SoCal Government Coalition Wants to Keep Planning for Cars

SCAG wants Measure R highway expansion projects, among others, grandfathered past new CEQA rules
SCAG wants Measure R highway expansion projects, among others, grandfathered past new CEQA rules.

SCAG sent a last-minute letter attempting to delay progressive updates to California’s outdated environmental standards.

In the letter [PDF], Southern California Association of Governments (SCAG)—the regional transportation planning organization for much of southern California—requested exemptions for highway expansion projects and freight corridors from proposed state rules that could show their true environmental impact in a way that old rules do not.

Regular Streetsblog readers know that the Governor’s Office of Planning and Research (OPR) has been working on rules that will remove traffic congestion from consideration as an environmental impact under the California Environmental Quality Act (CEQA).

The impetus came from the slowly dawning realization that measuring—and mitigating—traffic Level of Service, which is what CEQA rules have done for twenty-plus years, was creating many unintended consequences that were detrimental to the environment. The way CEQA rules are carried out, if it looks like a project is going to cause traffic delay, planners must figure out a way to fix it. That in turn has led to street designs with wide lanes and overbuilt intersections that discourage people from choosing more environmentally friendly ways to travel than cars.

The rule-change process has taken a long time. Over the past two years, OPR staff traveled to all parts of the state to discuss Level of Service issues to gather ideas and feedback from experienced planners and engineers. They settled on substituting Vehicle Miles Traveled (VMT) for Level of Service (LOS). Streetsblog coverage of the reasons for that choice can be found here; in brief, measuring how much travel a project induces rather than how much it slows traffic gives a better idea of its true environmental impact.

The deadline for comments was February 29, and SCAG’s letter came in just under the wire. In it, SCAG requests that OPR limit the new VMT measure to projects that are close to transit, and also to “grandfather in” highway expansion and freight corridor projects that have already been approved in planning documents.

“In other words,” said Amanda Eakin of the Natural Resources Defense Council, “SCAG is saying not to apply the VMT metric to the projects that are most likely to cause more VMT.”

To the NRDC, SCAG’s request makes no sense. “As a state,” she said, “we’ve acknowledged all the problems with LOS, and have agreed to move to a new measure that can promote greenhouse gas reductions and other environmental goals. It makes no sense to apply the new metric to only certain projects.”

“If we know that capacity expansion projects are going to increase VMT, then we have to be examining that now,” she added.

Ping Chang of SCAG told Streetsblog that SCAG’s primary intent with the letter was to request that OPR focus first on transit priority areas and allow a longer opt-in period for other areas. “It does take some time for cities to revise their internal systems,” he said.

But a longer opt-in period isn’t the same as grandfathering in certain projects, and SCAG’s stated reason for skipping VMT analysis is simply that they had already been approved, sometimes by voters (such as the Measure R projects in L.A. and Measure M projects in Orange County).

SCAG’s objections seem to be that the guidelines still need some work. “For areas within Transit Priority Areas,” said Chang, “they are ready. In other areas, we still have a lot of questions as to how they will be implemented.”

That’s fair, although it’s not clear why the distinction. Is it that for projects that are likely to induce more travel, the consequences of finding that out are unknown—and maybe scary?

VMT analysis is already carried out for those projects, according to Chang, but it is not used to determine mitigations under CEQA. “This changes the standard,” he said.

Chang said that among SCAG’s objections is that, if VMT analysis has to be done on for individual projects, it could show a falsely high level of new travel.

“Transportation use is a network,” he said. “No road can function in isolation. Changes are a result of a network as a whole, and individual project analysis needs to take into account this network analysis.”

But he also denied that induced demand is real, saying that any increased travel as a result of SCAG’s highway expansion projects will only come from “natural increase.”

“We are not attracting a lot of people to our region because of our transportation investments,” he said. “We are not attracting a lot of jobs from other regions. This is about catching up. The reality is that our transportation investments are primarily about catching up to the demand.”

For others, however, the concept of induced demand is well established and not so much subject to question as likely to cause some consternation, especially in connection with highway expansion projects. And as NRDC’s Eakin pointed out, if projects are going to induce travel, no matter where it comes from, we should know that now.

Greenhouse gas emissions aren’t going to decrease magically while Californians increase driving, and building highway expansions to meet existing demand doesn’t leave any room for thinking about better, more enviromentally friendly alternatives.

SCAG’s letter raises good questions about the details of how to implement the new guidelines, and there probably is more work to be done to figure out how to properly measure the VMT effects of individual projects within a larger regional context.

It’s a point well taken, since one lesson learned from the outdated LOS measure was that regional vs. local impacts could be quite different. An LOS measure, for example, shows less congestion impact for projects in areas that have low traffic volumes, but similar projects in areas with higher existing traffic numbers show a much bigger increase in traffic delay. Thus LOS has helped make small-scale infill more difficult to build than large developments in outlying areas.

But tweaks to the guidelines don’t mean the rule-making process has to be slowed even further. And grandfathering in highway expansion projects just because they have already been approved doesn’t add up. Those projects are the ones whose effects on traveling—whether measured by individual project or in the context of other development—need to be studied.

OPR is currently proposing a pretty generous two-year opt-in period, during which cities, counties, and regions can “adjust their internal systems” to meet the new rules. San Francisco has already formally adopted VMT and dispensed with LOS—and while not all regions are in the same position as San Francisco, they have already had two years to think about what’s coming, and they have two more to adapt to the new rules. Meanwhile, climate change is not getting any less urgent, and the projects being built now will have an impact on all travel—be it by car, bike, foot, or transit—for years to come.

If SCAG and others really need more than two years to adjust, they should be more specific about why, rather than just ask for a blanket dispensation for certain projects.

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  • True Freedom

    For people lauding the changeover to VMT from LOS: VMT gives just as incomplete a picture of environmental impacts as LOS does. VMT does not account for the quality of the mile. If a mile is driven, it is much better to be driven at a constant, relatively low speed. Stop and go/ congested miles are much more deleterious. VMT does not measure that.

  • Ray

    SCAG needs to start planning for the automated car future. It needs to start with a plan to force a LOS using pricing and/or quotas. Since the birth of the automobile, we have never been able to enforce limits on road use, but with the advent of automated cars, we will soon be able to. Highways need to operate at 45mph minimums at all times. Arterials need to operate at 25mph minimums at all times. Residential roads needs to be restricted to residential use. Only with these limits in place will we see proper land use and unsubsidized smarter mass transit. Imagine the significant air improvements that will occur. London’s cordon pricing is just the tip of the iceberg, we can do much better. The current/future regulations are still designed around free, unlimited road use which is absurd. This shouldn’t be a LOS / VMT argument, because neither addresses the root problem of free unlimited use of roads.

    • If that really comes into being, we’re probably more likely to see more sprawl, not a bigger investment in transit.

  • What’s really at stake is essentially the entirety of the plans of both Riverside and San Bernardino Counties (probably Ventura and Imperial too, but I’m less familiar with them). For decades, both have relied on expanding freeways to continue to serve as the bedroom and now increasingly warehouse of LA/OC/SD and being that priorities are still lopsided (even with the switch to VMT), it has primarily occurred as freeways. The rail that does exist could use a lot of help, with only the San Bernardino Line offering anything that resembles a reasonable schedule, but even that being hampered by the slow progress on critically-needed double tracking. Yet, even as the two transportation commissions continue to bemoan the shortfall of road funding caused by the gas tax debacle, they’re pressing ahead with new freeways and outlandish expansions that threaten viable transit projects, and cities around the region can’t wait for the “economic development” that those connections would bring. Given that both Measure A (Riverside) and Measure I (San Bernardino) mandate that ~90% of the money be spent on road expansion projects, the prospect of their wishlist of projects suddenly being out of compliance with CEQA obviously presents a real challenge because both counties instinctively know that on a good day, local dollars still only pay about half of project costs. SCAG is undoubtedly feeling that pressure from the IE (and probably Ventura, Imperial, and High Desert of LA County). Of course, since this region is slated to grow the most over the next few decades, this is the area where the change is most critical. There are a few stabs at TOD in the region, but they’re few and far-between still because the transit side in most places is not meaningful. This is especially true between Riverside and San Bernardino counties, with only Omnitrans’ Route 215 offering anything that’s truly timely enough to be considered useful. But getting out to the Perris, San Jacinto, or Temecula Valleys from the San Bernardino Valley takes forever via transit. Hopefully, the new guidelines will force a change, especially by tempering the propensity to build freeway-sized arterials everywhere that become massive drains on maintenance while also thwarting walking, biking, transit, and not even being particularly good for motoring.

  • 94110

    The LOS to VMT changeover has two affects:

    1. Make it vastly easier to do infill projects.
    2. Make it harder to do road expansion projects.

    I’m actually more excited about the first item. The second will be interesting to see play out, however. It’s very possible that SCAG had a plan to get everything done it two years, and just watched their highway money disappear due to cheaper gas.

    • 94110

      Oops. Meant “effects”, not “affects”.

  • theqin

    If what we care about in the end is climate change and thus emissions, why don’t we grade it based on co2 emitted instead of VMT? It seems to me that for example a project that would encourage time shifted driving would show up positively in an LOS measure but not a VMT measure, even though it driving at different times could have a large different in co2 emitted due to vehicles idling.

    • 94110

      The entire focus on vehicles idling seems absurd to me. Seems like vehicle emissions when stopped at a light should be easy to reduce:

      http://www.edmunds.com/car-reviews/features/do-stop-start-systems-really-save-fuel.html

      • theqin

        Idling is just one of the inefficiencies — slowing down and speeding up as in stop and go traffic can also cut fuel mileage in half. Anything greater or less than about 45 mph is less efficient.

        • neroden

          Electric cars render this completely untrue. And they’re going to take over very, very fast.

    • Ken

      Some vehicles are cleaner than others. Also, OPR considered a variety of possible metrics and even reviewed public comments recommending metrics. In the end it chose VMT.

      Idling can have local air quality impacts. That were result in a significant impact for CEQA. The point to SB 743 is that congestion (or delay) is not, by itself, sufficient to constitute a finding of significant impact under CEQA. Something else can, but not just delay. Part of this is acknowledgment that delay is not, by itself, a signifiant impact. That assessment is already showing up in public comment (and responses to public comment)

      From a climate change perspective, the appellate court in the SANDAG case debunked the idea that improving capacity to reduce idling does not impact GHG emissions (actually, SANDAG debunked it in its climate action plan). The court observed that improving capacity temporarily improved traffic flow, but induced demand again leads to congestion. Then you’re back where you started.

  • Joe Linton

    “Chang said that among SCAG’s objections is that, if VMT analysis has to be done on for individual projects, it could show a falsely high level of new travel.” Damn – when was SCAG ever concerned about “falsely high” predictions under LOS?!?!

  • I have an idea – just deny all highway-related funding to the SCAG region until they have a chance to figure out how to implement VMT. Five years ought to do it.

    • Ken

      They’re probably worried about projects that are planned, but haven’t reach CEQA review yet. The problem is that transportation projects sit on the books for years. There will always be concern about this. Also, I wonder how much of the SCAG Board represents suburbs.

      • calwatch

        The one thing that will make SCAG members paranoid is lack of Federal air quality conformity. Everything else is just an obstacle to be overcome. The regional council is an absurdly large 86 member board that includes all LA City Council members and 67 districts for the different cities. http://www.scag.ca.gov/about/Pages/GoverningStructure.aspx

      • Joe Linton

        Constituents should still know about the environmental impacts of those planned projects, unless they’ve already undergone CEQA

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