VMT vs. LOS: VMT FTW!

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.