Driving a stake through LOS

The Governor’s Office of Planning and Research has completed the first step in replacing level of service (LOS) with vehicle miles traveled (VMT) as the primary measurement for determining the CEQA impact of development on roadways by drafting the replacement language. This process was specified in In the second step, the Natural Resources Agency is holding a public process to implement the changes, and you can participate. Two meetings have been scheduled:

Date: March 15, 2018
Time: 1:30-4:30pm
Location: California Energy Commission, Rosenfeld Hearing Room
1516 9th Street, Sacramento, CA 95814

Los Angeles
Date: March 14, 2018
Time: 1:30-4:30pm
Location: California Science Center, Annenberg Building, Muses Room
700 Exposition Park Dr, Los Angeles, CA 90037

You can also comment by email at CEQA.Guidelines@resources.ca.gov.

I hope that you will support the changes either in person or by email. The use of LOS has caused incalculable damage to roadways and to livability throughout California. CEQA, originally intended to protect the environment, as been used instead as a weapon to harm the environment and encourage sprawl. Urban infill could rarely meet the requirements of LOS in CEQA, but suburban development almost always could, so what we got is square miles of suburban and exurban sprawl, and very little infill. This change to VMT will at least level the playing field, and may make sprawl more difficult. I don’t know how much opposition there will be, but there are several interests that would like thing to stay just the way they are: engineers who want to build highways instead of transportation systems, greenfield developers who make huge profits while shifting costs to society, and cities and counties (you, Sacramento county, and others) who want to preserve their ability to encourage and subsidize far-flung development. If you like cities, if you like livability, if you like infill, this is one of the most important things that can happen.

Of course, this is only the second step in driving a stake through the heart of LOS. The third step is to ensure that all cities, counties, and regional agencies remove LOS as a tool in planning development and transportation. The legislation and these regulations will prevent exclusive use of LOS by any entity, but it does not preclude use of LOS as a additional criteria. LOS must be eliminated completely. The most important question in transportation and development is what kind of world we want to live in, and though VMT is only a tool for achieving that, it is far far better than the tools we currently use.

For all the details of the Natural Resources Agency process and regulation, see the CEQA page and the notice of rulemaking.

Leave a Reply

Fill in your details below or click an icon to log in:

WordPress.com Logo

You are commenting using your WordPress.com account. Log Out /  Change )

Facebook photo

You are commenting using your Facebook account. Log Out /  Change )

Connecting to %s