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How three little letters can make such a big difference: LOS, meet VMT.

Amanda Eaken

Posted September 2, 2014

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If you prefer listening, or want to learn more, check out this Urban Solutions podcast. Jeff Tumlin of Nelson Nygaard, Chris Ganson of the Governor’s Office of Planning and Research and I connect the dots between California’s climate change laws AB32, SB375, and the possibility that one fix could change transportation and land use planning around the country.

I think it’s important to remember—as we slap each other on the back about this year’s legislative victories—that getting a bill passed is just the beginning of making change happen. Fortunately, we have some great progress to report on one of the bills that made it through in the waning hours of last year’s legislative session—a bill that could fundamentally change the way we think about development and traffic in California.

As I’ve written in the past, the crux of this issue comes down to three little letters: L.O.S.  It stands for Level of Service, which is essentially just a measure of how much a project will slow down cars, and it’s the way the California Environmental Quality Act (CEQA) has evaluated new projects for decades. Until now.

Last year the Legislature—in their infinite wisdom—decided that in fact, in California in the year 2014, transportation is about a whole lot more than moving cars quickly. In fact we have much more important goals, and volumes have been written about the deep flaws of the LOS paradigm: it makes road widening look good for the environment, discourages infill, encourages traffic engineers to remove pedestrian crosswalks and slows transit projects. Through Senate Bill 743, they directed the Governor’s Office of Planning and Research (OPR) to kick Level of Service (LOS) to the curb, and find a replacement that can better help reduce greenhouse gas emissions and create transportation choices.

So here’s the good news: they’ve done it. OPR has just released their draft guidelines recommending Vehicle Miles Traveled (VMT) as the much more appropriate metric. Let’s think about this for a second. Under the old system, a proposed bike lane had to analyze its transportation impacts and if it was found to slow down cars (by, say substituting a bike lane for a car lane) then our environmental statute would have said let’s either not build this project, or pay a lot of money to find some other way to speed up cars. Pretty backwards, eh? Considering the whole point of bike lanes is to encourage one of the cleanest, healthiest and most sustainable ways of getting around we know. Now, instead, the same project would be asked a simple question: will this project result in any more vehicle miles of travel? Even a four year old can figure this one out. NO! Abundantly clear that the answer is no. So these bike projects—not to mention transit projects, safe pedestrian crosswalks, and other livable communities projects—will get built faster, cheaper, with less headache. We all win.

We love OPR’s proposed new metric because it just makes sense. It’s worth pointing out that California is the first state in the nation to try to tackle the insidious LOS problem and OPR should be praised for setting the precedent. Comments are due October 10th, and we feel that certain elements of their draft guidelines need revision—such as the proposed threshold and which types of projects are presumed to be less than significant—and we will blog again with more information on these details.

But we can’t forget the bigger picture: we and a whole host of other livable, sustainable communities advocates have wanted to see the end of LOS for decades, and we say it’s about time. RIP LOS.


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H. E. Christian (Chris) PeeplesSep 3 2014 07:41 PM


Good idea, but needs to include the needs of bus transit. Most poor people in California travel on buses. This and other "complete streets" treatments treat buses as if they are just another car. Without some substitute for LOS there is no way for us to evaluate the impact of a project on our bus service and advocate for mitigations for those negative impacts. There is a "complete streets" proposal in Oakland that may slow one of out major lines to 3 1/2 mph.

-- Chris Peeples --

H. E. Christian (Chris) Peeples
At-Large Director
Alameda-Contra Costa Transit District
1600 Franklin Street, 10th Floor
Oakland, California 94612-2800

Jeff WoodSep 3 2014 08:27 PM

I see what you're saying. Basically a complete streets project that slows down the flow of an intersection is hurting the speed of buses which are already hampered by multiple stops along the route.

What then do you think is a good way to address this issue? I think LOS is doing a lot more harm than good and while it might help figure out the mitigation for some bus projects, it's also widening roads and making developers thing twice about adding a few extra units that might push them over the threshold towards having to do some major mitigations.

Leo H.Sep 4 2014 07:33 AM


Bus improvement projects will get a nice boost for their effects to lower VMT—both by reducing the space dedicated to cars as well as improving punctuality and speed.

SMSep 4 2014 01:31 PM

Even if you are not evaluating LOS, you can still evaluate potential transit delay, which does take into account, among other factors, the vehicle delay along a corridor.

Tilly ChangSep 6 2014 03:11 PM

Replacing LOS with VMT makes sense for environmental impact assessment purposes, but it doesn't mean LOS is not still a valid and useful measure for planning purposes. We still need to use it to size our facilities and analyze impacts to different road users, esp. transit.

Roberto EroomSep 8 2014 08:27 PM

Here in Sydney, Australia, we have Bus Only lanes, sometimes 24 hr or sometimes only peak hours. That solves the LOS for buses.

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