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Replacing LOS: Experts Debate How CA Should Measure Transpo Impacts

California is shaping a new transportation planning metric to foster transit-oriented development, such as this proposed affordable housing project at Los Angeles’ Soto Gold Line Station in the Boyle Heights neighborhood. Image: L.A. Metro

California planning experts continue to debate how to most effectively measure transportation impacts in a way that will foster smarter growth, after the state abandoned the car-centric metric known as Level of Service (LOS).

California is looking to reduce its “vehicle miles traveled” by encouraging infill development near transit, but the devil is in the details. Image: Federal Highway Administration

The acronym-laden process of measuring transportation under the California Environmental Quality Act (CEQA) may be complex and wonky, but it’s certainly important. In creating a replacement for LOS, the CA Office and Planning and Research (OPR) will shape the future of development in California for many years to come.

SB 743, passed last year, mandated that the state create a replacement metric for LOS to measure the transportation impacts of developments under CEQA. The Office of Planning and Research has proposed a metric called Vehicle Miles Traveled (VMT), which would measure the amount of driving developments would generate, instead of focusing solely on minimizing delays for drivers.

OPR has made several other suggestions in their proposed guidelines, and are seeking public input to help them refine the changes. Specifically, they are asking for help on the following questions:

  1. Under the proposed guidelines, any project built within a half mile of transit with frequent service (running at least every 15 minutes) would be deemed to have no significant impact on travel, and wouldn’t have to undergo a VMT review. Is this an appropriate rule? Are there other factors that should be considered?
  2. What amount of vehicle miles generated by a development should be considered significant, and thus require an environmental impact report (EIR)? Who should decide what those levels are?
  3. What kinds of strategies should be used to mitigate increases in vehicle miles generated by a project?

Two expert panels were held this week to address these questions. A panel including planners, engineers, attorneys, consultants, and an infill developer came together at a Sacramento forum to discuss the proposed guidelines at the first event. The next evening, the University of San Francisco’s Environmental Law Society invited several attorneys with opposing viewpoints to discuss CEQA, state climate change laws, and the proposed guidelines.

Although there has been some public sparring over the change, and not all of the feedback OPR has received on its proposed guidelines has been positive, there was more agreement than not at both panel discussions. For example, panelists agreed that Level of Service is not the right way to measure the environmental effects of a project.

OPR staff maintains that eliminating Level of Service would make it simpler and cheaper to develop infill projects, which can help the state meet its greenhouse gas reduction goals by reducing driving and encouraging transit, walking, and bicycling. A large part of that cost savings would come from eliminating the need for an environmental impact report.

Michael Schwartz, senior planner at the San Francisco County Transportation Authority and a participant in the university panel, said LOS was “the only reason [San Francisco] had to complete an environmental impact report for the Van Ness Bus Rapid Transit project.”

“By no other measure would the project have impacted the environment negatively,” he said. “Without LOS, we would have saved millions of dollars and several years of delay.”

But the details of how to apply the new measure still need to be worked out.

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Replacing LOS: CA Hones Details on Its New Transportation Planning Metric

New rules proposed by the California Office of Planning and Research are hoped to accelerate the state’s decline in driving seen in recent years. Image via Caltrans

Agreeing on a new way to measure transportation impacts — and not just delays for drivers — is no simple task for California’s planning policymakers.

The Governor’s Office of Planning and Research (OPR) is fine-tuning its proposal to replace  Level of Service, the metric recently ditched by the state which focused exclusively on car delays, by creating a new metric called Vehicle Miles Traveled (VMT), which measures how much driving is expected to be generated by a new development. Basically, when development and transportation projects are analyzed under the California Environmental Quality Act, they must no longer be judged solely on how many seconds of delay they cause drivers.

OPR has held a series of workshops and a webinar to explain the issues to city planners and other interested parties, but some public commentary shows that confusion and uncertainty reign.

Responses to the proposal so far have ranged from supportive to vehemently critical, but the harshest criticisms include inaccuracies about the intent of SB 743, the legislation mandating the LOS/VMT change.

OPR has extended its deadline for public comments about its Preliminary Discussion Draft of CEQA Guidelines [PDF] until November 21. Comments can be submitted by email.

In August, OPR released its proposal to replace LOS with VMT, following last year’s adoption of SB 743, which mandated the change. VMT looks at the entire lengths of car trips a project might generate — not just the number of vehicles making their way through an intersection. It gives a more accurate assessment of the environmental impact of travel induced by a project. Planners also say it’s easier to model VMT than to measure LOS, since the models involve fewer complicated assumptions they tend to be more accurate. Many jurisdictions already measure vehicle miles traveled as part of their efforts to reduce greenhouse gas emissions.

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California Has Officially Ditched Car-Centric ‘Level of Service’

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. Photo: ##http://www.peaktraffic.org/graphics/vmt-california.jpg##Peak Traffic##

Vehicle Miles Traveled in California has been on the decline for a couple of years. Changes in how the state manages transportation projects promise to drive it even lower. Graph: Peak Traffic

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 streets. It is basically a measurement of how many cars can be pushed through an intersection in a given time. If a project reduced a street’s Level of Service it was considered bad — no matter how many other benefits it might create.

Under the previous CEQA regs, the transportation mitigation for a development such as this would have been sprawl-inducing road widenings. Image:##http://blog.archpaper.com/wordpress/archives/67469#.U-OVrI1dUs0##Arch Paper##

Until now, California regulations made it much easier to build this kind of sprawl than compact, people-friendly places. Photo: Arch Paper

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). OPR today released a draft of its revised guidelines [PDF], proposing to substitute Vehicle Miles Traveled (VMT) for LOS.

In short, instead of measuring whether a project makes it less convenient to drive, the relevant question is now whether a project contributes to other 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 no more.”

This revision in state law promises many positive changes.

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California Legislation Watch: Weekly Update

For social media coverage of California’s statewide transportation issues, follow Melanie @currymel on Twitter or like the Streetsblog California Facebook page.

Here’s Streetsblog’s weekly highlight of legislation and events related to sustainable transportation at the California capitol.

  • News on the implementation of S.B. 743, which removes Automobile Level of Service from consideration as an environmental impact in areas with robust transit. The state’s Office of Planning and Research released the public comments it has received on its update of CEQA guidelines and its draft guidelines for S.B. 743, which Senator Darrell Steinberg (D-Sacramento) introduced and was passed last year. S.B. 743 requires the OPR to come up with a new urban planning metric to replace LOS that measures the effect of development and transportation projects on all traffic, not just car drivers. Proponents are enthusiastic about eliminating an outdated, car-centric measure that has led to wider, faster streets. Critics worry that longer have the means to require developers to improve streets. The next steps: drafting the actual guidelines, releasing them for public comment in late spring, and producing a final draft version of the guidelines by July 1.
  • Caltrans published a new mission statement: “Provide a safe, sustainable, integrated and efficient transportation system to enhance California’s economy and livability.” This is a vast improvement over the old one, “Caltrans improves mobility across California,” and it contains all the right buzzwords. The mission statement was the first item on the Early Action Plan outlined in the State Smart Transportation Initiative report urging deep reforms in Caltrans. Check — now to work.
  • More extensive senate hearings saw debates about the governor’s cap-and-trade expenditure plan and high-speed rail, this time in the Senate Transportation and Housing Committee and the Senate Budget Subcommittee on Resources, Environmental Protection, Energy and Transportation. CA High-Speed Rail Authority CEO Jeff Morales defended the use of cap-and-trade funds for high speed rail, and Senator Jim Patterson (R-Fresno) attacked cap-and-trade as a slush fund and high-speed rail as an expensive project that will produce a “puny” reduction in greenhouse gas emissions. Plenty of comments from the Legislative Analyst’s Office and various interest groups.
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Excitement, Confusion Over Proposed Removal of LOS in CEQA

This famous demonstration of how much space is taken to move people via different modes has an important lesson for those thinking LOS is the best measure of transportation impacts.

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 can only 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 affect 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 impacts.

“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 Bicycle Coalition.

“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 automobiles.”

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.

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The End for LOS in California? State Wants Input on a New Planning Metric

With little fanfare, California is considering a change in how it measures transportation impacts that could herald a major change in environmental law. SB 743, passed and signed into law in September, is a potential game changer because it could completely remove LOS — Level of Service, a measure of car traffic congestion — from the list of tools that must be used to analyze environmental impacts under the California Environmental Quality Act. As the state contemplates a broader, more sustainable metric to use for smarter urban planning, the public is invited to weigh in on what the LOS replacement should look like.

Streetsblog USA doesn’t pull punches when describing why many oppose”Level of Service” metrics. Image: Andy Singer

CEQA requires new projects, be they highways or housing units or basketball stadiums, to analyze potential environmental changes created by the proposed project. In copious detail. Water, air, land, noise, plants, animals: any physical aspect of the existing area that might be affected negatively must be analyzed.

For a variety of historical reasons, traffic congestion has crept into this group of environmental impacts under CEQA and become part of the law. Congestion is analyzed by measuring the flow of traffic at intersections (how many vehicles get through in a set amount of time) and grading those intersections on their performance. Planners refer to this as LOS, for Level of Service.

The irony of LOS is that CEQA requires mitigation when projects cause delay to automobile traffic—even if the projects create better conditions for other road users, such as transit riders, bicyclists, or pedestrians. Thus the San Francisco Bike Plan was held up for years because of a lawsuit claiming the city did not take into account the negative affects bike infrastructure would have on LOS.

Streetsblog covered SB 743 as it was passed last year, but at the time we missed a nuance that makes it an even bigger potential change for CEQA and planning. At first read it looked like the LOS provision, tacked onto a bill written to streamline environmental review for a new Sacramento Kings basketball stadium, applied only to areas designated as “Transit Priority Areas,” defined as within a ½ mile of high quality transit. In some places, this covers very large areas: for example, most of San Francisco is so designated because of its dense transit networks. This alone could make a huge difference in the way environmental impact reports are handled for many projects.

Neither Streetsblog nor many advocates monitoring the legislation realized on the first read is that the new law gives the Governor’s Office of Planning and Research (OPR) the discretion to come up with a substitute for LOS and apply it throughout the state—not just to urban areas “well served by transit,” but everywhere. And to all projects.

The long-term results of using LOS as a measure of environmental impact have been argued about for years and explained well elsewhere. Removing it from the CEQA process has the potential to profoundly affect the way cities are planned and built. And while some of the larger cities, including Los Angeles and San Francisco, actively pursue the question of whether traffic impact is an appropriate measure of environmental impact (and working on their own substitute measures), not every locale is happy about it.

OPR is asking for early feedback on two items: a draft list of goals it wants the new criteria to meet, and a preliminary list of possible replacement measures for LOS. These are both described in detail in this report, and summarized below. The deadline is this Friday, February 14, and comments can be sent to: ceqa.guidelines@ceres.ca.gov. Future drafts will incorporate feedback received now, with the goal of preparing a final draft by July 1, 2014.

Below is an explanation of why many people oppose using LOS as a measure to analyze environmental impacts. Streetsblog is also reaching out to municipal leaders who use LOS for a future story explaining why they may not want to remove it entirely from CEQA.

Read more…

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New “Kings Arena” CEQA Bill Would Still Nix LOS in “Transit Priority Areas”

Steinberg’s hasty press conference held after the passage of SB 743

Last night, both California’s Senate and Assembly passed SB 743, Senator Darrell Steinberg’s legislation that replaced his original CEQA reform bill, SB 731, which promised to end the reign of Level of Service (LOS)  in California urban planning. SB 743 would still eliminate of LOS to a more limited extent, and although it’s unclear if Governor Jerry Brown will sign the bill, he reportedly assured Steinberg he would do so because he favors a more tepid CEQA reform bill. SB 731 was drafted primarily to streamline environmental review for a new stadium for the Sacramento Kings basketball team.

While SB 731 would have brought the statewide elimination of LOS — a car-centric transportation planning metric that basically puts the movement of cars over everything else — as part of environmental review, SB 743 would still nix the metric for projects within designated transit priority areas (TPAs). Large swaths of most urban areas are considered TPAs, which are defined as areas within a ½-mile of high quality transit: a rail stop or a bus corridor that provides or will provide at least 15-minute frequency service during peak hours by the year 2035.

According to the Sacramento Bee, Steinberg said he would add into SB 743 “a provision at the governor’s request that gives the governor’s Office of Planning and Research the go-ahead to develop a new way of measuring traffic impacts of major projects, based on total ‘vehicle miles traveled’ rather than intersection congestion.”

Darrell Steinberg. The Sacramento Bee reported, "Steinberg and Sen. Ted Gaines, R-Roseville, showed team pride by wearing purple ties for the occasion."

Despite the LOS victory, many advocates fumed that it didn’t go far enough. Not a single environmental group backed the legislation, and thirteen — including The Sierra Club, Trust South L.A., and the Planning and Conservation League — signed a letter blasting the legislation as a “gut-and-amend.” SB 731, Steinberg’s larger CEQA reform bill that didn’t pass, would have ended the requirement to use LOS for the entire state. Under current law, the impact of projects, even ones that are building bike lanes, must be measured based on how the project interrupts or supports the flow of car traffic. This has lead to the creation of wider, faster streets and the laying of more asphalt to “mitigate” those projects’ impacts.

While most environmentalists and transportation reformers agree that this change to LOS is a positive step, many are angered that SB 731 was shelved so that a basketball team owned by billionaires could get an expedited environmental review that would lack teeth because the legal options available to the opposition are greatly reduced.

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Like Bike Lanes and Transit? Hope You Like the Sacramento Kings Too.

Note: This post originally appeared at Climate Plan.

What do the hoop dreams of a software mogul have to do with CEQA reform? As of last night, everything. In the waning days of session, strange things happen in Sacramento.

If this person happens to like bike lanes, they probably love SB 734. Photo: Associated Press

Late last night, Senate President pro Tem Steinberg announced that he cut a deal with Governor Brown to abandon SB 731, his main CEQA reform bill, in favor of a new gut-and-amend bill, SB 743, that would allow the Sacramento Kings to build a new arena in the ruins of the K Street shopping center without litigation delay. This is, of course, an attempt to stave off the courtship of Microsoft CEO Steve Ballmer, who wants to move the Kings to Seattle.

Roll your eyes, dear reader, but then read on.  Apparently some provisions of SB 731 have been grafted onto the stadium bill.  ClimatePlan and our CEQA + Infill Dialogue spent months working to influence SB 731. We hoped to align CEQA with our goals of building sustainable and equitable communities – and we had a lot of success. Of particular interest to us ClimatePlanners were two provisions in SB 731 that would:

* Reform CEQA’s transportation analysis to focus on reducing greenhouse gas emissions and car trips, rather that the outdated and car-centric metric known as Level of Service (LOS). This would be a game changer for transit-oriented development, bike lanes, bus rapid transit and other projects that are good for GHGs but bad for cars.  It would also eliminate insufficient parking as a standalone impact under CEQA.

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SF Agencies Take Aim at Bureaucratic Obstacles to a Transit-First City

San Francisco agencies are developing a wide-ranging program to streamline the funding and construction of improvements for walking, bicycling, and transit.

Image via SFMTA. See full PDF here.

The Transportation Sustainability Program (TSP) would reform the city’s transportation practices in three key areas: by eliminating reliance on the automobile-centric measuring stick known as Level of Service (LOS), by instituting a system of development impact fees that fund sustainable transportation improvements, and expediting the review process for pedestrian, bicycle, and transit projects. The details are on the wonky side, but if the city delivers on these reforms, SF could be looking at a much more rapid build-out of transit corridors, bikeways, and pedestrian safety measures.

“This program is taking a look at how we manage, regulate, and mitigate for development as it relates to transportation to develop a process that’s more transparent, equitable, and meaningful, and provides a much better nexus between land use planning and transportation,” said SFMTA Director of Transportation Ed Reiskin.

SF Planning Department Assistant Director Alicia John-Bauptiste presented details [PDF] about the TSP Tuesday to the SFMTA Board of Directors. The program, currently planned for adoption in late 2013, is a coordinated effort between the SFMTA, the Planning Department, the SF County Transportation Authority, and the Office of Economic and Workforce Development.

One key component to the TSP is the Transportation Sustainability Fee (TSF), which would replace the current Transit Impact Development Fee (TIDF) that building developers pay to the SFMTA to account for infrastructure costs due to car trips and transit trips made by users of those buildings. The TSF would be based on offsetting car trips added by a project, and its revenues could only be spent according to a spending plan to directly fund projects that improve transit service and bicycle and pedestrian safety. Developers would receive discounts on the TSF for building less car parking, and it would apply to residential buildings (except affordable housing), which the TIDF doesn’t.

According to John-Bauptiste, many developments and transportation projects will also no longer be required to conduct an environmental impact report (EIR) as part of the California Environmental Quality Act (CEQA), which would lead to major time and cost savings. “Individual projects will be relieved of having to study cumulative transportation impacts because the TSP EIR will study those impacts. Project-specific analysis will be limited to site design issues such as loading docks, curb cuts, and pedestrian and bicycle safety,” the presentation says.

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San Jose Provides Model for Bay Area Growth and Transportation Needs

pbo31_sj_bus_small.jpgPhoto: pbo31

In our ongoing coverage of the adverse affects of traffic engineers' over-reliance on automobile level of service (LOS) measurements, we've examined how new amendments to the California Environmental Quality Act (CEQA) would allow local jurisdictions greater freedom in choosing whether they want to develop their cities for cars or for transit, cycling, and livable streets.  Simply put, if the CEQA amendments are codified, cities all over the state could become more like San Jose.

While San Francisco labors with the development of its auto trip generation (ATG) metric and could spend a year or more setting a development impact fee that would go to improving transit, cycling and pedestrian safety, San Jose completed a citywide transportation environmental impact statement (EIS) in 2002 and adopted its vision for sustainable, transit-oriented growth in 2005 [PDF]. What's more, this transportation and land-use plan moves San Jose ahead of the curve compared to other cities in meeting the requirements under AB 32 (carbon reduction targets) and SB 375 (limiting sprawl).

"We want to grow up, not out," said Hans Larsen, Acting Director of San Jose's Department of Transportation (DOT), noting the city couldn't accommodate the 400,000 new residents expected by 2030 within San Jose's current boundaries by adding more sprawling developments and more traffic. "We had a policy conflict between our growth plan, which was really smart-growth, and our transportation management policies, which have historically been oriented toward providing enough capacity for cars."

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