The Many Benefits of 'Level of Service' Reform

A long read by Eric Jaffe serves as a primer on the "Level of Service" (LOS) requirement in the California Environmental Quality Act (CEQA), as well as predicting the large impact of LOS reform on planning in the state and around the country.

2 minute read

July 9, 2014, 2:00 PM PDT

By James Brasuell @CasualBrasuell


Eric Jaffe introduces LOS and its obstructive effect by citing the example of the planning process for the Van Ness BRT project in San Francisco. "The line was a signature project in the half-cent sales tax referendum, Proposition K, that city voters approved in 2003. The original plan called for Van Ness to be up and running by late 2009. The latest timeline has BRT beginning operations in 2018—a full decade and a half after the Prop K vote (which itself came years after the route concept emerged). Big city infrastructure projects get pushed back for countless reasons, but in the case of Van Ness BRT, a major source of the delay was the need to produce this massive report. It didn't receive final approval until late 2013, and was part of a preparatory phase that, all told, took 6 years and cost $7.6 million."

Jaffe explains where LOS goes wrong. "Here's the sad thing about the Van Ness BRT report: The only area where it had an unavoidable negative impact that couldn't be offset under CEQA was traffic...And here's the really sad thing about CEQA traffic impacts: They're determined using a car-friendly metric known as 'level of service' that bases a project's transportation performance on driver delay. In other words, Van Ness BRT required all the trouble of preparing this massive report because, in the twisted eyes of California law, public transit is considered a greater enemy to the environment than car travel."

And to sum up the possibilities for how LOS reform could improve the planning process, a metaphor: "The way it works right now, you might say public projects born into California cities grow up in a broken home. The planning profession, which looks favorably on dense mixed-use environments and multimodal networks, has long since been separated from the environmental law under LOS, which looks favorably on remote development and more road capacity. With VMT as the CEQA traffic metric, the marriage of urban planning and environmental policy should be a more harmonious one."

There are a lot more details in the Jaffe article about how the planning process could improve after LOS review is revised.

Tuesday, July 8, 2014 in CityLab

Young Professional

I love the variety of courses, many practical, and all richly illustrated. They have inspired many ideas that I've applied in practice, and in my own teaching. Mary G., Urban and Environmental Planner

I love the variety of courses, many practical, and all richly illustrated. They have inspired many ideas that I've applied in practice, and in my own teaching.

Mary G., Urban and Environmental Planner

Get top-rated, practical training for planners

Overlapping highways

The state-sanctioned urbicide of Austin

People don’t kill cities. Freeways do.

September 8, 2026 - Benjamin Schneider

The Hoover Dam blocking the Colorado River. The river's water level is noticeably low. The cliffs surrounding the blue water are brown and jagged.

US to reduce Colorado River water deliveries to Mexico

A new Colorado Treaty amendment reduces Mexico’s Colorado River water allocation by 250,000 acre feet.

September 11, 2026 - The Arizona Republic

Skyscrapers in Jersey City.

New Jersey’s second-largest city bans standalone data centers

Jersey City will continue to allow co-location facilities, such as those meant for research institutions that store their own data.

September 4, 2026 - The Cool Down

A New Jersey train approaches people waiting at the station.

Amtrak not solely to blame for New Jersey commuter rail's unreliability, report finds

A new study from the Garden State Initiative found that NJ Transit’s budget grew 20% across a 4 year period, but reliability declined significantly over the same period.

September 15 - Mass Transit

A tall, gray power plant billows smoke into a blue sky.

EPA erases limits on planet-warming pollution from power plants

Under Monday’s plan, power plants would still have some limits on how much mercury, arsenic and other contaminants they can emit.

September 15 - New York Times

A white RAPID bus. The lower half is light blue, and says RAPID in purple text. The bus is half visible, appearing from the left side of the image.

Phoenix announces new on-demand transit service, more frequent RAPID buses

Both new services will launch in October, and are part of Phoenix's Project Effective Access Solutions for Easing Congestion.

September 15 - KJZZ

FREE Course: Walkable City 1: Why Walkability?

After describing his path towards focusing on walkability as the essence of good planning, Jeff Speck marches through his five principal reasons for making more walkable places.

Reinventing Malls: Planning Alchemy—Turning Gray Fields Into Gold

The course focuses on the opportunities and imperatives that shape reinvention of mall sites.