It's always been a mystery to me why traffic modeling – and traffic mitigation – is such a big part of analysis done under the California Environmental Quality Act. After all, traffic in and of itself is not an environmental impact, any more than building a building is an environmental impact. Traffic may cause certain environmental impacts – air pollution, for example, depending on the fuels used – but there's nothing inherently damaging environmentally about traffic. Nevertheless, CEQA traffic analysis has always focused on identifying and alleviating traffic congestion. After careful environmental review, cities and counties have concluded – many thousands of times – that the solution to the environmental problem created by traffic is to build wider roads in order to accommodate more traffic.
Those days may be waning, however. As panelists at the APA California conference in Squaw Valley pointed out today, new policies in many jurisdictions are bringing the "Level of Service" approach to both CEQA analysis and general plans to an end. Even within the confines of CEQA, these jurisdictions are finding ways to place other priorities ahead of – or at least alongside of – alleviation of traffic congestion. "In the future, we're going to have fewer public resources for transportation," said Ron Milam of Fehr & Peers, "And we're going to have more objectives for our transportation system."
In particular, the panelists said, alleviating traffic congestion doesn't always jibe with the goal of reducing greenhouse gas emissions – which is suddenly a major goal of state policy and an important consideration in CEQA. And as Paul Shigley reported in these pages not long ago, proposed changes to the CEQA Guidelines may discourage the use of the LOS approach.
The APA panel presented cutting-edge techniques from both San Jose and San Francisco. Though the approaches are different, they show how local governments can end-run the LOS approach.
In San Francisco, the city came to the conclusion that using LOS was in conflict with its "Transit First" strategy and simply didn't measure the most important environmental impacts of driving – which, in San Francisco's case, is particulates. "We have to reallocate our limited right of way to other things," said Rachel Hiatt of the San Francisco County Transportation Agency. "We will degrade auto LOS in the short term as we implement our 'Transit First' policy."
In San Jose, the city took a different approach. Planners identified three job centers where transit is likely to be the primary transportation investment in the future, including downtown, North San Jose, and Edenvale. Downtown was exempted from the LOS standard. In North San Jose and Edenvale, a master environmental impact report was completed that contained an override option for not hitting the LOS standard at 23 "protected intersections". The rest of the city still uses an LOS standard, partly in deference to suburban-style neighborhoods and surrounding communities. "The City Council amended the general plan to be more flexible in places where we wanted to do smart growth," said planner Hans Larsen.
Milam from Fehr & Peers also showed how an alternative approach can be used on a specific project, though probably not in all locations. As an example, he pointed to an intersection analysis his firm did which concluded, initially, that the intersection in question had to be greatly widened. Upon further examination, however, the firm and the city concluded that the problem was not cars. Rather, the slow-downs were created by the need to accommodate the large amount of pedestrian and bicycle traffic at the intersection. So a ped/bike overpass preserved the intersection in its current configuration.
Not everybody can be Davis or San Francisco or maybe even San Jose. But everybody can think about what they're really trying to achieve with their traffic standards – and ditch the LOS if it's appropriate.
– Bill Fulton
