Davis, CA – During the Planning Commission meeting last Wednesday, Commissioner Greg Rowe indicated his skepticism of using VMT in order to justify project alternatives.
In fact, Rowe goes much further than that, arguing that the alternatives analysis seemed manipulated to meet specific VMT targets by increasing the project’s intensity, which he found unprecedented and nonsensical.
“I’ll be blunt, I think the city has corrupted the alternatives analysis,” Rowe said. I have real concerns about the veracity and the integrity of this alternatives analysis. For one thing, it seems like what was done when the city was giving guidance to you as the EIR consultant is they kept ratcheting up the number of units until they hit the VMT target they wanted and they finally hit 2,700 units and they said, bingo, we’ve got it. We now have met the regional and local VMT targets.”
He continued, “What it seems to me has [been] done is when you look at the staff report page five, it lists seven different impact areas that could have significant or unavoidable impacts, and we’ve sacrificed those factors on the alter of VMT and I think VMT has got a lot of problems with it.”
Catherine Brinkley expressed support for VMT as a metric, highlighting the benefits of density and how VMT can favorably capture those benefits.
“I agree with Commissioner Rowe that I don’t think that a viable and desirable alternative was presented, but I differ a bit because I do think VMT is a great metric and there are a lot of benefits to density,” Brinkley said.
As California lawmakers attempted to reach GHG emission goals, the state was able to pass SB 743 which finally completed the shift from LOS (Level of Service) to VMT as the standard of analysis.
Traditionally, Level of Service (LOS) has been used to evaluate traffic conditions, but experts are increasingly advocating for a shift to Vehicle Miles Traveled (VMT) as a more accurate measure tied to greenhouse gas emissions.
Clearly this remains somewhat controversial, but it’s important to understand the reasons for the change.
LOS measures traffic congestion at intersections based primarily on delay times, providing insights into how smoothly traffic flows. For instance, when evaluating a proposed development near a busy highway, a moderate LOS might suggest that traffic delays at intersections are acceptable.
Using LOS many experts believe could lead decision-makers to approve the project without considering broader environmental consequences.
Conversely, VMT quantifies the total distance driven by vehicles, offering a more comprehensive view of transportation-related emissions.
VMT is directly linked to greenhouse gas emissions, making it a better indicator when assessing the climate impact of transportation projects and land-use planning decisions.
To illustrate the difference between LOS and VMT, consider a scenario involving the proposal of a new development adjacent to a major highway.
Using LOS, the assessment indicates a moderate LOS, meaning that while there may be some traffic delays, they do not seem severe. Consequently, planners might view the project favorably, believing it will operate within acceptable traffic flow conditions.
However, upon further evaluation, the VMT metric reveals that the project could significantly increase the number of car trips generated by residents.
Even though the intersection congestion remains moderate, the rise in overall vehicle miles traveled raise concerns about increased greenhouse gas emissions associated with the new development.
This analysis could prompt planners to reconsider the project’s viability or to implement strategies aimed at reducing vehicle travel.
Here we see a big problem with using LOS.
One of the primary criticisms of LOS is its focus on driver experience, which often results in solutions such as road widening.
While these measures may alleviate congestion at specific points, they do not necessarily lead to reductions in emissions.
In fact, expanding road capacity can sometimes encourage more vehicle use, further exacerbating climate change.
Indeed, there are folks locally who are opposing the freeway widening project for this very reason, and yet they have failed to connect this to the VMT vs. LOS debate—at least some of them.
Moreover, LOS can be misleading when assessing climate change impacts, as it does not account for the total distance vehicles are driven. By prioritizing traffic flow over emissions, LOS may lead to transportation policies that fail to address the underlying environmental challenges.
As Laura McCamy, writing for CalBike in 2020 notes, “LOS seemed like a good idea — in 1969.”
She writes, “When the California Environmental Quality Act was signed into law by Governor Ronald Regan in 1969, it was intended to make sure that all steps were taken to protect the environment during construction projects. CEQA guidelines, as originally written, used LOS as a measure of traffic impacts of a project.”
As she notes, “LOS is an accurate measure of congestion, specifically, the seconds of delay suffered by a motorist at an intersection compared to free-flowing traffic. LOS forced cities and developers to analyze how new developments or traffic changes would impact nearby intersections.”
That analysis was considered a measure of environmental impact, because cars produce emissions when they idle at a red light.
However, she argued: “By placing top importance on relieving car congestion at intersections, however, LOS made cities prioritize driving over all other modes of travel.”
“From the point of view everyone gets around by cars, LOS is an important way to reduce inconvenience to the public. That’s why getting rid of it was so hard. But that point of view was wrong then, it’s wrong today, and disastrous carried into the future,” said Dave Snyder, CalBike Executive Director.
McCamy however argues, “A lot of changed since 1969.”
For starters, modern vehicles emit significantly fewer pollutants while idling compared to their predecessors. Additionally, urban planners have embraced the concept of induced demand, recognizing that widening roadways often exacerbates congestion rather than alleviating it.
Again, note the irony here when we look at the local situation.
“Counterintuitively, adding more lanes to a street or highway often leads to more congestion, not less,” she writes.
Moreover, the pressing issue of climate change has underscored the critical role of carbon emissions, which are closely tied to vehicle miles traveled (VMT).
“Carbon emissions are almost a direct function of vehicle miles traveled. By changing the measure of impact in CEQA analysis to VMT from LOS, project proponents will have to assess the added vehicle miles associated with a new building or road construction,” she writes.
This shifts the focus, from merely speeding up car traffic to enhancing the overall movement of people in a safer, more convenient manner with reduced carbon emissions.
As a result, “Mitigations could include investments in transit, widening sidewalks, or building bike lanes to help reduce the VMT of the building.”
The bottom line here is that the debate of VMT versus LOS has been settled at least in terms of the state and EIRs. So we can spend our time debating the merits of each approach, or we can, as a community, find ways to maximize housing while minimizing environmental impact.
Uh, huh – we’ve been through this. How much greenhouse gasses are generated when cars are stuck in traffic and aren’t moving at all (zero VMTs)?
Again, this isn’t an “either/or” choice. The combination of VMTs and LOS provides a more-accurate analysis than just examining one or the other.
I think I addressed most of this in the piece.
* The shift from LOS to VMT under SB 743 was designed to reduce overall GHG by discouraging sprawl (something you claim to support) and promoting developments that minimize travel distances.
* While idling vehicles in congested traffic DO emit GHG, expanding road capacity to improve LOS often leads to “induced demand” where increased capacity actually encourages more driving. This is the main point you have failed to acknowledge and it is why a lot of folks oppose the I80 expansion.
* Thus while LOS focuses on local traffic flow and congestion, VMT provides the broader perspective on regional traffic behavior and its environmental impact.
David says: “While idling vehicles in congested traffic DO emit GHG, expanding road capacity to improve LOS often leads to “induced demand” where increased capacity actually encourages more driving. This is the main point you have failed to acknowledge and it is why a lot of folks oppose the I80 expansion.”
You’re conflating two different issues. I didn’t suggest expanding freeways. Cars are already stuck in traffic on I-80, for example.
I asked how much greenhouse gasses are generated by cars stuck in traffic (zero VMTs).
David says: “Thus while LOS focuses on local traffic flow and congestion, VMT provides the broader perspective on regional traffic behavior and its environmental impact.”
Again, why not consider BOTH (in light of the question I asked)? That is, how much greenhouse gasses are generated when cars are stuck in traffic (ZERO VMTs)?
The purposeful ignoring of LOS appears to be driven by political concerns (forcing density), not science-based concerns. It is not the only time that the state has weakened CEQA to achieve political goals, nor do I expect it to be the last time.
I think you’re missing the points here that I have already addressed.
In short, the reason they have moved away from LOS is that the easiest remedy was expansion of roadways. Heck we did it in Davis on Mace when people complained. And it’s happening on I-80. That remedy was not getting to the actual problem and so they’ve looked to a different metric, attempting to shorten vehicle distance traveled.
Why not consider both? Frankly because that’s not what the law says at this time.
“The purposeful ignoring of LOS appears to be driven by political concerns (forcing density), not science-based concerns. It is not the only time that the state has weakened CEQA to achieve political goals, nor do I expect it to be the last time.”
You’re making assertions here without offering evidence to support it. What political concerns? You’re assuming the desire for density is driving this rather than the need for reducing commutes. What evidence do you have to support your chicken/ egg hypothesis in that direction?
Second, you are arguing this is weakening CEQA, what evidence do you have that VMT is weakening rather than strengthening CEQA? You’ve provided speculation on this point without data or analysis.
I feel like my piece addresses most of your points, so unless you offer something new, I will disengage at this point.
David says: “Why not consider both? Frankly because that’s not what the law says at this time.”
So, that’s a problem – as you just acknowledged.
Regarding the state’s motives in ignoring science, I am speculating that the reason behind it is to force density (e.g., in the Bay Area). But since LOS is obviously tied to greenhouse gasses (the state’s stated goal), perhaps that’s a question for an investigative journalist to ask. That is, why is the state ignoring one of the primary factors regarding creation of greenhouse gasses?
One of the reasons I question the state’s motivation is because we’ve witnessed efforts to weaken CEQA in other ways, and then engaging in political distortions to justify it (e.g., “students are pollution”) – when it was really about noise. (Something that you yourself have alluded to, in regard to the impact of “mini-dorms” in the city.)
There’s also attempts to weaken protections along the coast, by Wiener and company.
“So, that’s a problem – as you just acknowledged.”
It’s a fact, whether it’s a problem is subjective.
In terms of your speculation, you would need to back it with some substantive evidence, right now it is merely a theory of yours.
David says: “It’s a fact, whether it’s a problem is subjective.”
If it’s a fact that LOS is directly tied to greenhouse gasses (but the state is no longer including it in CEQA), it’s a “problem” if the goal is to reduce greenhouse gasses.
That’s not “subjective”.
You’re skipping too many steps in this process. You’re leaping from one point to a conclusion without evaluating the intermediate points.
Building more homes will increase traffic congestion locally (LOS) but will make some percentage of people more able and perhaps likelier to live near where they work and shop (VMT).
Project opponents don’t like VMT because it undercuts their most successful argument against development projects: traffic congestion.
A reasonable argument about VMT is that it is based on rather speculative arguments about how people will behave.
Assumptions about the impact of high-density housing, commuting decisions, and shopping behavior seem to ignore major changes in demographics over the last few decades. Two-income households, the different nature of how children and teenagers have their free time managed, and the vastly changed retail environment have made huge differences in how people live and shop. Anyone who knows young adults looking for work or housing understands this. But a lot of these planning arguments seem to be ignoring the realities of modern living.
Maybe the easy way to look at it:
LOS encourages sprawl
VMT encourages density
So, you’ve just acknowledged what I suspected – that the goal is to force density (at the expense of examining one of the factors tied directly to greenhouse gasses – LOS).
I did not acknowledge that.
I see. So you’re stating that cars stuck in traffic (zero VMTs) are not spewing greenhouse gasses.
The “Sargent Shultz” approach to science (“I see nothing . . .”)
Why do I get the sense that you do not wish to have a reasonable discussion here?
I very much believe you have a point that the state has prioritized dense developments, but the leaps you have taken are without evidence.
There is a serious issue behind this – the one already mentioned.
(Other than the fact that I misspelled “sergeant”.)
I understand that and agree that you have a point, but also think you have taken a huge leap to get to your ultimate conclusion.
“In fact, Rowe goes much further than that, arguing that the alternatives analysis seemed manipulated to meet specific VMT targets by increasing the project’s intensity, which he found unprecedented and nonsensical.”
City’s and consultants manipulating measures to further their goals ??? Gambling in Casablanca ???
“I’ll be blunt, I think the city has corrupted the alternatives analysis,”
Uh oh. With all the bothersome commissions and commissioners being re-orged out of existence, the “City” may be wishing the Planning Commission wasn’t mandated.
“ . . . they kept ratcheting up the number of units until they hit the VMT target they wanted and they finally hit 2,700 units and they said, bingo, we’ve got it.”
You could hear the ratcheting all the way at the south end of the Nishi Property.
“We now have met the regional and local VMT targets.”
Read: ‘we have successfully manipulated the numbers in plain site, and we believe we are going to get away with it’
“ . . . the alter of VMT and I think VMT has got a lot of problems with it.”
I like that. The alter. Without LOS, it should be VMTS: ‘vehicle miles traveled slowly’
“As California lawmakers attempted to reach GHG emission goals, the state was able to pass SB 743 which finally completed the shift from LOS (Level of Service) to VMT as the standard of analysis.”
GHG emission goals, and campaign contribution special interest goals.
“Traditionally, Level of Service (LOS) has been used to evaluate traffic conditions, but experts are increasingly advocating for a shift to Vehicle Miles Traveled (VMT) as a more accurate measure tied to greenhouse gas emissions.”
These two measures, measure two different things. Both should be measured and used, as LOS is specifically about traffic conditions which is a thing. And when LOS is super poor you get idling cars stuck in traffic, not measured by VMT, but contributing to more air pollution. The ‘build baby build’ crowd seems to believe everyone should suffer in traffic to allow for more farmland to covered with asphalt and people. You are sick sick puppies.
“Clearly this remains somewhat controversial, but it’s important to understand the reasons for the change.”
campaign contribution special interest goals
“Using LOS many experts believe could lead decision-makers to approve the project without considering broader environmental consequences.”
Thus VMTs, to the extent anyone uses them honestly.
“Conversely, VMT quantifies the total distance driven by vehicles, offering a more comprehensive view of transportation-related emissions.”
But that depends on how VMT is applied relative to transportation policy overall. Remember, most all our state, county and local politicians voted to widen I-80. Can’t turn down federal dollars earmarked for highways, even if the data shows upgrading the rail line is by far the greater alternative for reducing regional VMTs. Nope, gotta get those federal dollars like good little politician puppies.
“VMT is directly linked to greenhouse gas emissions, making it a better indicator when assessing the climate impact of transportation projects and land-use planning decisions.”
Not if it’s mis-used.
“To illustrate the difference between LOS and VMT, consider a scenario involving the proposal of a new development adjacent to a major highway.”
Teach us, Oh Great Fact Checking Oracle.
“One of the primary criticisms of LOS is its focus on driver experience, which often results in solutions such as road widening.”
Or, just ‘unavoidable impacts’
“In fact, expanding road capacity can sometimes encourage more vehicle use, further exacerbating climate change.”
More people can also exacerbate climate change. ZPG now!!! Heck, NPG now!!!
“Indeed, there are folks locally who are opposing the freeway widening project for this very reason, and yet they have failed to connect this to the VMT vs. LOS debate – at least some of them.”
Huh? You state this and then don’t explain yourself. How is connecting a freeway widening to a debate of measures helpful, and who and how, exactly, has failed to do whatever it is you think they should do?
“Moreover, LOS can be misleading when assessing climate change impacts”
It isn’t supposed to. And piddling around with local things isn’t a flea on an elephant’s back as effective as a massive global protest to demand India and China stop building more power plants en masse. But climate change obsessives tend towards cowardice and foolishness when it comes toward making a real difference.
As Laura McCamy, writing for CalBike in 2020 notes, “LOS seemed like a good idea — in 1969.”
And LOS still is, to measure traffic impacts. Want to discourage bicycle use? Force bicycles onto congested traffic corridors – exactly what the fools (poorly) planning Davis development are doing by not listening to the Davis Citizens Planning Group which is calling for a transit/bicycle route through the entire north and east of Davis set for development and having all projects build around that.
However, she argued, “By placing top importance on relieving car congestion at intersections, however, LOS made cities prioritize driving over all other modes of travel.”
Yeah, and if cities don’t prioritize expansion of intercity rail over highway expansion, which actually would make a *major* change in VMT impact, tiny project-by-project measures of cars on a project aren’t going to matter a blip. And not even blue blue Davis politicans had the b*lls to even make a statement by declaring so. Nope, gotta get those federal highway dollars, d*mn the VMTs.
“From the point of view everyone gets around by cars, LOS is an important way to reduce inconvenience to the public. That’s why getting rid of it was so hard. But that point of view was wrong then, it’s wrong today, and disastrous carried into the future,” said Dave Snyder, CalBike Executive Director.”
Hey, I’m all for bikes and bike infrastructure, dude, but bicycling is about having a choice than about making a huge difference in air pollutants. I wish modeling human behavior would show mass migration to bicycles with mass infrastructure improvements, but it doesn’t. Even when you spike gas prices, the change to public transit is minimal, because of travel patterns are complex, and our public transit still sucks. If you don’t believe this, try planning your day and those of a few friends with different lifestyles around public transit rather than driving. As an example, I looked at running an errand in Sac by bus, and it would have taken *two hours* by bus, whereas I could drive round trip in 20 minutes. And I wouldn’t even consider bike as the route suggested was deadly from at least two perspectives.
“or starters, modern vehicles emit significantly fewer pollutants while idling compared to their predecessors.”
Oh pleez. You build-baby-build types fail to ignore sitting in traffic is also a *time suck*. And the biggest factor in modeling human behavior in transit choice is *time*. See above about trying to model your day around public transit. And I am saying this as someone who has fought for better public transit my whole life – and transportation is the biggest factor in air pollution. The problem is, you can’t force people to spend mass amounts of time to make a minor change in air pollutant emissions – if they even care, and many people don’t.
“Additionally, urban planners have embraced the concept of induced demand, recognizing that widening roadways often exacerbates congestion rather than alleviating it.”
That is absolutely true. That is why we need to massively invest in and expand intercity rail, and that will make a measurable difference in air pollutants.
“Counterintuitively, adding more lanes to a street or highway often leads to more congestion, not less,” she writes.”
How is that counter-intuitive? It’s obvious.
Moreover, the pressing issue of climate change has underscored the critical role of carbon emissions, which are closely tied to vehicle miles traveled (VMT).
The “pressing issue” of so-called ‘climate change’ has mostly been used by politicans and their funders to delude dullards into wrongful so-called ‘solutions’
.
“Carbon emissions are almost a direct function of vehicle miles traveled. By changing the measure of impact in CEQA analysis to VMT from LOS, project proponents will have to assess the added vehicle miles associated with a new building or road construction,” she writes.”
And as an added benefit, it opens the door to more development! #mass-sarcasm#
“This shifts the focus, from merely speeding up car traffic to enhancing the overall movement of people in a safer, more convenient manner with reduced carbon emissions.”
That sounds like the VMT modeling apologist’s equivalent of a Rube Goldberg machine.
“As a result, “Mitigations could include investments in transit, widening sidewalks, or building bike lanes to help reduce the VMT of the building.”
And yet, IRONICALLY, Davis politicians aren’t even considering the transit/bicycle united transit route proposed by the Davis Citizen’s Planning Group to pass through all the future Davis Northeast and East developments. WHY? Because our Build-Baby-Build-Baby-Build-Baby-Build politicians don’t really care about air pollution or climate change or even building a better, more human-friendly Davis, they care about MORE PEOPLE all CRAMMED INTO A SMALLER SPACE and SITTING IN MORE TRAFFIC. LOL. Or should I say, LOS.
“The bottom line here is that the debate VMT versus LOS has been settled at least in terms of the state and EIRs. So we can spend our time debating the merits of each approach, or we can, as a community, find ways to maximize housing while minimizing environmental impact.”
And yet, as a city, we are failing miserably.
Alan in the midst of a rather impressive missive raises some interesting points…
Manipulation of Metrics: Alan expresses significant concern (understatement to say the least) that municipalities and consultants may manipulate VMT) metrics to achieve specific objectives, similar to past critiques of LOS. He suggests that such manipulation could be used to justify increased development under the pretense of adhering to environmental standards. (While I think Alan raises a valid objection here, he seems to me to miss the problem that somehow the city needs to build housing while it adheres to current environmental standards – which is not easy and made even more difficult by local regulations).
Critique of VMT as a Sole Metric: Alan argues that while VMT focuses on greenhouse gas emissions, it may not sufficiently address the complexities of traffic and environmental impacts. He (like Ron) recommends that both LOS and VMT, which measure different aspects of traffic, should be considered collectively rather than in isolation.
Concerns about Induced Demand and Infrastructure Projects: The concept of induced demand suggests that expanding roadways can lead to increased congestion instead of alleviating it. Alan advocates for investing in intercity rail and public transit as more effective solutions for reducing vehicle miles traveled and emissions. (Here I agree that rail and public transit are part of a solution to VMT and emissions).
Criticism of Local Political Priorities: Alan offers a strong critique (another understatement) of local politicians and planners, accusing them of prioritizing development and federal highway funding over meaningful environmental and community improvements. It is argued that current policies may exacerbate traffic and environmental issues rather than resolving them. (I definitely agree that current policies may exacerbate traffic and environmental issues, but part of that has been the refusal of Davis to build housing for 25 years which has already greatly exacerbated traffic and environmental. One former public official pointed out that Davis’ anti-growth policies have led to a huge increase in VMT for surrounding communities.)
Call for Comprehensive Planning: Finally Alan advocates for a more comprehensive approach to urban planning that incorporates both LOS and VMT metrics, investments in public transit, and thoughtful development strategies that consider the long-term impacts on traffic congestion and the environment. (Hard to argue with any of that unless your goal is to stop housing – which I don’t accuse Alan of doing).
David says: “One former public official pointed out that Davis’ anti-growth policies have led to a huge increase in VMT for surrounding communities.”
Surrounding communities would pursue growth, regardless. That’s what they do – it’s their “thing”.
But due to LOS and cold starts, fewer greenhouse gasses are generated (per VMT) from communities which aren’t as congested. And apparently, CEQA does not account for that difference.
If the state was actually interested in reducing VMTs and sprawl, they would do so. They’re obviously not interested in that, given what’s occurring around the region.
So far, the state has only tried to encourage density, WITHOUT seriously trying to reign in sprawl. (That’s also related to their support for the expansion of I-80.)
Honestly, the state and the growth advocates are continuing as if it’s “business as usual”, despite what’s occurring.
“Within 15 years, the state’s elderly population, or those 65 and older, will increase by 59% as the number of children declines by 24% and the working-age population remains largely stagnant, according to a report by the Public Policy Institute of California.”
“The news comes as California has experienced plunging birth rates over the past few decades, with the state now having one of the lowest total fertility rates, or the number of children a woman has in her lifetime, in the country. California additionally lost a net of 407,000 residents to other states between July 2021 and July 2022 . . .”
https://www.msn.com/en-us/news/politics/california-s-unprecedented-demographic-shifts-threaten-democrats-grip-on-the-state/ar-AA1yUcBG?ocid=hpmsn&cvid=8fef33adb18f4a43994eab4dfeecab25&ei=14
(As someone once said, “don’t be afraid of change”.)
You have a good argument that we might not have a housing problem in a decade or two, but that doesn’t address the current problems.
It’s not that it will “suddenly occur” in a decade or two. It’s happening every day.
And unlike whatever “problem” you’re referring to, subdivisions don’t revert back to single (e.g., farmland) parcels when the “problem” ceases to exist. See Detroit and New Orleans for some rather-extreme examples of that problem.