The Next Step in Getting Rid of Level of Service: Coming Soon

Screen shot 2015-10-09 at 11.12.52 AM
This illustration shows how a development in an outlying area might produce a lot of overall regional traffic, but so diffusely that it creates few impacts under LOS (the red dot). Click to enlarge. Image courtesy the Governor’s Office of Planning and Research

After several years of work, the Governor’s Office of Planning and Research (OPR) is almost ready to release draft guidelines on replacing vehicle Level of Service measures under the California Environmental Quality Act (CEQA). The shift was called for by Senate Bill 743, which passed late in the 2013 legislative session.

OPR will propose measuring a project’s environmental effects with an estimate of how many new vehicle miles it would produce, instead of the long-used Level of Service. LOS, as it is commonly referred to, focuses on how much traffic delay a project might cause. Its use under CEQA has produced many unintended consequences.

The draft guidelines, pending further refinement, are expected to be made available for public comment and discussion in a few weeks. Anticipating the release, Chris Ganson of OPR gave a presentation at a recent American Planning Association meeting in Oakland. There will be another chance to hear Ganson talk about the subject at the California Bicycle Summit in San Diego later this month.

While seemingly obscure and definitely wonky, the subject is an important one: the shift in perspective that the new guidelines call for is likely to have a profound impact on the way development happens in California—perhaps as profound an impact as using vehicle Level of Service has been until now.

Ganson’s presentation begins with background: LOS has been used in planning to estimate the effect that projects will have on traffic in the area around it. Estimates are made, numbers are crunched, and in the end nearby intersections are assigned a grade, A through F, which gives a general idea of how quickly cars get through an intersection without delay.

Under CEQA, depending on definitions set by local agencies, a “bad” grade can set off requirements for expensive mitigations, and those have frequently included widening roads and intersections to prevent the traffic delay.

The problems with this are turning out to be numerous. “Auto delay” by itself is not an environmental impact. LOS was supposed to be a proxy for environmental issues caused by traffic, but its focus became primarily on delay of cars at the expense of other things, like delay of people, or energy use, or overall travel (and greenhouse gas emissions) induced.

Using LOS, infill projects in already dense areas can show up as having a large effect on nearby intersections, while projects built in outlying areas tend to get a pass.  Even if they add more traffic overall to the region, as sprawl projects tend to do, they “look” better under LOS because the impact on specific intersections is less. See the accompanying illustration for an idea of how that works.

In other words, using LOS in CEQA has greatly contributed to the formation of California’s sprawling suburbs with big box retail on the exurban edges, inaccessible by anything other than a car.

Instead, says OPR, CEQA should require projects to estimate how many vehicles miles of travel they will induce. That would even the playing field, removing the advantage that sprawl development currently has over infill. Vehicle miles of travel, or VMT, are already being measured and estimated for other planning purposes. Also, California Air Resources Board regulations recognize the need to reduce VMT in order to reach climate change goals, even with an expected increase in electric vehicles.

OPR’s proposal is still in draft form, after more than a year of extensive public outreach and many public comments. Some comments support the shift to VMT because it has the potential to address air quality, and promote infill and other development patterns that are not sprawl developments. Some comments expressed concerns, including whether the new measures were mandates or suggestions, and how to set thresholds for CEQA that make sense.

Currently under CEQA, a developer submits an Environmental Impact Report estimating a project’s impacts on the area. If the impacts are above a certain threshold, then the developer has to figure out some kind of mitigation that lessens the impact. Thus using LOS, widening a road would reduce delay below a certain threshold—even though it has other unintended consequences. Using VMT, the question is what level of induced traffic triggers the need for mitigation, and what would that mitigation be?

The tension between the need for flexibility and the desire to make a difference—that is, to actually reduce VMT in line with state goals, not just keep levels the same—is part of the reason this process has taken so long and is so complex. OPR’s suggested solution is two-fold: to recommend thresholds, rather than set them in stone; and to create a separate technical advisory document that’s not part of the guidelines but is meant to help agencies figure out what thresholds should be.

Some key staff recommendations, which are still in draft form and may not end up in the final guidelines, include presuming that projects near transit won’t have a significant enough impact to trigger the need for mitigations; eliminating very small projects from the need to produce an EIR; and finding a way to look more carefully at the impacts on transit.

Chris Ganson’s presentation at the CalBike Summit will go into all of this in a lot more detail, and his talk is highly recommended for anyone interested in the future shape of development in California. More information about the Bike Summit can be found here.

22 thoughts on The Next Step in Getting Rid of Level of Service: Coming Soon

  1. These photos are dishonest: the angle is not the same for the 4 shots.

    I’m all in favor of better transportation infrastructure in general, including segregated bike lanes, pedestrianized areas etc., but the do-good, holier-than-thou tone of many activists in the are make me cringe and sometimes despise them completely.

  2. Two responses from OPR. First, delay, on its own, is a socioeconomic impact, not an environmental impact. Second, they want a different metric more in line with state climate change policy. As a result, they settled on vehicle miles traveled. Part of the goal is to encourage more infill. Yes, you may spend more time getting down a street or through a particular intersection, but if you don’t have to travel as far, because things are closer together, your trip time isn’t any longer.

  3. A four lane road is good for traffic volumes of 40k PCE/day. If Masonic only has 32k, that’s well within the range and the street still has room for at least 25% more PCE than are currently passing through there every day. They’re leaving it with at least four lanes, so it will not be the end of the world.

  4. LOS fails to predict real-life traffic. It has given us a system that fails everyone – people on foot, on bike, on transit, and in cars. Its place should be the scrap-heap of history.

  5. The response I hear from traffic engineers and planners is that congestion management measures (i.e. improving transportation alternatives to address the “demand” side of the equation) survive litigation challenges very poorly, because courts don’t think they’ll actually be implemented. I don’t really get this, because you can establish mitigation measures in your project using solely performance measures so long as they’re feasible. It worked for the City of Sacramento in defeating challenges to the Kings arena.

  6. Also, “4-3 conversions” are very good for auto traffic.

    With 2 lanes each way, obnoxious drivers weave back and forth between the lanes, slowing everyone down and creating a dangerous situation.

    With 1 driving lane each way and a pocket turn lane in the center, left-turners are separated out from other drivers, speeding the traffic up, and the weaving drivers are eliminated.

    Masonic, unfortunately, is still going to have a 4-lane configuration — basically, they’re just replacing parking with bike lanes.

    Which will certainly increase throughput!

  7. Yes. And what about level of service for those in nearby houses and shops? Increased volume and speed of cars increases noise, pollution, and general discomfort. I agree that we need LOS for cars. It should also account for other modes and other impacts:

    We should treat LOS similar to how incentives for people in business are calculated and measure success on all critical factors not just skate by on a single one.

  8. Converting one car lane out of four to two bikeways increases total capacity by over 80%. The best part is that only a very few people choosing to ride bicycles instead of drive will reduce congestion on the remaining vehicle lanes below what it is today.

    As more bike lanes are implemented creating a network that more and more people choose to use the impact on reducing congestion multiplies.

  9. You cannot build your way out of congestion. Cars take up too much space. For comparison they require 7 to 20 times as much space as bicycles which is why European cities with extensive bicycle infrastructure have so much less congestion.

  10. This is nuts like a lot of anti-CEQA baloney. Here in San Francisco the city is about to jam up traffic on Masonic Avenue to make bike lanes on a street that carries more than 32,000 vehicles a day based on nothing but the hope that more people will then give up driving and start riding bikes.

    That is, this bike project won’t generate more VMT, but it will jam up existing traffic on this busy, regionally significant street, which means it will be a success according to the VMT standard!

  11. When they mean remove LOS they mean remove it as the king of all measurements. A backed up intersection will not go ignored. A city built on VMT instead will have more options available to mitigate traffic at said intersection.

  12. LOS still has a place. No one wants to nor should they have to wait for ten minutes to get through an intersection. As such, the biggest problem isn’t LOS, it’s that traffic engineers, transportation planners, and the profession in general provide no mitigation measures beyond wider roads to help maintain LOS. Perversely, bike, ped, and transit projects that actually could help maintain LOS often get hamstrung and tabled because the analyses always assume that no one will actually not drive even with better options available.

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