Are the days of "levels of service" as a performance measure under the California Environmental Quality Act numbered?

Following up on the passage of SB 743, the Governor's Office of Planning & Research is considering a variety of alternatives to vehicle "level of service" under CEQA, including vehicle miles traveled, auto trips generated, and multi-modal level of service. OPR plans to deliver final draft CEQA guideline revisions to the Natural Resources Agency by July 1.

In a preliminary paper released last week, OPR declared unequivocally that SB 743 "marks a shift away from auto delay as a measure of environmental impact". Most specifically, OPR has proposed the following possible metrics:

1. Vehicle Miles Traveled (VMT), which OPR suggests "captures the environmental benefits of transit and active mode trips" and is easy to calculate

2. Automobile Trips Generated (ATG), already in use in San Francisco, which OPR suggests has many benefits but does not address the region of regional location of development projects.

3. Multi-Modal Level of Service (MMLOS), an spin on auto LOS, which creats an A through F grade for every intersection and roadway segment for every mode of travel. OPR notes that MMLOS could increase the cost of infill development by burdeningch projects with additional bike/ped facility costs.

4. Total fuel use, which OPR suggests would encourage infill development although it could sometimes add auto travel if road expansions and operations improvements (sometimes required to reduce idling or slow traffic) are used as mitigations.

5. Motor vehicle miles traveled, which OPR suggests could harm alternative modes by increasing vehicle speeds, thus making roadways less safe.

6. "Presumption of less than significant transportation impact based on location" – in other words, adopting the idea that infill development in transit-rich locations will affect the regional transportation network so differently than greenfield development that a "less than significant" impact can be assumed.

The law dictates that OPR develop new transportation metrics to accomplish three goals:

* Promote greenhouse gas emissions reduction

* Develop multimodal transportation networks

* Promote a diversity of land uses

In the preliminary evaluation released last week, OPR announced that it would consider a number of other factors as well, including:

* Maximizing environmental benefit and minimizing environmental harm

* Efficient use of local government fiscal resources

* Equity, meaning, among other things, equitable distribution of public facilities

* Health, especially the health benefits associated with "active transportation" (biking and walking)

* Simplicity

* Consistency with a wide variety of other state policies, including the AB 857 priorities (infill development, compact greenfield development, and protection of open space)

* Access to destinations – in other words, recognizing that the goal of transportation is to provide people with access to the things they need, rather than simply moving either people or vehicles.

The OPR document can be found here:

Comments may be submitted to, using the subject line "LOS Alternatives". Staff lead at OPR is Senior Counsel Chris Calfee.