Moving away from environmental reviews that favor driving: San Francisco, Mountain View, Menlo Park

Three recent environmental reviews reveal the dramatic transition under way in California’s assessment of the transportation impacts of new buildings.

San Francisco’s Central SOMA plan is the first “Environmental Impact Report” (EIR) in the Bay Area that we know of for a land use plan that moves away from a method of analysis that favors driving and promotes car-centric place design.   San Francisco’s recent report, using new rules, is dramatically different from new reports in Mountain View and Menlo Park, cities that have been transitioning to less car-centric policies, but still use the older standard in environmental reviews.

The California Environmental Quality Act, passed in 1970, requires projects, including land use and transportation projects to assess the impact of these projects on the environment, considering many factors including transportation.

The state is in the midst of a transition away from using vehicle “level of service” – a measure of car delay at intersections – as the tool to measure the transportation impact of a project – toward “vehicle miles travelled”. Under the new rules, instead of widening roads to improve convenience for drivers – which makes the area even less attractive for walking, bicycling, and transit – the city is motivated to invest in improved transit, walking, and bicycling to reduce vehicle miles travelled.

San Francisco Central SOMA Plan

San Francisco’s Central SOMA plan envisions adding space for 25,500 households and 63,600 jobs by 2040 in 230 acres surrounding the southern portion of the Central Subway transit line.

The City of San Francisco is one of the first leading cities, along with Oakland and Pasadena, which have adopted the new VMT/Capita standard to assess the transportation impact of new development.

The first conclusion in the EIR’s assessment of transportation impact is that “development under the Plan… would not cause substantial additional VMT or substantially increase automobile travel.” Using the new rules, because the large amount of infill development in a transit-rich area would not trigger increased driving, the main conclusion is that the plan would not have a major negative impact on the environment. (S-16)



The core finding of the report is this table showing that with the infill development in the plan, vehicle miles per capita is projected to decrease by 27% for employment uses and 31% for residential uses, well under the regional average – showing a benefit to the environment – see IV.D-37 

At the starting point, the driving mode share in the area is just under 40%. The implementation of the plan is projected to reduce the rate of driving even further to 30%, with a few points increase in transit use, and substantial increases in walking and bicycling due to increased density and improvements to streets and sidewalks.


However, the plan does foresee an increase in transit demand that would cause delays to local and regional transit routes.   Mitigations to reduce these impacts including raising revenue from parking, congestion pricing, and grant funding, to upgrade the transit system. Other mitigations to speed transit include include transit-only lanes, transit signal priority, transit boarding islands, pre-payment to speed boarding. (S-17, 18). Another impact found by the study is crosswalk crowding, to be addressed by widening crosswalks.  

The recommendations for improvements to transit, bicycling, and walking are richly detailed, in line with the area’s heavy use and projected increase in these modes.

Mountain View North Bayshore

The City of Mountain View also places a high priority on reducing the share of driving in the North Bayshore area, where Google is headquartered. The North Bayshore precise plan requires a reduction in drivealone mode share from the current rate around 60% to 45% in the time frame of the plan.  This year, the city is updating its North Bayshore Precise Plan to incorporate housing, transforming a single use office park into a mixed-use neighborhood with housing and services.

Adding housing and services near jobs would logically be expected to reduce driving, since some of the residents would take advantage of the convenient option to live near work, and would commute by walking and bicycling; and more people will also use nearby services without driving.  In fact, the report finds that adding housing near jobs reduces the expected driving by 27%.

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Unfortunately, Mountain View is still using the older Level of Service analysis to assess the transportation impact of adding housing to an office park. (A VMT analysis was also done and can be found here).  Therefore, the bulk of the transportation section of the environmental impact report is spent on analyzing the change to vehicle intersection delay in a large number of intersections on streets, roads, and highways in North Bayshore and surrounding areas.

In many cases, auto delay is expected to increase beyond a threshold, and therefore the EIR recommends adding turn lanes and widening roads in many locations.  Often, widening the roadway is analyzed and deemed to be infeasible, because the right of way is unavailable, or because the roadway is in a jurisdiction that Mountain View does not control.   Where the widening or lane addition is feasible, the presumption is that the changes will be made.

Even though the city’s policy goals are to reduce driving and increase the use of transit, walking, and bicycling, and driving is required to become a minority activity over the time period of the plan, the lion’s share of the content in the EIR is spent analyzing and proposing changes that will make driving more convenient, and will make walking and bicycling less convenient.

Finally, in a very unfortunate outcome of using the obsolescent LOS analysis, despite the city’s strong policies requiring a reducing in solo driving and the beneficial results of adding housing near jobs, the EIR concludes that the current plans for a single-use office park with modest services would be the “environmentally preferred alternative”.   The alternative adding housing and services near jobs would add delay to area intersections, and therefore is seen as environmentally “worse”, even though it results in less driving, greenhouse gas emissions, and pollution.

In summary, the EIR using LOS as a metric concludes that adding housing near jobs is environmentally harmful, and recommends many actions that favor driving over walking and bicycling, despite the city’s policies to make driving a minority travel mode mode.

Menlo Park – El Camino near Caltrain

Menlo Park is another city that has been updating its policies and plans to more effectively support multi-modal travel, though its multi-modal policies are less strong than those of Mountain View.  Like Mountain View, Menlo Park has not yet made the shift to VMT. Menlo Park recently adopted a new General Plan. Updates to its Transportation Impact Analysis guidelines, including rules to incorporate the use of VMT, and changes to transportation impact fees, are proposed for a transportation guidelines update to be completed in 2018.   

Consequently, as in Mountain View, the Menlo Park EIR for a project on El Camino Real near Caltrain puts most of its attention in the transportation section toward many changes to add lanes and widen roads, despite acknowledging that these changes will have negative consequences for walking and bicycling.  The impacts on walking and bicycling, including longer crossing distances and more challenging intersections, are proposed to be mitigated by better crosswalks and intersection treatments. As in the past, the bulk of transportation impact fees are expected to be devoted to “improvements” intended to reduce auto intersection delay, while adding challenges for people walking and bicycling.

In summary, the future is here, but it is not yet evenly distributed (to use a quote from Paul Saffo). The state of California has a clear direction to change the way that the environmental impact of transportation is assessed.  However, until these changes are adopted by cities, we will continue to see environmental reviews that generate results counter to the goals of cities that want to increase the use of sustainable transportation, recommending less mixed use infill development, and more roadway widening that tends to increase driving and decrease active transportation.