Alternatives To Auto LOS For Impact Analysis 111505

Hiatt 5
Though auto LOS provides valuable information for planning purposes, it does not meet
the needs of urban multimodal areas when used as a legal standard to define the adequacy of
transportation facilities.
Reinforcing the Incumbent Mode
Strict standards for auto LOS can make infill development and improvements to modes other
than the auto difficult, particularly on mature street networks where roadway space is
constrained. San Francisco’s next generation of transportation improvements to transit,
pedestrian, and bicycle facilities will require reallocating roadway space from mixed traffic uses
to pedestrian, bicycle, or transit use, sometimes worsening auto LOS (14). Consequently, using
auto LOS as the standard for roadway adequacy ostensibly favors preserving auto LOS at the
expense of improvements to transit, bicycle, and pedestrian conditions.
Discouraging Multimodal Improvements
In San Francisco, a proposed project with impacts forecast to worsen LOS to grade “E” or “F”
must typically either: 1) mitigate the impact by reducing auto delay; 2) modify the project to
reduce auto delay; or 3) the project is denied approval. Although projects with unmitigatible
significant negative impacts may nevertheless be approved by elected officials through a
declaration of overriding considerations, the project sponsor must complete the costly and
unpredictable impact assessment process. Project sponsors may therefore be reluctant to
propose projects that potentially impact auto LOS.
Avoiding “Difficult” Multimodal Projects
In practice, proposed bicycle or transit lanes that would remove a lane of auto traffic are
considered to have significant negative environmental effects since removing a lane of auto
traffic often worsens auto LOS. Moreover, it is often difficult to identify mitigations that restore
auto LOS while preserving the spirit of the project to improve conditions for transit, bicycling, or
walking.
The City of San Francisco has attempted to minimize the burden of environmental review
process within the constraints of current LOS standards. These strategies include implementing
bicycle projects as “trials” before undertaking the environmental process and earning final
project approval. This is only feasible when the project in question is “reversible” in the event
that auto LOS impacts are unacceptable (e.g., projects which involve primarily re-striping).
Because San Francisco has a mature road network and finite public rights-of-way, it is
easy to assume a priori that many bicycle, pedestrian, and transit improvements cannot be
implemented without significantly impacting auto LOS. But, an increasing body of research
shows that when vehicle capacity is reduced, trip patterns have adjust in terms of absolute
vehicle trips or the time and route of trips. This is especially so when alternative modes and
routes are available. However, it is easy to suspect that projects don’t move beyond the
conceptual phase because from the project sponsor perspective, lane removal functions as a “de
facto” rejection criterion because removal of a traffic lane usually decreases auto LOS.
Auto-Oriented Mitigation Measures
Maintaining LOS affects local transportation investments. CEQA and other growth management
rules allow for project sponsors to make project changes that “mitigate” the impacts of the
project on LOS. The proposed project may then be approved if it is timed to occur with
mitigations that would preserve LOS at adopted standards (8).