LOS "reform": Blank check for bike nuts

Here's a description of item #3 on the agenda of the Board of Supervisors' Land Use Committee next Wednesday, 1:00 p.m., room 263, at City Hall:

051964 Urging Planning Commission to Update Transportation Analyses under CEQA (Supervisor Mirkarimi) Resolution urging the Planning Commission to set policy directing the Environmental Review Officer to modify local environmental review criteria to assess transportation impacts more accurately in conformance with updated analytical methods.

Rather cryptic stuff for the uninitiated. A translation: Supervisor Mirkarimi---the bike nuts' best friend on the Board, now that Matt Gonzalez is gone---is carrying a resolution to "update" the Level of Service (LOS) criteria for environmental traffic studies required of projects in the city under CEQA. Once this resolution is passed by the committee, it goes to the Planning Commission, a body not known for its intellectual/political independence, which will dutifully pass it unanimously. Then it will come back to the Board of Lemmings for a last unanimous stamp of approval so that it can take effect.

What it means is that none of the projects in the Bicycle Plan---including removing traffic lanes for bicycle lanes---will be challengeable because of those irksome traffic studies that make it difficult to implement their sweeping plans to remake the streets of the city on behalf of a tiny minority of cyclists. 

Once the LOS is "updated," it will be difficult for anyone to invoke CEQA when traffic is made worse on city streets as the 527-page Bicycle Plan---a plan that has had no environmental study thus far---is implemented with no public debate, piece by piece. Changing the LOS traffic standard in itself should have its own environmental study, since it will have negative impacts on traffic in the city, not only making traffic worse for all those wicked cars but also for buses and emergency vehicles.

The proposed resolution can be viewed/printed out by going to the SF government site, clicking on "activities" under the Board of Supervisors, scrolling down to the Land Use and Economic Development Committee, and clicking on 051964.

Anyone who thinks this is a questionable idea should show up at next week's meeting and say so: 1:00 p.m., room 263, City Hall. It's also helpful to submit written public comment (see mine below) at that time for the record, citing the above number (051964).

April 7, 2006

Public comment by Rob Anderson on 051964 to the Board of Supervisors’ Land Use Committee, Agenda Item #3 for the April 12, 2006 committee meeting.

Last June the Board of Supervisors passed an ordinance making the Bicycle Plan part of the city’s General Plan without an environmental study as required by CEQA. As you know, that action is now being litigated. Changing the Level of Service (LOS) standards in the city is part of the Bicycle Plan (San Francisco Bicycle Plan Policy Framework, May 2005, Action 2.8, pages 2-27, 2-28).

In other words, the city is continuing its attempted end-run around CEQA by implementing the Bicycle Plan as if that litigation is not happening, showing contempt for both proper environmental review and for the legal process itself. Changing the LOS standard would be worthy of an EIR all its own, since the impact on city traffic can only add to the city’s traffic woes.

The idea of changing the LOS standard to accommodate the 1% of city residents who ride bicycles is outrageous, since, as of Dec. 2004, there were 464,903 motorized vehicles registered in San Francisco, with, on average, more than 3000 additional vehicles registered in the city every year. The resolution assumes that air quality is the only consideration under the current LOS standards, but of course you must know that time is a crucial matter for automobiles and public transit: How long vehicles have to sit in traffic to reach their destinations is a crucial part of the present CEQA/LOS standard. What you are trying to do will further snarl traffic in the city, not only for cars, but also for buses, streetcars, and emergency vehicles.

It’s understandable that you and the SF Bicycle Coalition don’t want any serious review of this; once the people of the city understand what you are doing, they will likely register their disapproval at the polling booth. What’s the hurry? Why not wait until later this year, when the court decides whether you should do an environmental study of the whole Bicycle Plan, including Action 2.8 in the Framework Doc?

This resolution is bad public policy and, in the long run, bad politics.

Rob Anderson
1516 McAllister St.
SF CA 94115