.</p>
<p>But, I like it.</p>
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		<title>By: Andy Thornley</title>
		<link>http://sf.streetsblog.org/2009/10/26/ca-poised-to-reform-auto-centric-level-of-service-environmental-rules/comment-page-1/#comment-50571</link>
		<dc:creator>Andy Thornley</dc:creator>
		<pubDate>Mon, 26 Oct 2009 22:31:28 +0000</pubDate>
		<guid isPermaLink="false">http://sf.streetsblog.org/?p=72961#comment-50571</guid>
		<description>This is indeed a Very Big Thing, the SF Bike Plan injunction would almost certainly have been avoided if the CEQA Guidelines Checklist had looked like this five years ago, assuming San Francisco had also established a &quot;measure of effectiveness for the performance of the circulation system,&quot; such as Auto Trip Generation (ATG), get caught up on ATG here [PDFs]:

 http://opr.ca.gov/sch/pdfs/Rachel_Hiatt.pdf

http://www.sfcta.org/images/stories/Executive/Meetings/pnp/2008/09sept09/atg%20memo%20pnp.pdf

Even without an ATG measure in place, this draft Checklist would probably have let bike lane projects go forward without any special CEQA scrutiny, since bike lanes don&#039;t conflict with the city&#039;s long-established Transit First Policy and General Plan or any other plan, ordinance or policy that I&#039;m aware of (apart from the customary use of auto LOS by Planning MEA); indeed, bike lanes and bike-encouraging infrastructure are explicitly supported by those official policies and plans.

Still, draft question b) calls for harmony with &quot;an applicable congestion management program, including, but not limited to level of service standards and travel demand measures, or other standards established by the county congestion management agency for designated roads or highways,&quot; so it&#039;s critical that the SF County Transportation Authority and SF Planning adopt ATG (and a supporting mitigation protocol, since even a single new car trip related to a project will be environmentally significant as a CEQA concern) as quickly as possible to provide full cover for the discontinuation of auto LOS in our practice of CEQA, there are a lot more bike lanes and cycle tracks and busways and crosswalks to build out . . .</description>
		<content:encoded><![CDATA[<p>This is indeed a Very Big Thing, the SF Bike Plan injunction would almost certainly have been avoided if the CEQA Guidelines Checklist had looked like this five years ago, assuming San Francisco had also established a &#8220;measure of effectiveness for the performance of the circulation system,&#8221; such as Auto Trip Generation (ATG), get caught up on ATG here [PDFs]:</p>
<p> <a href="http://opr.ca.gov/sch/pdfs/Rachel_Hiatt.pdf" rel="nofollow">http://opr.ca.gov/sch/pdfs/Rachel_Hiatt.pdf</a></p>
<p><a href="http://www.sfcta.org/images/stories/Executive/Meetings/pnp/2008/09sept09/atg%20memo%20pnp.pdf" rel="nofollow">http://www.sfcta.org/images/stories/Executive/Meetings/pnp/2008/09sept09/atg%20memo%20pnp.pdf</a></p>
<p>Even without an ATG measure in place, this draft Checklist would probably have let bike lane projects go forward without any special CEQA scrutiny, since bike lanes don&#8217;t conflict with the city&#8217;s long-established Transit First Policy and General Plan or any other plan, ordinance or policy that I&#8217;m aware of (apart from the customary use of auto LOS by Planning MEA); indeed, bike lanes and bike-encouraging infrastructure are explicitly supported by those official policies and plans.</p>
<p>Still, draft question b) calls for harmony with &#8220;an applicable congestion management program, including, but not limited to level of service standards and travel demand measures, or other standards established by the county congestion management agency for designated roads or highways,&#8221; so it&#8217;s critical that the SF County Transportation Authority and SF Planning adopt ATG (and a supporting mitigation protocol, since even a single new car trip related to a project will be environmentally significant as a CEQA concern) as quickly as possible to provide full cover for the discontinuation of auto LOS in our practice of CEQA, there are a lot more bike lanes and cycle tracks and busways and crosswalks to build out . . .</p>
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		<title>By: Aaron Bialick</title>
		<link>http://sf.streetsblog.org/2009/10/26/ca-poised-to-reform-auto-centric-level-of-service-environmental-rules/comment-page-1/#comment-50561</link>
		<dc:creator>Aaron Bialick</dc:creator>
		<pubDate>Mon, 26 Oct 2009 22:26:56 +0000</pubDate>
		<guid isPermaLink="false">http://sf.streetsblog.org/?p=72961#comment-50561</guid>
		<description>*Tear of joy*

California? Is it really you? I never thought I&#039;d see the day...

This had better not be some &lt;a href=&quot;http://www.youtube.com/watch?v=SlUQ2sUti8o&quot; rel=&quot;nofollow&quot;&gt;&quot;Yes Men&quot;&lt;/a&gt; hoax.</description>
		<content:encoded><![CDATA[<p>*Tear of joy*</p>
<p>California? Is it really you? I never thought I&#8217;d see the day&#8230;</p>
<p>This had better not be some <a href="http://www.youtube.com/watch?v=SlUQ2sUti8o" rel="nofollow">&#8220;Yes Men&#8221;</a> hoax.</p>
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