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LOS Reform

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 ## PDF here##.
Image via SFMTA

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.

The savings largely come from relieving planners of the need to measure projects using LOS, a tool that grades transportation projects based on how much they might slow down cars. LOS often calls for planners to take measures that "result in inconsistencies with achieving the city's transit-first policies," said John-Bauptiste.

A recent cartoon about LOS by Andy Singer.
Image: Andy Singer

"If what we're concerned about is how quickly automobiles are moving through a particular intersection or roadway segment, a logical mitigation might be to expand roadway capacity, to add a lane of traffic," said John-Bauptiste. "That is, first of all, often infeasible in a built-out, urban, dense environment such as San Francisco. It, secondly, can often be in contradiction to our policies supporting the bike network or pedestrian safety."

Instead, the program would implement a new metric called Transit System Performance (formerly Automobile Trips Generated), which turns the LOS approach on its head by evaluating the transportation network holistically and focusing on reducing driving and improving conditions for transit, walking, and bicycling. This metric was developed as an alternative to LOS over recent years, and in 2009, San Francisco agencies successfully lobbied the state to allow cities to use alternative metrics.

"This is the latest in a long-running conversation about reconciling our practice of CEQA with our city's wonderful adopted policies," said Andy Thornley, policy director of the San Francisco Bicycle Coalition. "We decided as a city quite a long time ago that we didn't want to use LOS in CEQA."

Under the TSP's new environmental review system, projects would move so much faster that Reiskin said some improvements currently in development might get finished sooner by waiting until after the reforms are adopted.

"One of the main cost- and schedule-drivers of environmental review is transportation analysis, and that's for any large development project," said Reiskin. "Somewhat ironically, that has created cost and schedule extensions for our own projects, even those that on the surface would appear to be very clearly imparting positive environmental impacts to the city -- the Bike Plan is perhaps the poster child for that."

As another example, he pointed to the Transit Effectiveness Project (TEP), which Mayor Ed Lee has said is his #1 priority for Muni. The SFMTA is now at the outset of a 21-month, $2 million environmental review process for the TEP, said Reiskin. The TEP "is really about speeding up transit -- a very clearly environmentally-beneficial initiative, but because we currently are under a Level of Service methodology... the TEP is subject to a full environmental impact report," he said, though he noted that the TSP reforms won't come soon enough for the project to take advantage.

The SFMTA Board roundly praised the program, and directors Joél Ramos and Bruce Oka emphasized the urgent need to implement it. "Every month that we don't have a policy like this in place, we stand to lose, who knows, millions of dollars," said Ramos.

Director Malcolm Heinicke hailed the program as a "creative way to restructure at the more local level to meet our goals and still satisfy the state act."

"There's always complaints about the CEQA process. There's always calls to reform it at the state level," he said. "It's impressive that someone is actually doing something about this rather than just throwing up their hands and saying, 'CEQA screws up everything.'"

Aside from the program's cost savings, the TSF is expected to generate $630 million over 20 years and leverage $820 million more in other funding. The streams of revenue would fund "a comprehensive and strictly regulated $1.4 billion plan targeted at highly-efficient transportation system improvements," according to the SFMTA presentation. Every two years, the city would dedicate funds to projects like the Market Street redesign, Muni's TEP, Bus Rapid Transit on Van Ness and Geary, regional improvements like Caltrain electrification, the bikeway network, and pedestrian improvements.

City staff are currently reaching out to stakeholders for the program. This month, they plan to introduce a legislative ordinance and begin conducting the program's EIR, which should finish next summer. The program is set to be heard and adopted by the SF Board of Supervisors in fall of 2013.

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