Traveling beyond LOS (By foot? On a bike?)

Lisa Feldstein's picture

Let me start with a disclaimer: I am not a transportation planner. At the points where transportation planning shares borders with engineering, I tend to zone out and start doodling in the margins. I do, however, have a lifelong interest in transportation, which is why I share the excitement of some of my more transportation-focused colleagues about potential changes in how California measures transportation impacts of projects.

The California Environmental Quality Act (CEQA) measures transportation impacts of proposed projects with a traditional Level of Service (LOS) metric. Because LOS measures the speed and free-flow of automobiles as the proxy for impact, any changes that impede cars end up determined as having a (potentially) negative impact. Since slower moving transit, bikes and pedestrians slow down cars, changes that benefit these modes all come up as having negative impacts. Although California doesn't require projects be abandoned because of these impacts, where feasible the negative impacts must be mitigated. Thus, there is a de facto imbalance in determining impacts and improvements for alternative modes can end up far costlier because lessening the impact on cars may have to be rolled into the cost.

California's legislative attempts to require that greenhouse gas levels be reduced to 1990 levels by 2020, however, have led to a sequence of events that are likely to change this modal balance of power. The Governor's Office of Planning and Research (OPR), the body responsible for writing and amending the CEQA guidelines related to transportation and traffic, is considering de-emphasizing the LOS standard, relying instead on a Vehicle Miles Travelled (VMT) standard. OPR believes that because VMT is more closely tied to greenhouse gases than is LOS, it will VMT will provide a better understanding of potential environmental impacts of proposed developments.

For the advocates who have long sought these changes, this is great news. For example, under an LOS model, widening a road is a reasonable way to accommodate more vehicle trips. Under a VMT metric, however, road widening provides the opposite result. Improved pedestrian infrastructure - signaled crosswalks, or streets that are closed to private vehicles - do poorly under an LOS analysis but are beneficial when measuring VMT.

As reported by Streetsblog SF's Matthew Roth, Terry Roberts, Director of the State Clearinghouse at the OPR, said "OPR had been receiving suggestions months and months ago from various parties, some from local governments, others were environmental organizations, and they all seemed to be saying the same thing to OPR and that is the over-emphasis on Level of Service in the CEQA analysis of a project was creating obstacles to better planning and smart growth."

It isn't clear that these changes will make it over every hurdle they must clear to be implemented. Less certain still is whether or not LOS will be removed from CEQA, or just de-emphasized. I certainly hope for the former, which would be a big step towards multi-modal transportation analysis of environmental impacts and, perhaps, a boost for bikes, peds, and transit. 

Lisa Feldstein seeks to use land use as a tool for social and economic justice.



Ian Sacs's picture

vmt cannot be a complete substitue for los

lisa, i share your desire to find a way out of the stranglehold that los puts on other modes in the environmental review process. i think the challenge coming out of the current debate is the fact that substituting vmt for los works in some ways at the macro level (which is where most planners are focused), but completely falls apart at the micro level (where the engineers are). by this i mean that vmt, as it is used currently, cannot allow for the design of an intersection, or corridor of intersections, that operate at an acceptable level for all users. the solution, i think, is a painful rework of the existing capacity analysis methodology for urban, multi-modal roadways that allows for an analysis of volume ot capacity based on a given mix of modes across a roadway cross-section. considering the current methodology in the totally inappropriately named "highway capacity manual (hcm)" is the culmination of five decades of incremental meddling, i don't think the answer will be quick to surface without a major, concerted effort from professionals. this is not an answer, i know, but it is something more constructive than abandoning the level of service/capacity analysis concept altogether, because ultimately, whether it is cars, buses, bikes, or peds, we will still want to know the level of service (or more precisely, the volume to capacity ratio) experieinced by users of each mode in the right of way.

as an aside, there is a lot of talk about shifting from vmt altogether to something more fittin gto urban environments, such as "person miles traveled". calculated this way, bus lanes blow away auto lanes, and sidewalks in very busy places, like time square, will demand the widest cross-section in the right of way.

VMT or LOS--why choose?

If the goal is to reduce GHG and/or energy consumption, both VMT and LOS are important. In a congested area, the VMT is likely to be lower, but it's questionable as to whether their GHG emissions are less because more time is spent sitting in the congestion. In less congested areas, the VMT may be higher, but mile for mile, the GHG production will be less. Also, in dense areas, there seems to be less ability for GHG and pollutants to dissipate because of the density itself.

A study in Seattle a few years ago indicated that most people, irregardless of their setting (urban or otherwise) generally traveled about 90 minutes during a typical day regardless of the distance they traveled or the mode they used.

In the end, it's probably better to replace either of them with a measurement based on the time a person spends in a vehicle each day. The appropriate metric would then be VHT/person/day (vehicle hours traveled per person/day) with the values factored for the vehicle type to account for different emissions rates. Transit options would be inherently favored because they provide more person service per gallon or per emissions and replace the energy and emissions use from lower occupancy vehicles. Under-utilized or poorly planned transit service would be penalized because it doesn't provide enough bang for the GHG buck. If congestion gets to the point that all vehicles, including transit vehicles, are progressing so slowly that they lose their advantage they should be charged accordingly. Systemic pressure should be applied to assure that the intersections and roadways are modified accordingly to rebalance the mobility provided with the service desired. In any case, pedestrian and bicycle travel gains the highest preference because no offending vehicle is involved.

All of this information is potentially available to a relatively skilled modeler or consultant. Travel demand models could be used to establish the vht/person/day for cars that use a project. Dense but disconnected developments would have higher impacts than dense inter-connected developments because research shows that users tend to make more vehicle trips when the distances are short and the pedestrian environment is less than ideal. Pedestrian or bicycle oriented environments would engender the greatest advantage because they produce no GHG and require no mechanical energy consumption. Many urban transit systems would have the ability to measure in real time the number of vehicle hours used and the number of person trips provided and then project that usage onto a new development. If a comparison is needed between modes, then an FTE system can be used to make sure that the persons served is not inaccurately confused with the person trips provided.

I know you're probably doodling now...

Patricia C. Tice, PE, AICP, LEED AP
Glatting Jackson Kercher Anglin, Inc.

Why Not To Choose LOS

Studying LOS in EIRs generally gives planners a reason for expanding roads and highways. If the EIR finds that the project reduces the LOS at a given intersection, the obvious mitigation is to widen that intersection - or the whole highway - to bring LOS back to its previous level.

Needless to say, the wider intersection or highway induces more VMT and more GHG emissions.

For example, under current rules, a developer proposes a huge office park on the suburban fringe. The EIR finds that traffic will congest nearby country roads. The developer widens the roads, and the impact is fully mitigated.

Under proposed rules, a developer proposes a huge office park on the suburban fringe. The EIR finds that there will be a huge increase in VMT. Maybe the developer is required to mitigate that impact by providing trip reduction programs for tenants. Or maybe the EIR finds that the impact cannot be mitigated, and the project is stopped.

Charles Siegel

A more radical suggestion


I'm glad that you are drawing people's attention to the movement to reform LOS, which seems to be gathering steam -- both at the state level, as you describe, also in San Francisco. (Perhaps other places as well.) This is desperately needed and decades overdue.

However, I'd like to put forward a suggestion that CEQA review be entirely eliminated for certain categories of projects with clear environmental benefits. How about this -- any transportation project that is solely intended for pedestrian or bicyle improvements is 100% exempt from the CEQA process. No different methodologies, no reduced requirements -- just a complete, total exemption, period.

I say this as someone who has observed up close the painful, absurd, and heartbreaking spectacle of one city, San Francisco, being completely paralyzed in its ability to so much as stripe one new bike lane or install one new bike rack for well over two years, due to an injunction stemming from a lawsuit that took San Francisco to task for failing to go through the CEQA process for its bike plan. A more preposterous state of affairs -- where a lawsuit launched by one well-funded, savvy anti-cycling activist can thwart all bike improvements in a city with an overwhelming public conseunsus in favor of them -- I could not imagine.

Now, all this time, and hundreds of thousands of dollars later, we have an exhaustively detailed EIR of hundreds of pages that presents the blindingly obvious result: making urban biking easier and safer by implementing the Bike Plan has substantial ecological benefits.

And our problems will by no means be over once the Bike Plan EIR is formally certified. The Bike Plan that will now be implemented represents bike infrastructure that would be regarded as hopelessly outdated in Copenhagen or Amsterdam or even Portland. It includes no bike boxes, nor in-street physically separated bike lanes, nor bike-only traffic signals, nor colored pavement treatments for bike lanes. It will do little to encourage the elderly, or small children, or other risk-averse people to take up cycling as a means of daily transportation. Taking the needed steps will require yet more expensive and time-consuming environmental studies in order to comply with CEQA. Perhaps worst of all, the spirit of experimentation and the possibility for public enthusiasm to mount for bike improvements due to a critical mass of them (as seems to have occurred in New York and Portland) will be doused by all of this endless, pointless process.

In San Francisco, we have just lost over two years in the fight to undertake one of the simplest and cheapest actions in reducing greenhouse gas emissions: make biking easier. This at a time when a lot of the latest science suggests that we have about ten years to do something meaningful to deflect the impact of climate change from catastrophic to merely highly problematic.

We can do better than this, can't we? CEQA was originally enacted to protect the environment. Undoubtedly it still serves that purpose in many cases, such as when it is applied to large suburban developments or new highways. In certain other cases, such as bike/ped improvements and below-market rate infill housing, it is worse than useless, and is in fact actively harmful. Do we as progressive thinkers have the courage to push to jettison our cherished process in cases where it is so demonstrably counterproductive? Are we ready to support good projects as fervently as we oppose bad ones?

(And by the way, if someone knows for a fact that a process resembling CEQA is applied to bike improvements in Copenhagen or Amsterdam, I would be fascinated to hear about it. But I would be shocked.)

Jake Wegmann

SF Bike Plan And LOS

Was the suit against the SF bike plan based on its possible impact on LOS for automobiles? If it was, then if LOS were no longer on the checklist, there could simply have been a negative declaration.

I don't know too much about this law suit, but the only possible impact of the bike plan that I can even imagine is its impact on LOS.

Charles Siegel

Not related to VMT or LOS

The City of San Francisco, in its infinite wisdom, basically just ignored the CEQA process altogether. So one guy (with the backing of others I am sure) sued the City for not following the proper process in place and the City had to go back to square one and do a full EIR. It was actually hilarious to watch certain segments of the City's population huff and puff as tactics they have used for years to block (any and all) development were used against them so successfully. It was a very Leona Helmsley (sp?) reaction ... "the rules apply don't apply to us do they... we thought they were only for everybody else?" I would hope it highlights some of the major flaws in the CEQA process as it is constantly abused by everyone to intentionlly stop projects for financial gain... but I wouldn't hold my breath. Most likely, our betters will just amend the exceptions to exclude their favored outcomes from CEQA while keeping the rest of the mind-numbing retardation that is CEQA in-place so they can prevent 3-story inflill apartment buildings from "manahattanzing" their neighborhood and ruining the environmental integrity of a trash-strewn vacant lot.

CEQA Process

The CEQA process is: when there is a project, first planning staff goes through a checklist of possible environmental impacts. If the answer is no to all of those impacts, they can issue a neg dec. If the answer is yes but the impact is small, they can issue a mitigated neg dec. If the answer is yes and the impact is significant, they have to do a full EIR.

Going through that checklist for the SF bike plan, the only possible significant impact I can think of is on LOS. If that were not on the list, it seems to me that CEQA would only require a neg dec, and that the neg dec would stand up in court.

"while keeping the rest of the mind-numbing retardation that is CEQA in-place so they can prevent 3-story inflill apartment buildings from "manahattanzing" their neighborhood"

Come, now, Ricardo. Surely you know that environmentalists support infill development and support the bike plan. The NIMBYs who sued to stop the bike plan are from the same faction that also wants to stop infill development

Incidentally, I read the link you provided to a summary of the monetary theories of Ludwig von Mises. Though I don't agree with it, I found it very interesting, and I want to thank you for the link.

Charles Siegel


Correct, I believe the only impact that the bicycle plan would have had was on traffic, and were LOS not part of the CEQA only a neg dec would be required. The problem, as I remember it, was that the City didn't even maake a good faith attempt to go through the CEQA process. Hence they were vulnerable to one person's lawsuit. That's what I meant about it being more about the process than LOS, but one could easily see it both ways.

The funny thing is I used to be a CEQA planner (for a short while) some time ago. It was very frustrating as I actually did see small infill projects held up by "environmentalists" all the time (from very well known environmental organizations) with such asinine arguments (blocking one's private view as an environmental impact and vacant lots as "habitat"). I couldn't continue on watching as the intent of the law was twisted around in the name of the "environment". I guess I have a somewhat jaded view of "environmentalists" until I hear what they're really selling.

No problem on the link. I too appreciate your (and eveyone's) linked articles because it is great to be exposed to any new thoughts, whether you are in agreement or disagreement. Thanks for not chiding me too much when I get all worked up in my posts (as I tend to do).

Purpose of CEQA

Just a side note: CEQA was NOT enacted to "protect the environment." There is nothing in the code that requires a jurisdiction to deny a project with negative environmental effects, or to choose an environmentally better alternative. CEQA's intent was to provide the decision makers, and, secondarily, the public, with as much information on the potential effects of a project as reasonably possible. The jurisdiction can still make a "finding of overriding consideration" and approve the project, in spite of any negative effects.

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