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Tag Archive for: Level of Service

VMT vs. LOS: VMT FTW!

July 8, 2020/by Laura McCamy

On July 1, 2020, a quiet change happened on California streets. You won’t notice a difference right away, but the change will have huge ramifications for years to come. The change involves a win for VMT vs. LOS. For the past seven years, Caltrans has dragged its feet on a change to CEQA that would switch the way we evaluate traffic impacts for projects from level of service (LOS) to vehicle miles traveled (VMT). Builders associations also desperately opposed this change. BIA Southern California even recorded an anti-VMT rock song parody.

There are a number of reasons why this change to CEQA reviews has inspired so much angst. At its core, however, the resistance comes down to this: the switch from LOS to VMT is a fundamental shift in the way we view the world. This is nothing less than changing from a through-the-windshield view of life to an outlook that gives weight to the impacts of climate change and quality of life.

CalBike is proud to be a member of the coalition of groups that pushed to get the VMT Bill, SB 743, passed and then continued the push to get it implemented. We know that big changes can come from quiet victories, like SB 743. Here’s what will change

LOS seemed like a good idea — in 1969

When the California Environmental Quality Act was signed into law by Governor Ronald Regan in 1969, it was intended to make sure that all steps were taken to protect the environment during construction projects. CEQA guidelines, as originally written, used LOS as a measure of traffic impacts of a project.

LOS is an accurate measure of congestion, specifically, the seconds of delay suffered by a motorist at an intersection compared to free-flowing traffic. LOS forced cities and developers to analyze how new developments or traffic changes would impact nearby intersections. That analysis was considered a measure of environmental impact, because cars produce emissions when they idle at a red light. By placing top importance on relieving car congestion at intersections, however, LOS made cities prioritize driving over all other modes of travel.

Why VMT vs. LOS matters

CEQA analysis (which produces a document called an EIR) will indicate measures that a project may take to mitigate its environmental impact. In order to mitigate worsening LOS, engineers could change signal timing to move traffic faster, widen the roadway, add turn lanes, reduce the time of the pedestrian crossing, or, as most bike riders are painfully aware, remove a bike lane at the approach to an intersection. Intersections are choke points because people have to stop and wait for cross traffic. You might need a turn lane at an intersection to satisfy the demands of LOS. Perversely, the rules of analysis would indicate that keeping the bike lane at the intersection to allow safe bicycle passage would cause a negative environmental impact.

Under CEQA law, a restriping of the roadway to add vehicle lanes was exempt from environmental analysis. In other words, you could change a wide 2-lane road to three lanes, which would be a huge increase in capacity, without considering the environmental impacts of this project. On the other hand, if you wanted to turn one of the lanes in a 3-lane road into a bike lane, that would impact LOS for car traffic and you’d have to do an environmental impact analysis. 

“From the point of view everyone gets around by cars, LOS is an important way to reduce inconvenience to the public. That’s why getting rid of it was so hard. But that point of view was wrong then, it’s wrong today, and disastrous carried into the future.” – Dave Snyder, CalBike Executive Director

A lot has changed since 1969. First of all, cars don’t pollute as much when they idle as they used to. Secondly, planners have come to understand and accept the concept of induced demand. When you widen a roadway, rather than relieving congestion, you induce additional demand. Counterintuitively, adding more lanes to a street or highway often leads to more congestion, not less. Finally, we’ve come to understand the impact of carbon emissions on climate change. Carbon emissions are almost a direct function of vehicle miles traveled.

By changing the measure of impact in CEQA analysis to VMT from LOS, project proponents will have to assess the added vehicle miles associated with a new building or road construction. This shifts the focus from moving cars faster to moving people more safely, conveniently, and with less carbon emission. Mitigations could include investments in transit, widening sidewalks, or building bike lanes to help reduce the VMT of the building.

A victory seven years in the making

Although SB 743 passed in 2013, Caltrans clung stubbornly to LOS for assessing its projects. It took a great deal of pressure, but the agency finally switched to a VMT analysis as of July 1. Now, projects that impact state-controlled roadways will be subject to VMT analysis rather than LOS. Caltrans controls roads that double as local streets in many California communities. Often, these state routes are the most direct way to get across town. They are also often the most dangerous streets in a community.

VMT won’t change the condition of Caltrans-controlled roads overnight. But this CEQA change opens the door to more Complete Streets projects, more bike lanes, better intersections, and safer streets across California. And it represents one small but necessary step in mitigating the worst impacts of the climate crisis.

If you want to learn more about Caltrans’ adoption of VMT, you can view a recording of the agency’s webinar, Senate Bill 743: A Virtual Town Hall; Rethinking How We Build So Californians Can Drive Less.

VMT will change your bike plan, too

Before the change to a VMT standard, bike lanes almost always required an environmental review. The process is costly and it added delays to bike infrastructure projects.

However, by definition, a bike lane doesn’t increase VMT – it actually reduces the need for car travel. Bike plans are exempt from CEQA, thanks to a 2005 CalBike victory, However, the projects that implemented the plan used to require CEQA analysis. In some cases, an entire planned bike network might require a cumulative impact analysis under CEQA. Now that the primary measure to determine impact under CEQA is no longer automobile traffic, bike lane projects will be cheaper and quicker to build. 

On the other hand, projects like adding a vehicle travel lane used to get a pass because they theoretically reduced car congestion. Under the VMT standard, those projects will now require analysis because they are likely to increase vehicle miles traveled.

Is the switch to VMT from LOS enough to mitigate the looming climate catastrophe? No. We need to do much, much more to build bikeable, livable communities where people don’t need to burn dinosaurs to get to work or to the store. However, the VMT win is a vital piece of a larger strategy to take the car-centric blinders off agencies like Caltrans. CalBike will keep fighting for those changes, large and small. 

https://www.calbike.org/wp-content/uploads/2020/07/Intersection.jpeg 625 500 Laura McCamy https://www.calbike.org/wp-content/uploads/2018/07/calbike-logo.png Laura McCamy2020-07-08 17:19:312020-07-24 12:07:27VMT vs. LOS: VMT FTW!

CalBike Joins Coalition Calling for Implementation of Commonsense Environmental Impact Analysis

June 26, 2020/by Kevin Claxton

For decades, the laws that protect the environment by requiring traffic impact analysis had a serious flaw. The analysis considered car congestion as a negative impact that should be mitigated. This led to road widenings to relieve congestion (which only led to more traffic and, soon after, more congestion). Even worse, these level of service (LOS) analyses prevented safety improvements if those improvements would delay automobiles. The result of these rules was perverse. A huge office development in the sprawling suburbs with easy highway access and no safe way to get there by bike would be deemed to have no significant environmental impact. At the same time, a simple bike lane or retiming of traffic lights to make it safer to walk or bike might be declared to have a significant negative impact on the environment using the LOS traffic impact analysis.

In 2013, the legislature and governor approved SB 743. The new law changed the rules for traffic analysis in California. It forbid analysis of congestion for environmental review purposes. Instead, SB 743 required an analysis of vehicle trips generated by a project. This new vehicle miles traveled (VMT) traffic impact analysis will change the way new projects are assessed. In keeping with California’s goals to reduce car traffic to mitigate climate change, a project that would generate lots of car traffic would require mitigation. After SB 734, a project that would reduce car traffic and provide access for alternative transit options would be considered a good thing for the environment.

The California Department of Transportation resisted this law for years. Only now, in 2020, have they produced guidelines for agencies to implement the new rules. These guidelines were about to go into effect when the COVID-19 crisis hit. Now, a coalition including real estate developers and automobile interests has asked the governor to delay implementation of the new rules, claiming that any change to the rules regarding development will delay crucial economic recovery activity.

CalBike is opposing the delay in a letter sent to the governor on May 26, 2020.  The letter, written by the Planning and Conservation League and joined by our partners in the Climate Plan Coalition, contradicts the developers’ claim that implementing SB 743 will harm the economy.

“Not only have developers and agencies had 7 years to prepare for the implementation of this statute, the VMT-based methodology is in most cases less complex to conduct than LOS. Upon implementation of SB 743, many land use and infrastructure projects that California needs to meet its climate, public health and equity goals will not be required to analyse transportation impacts at all. Projects presumed to reduce VMT—including transit and active transportation projects, commercial and housing development within proximity to transit or within low-VMT zones, and all affordable housing—are all exempt from conducting the new analysis.”

In 2013, California’s legislators enacted a commonsense law to ensure that new building projects support active transportation and transit rather than recklessly expanding car travel. Now, in the midst of a pandemic that has provided a stark example of the importance of clean air and green transportation, Governor Newsom must not delay the implementation of SB 743 any longer.

View or download the full letter: 6/26/20 Resubmitted SB743 Letter to Governor Newsom et al.

https://www.calbike.org/wp-content/uploads/2020/04/building-under-construction.jpg 375 500 Kevin Claxton https://www.calbike.org/wp-content/uploads/2018/07/calbike-logo.png Kevin Claxton2020-06-26 15:23:282020-06-26 17:55:21CalBike Joins Coalition Calling for Implementation of Commonsense Environmental Impact Analysis

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