Proposed CEQA Guideline for Highway Projects Promises Flexibility In the Measurement of Traffic Impacts, But Delivers Ambiguity

By: Robert D. Thornton, Benjamin Z. Rubin, Liz Klebaner : 

In response to material opposition from many of the transportation agencies in the State, the California Natural Resources Agency  has proposed to provide transportation agencies with the discretion to determine the metric for evaluating traffic impacts of highways and road projects.  Unfortunately, instead of putting the issue to bed, the proposed regulation introduces considerable ambiguity that will likely lead to a CEQA challenge if any project EIR relies solely on Level of Service (LOS) to evaluate the significance of traffic impacts.  The proposed regulation states:

For roadway capacity projects, agencies have discretion to determine the appropriate measure of transportation impact consistent with CEQA and other applicable requirements. 

The language “consistent with CEQA and other applicable requirements” arguably creates ambiguity as to whether transportation agencies may rely solely on measures of traffic congestion such as LOS to determine the significance of traffic impacts, or whether the State’s climate change legislation mandates a “Vehicle Miles Traveled” (VMT) analysis.

As we have previously reported, the proposed SB 743 implementing regulation represents a paradigm shift in the evaluation of transportation impacts of road and development projects, by replacing the traffic congestion-based LOS metric with the VMT metric.  With VMT, the very acts of driving a vehicle or inducing vehicle travel by improving roadway infrastructure is an environmental impact requiring analysis and potentially mitigation.  The proposed regulation generally removes traffic congestion from the required scope of a CEQA impacts analyses… (more)


The one thing we can count on is a daily Muni meltdown.

Let’s face it, the grand experiment failed and it is time to stop the bleeding.
We used to have some Muni meltdowns every now and then. Now we have them daily. We also have the daily updates on where and when the Muni will stop and the route of the day musical chairs. No one is happy with the system. We need a new method of managing transportation based on the real world and the needs of today’s residents.

The SFMTA spends way too much time envisioning and trying to sell the perfect design for the future (They are planning for 2045). while ignoring the needs of the public today. Any agency that ignores its customer base, blames everyone for their failures, and can’t get by on 1 billion dollars a year, deserves a quick timely demise before they do any more damage or sign any more bad contracts.

Hopefully, the Board of Supervisors will not dole out any more money to start any new projects until they finish the ones they are already in the middle of. If you agree let your supervisors know this is your first priority.

If you missed the hearings on impacts of SFMTA poliicies and procedures and handling of contracts and fund, you should watch tapes of some of the hearings that have been conducted recently at City Hall in various committees meetings.

The SF Board of Supervisors has been the brunt of thousands of complaints, petitions and angry public comments. Bad decisions on the part of the SFMTA management are costing the city possibly hundreds of millions of dollars. It is past time to cut our loses and change the program.

The reason the Supervisors cut themselves out of the management and legislative process is that they didn’t want to have to deal with the complaints, same as they did for the street trees. Hopefully the street tree management program will go better the SFMTA experiment did. The Supervisors are getting more complaints than ever and feel like they have no control over the issue they are blamed for. At least that is one of the comments we have heard so far to explain the latest proposal to split the SFMTA between Muni and the other departments. In this version, the Board of Supervisors would have control and final say on the local street and traffic issues.

Stay tuned for details as they come in.

Land Use Development & Transportation Integration

Why it makes sense for San Francisco

Integrating transportation and land use planning is essential to meet the ever growing needs of a vibrant city like San Francisco.  Research has proven that development patterns (and their related parking needs) heavily influence transportation choices, and the city’s current and future needs cannot be accommodated through roadway expansion and separated land uses alone. These traditional ways of planning take up precious city land and create a host of negative public and private costs and impacts on our economy, environment infrastructure and society. Compact, mixed-use infill development with streets designed to prioritize transit, walking and bicycling has proven to meet multiple quality of life objectives and is part of a suite of critical strategies to reduce transportation emissions, waste and noise and improve public health through more active lifestyles while minimizing severe and fatal traffic related injuries.

While this type of development ensures that many destinations can be reached through walking, public transit, car-sharing and bicycling, strategic investments will be needed to ensure that the transportation network can meet this demand. Locating new housing and employment centers along transit corridors is only the first step; creating partnerships that identify and provide the needed tools to make these plans and projects successful is vital. These tools include increasing transit peak-period capacity (including fleets and fleet storage) and reliability; walking and bicycling safety and comfort, and travel demand management tools like parking needs for bicycles and car-sharing and household transit passes. By coordinating land-use and transportation planning early in the design stage, we can create better outcomes that meet our city’s overall quality of life goals.

Why it makes sense for San Francisco...(more)

In their own words  SFMTA lays out their plans for the San Francisco they envision, and it doens’t include many of us’ – “Locating new housing and employment centers along transit corridors is only the first step; creating partnerships that identify and provide the needed tools to make these plans and projects successful is vital…By coordinating land-use and transportation planning early in the design stage, we can create better outcomes that meet our city’s overall quality of life goals. “

PARTNERSHIPS being the key word here. So far who have SFMTA partnered with? Not the neighborhood groups or the Muni riders. They appear to prefer to partner with Ford, GoBikes, Getaround, Scoot, Uber, Lyft and tech buses, developers and contractors instead.

SFMTA is laying out their plans to privatize the streets and gentrify the city by partnering with more corporate entities and excluding more residents from the decision making process, although it is hard to know how they could exclude too any more people when they ignore the requests of Supervisors and hundreds of citizens that object to bus stop removals.

If you object to handing over mover power to the SFMTA and their friends and allies, please take the time to let our city leaders now how you feel about this top down planning program that would merge the SFMTA with the Planning Department, creating a really big autocratic system of government.

Knowing where this is going you might want to sign the petition to repeal the gas tax and not approve any more taxes or bonds at this time. Staring the monster is a good way to cut down the damage it can do.

Neighborhoods need time to review and comment on major changes.

If you agree with that statement, and want a transparent system that informs and engages the public in legislative and administrative changes BEFORE they become law instead of notifications after, please consider supporting this letter and sending it along with your personal comments on this process to the recipients. This letter was drafted after much time and consideration by a coalition of neighborhood groups our supervisors.


Dear Mr. Joslin,

Please see attached letter from the Coalition for San Francisco Neighborhoods (CSFN) on the Urban Design Guidelines (UDGs).

Thank you very much.


Rose Hillson for George Wooding, President


CSFN-UDGs Letter 2017Nov21.pdf

Text version: CSFN UDGs Letter 2017Nov21.docx



Governor Brown Vetoes CEQA Bill That Would Mandate Lead Agencies To File NOEs For Projects Approved As Categorically Exempt

By Miller Starr Regalia : jdsupra – excerpt

On October 15, 2017, Governor  Brown vetoed SB 80 (Wieckowski), a bill that would have added to CEQA’s already detailed notice requirements.

Specifically, SB 80 would have amended Public Resources Code §§ 21092.2, 21092.3, 21108 and 21152 so as to require, inter alia, that state and local lead agencies:  (1) offer to provide scoping notices, notices of preparation, and notices of determination by email to persons so requesting; (2) post all such notices on the agency’s website (if any); and (3) file with OPR or the County Clerk, as applicable, all Notices of Exemption (NOEs) for approved projects found exempt pursuant to the categorical exemptions contained in the CEQA Guidelines (as opposed to other possible bases for exemption).

The bill would have also required county clerks to post on their counties’ Internet Web sites EIR scoping notices and notices of preparation for EIRs and negative declarations, for specified periods… (more)

$2.3M Guy Place Park Redesign Approved!!

We are pleased to report a small success that took a lot of effort from a lot of people in District six to pull off. This proves it can be done and gives us hope. One question remains. Why so much concrete in the parks? Why no grass?

Oct 31, 2017 — After nearly 2 years of protests and official appeals, Guy Place Park has been redesigned with the removal of 7 futuristic steel and concrete 20-foot vertical columns and their replacement with 8 mature multi-trunk heritage Birch Trees that will serve as a refuge habitat for Allen’s Hummingbird. The 4 remaining columns will function as living “green” towers adorned with nectar producing foliage. At the same time, the 3 “significant” Avocado and Ash Trees will still be demolished to make way for the minipark in Rincon Hill. The vertical column planned for the sidewalk bulbout fronting the new park has been removed from the bulbout design, per our winning appeal on a unanimous vote by the City Board of Appeals. Here is the new design approved October 23rd by San Francisco Arts Commission, to be put out to bid November.

Thanks to everyone who signed the petition and supported the effort(more)

Westlands dumps Jerry Brown’s Delta tunnels

centralvalleybusinesstimes – excerpt

• Farmers’ rejection puts project in question
• Cite costs of tunnels

The Wedtlands Water District board of directors Tuesday afternoon voted not to participate in Gov. Edmund Gerald Brown’s proposed legacy project– twin water tunnels to drain water out of the Sacramento River before it could flow into the California Delta.

Westlands says the cost is too much. The state has estimated the cost at $17 billion, but an independent economist has put the true cost at as much as $67 billion.

Critics have said the costly project would make irrigation water too costly for farmers to make a profit… (more)

Don’t bend California’s environmental rules for billionaire sports owners or the Olympics

Editorial by The Times Editorial Board : latimes – excerpt

California lawmakers are — again — considering a last-minute bill that would let deep-pocketed developers and favored projects cut corners on the state’s landmark environmental law.

Last week Sen. Steven Bradford (D-Gardena) introduced a bill that was pitched as a way to dramatically speed the construction of transit lines and parking lots needed for the Olympic Games in Los Angeles in 2028. Bradford’s big idea? Exempting the projects from all the studies and public input required by the California Environmental Quality Act. The primary beneficiaries of Senate Bill 789, however, would be the proposed Clippers arena and other projects in Inglewood’s sports and entertainment district… (more)

Environmental Report: Legalization not harmful

By Chris Conrad : theleafonline – excerpt

The Bureau of Cannabis Control announced the conclusion of the California Environmental Quality Act (CEQA) Proposed Program study on September 6, 2017 regarding implementation of Proposition 64, and the news so far is good for the legalization movement.

As the lead agency under CEQA, the Bureau prepared an Initial Study/Proposed Negative Declaration (IS/ND) for its proposed regulatory program. Based on the findings of the IS/ND, the Bureau has determined that the Proposed Program would not have any significant effects on the environment, said Alex Traverso, who works with the BCC. Public hearings will follow…(more)