Posts Tagged ‘EIR’

VMT And EIR Reform

There is widespread agreement that automobile LOS is a bad metric for determining the environmental impact of projects. But what should replace it?

The California Office of Planning and Research (OPR) proposes to replace LOS with VMT for the EIR process. That is a step in the right direction, but I am not optimistic it will make transit projects “much much easier” to implement — as some seem to think.

One problem is that LOS is firmly established in transportation agencies. They will continue to use the metric, regardless of what is required in an EIR. It is unlikely that a transit agency, or bike planner, will get to build a project if it were to significantly degrade LOS at an intersection. A City Council is even less likely to approve of such a project. LOS will continue to be a flaming-hoop-of-fire that projects will have to jump through.

Yes, but what about all those frivolous EIR lawsuits? Actually, that problem is greatly exaggerated. Only a tiny number of EIR’s are successfully challenged. The most famous example, the injunction against the San Francisco Bike Plan, will probably never happen again now that California has exempted bike projects from EIR’s.

So using VMT is fixing something that isn’t horribly broken — though it might make it worse. Why might VMT make EIR’s worse? Because sweeping changes in the regulations could provide fertile ground for creative lawsuits. LOS has decades of case precedent, whereas the courts may have to re-define terms like mitigations and significant impacts in a new VMT regime.


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Grade Inflation

LOS (Level of Service) is one of the most misunderstood metrics of traffic analysis.

The term is familiar to anyone who has read an EIR. LOS assigns a “grade” for intersection performance. The grades run from “A” to “F”, with “A” being most free-flowing, and “F” having the most delay.

The first misunderstanding  is that LOS measures vehicles, not people. So a delay to a bus with 40 passengers counts the same as an SOV. Most environmentalists are aware of this issue, and some localities try to compensate for this.

The second misunderstanding is that LOS only measures delay during the “peak-of-the-peak” (usually just the busiest 15 minutes of the day). Many people will see a bad grade and not understand that it only applies to a small portion of the day.

But the really big misunderstanding is that LOS “A” is not the best grade. LOS “A” means the road is overbuilt. In other words, taxpayers wasted money on the roadway. The best grade is actually around “C”. Intersections with LOS “C” still perform pretty darn well during peak hours, and very well the rest of the day.


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