City of Sac blind adherence to ADT

Another post on the Freeport Blvd Transportation Plan. See the category Freeport Blvd for other posts.

“We are designing for the traffic we have, not for the traffic we want.”

Ali Doerr Westbrook, Chair of Sacramento Active Transportation Commission

I could stop at that, but perhaps you’d like some more detail. This comment was made during the Sacramento Active Transportation Commission (SacATC) meeting on January 18, 2023. The context was the admission by the two city planners, Leslie Mancebo and Jennifer Donlon Wyant, that the city eliminated the possibility of a road diet (roadway reallocation) before even starting planning for Freeport Blvd. The reason expressed is that the ADT (Average Daily Traffic count) is above 20,000 for Freeport, and that requires more than two lanes (one each direction). Interestingly, ADT counts for various locations along Freeport are nowhere to be found in the plan or appendices. In a different location on the City of Sacramento website, Traffic Counts, the ADT for various locations along Freeport Blvd, rarely exceed 20,000, and have not exceeded 20,000 since 2011. There is no indication that the city even did new traffic counts in preparation for this planning effort. So far as can be determined, they just decided to not consider a road diet from four lanes to two lanes, or two+one lanes, 3/2 configuration) because they wanted to prioritize motor vehicle traffic over all other uses of the roadway.

The city planners also acknowledged that a road diet was a prominent request of the community during the planning process. But, community input be damned, the city is going to serve car drivers before anyone else.

A reduction of lanes from four to two is the single most important traffic calming effort that can be made on a roadway. That does not mean it is the appropriate solution for Freeport Blvd, or for all of Freeport Blvd in the planning area. What is does mean is the that city should have considered it in the planning process.

Back to Ali’s comment. The city is planning for a roadway configuration that should have already been in place years ago, before the city over-widened the roadway, and in several cases narrowed sidewalks to accommodate the widening. They are not planning for a roadway which would reduce vehicle miles traveled (VMT) or increase safety and access for those outside cars. The city’s responsibility, under the Mayors Commission on Climate Change report, is to reduce VMT in order to reduce greenhouse gas emissions (GHG), not to maintain VMT at current levels. But this Freeport plan is a plan to guarantee current VMT for at least 30 years in the future, which is about the length of time before the city will be able to reconstruct the roadway again, and correct the mistakes they made this time around.

The intent of the city in this plan is made very clear in the common design principles: “10. Maintained necessary travel lanes, turn lanes, and parking: Maintaining travel lanes and turn lanes ensures that drivers traveling along the corridor will not be compromised, and preserving parking spaces where 5 the utilization is higher so it serves better adjoining businesses.” Though this is the last item in the list of ten, it is clear that this is the highest priority for the city.

The refusal to consider a road diet/lane reduction/roadway reallocation is a fatal flaw in this plan. The effort should be sent back to staff to re-do. It should not be adopted by city council. If the city council does not reject this kind of flawed planning, city staff will continue to make the same mistake, again and again and again.

I’ll post on some of the other flaws in the plan, but this is the most important, not just because it misses the best opportunity for traffic calming, but because it retains roadway width for the exclusive use of motor vehicles that could be better used for walking, bicycling, trees, and even parking for businesses.

Added graphic below, which I had not noticed in the plan, that documents vehicular counts on sections of Freeport Blvd. Is it suspicious that half of the plan area is ‘just’ over the city’s criteria of 20,000 ADT? Remember, the plan itself and the city’s traffic counts website do not indicate this level of ADT.

Measure 2022: Southeast Connector exceptionalism

A group calling themselves A Committee for a Better Sacramento is sponsoring a citizen-initiated ballot measure for the November election, titled “Sacramento County Transportation Maintenance, Safety, and Congestion Relief Act of 2022—Retail Transactions and Use Tax”. (Note: Some people are referring to this as Measure A, but measure letters are assigned by county elections, not by the sponsors. I’ll continue to refer to it as Measure 2022, for now.)

One of the major projects in the measure is the Capital Southeast Connector, a new freeway from Folsom to Elk Grove. Future posts will talk about what a bad transportation idea this is, but for now, what a bad part of the measure it is.

The measure essentially makes the Capital Southeast Connector JPA the judge of whether the project meets air quality requirements – the fox watching the henhouse. It is somewhat obscure what the language means, and takes a close reading, but the gist is that if the project fails to meet air quality requirements and therefore is not included on the project list in the MTP (SACOG Metropolitan Transportation Plan), the JPA can go its own way and decide for itself that the project meets requirements.

K. Metropolitan Transportation Plan & GHG Reduction Targets. The Sacramento region Metropolitan Transportation Plan/Sustainable Communities Strategy (MTP) currently requires that the region meet a 19% per capita greenhouse gas (GHG) reduction target. Expenditure Plan projects that are planned or programmed for construction in an MTP, as may be amended from time to time, shall be eligible for Measure funds. Expenditure Plan projects not planned or programmed for construction in an MTP shall be eligible for Measure funds if the construction phase of the project is exempt from project-level and regional level air quality conformity.

For any non-exempt projects that are not planned or programmed for construction in an MTP, as may be amended from time to time, the following requirements will apply:

For any non-exempt projects that are not planned or programmed for construction in an MTP, as may be amended from time to time, the following requirements will apply:

1. In order to meet the then applicable regional GHG reduction target for the MTP, project sponsors (parties) shall develop mitigation measures for any project(s) that increases GHG emissions.

2. If the parties can mitigate any such project impacts to maintain adherence to the then applicable regional GHG reduction target, the project(s) shall be eligible for Measure funds.

3. If the GHG impacts are not mitigated to meet the region’s then applicable GHG reduction target, and as a result the region cannot meet its applicable GHG target, the funds planned for the non-exempt project(s) may be used by the corresponding Implementing Agency at their discretion, for other than the originally intended project(s), provided any alternative project(s) are consistent with the Expenditure Plan and included in an MTP, as may be amended from time to time, that meets the then applicable target. Per above, alternative project(s) not planned or programmed for construction in an MTP shall be eligible for Measure funds if the construction phase of the project(s) is exempt from project-level and regional-level air quality conformity.

Measure 2022, Exhibit A, Chapter 1, Section K

This treatment of the JPA might very likely be found to be unconstitutional, but the measure proponents have thought of that too:

If any portion of this Measure is held by a court of competent jurisdiction to be invalid, we the People of the Sacramento Transportation Authority indicate our strong desire that: (i) the Authority use its best efforts to sustain and re-enact that portion, and (ii) the Authority implement this Measure by taking all steps possible to cure any inadequacies or deficiencies identified by the court in a manner consistent with the express and implied intent of this Measure, including, to the extent permitted by law, adopting or reenacting any such portion in a manner consistent with this Measure.

Section XII, Paragraph B, of the potential measure

In other words, if we, the sponsors included something illegal or unconstitutional in this measure, we expect the Sacramento Transportation Authority to defend the measure and make sure it all gets implemented.

To mitigate the immense GHG/VMT (greenhouse gas emissions / vehicle miles traveled) generated by the Connector, the measure proposes Transit and Rail Congestion Improvement Projects. With somewhat less money allocated to this than the Connector, these expenditures might make up for the harm of the Connector, but would not address any other needs in the county. It also proposes BRT features for the Connector, which is ridiculous as this is the last place in the county that a transit agency would propose BRT.

If the Connector, as a whole or in the piecemeal projects by which is has already been partially constructed, causes the region to not meet its legally required greenhouse gas reduction target of 19%, the entire region would therefore be under non-compliance, and therefore ineligible for federal grants.

The proponents see the value of the Connector as enabling greenfield development in the southeast area of the county. Though touted as a solution to congestion on Hwy 50 and Hwy 99, it will not be. What it will do is encourage long distance commuting between El Dorado County and Elk Grove, and generate VMT trips due to the greenfield developments along the corridor. The Connector will not turn out to be a boon to Folsom, Rancho Cordova, and Elk Grove, but yet another congested highway, sucking value away from the cities and citizens.

Search for category Measure 2022 to see posts as they are added.

CEQA hearing

This is a follow-on to my Wednesday post on the CEQA Guidelines update/reform: CEQA VMT reform has a fatal flaw.

Four organizations spoke at the hearing:

  • Climate Resolve (Ella): spoke against exemption, spoke about equity and displacement, mentioned request to Caltrans to use VMT instead of LOS
  • City of San Jose: spoke against transportation exemption, apparently submitted letter signed by other cities but I didn’t catch which ones; San Jose recently adopted VMT as their measure for transportation and development (Streetsblog Cal: San Jose Becomes Fourth California City to Adopt VMT as Metric for Traffic Impacts)
  • Coalition for Clean Air: spoke to reducing VMT as the best path to reducing emissions
  • California Bicycle Coalition (Linda): spoke about equity and displacement issues, on need to monitor and determine consistency, spoke against exemption

And I spoke, the sole citizen speaker:

  • I reject the language in 15064.3, Subdivision (b)(2), which exempts transportation from any requirement to use VMT rather than LOS.
  • Overall, the changes will affect development in a positive way, encouraging infill and discouraging greenfield development, however, transportation drives greenfield development drives rather than greenfield development driving transportation, so the overall benefit will be much lessened by the transportation exemption.
  • Transportation is the largest single contributor to greenhouse gas emissions in California (about 39%), but this language does little to address transportation
  • The draft guidelines specifically say “this provision does not prohibit capacity expansion.” But capacity expansion is the largest single contributor to exist and future emissions. This is exactly the issue that most needs to be solved
  • In the Sacramento region, nearly every county and city will continue to use LOS rather than VMT, with the possible exception of Sacramento city and Davis. Even the discussion of a possible change had most transportation ‘professionals’ and politicians up in arms.
  • Though it did not talk about it, the draft clearly contravenes the intent of the legislature in SB 743, which was to kill LOS.

I hope that there is enough opposition on the transportation issue that the agencies will come back with a better proposal, but if not, the legislature will have to come back to the issue again. If this exemption stands, the state cannot possibly meet its greenhouse gas reduction targets.

CEQA VMT reform has a fatal flaw

If you are not otherwise occupied on Thursday afternoon, you may want to attend the California Natural Resources Agency hearing on CEQA reform. The hearing is Thursday, March 15, 1:30 to 4:30, at California Energy Commission, Rosenfeld Hearing Room, 1516 9th St, Sacramento, CA 95814. One of the great things about living in Sacramento is the opportunity to influence state policy and legislation in a way that people in other parts of the state cannot. We can be their proxies.

As a result of a multi-year planning process, the Office of Planning and Research (OPR) developed recommendations to improve CEQA to address some shortcomings, particularly that it has been used to stop good development, infill and mixed use, while encouraging greenfield development. The recommendations are now being passed along to the California Natural Resources Agency for adoption, since that is the agency that administers CEQA.

While there are great improvements contained in the proposal, there is what I consider to be a fatal flaw. From the OPR document (15064.3, Subdivision (b)(2): Transportation Projects): “Subdivision (b)(2) clarifies that projects that reduce VMT, such as pedestrian, bicycle and transit projects, should be presumed to have a less than significant impact. This subdivision further provides that lead agencies have discretion in which measure to use to evaluate roadway, including highway, capacity projects, provided that any such analysis is consistent with the requirements of CEQA and any other applicable requirements (e.g., local planning rules). Importantly, this provision does not prohibit capacity expansion.”

What this means is that transportation agencies can continue to use outmoded and harmful Level of Service (LOS) instead of using Vehicle Miles Traveled (VMT). To my mind, the main point of CEQA reform was to eliminate LOS, the insidious concept that has led to our unsustainable transportation system. It does so for land use, but does not do so for transportation projects. This is a fatal flaw.

A coalition of environmental and transportation advocacy organizations developed a letter to Resources that addresses the flaw, but seems to give up any hope of making it right, instead hoping that Caltrans will adopt VMT. They might, but I can assure you that many agencies never will unless forced to. Sacramento County, for one, lives in a 1970s mindset that congestion is the great evil that can be met only through roadway expansion, now and forever. [“Apply a VMT-based approach to all projects, including road capacity projects. We are sorely disappointed that the proposed Section 15064.3(b) exempts roadway capacity projects from using a VMT-based measure of transportation-related environmental impacts. With the proposed rulemaking, the State has determined that the best approach to measuring transportationn-related environment impacts is vehicle miles traveled; yet, at the same time, the State has exempted projects with arguably the greatest impact on the environment from using that metric. To close this loophole that threatens California’s environment and public health, we will be recommending that Caltrans commit to applying the VMT metric when they are the responsible agency.”]

If this exemption of transportation projects is not deleted, the exercise will be one of futility because transportation projects have such a huge impact on greenhouse gas emissions, both directly from vehicle emissions, and secondarily by encouraging sprawl which itself has a huge impact on emissions.

To be honest, it took me a while and help from several people to find this flaw, and there may be others I’ve missed, but I do still think that the remainder of the proposal is good.

OPR Current CEQA Guidelines Update page:

NRA CEQA page:

NRDC: California Gets It Right on Transportation—Almost

Streetsblog California: Update: Last Chance to Comment on Statewide Changes to CEQA

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

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.

transportation funding must be weight-based

The California legislature is meeting in special session to discuss sources of funding for transportation (they are on summer break, but will get back to it). The state uses the number $5.7B as the annual shortfall in funds available for maintenance, and these discussion are largely an effort to close that gap. Some of the solutions are: 1) indexing the gas tax so that it doesn’t fall behind (it was last raised in 1990); 2) increasing transportation related fees such as vehicle registration; 3) increasing the tax on specific fuels such as diesel; and 4) basing taxes on VMT (vehicle miles traveled) rather than fuel purchase. Of course there have been other ideas such as redirecting high-speed rail funds (which would be illegal unless legislation and the voter-passed bond are completely undone), and using cap-and-trade funds for highways (also illegal because maintenance and certainly construction would not reduce greenhouse gases), but those right-wing ideas won’t receive consideration by me.


I think it extremely important that all taxes and fees be at least partially based on the weight of the vehicle. The amount of damage caused to roadways and bridges is almost exactly proportional to the weight of the vehicle, and those that weigh more should pay more, at least for the maintenance portion of the transportation budget. If, for example, VMT were used instead of or in addition to fuel tax, one mile by a lightweight passenger vehicle is in no way proportional to one mile by a heavy truck. The tax should instead be a multiplier of VMT and weight, with a strong component of weight. And yes, all vehicles should be charged, including government-owned vehicles, which cause just as much damage to roadways as commercial vehicles. There has been a ballooning of vehicle sizes and weights with the government to match the commercial sector, and this is one way of bringing that under some control. Yes, I realize this means public buses would be paying weight fees, and I think this is appropriate since they do cause significant damage to the roadways. However, public transportation could be more than compensated as we save money on wasteful parts of our transportation system.

Vehicle registration fees are based on the type and price of a vehicle, which means that commercial vehicles are already paying relatively more than less expensive private vehicles, but they are not paying their fair share in relationship to damage caused to roads. It is not just an issue of commercial vehicles, however. Heavy passenger vehicles (you know what I’m talking about) also pay much less than their share of maintenance because the price differential is not as great as the weight differential.

Commercial vehicles do pay a weight fee, which is the sort of thing I’m requesting, but it is not assessed at a high enough level to pay for the damage caused, and at least for now these fees are being diverted to the general treasury rather than being used for maintenance.

Note that I am intentionally ignoring the finer points of sales tax, excise tax, and the arcane fuel tax swap. They are important, but not important to this issue of all users paying their way. It is important to remember that only a portion of transportation funds in the state flows through the federal and state government. Local governments are actually the larger and more significant players. As well, the idea that gas tax pays for roadways is myth, it pays less than half, and has never paid all.

A lot of information about funding, including the chart above, is in the Transportation Funding in California – 2014 document from Caltrans. If this document doesn’t make your head spin, I don’t know what will.

comments on Transportation Impacts Analysis

I’ve commented on the California Office of Planning and Research’s (OPR) Updating Transportation Impacts Analysis in the CEQA Guidelines: Preliminary Discussion Draft of Updates to the CEQA Guidelines Implementing Senate Bill 743 (Steinberg, 2013), below. OPR’s page is Developing Alternatives to Level of Service, which includes the downloadable discussion draft. Climate Plan has a good if too brief analysis at Support a stronger law to reduce greenhouse gases and fight climate change! If there are other good resources, please let me know.

The deadline for comments is this Friday, November 21!

  1. I completely agree with removal of level of service analysis and the statement “A project’s effect on automobile delay does not constitute a significant environmental impact.”
  2. I fully support subdivision (b)(1) use of VMT analysis.
  3. I fully support subdivision (b)(2) which states that “For example, projects that are primarily designed to improve safety or operations would not typically be expected to create significant impacts. The same is true of pedestrian, bicycle and transit projects, including those that require reallocation or removal of motor vehicle lanes.”
  4. I fully support Subdivision (b)(4) which states that “a lead agency would be expected to consider vehicle miles traveled that extend beyond the lead agency’s political boundaries.”
  5. Appendix E: Estimating VMT From Roadway Capacity Increasing Projects (of the discussion draft) is useful and has an appropriate level of detail for initial use, but detail and specificity may need to be increased in the future.
  6. The draft uses the terms “major transit stops” and “high quality transit corridors” without defining the terms. What frequency of service, hours of service, or ridership at that particular stop would define a “major transit stop?” What defines a “high quality transit corridor?” Rail? BRT? Regular bus service? Ridership?For example, bus service on 30 or 60 minutes headways, or running only during commute hours or only during the day time, certainly does not qualify as a “high quality transit service.” A bus service sign by the side of the road, without any associated facilities such as seating, shelter, transit signing, trash can, and perhaps bicycle racks, does not qualify as a “major transit stop.”

    Using the terms without more specific definition might encourage some agencies to claim exemption when it really doesn’t apply. As an example, some agencies have claimed that a development is “transit oriented development” when it is not oriented to transit at all but simply located in proximity to transit. I can imagine that some agencies would make similar claims about “major transit stops” and “high quality transit service.”

Fatality trends

The Sacramento Bee today had an article titled Fatal wrecks decline across Sacramento region. I was curious about where the data came from, and asked the author, Phillip Reese. He pointed me to the FARS (Fatality Analysis Reporting System) database. With reluctance, I finally dove in to this database which I’ve long been curious about but afraid of. It is quite hard to use, and it does not allow retrieval of multiple years at once. I compiled a data table of fatalities in the Sacramento region for the last ten years, and the table and graph are below. I used the SACOG region, which includes the six counties of El Dorado, Placer, Sacramento, Sutter, Yolo, and Yuba, so my numbers do not exactly match the four county region used by the Sacramento Bee for the map and 170 number.

The chart shows that there is in fact a downward trend in fatalities in the region, though it is not a consistent decline. Part of the reason 2011 looks good is that 2010 was bad.

Let me say, as I’ve said before, that fatality counts are a mis-measure of roadway safety. The best measure is the rate per vehicle mile traveled (VMT). Injuries are just as important as fatalities because they indicate trends in driver behavior, while fatalities reflect the internal safety of motor vehicles for occupants, and the effectiveness of the emergency medical system in responding to crashes. I will look more at the data, including looking specifically at pedestrians and bicyclists, and the rate for all modes. In meanwhile, here is the data and chart, to be taken with a grain of salt.

chart of traffic fatalities in Sacramento region
chart of traffic fatalities in Sacramento region