California Has Officially Ditched Car-Centric ‘Level of Service’

Vehicle Miles Traveled in California has been on the decline for a couple of years. Changes in how the state manages transportation changes promise to drive it even lower. Photo: ## Traffic##
Vehicle Miles Traveled in California has been on the decline for a couple of years. Changes in how the state manages transportation changes promise to drive it even lower. Photo: ## Traffic##

Ding, dong…LOS is dead.

At least as far as the state of California is concerned.

California will no longer consider vehicle delay an "environmental impact." ##
California will no longer consider vehicle delay an “environmental impact.” ##

Level of Service (LOS) has been the standard by which the state measures the transportation impacts of major developments and changes to roads. Level of Service is basically a measurement of how many cars can be pushed through an intersection in a given time. If a project reduced a road’s Level of Service it was considered bad — no matter how many other benefits the project might create.

Now, thanks to legislation passed last year and a yearlong effort by the Governor’s Office of Planning and Research (OPR), California will no longer consider “bad” LOS a problem that needs fixing under the California Environmental Quality Act (CEQA) . This won’t just lead to good projects being approved more quickly and easily, but also to better mitigation measures for transportation impacts.

Late yesterday, OPR released a draft of its revised guidelines [PDF], proposing to substitute Vehicle Miles Traveled (VMT) for LOS.

In short, instead of measuring whether or not a project makes it less convenient to drive, it will now measure whether or not a project contributes to other state goals, like reducing greenhouse gas emissions, developing multimodal transportation, preserving open spaces, and promoting diverse land uses and infill development.

“This is exciting,” said Jeffrey Tumlin, principal and director of strategy at Nelson\Nygaard. “Changing from LOS to VMT does away with a  contradiction that applicants currently face under CEQA. The contradiction between the state’s greenhouse gas reduction requirements and the transportation analysis requirements is no more.”

This revision in state law promises many positive changes.

Under the previous CEQA regs, the transportation mitigation for a development such as this would have been sprawl-inducing road widenings. Image:## Paper##
Under the previous CEQA regulations, this kind of sprawl was much easier to build than compact, people-friendly places. Image:## Paper##

The most obvious one is that sponsors of projects that aim to reduce car dependency will no longer have to spend time and money measuring their potential to delay cars. VMT is easier and faster to estimate, and it produces a measure of a project’s effect on overall travel, rather than just focusing on delay caused to cars at certain intersections.

In an extreme example of LOS wreaking havoc, a lawsuit in 2009 forced San Francisco to spend more money studying the traffic impacts of its bike plan than it will take to completely implement it.

Such a study will no longer be necessary.

But perhaps a larger change will be what kind of development the law now encourages. When the state measured transportation impacts of a project based on car delay, it was fighting against its own environmental goals. Using LOS, it was easier and cheaper to build projects in outlying areas where individual intersections would show less delay resulting from new development. At the same time it was much harder and more expensive to build in dense areas where there was already a lot of traffic, and where measured LOS impacts would require expensive mitigations or reduced project size — but also where higher density would make transit, walking, and bicycling more viable transportation choices.

Now, projects that are shown to decrease vehicle miles traveled — for example, bike lanes or pedestrian paths, or  a grocery store that allows local residents to travel shorter distances to shop — may be automatically considered to have a “less than significant” impact under CEQA.

Another change will come in how developments mitigate their transportation impacts. In many urban areas, under LOS analysis the only way a development could lessen its impact would be to slim the sidewalk and widen the roadway. This was particularly frustrating along major bus routes or near rail transit stations, or anywhere bicyclists wanted to travel safely.

Under the new rules, the hypothetical development would instead be able to mitigate transportation impacts by funding better transit, creating better access to transit, building better pedestrian facilities, or a host of other improvements that would actually improve travel choices.

The change in law does not require individual cities and local governments to change the way they analyze traffic impacts for other purposes, although some cities have already been working on more creative analysis than LOS.

While the change from LOS to VMT is clearly a good one in many respects, many of the state’s most progressive transportation leaders hope this is just the first step towards more progressive transportation planning in the state. In her confirmation hearings, incoming Los Angeles Department of Transportation General Manager Seleta Reynolds argued that when projects are analyzed, they should be scored on their value in creating a stronger community by providing better housing, cleaner air, more transportation options, or something else.

Tumlin agrees. “Ultimately, what we need is a process and tool to help us imagine what a better California would look like and what we would need to move toward that vision,” he said. “Even with these improvements, CEQA can’t do that.”

The proposed guidance must still go through a formal rulemaking process, which may involve further revisions. OPR welcomes public comments on the draft. Send them by 5 p.m., October 10, to:

  • Jeffrey Baker

    A big, well-deserved middle finger from Jerry Brown to Rob Anderson.

  • And what about if a project or an initiative actually _increases_ VMT? Does it fall afoul of CEQA and require mitigating measures?

  • Presumably yes. Which will hopefully lead to more/better bike infrastructure as mitigation measures instead of right turn pockets.

  • Melanie Curry

    Yes, that’s the idea. The details would be left up to the agency to figure out, but could include transit passes/funding, managing traffic (HOV or tolls), and other travel demand management strategies.

  • Sometimes stuff gets better. In San Francisco the biggest “environmental” hurtle to new high-density mixed-use has been the dreaded “Traffic Study”: pretty much institutionalized insanity. And it’s possible that stuff like funding bike infrastructure will become a desirable mitigation, which was impossible before. Woo hoo!

  • So, let’s just say a certain reprehensible, Republican-sponsored car-centric SF ballot measure passes this fall…would anyone who followed its prescription have to prove it did not increase VMT, and if it did, have to mitigate with bike/ped measures?


  • Michael Smith

    Releasing a draft of guidelines hardly constitutes the actual death of LOS. Until it becomes law and San Francisco establishes new guidelines LOS will still cause problems. Any estimate of when things will be finalized and we can declare LOS as really, truly dead?

  • Juan Matute

    This depends. Was it a voter initiative or placed on the ballot by the supervisors?

  • No, Prop L was put on the ballot mainly by the Republican Party:

  • Juan Matute

    Findings of significant impacts based on LOS are now dead. OPR still needs to send the guidelines to the Resources Agency for official rulemaking and comment periods before the new VMT-based guidance for significant impacts applies in High Quality Transit Areas. On Jan 1, 2016, VMT-baaed impacts apply nowhere.

    Legal question is whether a governing body can still adopt a finding on LOS for a document that was prepared prior to these new proposed guidelines, or if it is now precluded from doing so. I think the latter is true, but it may take a court case to find out. Not sure if anyone will press the ambiguity though, as the writing is on the wall and the direction to abandon LOS is in the Code.

  • Juan Matute

    The initiative text doesn’t work on my mobile – but from the summary it doesn’t appear anything proposed is a “project”. CEQA doesn’t apply to the voter initiative, but it would apply to its implementation.

  • Guest

    Thanks for the analysis. Doesn’t this basically do away with any measure of vehicular traffic impacts to local intersections? I guess that’s the point? We don’t care because it encourages alternatives to driving? This will definitely anger some anti-development folks.

  • Baker and Upright Biker are bike guys and anti-car. The notion that building housing with no parking spaces or limited parking spaces is all the rage now in San Francisco. All those new, well-heeled residents will supposedly ride bikes or our under-funded Muni system. They won’t have cars because…? This is the way we do things in what I call Progressive Land.

  • I’m a Democrat and I support the initiative, which will be the first chance city voters have had to weigh in on City Hall’s attempt to redesign city streets on behalf of a small, obnoxious minority of cyclists.

  • anon_coward

    same thing in NYC
    residential areas have cars parked on the street and in garages 24×7 and yet the anti-car nuts are all into less parking and spouting nonsense that owning a car means you will automatically drive it every day
    on the bright side these people are willing to overpay for housing which means i’ll just sell and buy a mcmansion far away

    and they are spending money for more subways in manhattan but not in the car heavy parts of the city to get people to drive less

  • Melanie Curry

    LOS can still be used in general plans to help determine development impact fees–but that is up to local jurisdictions. San Francisco long ago decided that LOS is largely irrelevant for its planning purposes, but has been required by CEQA to measure it anyway–at great time and expense. Other cities may make different decisions, but the relative simplicity of estimating VMT may be hard to argue with.

  • Dennis_Hindman

    What about that small, obnoxious minority who walk on sidewalks who get separated space that could used for more travel lanes for the much larger majority who drive?

    Or the wheelchair users who should be traveling in the streets with the cars instead of using separated sidewalks?

    You remind me of the guy on the bus who sat behind a lady in a wheelchair. When the woman in the wheelchair told the driver to strap her in the man behind her leaned forward and said “You think your special, but your not. Your no better than the rest of us.”

    Safety improvements to those who ride in cars has been required to be installed by manufacturers for decades. Those that ride a bicycle should also have a safer place to travel in by getting separation from the faster and greater mass of motor vehicles.

    The share of commuters who were residents of the city of San Francisco who drove to work in 2005 was 48.0% and the bicycling share of the commuters was 1.8%.

    The share of commuters who were residents of the city of San Francisco who drove to work in 2012 was 44.0% and the share of those who commuted by bicycle was 3.8%.

    The percent of commuters who reside in the city of San Francisco and drive to work has fallen since 2005 and the percent who bicycle to work has risen. To be equitable some of the fixed amount of road space on major streets that is devoted to driving should be reallocated for separated space for those that bicycle. That is what San Francisco has been doing and the city should continue to do that as the percent of commuters who drive shrink and those that bicycle grows.

  • Charles_Siegel

    It doesn’t do away with measures of traffic impacts to intersections. It just says that they are not an environmental impact under CEQA.

    Cities’ traffic engineers will undoubtedly consider capacity of intersections and keep traffic flowing, but this issue will no longer trigger an EIR and the lawsuits that might go with it – which will anger anti-development folks.

  • Charles_Siegel

    and on behalf of reducing greenhouse gas emissions and preserving a livable planet for our children and grandchildren.

  • Even your numbers/percentages show that cycling is in fact an insignificant share of commuters. According to the city’s own study, only 3.4% of all daily trips in SF are by bicycle, and that’s after ten years of anti-car, pro-bike propaganda from City Hall and the Bicycle Coalition.

    But the real alternative to driving in SF is our chronically under-funded Muni system, not bikes.

    What the city is doing now is probably not politically sustainable: redesigning city streets on behalf of a small minority of cyclists against the interests of the overwhelming majority who use city streets, including the 79% of city households that have at least one car or truck.

  • Think we can get the politicians to call it “Rob’s Law?” I think it’s only fitting that some people should be reminded for a lifetime that mindlessly illogical and ultimately futile tactics can have significant, unintended consequences…

  • Fakey McFakename

    California hasn’t “officially” ditched LOS until the rule is finalized and adopted. Get commenting, folks.

  • Dennis_Hindman

    Commuting to work by walking is a 9.8% share of commuters in San Francisco according to the Census Bureau’s American Community Survey results for 2012. Is that an insignificant amount in your world?

    Using a bicycle as the main mode of transportation to work is more than a third as large as those who walk to work. The survey does not count bicycling if someone rides a bicycle to a transit stop. So the rate of using a bicycle for at least part of the journey to work is actually higher than that and still growing.

    Bicycling to work is a increasing percentage of commuters and driving is a shrinking percentage. To say that all of the road space should be devoted to motor vehicles while its share of commuters is shrinking and bicycling is rising is not a equitable distribution of this space.

    No street where bicycle lanes are installed is preventing access for those using a automobile. Not separating bicycle riders from the much faster and greater mass differential of motor vehicles on a busy street would eliminate bicycling as a choice of transportation for many. Putting bike lanes on a street does not eliminate driving on that street, but it does increase the choices of transportation available.

    Having more ways to move around in a large city makes it more livable, not less.

  • Clearly you don’t know San Francisco, which is a relatively small, densely-populated city with already congested streets. Taking away traffic lanes and street parking to make bike lanes does in fact impede traffic by funneling the existing traffic into fewer lanes.

    As the city gentrifies, there are in fact more cars and trucks on city streets. Millions of tourists drive to and around the city every year. The idea that a major American city is somehow going to turn into Amsterdam or Beijing circa 1964 is entirely fanciful.

    City Hall has been trying for years to sell cycling to city residents but with limited success, except to the young and fashionable—the city of course has many college students that tilt the city’s politics in an immature direction.

    As I say, the city’s bus system—700,000 passengers every workday—is the real alternative to driving, not bicycles. The anti-car policies are nothing but foolishness that ultimately will be rejected by city voters.

  • Of course you do.

  • Dennis_Hindman

    Clearly you don’t understand how much more space it takes to store and move automobiles around in a densely populated city compared to bicycles.

    Taking away most of the 3.8% share of commuters using a bicycle and replacing a good portion of that means of travel with car commuting is not going to reduce the congestion in San Francisco. It only takes a small single digit percent of increase in driving to cause a significantly longer delay in traffic.

    A very small portion of the parking and moving lanes for motor vehicles has been taken away and given to bicycling. I know that because two standard 5-foot bike lanes equals one through lane for motor vehicles and many of those bicycle lanes can be located in the left over space where parked car doors swing open.

    Your not going to reduce traffic congestion in San Francisco by encouraging more and more people to drive during peak hours in what is essentially a fixed amount of road space.

    The amount of workers aged 16 or older who reside in San Francisco increased by about 66,187 between 2005 and 2012 according to the Census Bureau.

    Out of that increase there were about 13,845 more people who primarily drove a car, truck or van to get to work.

    In that same time period, there was an increase of about 10,154 more residents of San Francisco who used a bicycle as their main means of getting to work.

    That’s a total increase of 47,998 residents who bicycled, or drove a van, car or truck to work. Forty-two percent of that increase was from people who used a bicycle as their primary means of commuting to work. Which is much more than a small percentage of the increase in commuters who reside in San Francisco.

  • Charles_Siegel

    When the voters weigh in on this measure, we will see who is the majority and who is the small minority.

    Hint: The supervisors are elected by the majority of the voters, and not a single sup supports the measure.

  • Dennis_Hindman

    Looking at the change in commuting in the ACS results from 2011 to 2012 for San Francisco is even more interesting.

    There was an increase of about 10,984 more residents who worked from the 2011 ACS results to the 2012 results.

    Out of the total amount of workers in 2012 compared to 2011, about 461 more used a car, truck or van as their primary means of traveling to work.

    About 2,166 more workers in 2012 compared to 2011 used a bicycle as their primary means of getting to work.

    The increase in commuting by bicycle was about 4.67 times more than the increase in driving to work by car, truck or van in that time period. The growth in the amount of workers who reside in San Francisco choosing to bicycle in the 2011 ACS results compared to the 2012 results far outpaced the increase in driving by car, truck or van to work.

  • anon_coward

    that’s why you build out mass transit and have ample space for people to park their cars so they can choose not to drive to work

  • Dennis_Hindman

    Increasing the amount of bikeways in San Francisco is clearly substantially reducing the growth in driving to work and this is being done for a small fraction of what it costs to build parking lots for cars and more transit lines.

  • anon_coward

    the drop in driving was larger than the growth in biking so it’s obviously not the bike lanes. even if biking doubled over the last few years that’s still less than 2% of all commuters decided to bike instead of another method

  • Dennis_Hindman

    You’ve got the numbers wrong.

    The percent of workers who resided in San Francisco in 2012 and who used a bicycle as their primary means of getting to work was 3.8%.

    About 6.7% of the 100% total number of workers in the 2012 ACS results stated that they worked from their home.

    A portion of the people who used a bicycle to get to work are counted as using transit as their primary mode of transportation to work if they rode on transit for the longest portion of the trip.

    Transit use also increased in that time period.

    From the 2005 ACS results to the 2012 results, transit gained 0.4 of one percent of the total workers. Bicycling gained a full 2% greater share of the total workers. That’s five times greater gain in the percentage of bicycling to work compared to transit.

    Its obvious that you cannot believe that people would choose bicycling to work over driving even when the data strongly suggests that is increasingly the case.

    The bicycle count in San Francisco for 2013 increased 7.5% over 2012. That means the percentage of workers who choose bicycling to their jobs will likely increase in the 2013 ACS results as the growth in the number of people commuting will likely be far less than that.

  • You’re just fiddling with numbers. The real question in San Francisco is, Where are you going to take away traffic lanes and street parking to make bike lanes? The city’s proposal for Masonic Avenue, for example, is based on falsehoods about safety. The project will take away 167 parking spaces to make protected bike lanes for a completely unknown number of future cyclists:

  • Actually, supervisors are elected by district in SF, not citywide, which is why the vote on the initiative has a better chance of passing.

  • Dennis_Hindman

    I haven’t “fiddled” with the numbers. These are ACS results that don’t jive with your personal beliefs. An increasing percentage of commuters are bicycling while the percentage of those driving to work is dropping.

    Its great that San Francisco has got the political will to take away storage space for motor vehicles on arterial or collector streets to install moving lanes for bicycles. Moving people on arterial/collector streets should have priority over storage.

    An increasing percent of those that travel on the streets are riding a bicycle, therefore more of that road space devoted to motor vehicles should be reallocated to bicycling.

  • sebra leaves

    SF drivers are pushing back against the anti-car movement. We started with the parking meters and Sunday parking and now are we going after the fines and fees, much like LA citizens are doing. We are no longer asleep at the wheel.

  • It’s obvious you don’t really know anything about San Francisco. Please cite the specific streets where the city has “installed lanes for bicycles.” The gains you claim are trivial compared to traffic overall.

  • Dennis_Hindman

    So far, you haven’t refuted any of the numbers I have provided other than to give your opinion, but you have tried to attack my credibility and made some unsubstantiated claims.

    One of your claims is that taking away travel lanes and parking for motor vehicles to install bike lanes impedes traffic. If this has had a significant negative impact on travel during peak hours in the city, then the average time it takes residents of San Francisco to travel to work should have gone up after bike lanes were installed (29 miles in just the last 5 years alone).

    You had previously provided a link that has on page 3 the mean travel time to work that had been collected from surveys by the Census Bureau:

    The mean travel time to work over a three year average in both 2000 and 2012 are essentially the same even though there was an estimated 29,556 additional workers who were residents in 2012 compared to 2000.

    The average travel time to work for San Francisco overall has not gone up, according to the ACS results, even though there were 29 miles of bike lanes added from 2009 to 2013 (64% more). The 2013 ACS will be released next month. I suspect the mean travel time to work will not have gone up in that year either.

  • With few exceptions, the bike lanes created in SF in recent years weren’t separated bike lanes that removed traffic lanes or street parking. They were just lanes painted on the streets. Hence, they wouldn’t have had any effect on commuting time. As I pointed out earlier, you’re indulging in an abstract numerical exercise that has little to do with the reality on the streets of San Francisco.

  • tooter turtle

    I have driven a LOT in my life. I am not anti-car. But my life is SO much better since I have moved to a walkable and bikeable city neighborhood. I still typically get in the car one time each day, but I do almost all of my errands by bike or on foot. I support making places friendly for people, not just for cars. Does that make me anti-car? Real misery is being forced (by bad planning that leads to car-centric infra) to drive for short trips for which biking is cheaper, healthier and more environmentally responsible. Why anyone would not want to reduce the number of car trips we make is a real mystery to me.

  • Dennis_Hindman

    If a mode of transportation increases its share of commuters on public roads, then more space should be available to reallocate to it. The percentage of commuters who bicycle has increased, therefore more road space should be devoted to that form of transportation. It should not be the majority taking all of the space.

    Space for sidewalks was created to provide protection for a minority and likewise separation should be made for vulnerable bicyclists on busy streets. There should be safety improvements for those riding bicycles as there have been for car occupants and pedestrians.

    Of those 29 miles of bike lanes installed in the last five years, 12.16 miles (42%) are protected bike lanes. These protected bike lanes were installed from 2010 through 2013. An additional 0.20 miles of protected bike lanes were installed on Polk St. this year.

    The ACS mean travel time to work is the average of the thousands of yearly survey responses from residents of San Francisco who stated what their commute times were. Your essentially stating that their responses are not reality and your viewpoint is.

    Admit it, Rob, you have a vendetta against bicycling in San Francisco and no amount of facts and information is going to change your mind about it.

  • Dennis_Hindman

    There were 23,225 bicycle riders counted by the SFMTA at 51 intersections in a two hour peak period in 2013. Double that number to include those same people riding back in the other direction and the total would be 46,450. That number is for four hours out of a day and is equivalent to 6.6% of the amount of people that board the bus system in an entire day.

    Market St. has approximately 6,000 bicycle riders on a average weekday.

    The share of commuters who bicycle will likely pass 4% in the next two ACS results. It should hit 5% in a handful of years after that.

    Bicycling is growing in San Francisco and your attempts to stop it from increasing have failed.

  • Dennis_Hindman

    Its not buses that are getting people to leave their cars at home for their commutes, its that growing “small minority of cyclists” as you put it.

    The share of commuters who drive to work has fallen from 48% in 2005 to 44% in 2012 for residents of San Francisco and the share of commuters who bicycle to work has risen from 1.8% in 2005 to 3.8% in 2012.

    People are voting with their pedals and its obviously not buses that are getting them to leave their cars at home for their commutes, its bicycles.

  • Dan Vickerman

    Please enjoy your McMansion… and soon!! And take the train when you come to the city :)

  • Alicia

    If driving dropped by 4% and biking increased by 2%, that leaves 2% unaccounted for. So what are they doing – taking public transportation? Walking?

  • Jerard Wright

    The large elephant in the room in particular with transit projects is how does this change from LOS to VMT effects opportunities for Federal Funding (the State doesn’t have any money for projects)?

    LOS isn’t perfect but it’s hardly the problem, its more of how various interests manipulate the metrics in a legalistic manner for the wrong reasons to get whatever result they want.

  • Joe Linton

    I don’t think that transit has done very well under in the LOS era (may it rest in peace.) I don’t think the end of LOS will change transit investment overnight – LOS is only one big car-centric rule in a huge book of car-centric rules …but I think that ending LOS’s practice of counting a bus and a car the same could be a step in the right direction.

  • Jerard Wright

    Making the note of “no significant impacts” when talking about transit and other mobility is key. Changing the metric will not magically do this.
    Because one is more localized the other is more regional in how the network is composed together. Both are needed to understand what works and what alternatives can be used.

    In practice, this occurred under CEQA/EIR process wearing my Sierra Club Transportation hat, for the Farmers Field Transportation Impact analysis both advocates and AEG realized that you can’t build more auto-lane capacity out of an existing right and that there should be a Transportation System Management alternatives to relieve these impacts. No change to LOS to VMT. It’s recognition of the planning and impact scales (local vs regional) and finding the best fit for both.

    With VMT under this potential idea per the bill language, transit to even get a foot in the door will have to require a definition of the corridor in question to be a “Transit District”, most transit projects aren’t quantified by districts but rather than corridors that connect the districts together.

    That is a very important distinction because projects that can help mobility; like a bike lane in a local district would have the allusion of competition in the same corridor and same street right of way where a bus-only lane project may exist that benefits a regional perspective and given the authoring bill in SB743 had more references to the Sacramento NBA arena (6 times) than to SB375 -the key fulcrum to which all these planning, mobility and land use factors are leveraged (once in the preamble) is making this advocate a little weary.

  • Here is a letter from the Downtown Pasadena Neighborhood Association offering some tips and advice about implementing this change, based on the work that was done in Pasadena.

    Pasadena was actually the first city in the state to eliminate level of service from transportation metrics used in CEQA.


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