Streamlining the Development Approval Process in a Post–Level of Service Los Angeles

Abstract

Problem, research strategy, and findings: Local governments across the United States have for decades relied on the autocentric level of service (LOS) metric to analyze and impose exactions for the transportation impacts of land use developments. In California, LOS has dominated transportation impact analysis under the state’s project-level environmental review law. In that role, LOS has exacerbated the state’s notoriously tortuous development approval processes, particularly in urban areas. But LOS is on its way out. The state recently replaced LOS with vehicle miles traveled (VMT) as the primary measure—and basis for mitigation—of transportation impacts under the California Environmental Quality Act. Local governments must make the switch by July 1, 2020. We use a historical counterfactual approach to assess how replacing LOS with VMT could have affected the approval process for 153 land development projects over 16 years in the city of Los Angeles. We find that most projects could have benefited from at least some environmental review streamlining under the VMT-based framework recommended by the state, including more than 75% of residential-containing projects.

Takeaway for practice: Our results suggest that swapping LOS for VMT could reduce the environmental review burden for development in low-VMT urban areas and provide at least some of the approval process streamlining necessary to increase housing production in California. Similar impacts from an LOS-to-VMT switch could also potentially accrue outside of California under the right conditions, but more research is needed.

Keywords:

• CEQA
• development
• housing
• level of service
• vehicle miles traveled

ACKNOWLEDGMENTS

Many thanks to Joseph Kaylor for his tireless research assistance, to Susan Handy for her always trenchant feedback, and to the Editor and the three anonymous reviewers for their thoughtful and constructive suggestions.

NOTES

Notes

1 According to a recent survey of 46 cities and counties, the exemption most frequently applied to housing projects between 2015 and 2017 was the small infill exemption, which limits projects to 5 acres (Smith-Heimer & Hitchcock, 2019; Guidelines Section 15332). The exempted projects averaged 37 units in size.

2 The SB 743–implementing regulations became effective on December 28, 2018. They include a new CEQA Guidelines section (15064.3) and revisions to Appendix G of the Guidelines and are complemented by OPR’s informal 2018 Technical Advisory on Evaluating Transportation Impacts in CEQA (California Natural Resources Agency, 2019; Office of Planning and Research, 2018).

3 None of the 76 respondents to a recent SB 743–related survey of city and county planning departments in California reported that they do not plan to use OPR’s recommended screening thresholds (Volker, Lee, & Kaylor, 2019).

4 Pasadena was the first to adopt a VMT-based policy in 2014 (City of Pasadena Department of Transportation, 2015), followed by San Francisco and Oakland in 2016 (City of Oakland, 2017; San Francisco Planning Department, 2016), and San Jose in 2018 (City of San Jose, 2018).

5 Los Angeles is frequently cited as the poster child for sprawl. However, the city is actually one of the most compact urban areas in the United States according to recent metrics, even when combined with adjacent areas (Ewing & Hamidi, 2014; Laidley, 2016).

6 Our data set includes seven petitions challenging projects whose draft EIRs were published before 2013, the earliest two from 2007.

Additional information

Notes on contributors

Jamey M. B. Volker

JAMEY M. B. VOLKER ([email protected]) is a PhD candidate in the Transportation Technology and Policy (TTP) graduate group at the University of California, Davis (UC Davis), and a practicing environmental attorney.

Amy E. Lee

AMY E. LEE ([email protected]) is a PhD student in the TTP graduate group at UC Davis.

Dillon T. Fitch

DILLON T. FITCH ([email protected]) is a postdoctoral researcher at the UC Davis Institute of Transportation Studies.