SB 743 - Replace "Level of Service" (LOS), the measure of automobile delay,
with “Vehicle Miles Traveled” (VMT).
VMT is a simpler less accurate and more general measure of Traffic
Congestion. Projects can no longer be challenged on the basis of the
LOS Traffic Congestion the project would generate.
Touted as an anti-sprawl policy, this change is really an aggressive
pro-development maneuver that
sacrifices quality of life to the dystopian fantasies of “Smart Growth".
Unfortunately, for now, the defenders of neighborhood livability have lost
this battle. The switch is mandated by
SB
743, which was passed by the
California legislature in September 2013. The
Governor’s Office of Planning and Research, has said that the new rules won’t be
finalized until they’re certified by the
California Natural Resources Agency by the
end of 2016.
The smart growthers’ larger argument against LOS
is that speeding up car traffic is likely to increase
greenhouse gas emissions. By contrast, they contend, limiting the
distances people drive—and judging proposed developments by the amount of
driving they’re likely to induce—addresses air quality and
climate change.
Moreover, the traffic congestion standard puts infill projects at a
disadvantage. By its very nature, infill is a
latecomer to a place. In an already congested area, the traffic generated by a
new infill project can easily tip the
LOS into E or F territory, rendering the
development vulnerable to a challenge from opponents on
CEQA grounds. VMT, by contrast, is
hospitable to infill, because infill increases density
and mixes uses (housing, shops, offices), making it easier for people to do what
they need to do without a car.
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In a new 300-unit development in
SF it is stated that a relatively small number
of cars would be added as a result of this project, they would be in an area
with highly congested intersections. Under previous guidelines, this could
lead to a conclusion that the project might add to
traffic congestion and require several years and millions of dollars
spent [by the developer] to prepare an environmental
impact report (EIR). If the same development were assessed on the
basis of the amount and distance of automobile it would generate,
VMT, no EIR would
be required.
What leads them to assume that people living in a new 300-unit
development would add only “a relatively small number of cars” to the
neighborhood stock. The reply was vague:
"Data shows that a much higher proportion of trips in
San Francisco occur by means other than the
single occupant vehicle. In a location such as SoMa,
where there is already a high volume of traffic (much of it going through
the area, not originating or ending there), a single building will not
substantially add to overall traffic levels."
But surely the size and type of a single building makes a big difference
in how much traffic the building generates? The city has no prediction of
the auto use generated by the project. |
Transit priority area:
“an area within one-half mile of a major transit stop.” Almost all of
San Francisco is covered by transit priority
areas:
If even a “relatively small number of additional cars” makes a highly
congested area even more congested, shouldn’t that count as an environmental
impact?
It should not, say planners and the
state. According to them, traffic congestion is a
social impact, not an
environmental one.
Governor's Office of Planning and
Research (OPR): " [the
California Environmental Quality Act]
analysis. (CEQA Guidelines §15131.)
….As a measurement of delay,
LOS measures motorist
convenience, but not a physical impact to the
environment. "
Urban locales will be degraded by the replacement
of LOS by VMT. “Placemaking”
is the name of
the community newsletter that the SF
Planning Department.
During OPR’s
webinar on the implementation of
SB
743, staffer Chris
Ganson said, “LOS just addresses localized congestion,”
but “worsens regional congestion.” VMT, Ganson opined, “attacks
regional congestion more effectively,” but—he did not add—worsens local congestion.
Local congestion is something that everyone will experience more intensely
as a result of
SB
743. Making local traffic congestion
worse by disregarding the local traffic impacts of
infill development.
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Nowhere in SB743 is there any mention of
Fuel Efficiency increase, Electric Cars and the
capacity for electric cars to power the grid.
Concerns about the maximum
population a place can support—do not arise in the
smart growth world.
Land use forecasts are prepared by ABAG
(and adjusted by SF Planning).
The land use scenario we currently use is the
Sustainable Communities Strategy: Jobs-Housing
Connections from Plan Bay Area.
SF Planning Commission Staff
said that "it would be the rare project that
exceeded the VMT thresholds of significance". |
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Even more distressing, the
abandonment of traffic congestion as an
environmental impact is only one of the ways in which actual places are
written off by the changes to the
California Environmental Quality Act
that are mandated by
SB
743. Unmentioned by the staff report,
the law also stipulates that
"aesthetic and parking impacts of a
residential, mixed-use residential, or employment center project on an
infill site within a transit priority area
shall not be considered significant impacts on the environment. Public
Resources Code 21099(d)(1)"
state legislation (AB 1886) will
expand CEQA exemptions to include projects where 50% of the project area
is
farther than a half-mile from a high quality transit corridor or major
transit stop. Currently only 25% of a project area can be over a half-mile
away. |
Plan Bay Area, the regional
land use and transportation “blueprint” mandated by
SB
743’s antecedent,
SB 375, also authored by
Steinberg, foresees a 34% increase (190,780) in
jobs in San
Francisco, from 568,720 in 2010 to 759,500 in
2040. It also foresees a 35% jump (284,490)
in the city’s population, from 805,240 to
1,089,730.
These numbers should be subject to public vetting. The people of
San Francisco have never been asked if it would
be a good thing if 190,780 more people worked in the
city, or if 284,490 more people lived here.
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Who’s responsible for this debacle?
The
legislators who voted for it
Senate: Beall, Berryhill, Block,
Calderon, Cannella, Corbett, Correa, De León, DeSaulnier, Emmerson, Fuller,
Gaines, Galgiani, Hernandez, Hill, Huff, Jackson, Knight, Lara, Liu, Monning,
Nielsen, Padilla, Roth, Steinberg, Torres, Vidak, Walters, Wolk, Wright,
Wyland, Yee. ABSTAINING: Hueso, Pavley
Assembly: Achadjian, Alejo, Allen,
Atkins, Bigelow, Bocanegra, Bonilla, Bonta, Bradford, Brown, Buchanan, Ian
Calderon, Campos, Chau, Conway, Cooley, Dahle, Daly, Dickinson, Eggman, Fong,
Fox, Frazier, Beth Gaines, Gatto, Gordon, Gorell, Gray, Hagman, Hall, Roger
Hernández, Holden, Jones, Jones-Sawyer, Linder, Logue, Lowenthal, Maienschein,
Medina, Mitchell, Mullin, Muratsuchi, Olsen, Pan, Perea, V. Manuel Pérez,
Quirk, Quirk-Silva, Rendon, Salas, Ting, Wagner, Weber, Wieckowski, Wilk, John
A. Pérez.
ABSTAINING:- Bloom, Chesbro, Garcia,
Gomez, Nazarian, Skinner, Yamada
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Thankyou to the NO
VOTERS: Senate:- Anderson, Evans,
Hancock, Leno, Lieu. Assembly:-
Ammiano, Chávez, Donnelly, Gonzalez, Grove, Harkey, Levine, Mansoor,
Melendez, Morrell, Nestande, Patterson, Stone, Waldron, Williams |
source Berkeley Daily Planet
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