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Is LOS Obsolete?
How SB 743 May Change CEQA
Transportation Practice in California
“All truth passes through three stages. First, it is ridiculed. Second, it is violently opposed. Third, it
is accepted as being self-evident.”
- Arthur Schopenhauer, German Philosopher
“All CEQA changes pass through three stages. First, they are ridiculed. Second, they are legally
opposed. Third, they are accepted after being validated by the courts.”
- Ronald T. Milam, Fehr & Peers Philosopher
Regulatory
changes Have occurred but will continue to evolve (especially technical practices)…
SB 375
AB 32
SB 97
SB 226
SB 743
What is LOS?
To a driver: LOS A To an economist: LOS F
To a driver: LOS F To an economist: LOS A
Analysis of infill
development
using LOS
Analysis of infill
development
using LOS
Relatively little vehicle travel loaded onto the network
Analysis of infill
development
using LOS
Relatively little vehicle travel loaded onto the network
…but numerous LOS impacts
Analysis of
greenfield
development
using LOS
Analysis of
greenfield
development using
LOS
Typically three to four times the vehicle travel loaded onto the network relative to infill development
Analysis of greenfield
development using
LOS
Typically three to four times the vehicle travel loaded onto the network relative to infill development
…but relatively few LOS impacts
Traffic generated by the project is disperse enough by the time it reaches congested areas that it doesn’t trigger LOS thresholds, even though it contributes broadly to regional congestion.
• LOS is predominant transportation impact measure
• Typical LOS analysis represents only the driver perspective
• LOS mitigation usually requires expansion of the network
• LOS mitigation generates impacts to other modes and the environment
• Physical mitigation may not even be possible in urban setting, leading to unavoidable impacts and SOCs
Consequences of Current Practice
• Promote GHG reduction
• Promote multimodal transportation networks
• Promote diversity of land uses
• Eliminate auto delay/LOS as significance criteria
Mobility
Accessibility
What SB 743 Proposes to Do
Understanding the thresholds:
• Significant if greater VMT than regional average for land use type
• Or increase in VMT compared to existing
• How much discretion will lead agencies have?
Development Project VMT
Regional average for similar land use types
Proposed Section 15064.3 (b)(1) - Development Project VMT
VMT by Land
Use Type How should it be calculated?
Residential VMT What’s acceptable?
Source: SACOG
Understanding the thresholds:
• Not significant if within ½ mile of existing major transit stop or along existing high quality transit corridor
• How much discretion will lead agencies have?
Proposed Section 15064.3 (b)(1) - Development Project Location
Understanding the thresholds:
• Not significant if consistent with SCS
• Or equivalent reduction in VMT
Proposed Section 15064.3 (b)(1) - Land Use Plan/SCS Consistency
Understanding the thresholds:
• Significant if increased roadway capacity induces additional travel
Proposed Section 15064.3 (b)(2) – Transportation Projects Induced Travel
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General Purpose lanes vs. Managed or Auxiliary lanes
Proposed Section 15064.3 (b)(3) - Local Safety
Copyright: <aref='http://www.123rf.com/profile_leaf'>leaf / 123RF Stock Photo</a>
Understanding the thresholds:
• Consider localized effect on safety
Timeline for Adoption & Interim Actions
• When will the guidelines be finalized?
• When do jurisdictions need to adopt their own criteria for VMT & safety?
• Why it is important to address VMT in CEQA documents ahead of adoption?
Actions During Interim – Project VMT
• Prepare VMT estimate: Use a spreadsheet/sketch model;
Estimate average trip length using travel demand model;
Or estimate average trip length using CHTS/cell phone/GPS data
• Compare average trip lengths to regional average
• Compare VMT per capita to existing
• Require trip reduction as mitigation
Actions During Interim – Plan
Consistency
• Review General Plan assumptions for land use growth & circulation
• Review growth
assumptions in MPO model as a means to assess SCS consistency
Actions During Interim –Safety
• Key questions to answer:
Are there any collision “hotspots” around the project
Will the project aggravate an existing safety issue?
Will the project create a new safety issue?
• Driveway locations
• Conflicts with pedestrians or cyclists
• Design standards
‘Sketch’ Model VMT Methods
Source: Calthorpe
UrbanFootprint – VMT Module
VMT = Volume x Distance
Boundary VMT Method
• Traffic count based estimate (speed not a factor)
• Estimate depends on traffic count coverage and quality
• Only captures VMT on jurisdiction’s roadways
• Citrus Heights = 1,000,110 daily VMT (weekday)
Travel Model VMT Method • Traffic volume and
speed based estimate
• Volumes derived from trips generated by land uses or activities
• Estimate depends on model form, limits, and data quality
• Can capture VMT multiple ways
• Citrus Heights = 1,397,340 daily VMT (weekday)
VMT Validation UrbanFootprint
VMT Apples vs. VMT Oranges
Trip Length Estimates
Average Trip Length by Trip Purpose
HBO HBS HBW
CalEEMod 7.50 7.30 10.80
VMT Spreadsheet Model 7.22 7.22 12.54
MPO Travel Forecasting Model 7.26 7.26 5.87 Notes: HBO = Home-Based Other HBS = Home-Based Shopping HBW = Home-Based Work
VMT Threshold Example Yolo County General Plan
Comparison of Daily Vehicle Miles by
Land Use Pattern
2035 Daily VMT for Yolo County
New General Plan Policy: Add a VMT Threshold
Relationship of Freeway LOS, Speed, and CO2 Emissions Factors
With VMT, Speed Matters….
