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

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.

3 minute read

March 28, 2009, 6:55 PM PDT

By Lisa Feldstein


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

Lisa Feldstein is a Doctoral Candidate at the Department of City and Regional Planning at UC Berkeley. She is a 2012 Robert & Patricia Switzer Foundation Fellow, a 2012 Fellow at the Institute for the Study of Societal Issues, the 2010 recipient of The Robert A. Catlin/David W. Long Memorial Scholarship, and the 2009 recipient of the Friesen Fellowship for Leadership in Undergraduate Education. Lisa is formerly the Senior Policy Director with the Public Health Law Program, in which capacity she directed the organization's Land Use and Health Program.

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