SAN FRANCISCO Automobile Trips Generated CEQA Measure and Mitigation Program

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SAN FRANCISCOAutomobile Trips GeneratedCEQA
Measure and Mitigation Program

• Tilly Chang, SFCTA
• Alameda County Climate Action Working Group
• October 14, 2009

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Purpose and Background

• What is the best way for San Francisco to measure
  transportation impacts under California
  Environmental Quality Act (CEQA)?
• Strategic Analysis Report on Automobile LOS
  requested by Authority Board and completed in
  2004
• Identified problems with current measure
• Suggested several possible approaches for moving
  away from LOS
• Automobile Trips Generated Study completed in
  2007
• Recommended discontinue use of Level of Service
  (LOS) as CEQA impact measure
• Measure impacts based on automobile trips
  generated (ATG)
• Provide more effective impact mitigation via fee
  program
• Nexus Study currently underway

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The Problems with LOS

• Today, project CEQA impacts on transportation are
  defined as auto delay at intersections (LOS)?
• Three problems with this measure of impact
• LOS does not capture important environmental
  impacts (rather reflects motorist pov)
• LOS contradicts the Citys Transit First/Climate
  Action Plan policies and priorities (again,
  optimizes individual motorist experience vs.
  system performance)
• LOS makes CEQA review process inefficient (for
  both Planning Department and project sponsors)

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LOS does not capture environmental impacts

• LOS measures the delay experienced by drivers at
  an intersection
• LOS does not capture environmental impacts
• Carbon emissions
• Safety
• Transportation system efficiency
• Air and water quality
• Neighborhood livability
• Noise
• Environmental impacts ARE related to the
  automobile trips generated (ATG) by a project

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LOS does not capture environmental impacts
Automobile Delays (LOS)?
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LOS does not reflect City policies

• LOS impacts contradict the Transit First Policy
• LOS standards discourage density
• Climate Action Plan calls for reduction in
  driving
• Auto tripmaking is 50 of SFs greenhouse gas
  emission
• Mitigations to LOS are environmentally harmful
• Worsen conditions for pedestrians, transit, and
  bicycling
• Induce more driving

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LOS does not reflect City Policies
Providing a pedestrian crossing here would
increase delays for right-turning drivers,
potentially triggering significant LOS
impacts... Minimizing automobile delays takes
precedence over minimizing pedestrian delays.
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LOS results in inefficient CEQA review

• LOS analysis and impacts are
• Difficult for project sponsors to predict
• Not transparent for project sponsors or the
  public
• A burden to the last project in (last-in
  problem)?

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The last-in problem
Project 1 LOS B No Impacts
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The last-in problem
Project 2 LOS D No Impacts
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The last-in problem
Project 3 LOS F Significant Impacts!
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The Problem

• Fortunately, CEQA statute grants local
  jurisdictions the authority to define impact
  measures and thresholds consistent with local
  policy
• However, this is constrained by State CEQA
  Guidelines and past practice
• Transportation is an impact area distinct from
  air, water, noise, etc.
• State CEQA Guidelines recommend use of LOS to
  measure impacts

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State CEQA Guidelines Revisions

• Proposed Language for CEQA Guidelines Appendix G
  (Transportation Impacts)
• Explicitly recognizes local variation in
  environmental context
• More supportive of an ATG impact measure than
  current language
• Further improvement would replace capacity
  concept with performance
• XVI. TRANSPORTATION/TRAFFIC --Would the project
• a) Exceed the capacity of the existing Conflict
  with an applicable local plan, ordinance, or
  policy that establishes a measure of
  effectiveness for the performance of the
  circulation system, taking into account all
  relevant components of the circulation system,
  including but not limited to intersections,
  streets, highways and freeways, pedestrian and
  bicycle paths, and mass transit?

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San Francisco's New Proposed Approach

• ATG Measure Transportation Impact Mitigation
  Fee
• Each net new automobile trip added by a project
  contributes to negative impacts for CEQA purposes
  (Conservative)
• Each added automobile trip (starting with 1 trip)
  contributes to impact
• Projects that do not generate net new automobile
  trips have no impact
• e.g. bicycle or BRT projects
• Automobile trips generated mitigation fee (ATMF)
  program
• Project sponsors pay per-trip impact mitigation
  fee
• Fee revenues fund actions that help reduce new
  automobile tripmaking (by improving transit,
  walking, and bicycling as choices)?
• Payment of fee mitigates ATG impacts for CEQA
  purposes

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ATMF improves mitigation effectiveness

• Mitigate local and citywide impacts
• Nexus study to demonstrate link between
  countywide program of improvements and cumulative
  reduction in ATG
• ATMF revenues contribute to large projects that
  will have significant effects on tripmaking
  patterns
• Portion of ATMF dedicated to local area
  improvements
• More equitable and accountable (for project
  sponsors and the public)?
• Eliminates last-in problem each project
  contributes in proportion to impact levels
• More simple and transparent process for
  identifying and mitigating impacts
• Clear nexus between fee collected and projects
  funded

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Process for Applying ATG Measure
Will the Project generate new auto trips?
Yes
No
Stop. No impacts in this area.
Determine Impact Estimate automobile trips
generated or induced by the project
Determine needed mitigation Calculate impact
mitigation fee payment based on volume of trips
generated / induced
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The Benefits

• Environmentally protective
• Captures incremental impacts
• More closely related to actual environmental
  effects
• Consistency with City policies and vision
• Reduces time and cost to implement Transit First
  projects
• More effective at discouraging auto-oriented
  projects
• Improved efficiency
• More predictable for project sponsors
• More transparent for the public
• More accountable - mitigations linked directly to
  local and citywide improvements

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Implementation Roadmap

• Authority Board approved final report in October
  2008
• Nexus Study
• Jointly led by Mayors Office of Economic
  Development, SF Planning Department, the
  Authority, and SFMTA
• Scheduled for completion in 2009/10
• Planning Commission adoption of an ordinance
  approving the ATG measure and ATMF package
• Refine trip generation rates
• Refinements to current trip generation rates
  should account for smart growth project
  features as much as possible
• San Francisco often has unique trip generation
  rates (difficult to import generalized rates)

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• Thank you!
• www.sfcta.org