Blogging Bayport Alameda

January 26, 2016

Lost LOS

Filed under: Alameda — Lauren Do @ 6:06 am

It’s always a bit surreal when folks minimize something that has been in the works now for about a year and a half as a:


Case in point, the on-going effort to reform the California Environmental Quality Act (CEQA) process to be less abused by folks simply trying to stop development by throwing the kitchen sink at an individual project to see what sticks.  Despite the bill removing Level of Service being passed years ago suddenly it’s something to OMG about.

Level of Service or LOS has long been criticized as an ineffective tool for measuring environmental impacts.  While no one likes to be stuck in traffic congestion, it’s not the traffic congestion itself that is an environmental issue, it’s the impacts of that congestion which are the environmental issues: noise, air quality, and safety.  But, again, it’s not the delay that is caused to individual vehicles that is an environmental impact.  This set of slides defines the problem with LOS as an environmental measure pretty plainly, here are a few highlights:

Scale of analysis is too small
• Registers impacts adjacent to project, ignores impacts regionally
• Spot metric insufficient to show corridor/network impact/benefit
LOS mitigation is itself problematic
• Reducing project size pushes development to worse locations
• Widening roadways worsens livability, induces vehicle travel
Mischaracterizes transit, biking, walking as detriments to transportation
• A transit priority lane worsens LOS even as it improves person-throughput
• LOS characterizes pedestrians and cyclists as obstructions to cars, to be channeled/restricted

The change doesn’t mean anything from a local level.  If the City of Alameda wants to use LOS on a local level for whatever, they’re welcome to.  But, the difference is it will no longer be used for CEQA as a reason to require a project, specifically projects that are design to encourage alternate methods of transportation, to spend thousands of extra dollars on additional studies rendering the overall project more expensive in general because LOS mischaracterizes those methods as a “reduction” in service.

From that article from 2014:

As the primary arbiter of traffic impacts under CEQA—adopted in 1970 by Governor Ronald Reagan—the metric not only determines the fate of many transportation and development projects, but has the awkward role of promoting car use within a law designed to protect the environment. “We have one section of CEQA saying we’ve got to reduce greenhouse gas emissions,” says transportation consultant Jeffrey Tumlin of Nelson\Nygaard, “and another section of CEQA saying we need to accommodate unlimited driving.”

Ganson told me OPR was planning to recommend “vehicle-miles traveled” as the new “central metric” under CEQA. He says VMT meets all the state’s major criteria for a traffic evaluator: fewer greenhouse gases, more multimodal networks and urban infill developments, a general boost to both the environment and public health. Where LOS encouraged public projects to reduce or eliminate driver delay at city intersections, VMT would encourage them to reduce or eliminate driving at all.

“If we’re using delay metrics to rate our progress, we’re going to look like we’re doing bad, even as we’re doing exactly what we’re trying to do,” says Ganson. “Even as we’re meeting not just our environmental goals, but our goals for the fundamental purpose of transportation—providing access to destinations. Getting people places.”

From a Streetsblog piece:

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.

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.

In short the death of LOS is a good thing when it comes to actually getting stuff done that benefits the environmental goals of the state, which was largely a reduction in greenhouse gas emissions.  Allowing transit, superior pedestrian and bicycle infrastructure to proceed without costly studies will allow people to have safe and viable alternatives to single occupant vehicles.

The move to Vehicle Miles Traveled (VMT) aligns better with the environmental goals of the State of California.  And, for those wondering, here are the proposed thresholds for VMT for projects:

Recommended threshold for residential projects: A project exceeding both
 Existing city household VMT per capita minus 15 percent and
 Existing regional household VMT per capita minus 15 percent may indicate a significant transportation impact

Recommended threshold for office projects: A project exceeding a level of 15 percent below existing regional VMT per employee may indicate a significant transportation impact.

Recommended threshold for retail projects: A net increase in total VMT may indicate a significant transportation impact

But, I suppose if the first time you’ve read of this is in a glowing op ed from someone in the Planning universe who should be immediately mistrusted.  Or if the first you’ve been exposed to anything with regard to CEQA and LOS is from a blog which states that “OMG no one cares about us sitting in traffic!” then, understandably, you’ll be a little nervous about what this all means.

If you only care about development, or rather you only care about new development’s impact on you because you are concerned about how much longer it will take you to get through the tube in your morning commute, then yes, be worried because the State is taking away a key bullshit loophole dressed up in “environmental” clothing to tank a project.  But if you are concerned with real traffic mitigations and supporting projects that have examined all real environmental impacts, then this change is nothing to be concerned about and, truly, begins to measure what really is important.



  1. And the Oscar for “Typing BS with a Straight Face” goes to……..

    Comment by dave — January 26, 2016 @ 6:22 am

  2. #1 Robert Sullwold?

    Comment by notadave — January 26, 2016 @ 9:01 am

  3. I like LOS because I am a citizen with no degree from Wonk University, and it is easy for me to wrap my old untrained mind around an intersection that is rated LOS A or B or C or D, dare I say it’s also easier for very local governing entities (like, maybe, City Councils?) to understand and address. LOS deals in hard facts- numbers of vehicles transiting a certain point in a given time span, and you can measure the result of mitigation in the same way. Less opportunity for a local elected official with little or no expertise to mis I terperet, obfuscate, mislead about the possible results of some pie in the sky VMT scheme. Better to keep LOS and just amend it to read that the root causes of an intersection being at LOS D or F need be addressed, even if that root cause is a new residential project two miles away. Consultants, local political gadflies, and politicians cN spin VMT to suit their purpose, where if an intersection is at LOS D or F you know you have a problem and need to fix it.

    Comment by Not. A. Alamedan — January 26, 2016 @ 9:12 am

  4. LOS can still be used for local planning projects but it won’t be used as an environmental impact that needs to be mitigated. LOS delays can typically only be mitigated through street widening which will not necessarily reduce congestion or traffic.

    Vehicle Miles Traveled is not pie in the sky, it’s a metric that has been used and still is used by the Federal Highway Administration. Understanding how many miles the average car drives is much easier to understand than LOS A, B, C, D or F and is definitely more of an apples to apples comparison. I would say that few people would understand the difference between an LOS of B or C and how much additional delay going from one measurement to the other.

    Comment by Lauren Do — January 26, 2016 @ 9:42 am

  5. LOS delays can typically only be mitigated through street widening which will not necessarily reduce congestion or traffic


    They can also be mitigated by reducing or halting development where infrastructure is insufficient.

    Comment by dave — January 26, 2016 @ 9:56 am

  6. Vehicle Miles Traveled is not pie in the sky, it’s a metric that has been used and still is used by the Federal Highway Administration


    VMT is a valid measure for highways. For a residential community that lacks highways but is full of citizens who need to work and lack the moral fiber to find a job in downtown SF and send their kids to soccer practice on the 51 line, LOS makes a lot more sense.

    Comment by dave — January 26, 2016 @ 9:59 am

  7. Algore: We Have Ten Years Left Before Earth Cooks
    January 27, 2006

    Ten years left to save the planet from a scorching. Okay, we’re going to start counting. This is January 27th, 2006. We will begin the count, ladies and gentlemen. Al gore.

    Helpful hint: Don’t go outside tomorrow folks. Wrap yourselves in asbestos.

    Comment by jack — January 26, 2016 @ 4:36 pm

  8. Let’s be clear. The traffic complaints in Alameda are based on the difficulty of leaving/entering the Island during peak commute hours. There simply are not intersections or streets in Alameda that are gridlocked with LOS “failures”. The time to drive across and within Alameda is simply not affected by traffic, rather by the normal navigation of stops and lights. The main source of the doom and gloom predictions are strictly regarding the problems driving through the tube or over a bridge, made by people who think it is a LOS entitlement to be able to drive solo unfettered at any time. Claiming that an intersection in Alameda is getting an LOS D or F because it has not been designed well or that the connecting streets aren’t designed well, is hogwash. The main reason for LOS failure is the inability or unwillingness of auto drivers to not make single-occupancy trips off/on the island during peak commute times. If you are commuting alone (i.e. not providing a ride share or other carpool), you are exasperating the problem. You are traffic. LOS is also flawed because it only applies to auto service, which by its nature is highly inefficient. I mean, only 1 can can fit in a 10 foot wide lane and only one car can navigate an intersection at a time. Not inefficient.

    Comment by AJ — January 26, 2016 @ 4:55 pm

  9. Regardless of the metric used, how do you think it will be to navigate off this island in the morning with 1000 more housing units build on the north side as is planned by the Housing Element? If you think things are bad now, hope you can be retired or working from home when this is completed. The jobs planned so far in these developments will not pay the bills for the families of tomorrow so they will not be living here. Grocery store employees do not buy million dollar homes.

    Comment by Nancy Hird — January 26, 2016 @ 8:29 pm

  10. I went to South Shore this weekend and I saw 2 bikes using the Bike Track at 2 pm on Sunday…one guy was walking his from the beach…I passed probably 100 cars going the other direction. I know we need bike lanes but there is no bang for the buck. Just because we build them doesn’t mean more people will use them. Probably less than 1% of people in Alameda will use them…I know it is a sticky point.

    The other thing is why didn’t they build the other half of Stargell past the point 5th to Coral Sea when putting in the new development which includes the low income housing at Alameda Landing and Shinsei Gardens when the developer would be responsible for the infrastructure build out of this part of the street…or are the $’s put into some sort of reserves to complete the build out of this portion in the future which may be sooner then later. The whole 5th and Stargell intersection is sort of messed up with the lights not lining up with the lanes ect… because of the future expansion. No one going down 5th towards Stargell turns left at Stargell that should the lane to go straight or turn left and the other lane for right turns only.

    Comment by joelsf — January 27, 2016 @ 4:09 am

  11. #10 Ahh yes the old false comparison to Shoreline argument. The Shoreline bike lane was always intended to be a recreational pathway, not an important route to get from one place to another. It shares nothing in common with other transportation-related bike projects. The number of cyclists using it during one moment in time while you ran your super-scientific assessment is irrelevant. The reason Shoreline “feels” busy and “feels” unsafe is because during the planning process, people insisted on making more parking available 24 hours per day along Shoreline, and could not accept any elimination of parking as had been proposed. Auto drivers who believe that warehousing private vehicles along the beachfront is their entitlement is what messed up the view and made things tight. Making more and safer bike infrastructure on main travel routes does eliminate auto trips. Using TOS transportation policy to affect only auto transport is a failed policy and a losing battle.

    Comment by AJ — January 28, 2016 @ 12:02 pm

  12. 11. ” The number of cyclists using it during one moment in time while you ran your super-scientific assessment is irrelevant.” I understand the desire for bicyclists to have a place of their own to recreate, just as tennis players and golfers and scuba divers want a place to recreate. However, I also have been down Shoreline many times, lot of times on beautiful sunny weekend days, and I have counted the number of bicyclists recreating on that beautiful modern bicycle pathway on the fingers of one hand, and still have fingers left over. So, at what point does it become a waste of taxpayers’ money, and an entitlement for the privileged few that do use it? It makes no difference to me if the bike lanes are there or not; I generally don’t go down to the beach. I have made detours while i am in the area just to check it out. So, if Joel’s ‘one moment in time’ is irrelevant, what are the stats on usage so far? Surely someone has done an in depth, scientific study to satisfy even you?

    Comment by Not. A. Alamedan — January 28, 2016 @ 1:35 pm

  13. yes I have done an absolute super, super scientific survey on Sunday mornings when my son and I drive to the golf course. We also take the same route back home. not only did I use up all of my fingers, I had to take off my shoes and still ended up losing count. Its those darn “privileged bike owners” that are destroying Alameda. I can’t see the beach because of them.

    Comment by John P. — January 28, 2016 @ 2:23 pm

  14. #13 – Thank you John, so well put!

    Comment by Karen Bey — January 28, 2016 @ 4:17 pm

  15. I hate to point this out John with a city of 75,000 people less than 1% you don’t have enough fingers or toes. I lived in SF where they close the main street on Sundays for 1,000’s of bike riders, roller blades, walkers, but that doesn’t happen in Alameda. People don’t ride bikes in Alameda…just go by a school…in the morning or evening…there is a line of cars waiting for people to drop their kids off…and no bikes traffic.

    Comment by joelsf — January 29, 2016 @ 2:40 am

  16. I can only speak for the two schools my kids attend, but in the case of their elementary school, the overwhelming majority of kids walk to school. If I had to guess, I’d say more than 80%. This is no surprise, it’s one of the great things about Alameda’s neighborhood elementary schools.

    As for middle school, a few more drive, which makes sense because the attendance zone is so much larger and includes Harbor Bay, but a solid majority walks or bikes. So many bike that on non-rainy days the racks are all full and bikes are locked to fences and other makeshift places. There are so many bikes it can be difficult to find a place to lock a bike. There is a line of cars at pick up time but rarely more than a few dozen, while the school has over 800 students. Bikes outnumber cars several fold.

    Comment by dave — January 29, 2016 @ 7:04 am

  17. Piling on to Dave’s point. One could look at the buckle infrastructure on the east end and correlate it with significant higher bicycle riding than the west end, where there are no east/west lanes west of Webster. So if course kids biking to school is less frequent there.

    The shoreline argument is odd. The street is functioning perfectly, there’s no congestion, the road diet has not caused carmageddon. It’s slowed traffic along the beach and increased the number of people walking there because what few bikes were there before (fewer than now) are not competing with people walking on the path.

    The city’s recent poll of citizens found that nearly 60% of alamedans ferl it’s at least somewhat important to increase the number of bike lanes in town. And 87% want to create safer space on the street for people who walk and bike.

    This is not a discussion about a vocal minority, the vocal minority are the people complaining about biker lanes and the city note had the data to prove it.

    Comment by jkw — January 29, 2016 @ 8:23 am

  18. what a ridiculous red herring. Even if there is only use at peak hours for kids commuting schools, it is worth the investment for their safety. Even if you are not a parent, what is the value of one kid’s life? The safer street comes at very little ( arguably none) of the ability of the street to channel autos.

    Comment by MI — January 29, 2016 @ 8:50 am

  19. where there are no east/west lanes west of Webster


    Santa Clara?

    Comment by dave — January 29, 2016 @ 8:54 am

  20. 12. You have such a disconnect to reality. Biking is transportation and recreation. I have never ridden my tennis racket to work. So let’s see…. there are 5 “lanes” on Shoreline now: two for parking private vehicles, two for driving cars and 1/2 a lane for riding a bicycle. So 8/9 of the street surface is dedicated to cars. 44% is dedicated to simply storing private autos in public space. Yet you complain that the road is ruined when ~11% of the road surface is allocated to biking. So who’s entitled?

    Comment by AJ — January 29, 2016 @ 9:27 am

  21. 19. There is no bike lane on Santa Clara west of Webster. The road narrows dramatically once you cross Webster. There is a white line between the parked cars and travel lane, but it is not a bike lane. I don’t know what purpose it is supposed to serve, but your average sedan parked against the curb would be about six inches from the driver side tires, not even the side view mirror can fit.

    jkw’s point about the imbalance in infra for bikes on the west side of town (west of Grand, even) is stark. It was very clearly put into focus for me personally in November. Two meetings in council chambers in the same week had large numbers of children speak during public comment. On Tuesday you have brown kids on the West End (everyone of whom I bet walks or rides to school w/out the benefit of defined bike space) begging council to let them stay in their homes. On the next day you have a large group of otherwise privileged white kids from the Gold Coast or East End asking for safer streets for getting to and from school. One population has the luxury of advocating for a fair share of the roadway while another is scrambling for their continued existence in the community.

    Comment by BMac — January 29, 2016 @ 9:57 am

  22. BMac, that is exactly what to expect if you live in the West End. I’m bitter after 72 years here.

    Comment by John P. — January 29, 2016 @ 10:51 am

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