LOS Reform

California administrative rulemakers recently moved a step closer to reforming the section of the California Environmental Quality Act (CEQA) that has compelled cities to focus undue attention on the age-old Automobile Level of Service (LOS) threshold for impacts of new projects and has led to the construction of excess off-street parking.

As soothsayers of the Sacred RAC priesthood like Rob Anderson will let you know time and again on his own blog, and sometimes on ours, all this talk of bike plans, Level-of-Service reform, parking restrictions in new development, and greening boulevards is nothing more than a thinly-veiled assault on our national right to drive freely and not pay for it.

Transportation consultants and planners associated with the San Francisco Transportation Authority's (TA) ATG working group sent excited bursts of email to each other earlier this month about a new development coming from the state Office of Planning and Research (OPR), the body responsible for writing and amending the CEQA guidelines related to transportation and traffic.  The OPR had adopted much of the spirit of the working group's recommendations and proposed an amendment (PDF) to CEQA guidelines that de-emphasized LOS and indicated that it would be much better to use measures for vehicle miles traveled (VMT) reductions such as ATG.

One of the unintended consequences of San Francisco’s bicycle injunction, which Rob Anderson and fellow NIMBYs will likely rue for some time to come, is the arduous thought and labor that advocates and professional planners have invested in doing away with LOS all together.  

The idea that the speed and free-flow of cars is the proxy that is being used across the state of California to measure whether a project is [environmentally] impactful is in the long run undermining the very quality of life [we] are working to protect.