What I heard at yesterday’s Bike Plan Impedimentation Team meeting

zzzt! mayday mayday! bike plan under attack! zzzzt!

Yesterday, Tuesday May 3rd 2011, when I should have been doing important stuff (like raising funds for CicLAvia), I took my afternoon off to attend the city of Los Angeles’ monthly “BPIT” meeting. The “Bike Plan Impedi… er… Implementation Team” is a monthly meeting where, theoretically, city staff meet with interested non-city staff and figure out how to implement the city’s Bike Plan… or not.

Yesterday’s meeting was particularly frustrating because the city is proposing to spend 500 thousand dollars to spend “12-18 months*” to decide whether it will implement 100-200 thousand dollars worth of bike lane projects. The main issue is whether the city has to spend huge amounts of money studying environmental impacts before proceeding with implementing approved bike lanes. Here are a few excerpts from the meeting… I’ve definitely reworded them, putting them in my own words.

Exchange 1:

City Staff: We asked consultants who get paid to do expensive studies, and they said the city should pay to do expensive studies.

Public: Did you talk to cities, like Long Beach or Burbank, that have been successful in bike project implementation?

City Staff: No. The consultants said we should pay and delay, so that’s what we’re doin’. 

Exchange 2:

City Staff: We met with a city attorney and they said that we should do these studies.

Public: Even though the city’s own guidelines** say we don’t need to?

City Staff: Yes – pay no attention to those guidelines. Time to delay is now.

Public: Did you get the city attorney to put that in writing?

City Staff:  No. The city attorney just verbally said we should pay and delay, so that’s what we’re doin’.

Exchange 3:

City Staff: We decided that we need to study, pay and delay on these projects but not on those projects. And some of the projects we told you we weren’t going to delay – well, we’re delaying those… and some of the projects we were going to delay, well, we decided maybe not to delay.

Public: How did you decide which projects to delay? What’s the threshold?

City Staff: Well, it’s a complicated engineering thing, you wouldn’t understand it. It’s really complicated. Trust us.

Public: Please share your data and results with us so we can review it. [repeat five or six times]

City Staff: Well, if you insist, we’ll reluctantly share our data, in a couple weeks or so, but we don’t think you’ll understand it. (following on indignantly) We’re all on this team together. Why don’t you trust us?

Public: We don’t trust the LADOT [Department of Transportation] because the LADOT has lied to us before.*** Show us the data. If you want trust, build it.

And that’s the topsy turvy world of the BPIT. It occurred to me that bicyclists should really let the Mayor Villaraigosa and councilmembers know that the bike plan they touted, with 40-miles of bikeway per year is being delayed and demolished before our eyes.

Here’s a sample letter to the mayor – you can post it via email at his website:

Honorable Mayor Villaraigosa –

Please make sure that you make good on your promises to implement bike lanes. The Departments of Transportation and Planning are blocking and delaying these projects. Please exercise your leadership to make sure bike lanes are implemented at the 40-50 miles/year specified in your plan. Don’t delay.

Thanks for your attention to this important matter!


Send an email to the mayor and to your councilmember.

* Regarding “12-18 months” for environmental review. City staff clarified that the clock doesn’t start on this until, at earliest, this fall. My hunch is that “12-18 months” is a euphemism for 2-4 years.

** City of Los Angeles Environmental Quality Act Guidelines, adopted July 31st 2002, Council File Index 02-1507, page 15 listing of projects exempt from environmental clearance, #13 “The creation of bicycle lanes on existing rights-of-way.”

*** For the most egregious and well-documented example of LADOT lying about bike lane stuff, see the Reseda Boulevard bike lane lies, where the LADOT in writing said it had no plans for additional car lanes, even though those plans had already been reported in writing by the LADOT. Told in gory details here.

30 thoughts on “What I heard at yesterday’s Bike Plan Impedimentation Team meeting

  1. Email sent to hizzoner, and when I get home, I’ll dash one off to Herb Wesson, my council member.

  2. Mayor and Garcetti e-mailed. Boy, do I hope I’ll have the pleasure of riding some of the planned bike lanes sooner than 2-4 years from now.


    Did they think this was over after that goddamned POS plan passed through council?!

    The uber strategy on this is to wait it out until the lame duck mayor is gone, or checked out mentally. With the new administration (whoever that is going to be), the staff at the LADOT have a chance to pollute them early on and keep us away from them.

    They also have the ability to act while we are unfamiliar with whomever gets elected.

    What is the plan? Can I help?

  4. Genius. After years of taking copious notes and getting down precise quotes from officials in city meetings, I now see that there is much more communicative power in an imprecise summation that foregrounds the tone and tenor of the exchange.
    After all, we know only too well that to read officials’ positions is not to pay attention to what’s said but what’s actually not said but communicated clearly nevertheless.

  5. @Plebis – welllll… these definitely definitely aren’t quotes, and not even summations… they’re a product of my thinking about what was said… and replaying it in my head… and crystalizing it into over-the-top expressions of my feelings of frustration at the difficulty of getting the city to take steps in support of implementing bike facilities.

    @Josef – I think we need to keep pressure on staff and on elected officials now. If we wait, we allow them to set precedents that we have to work to undo later. I think it’s going to take culture change at the top of LADOT… which probably has to wait until the next mayor… but we still need to press today.

  6. What Josef said. These people are delaying until the mayor is out. Joe do we need more people to show up next meeting?

    Sending emails now.

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  9. “500 thousand dollars to…decide whether it will implement 100-200 thousand dollars worth of bike lane projects”? Fantastic numbers–in the original sense of based infantasy. Here are the actual numbers from the Planning office–and yes, I do trust them, since the data are available for outside review:

    There are currently 21 projects total[ing] 43 miles planned to be bundled for CEQA review.

    We’re estimating $500,000 for the EIR.

    Typically, each bicycle lane costs $50,000/mile which at 43 miles would amount to $2,150,000.

    The review does not apply to streets with bike lanes only if they can be implemented without removing traffic lanes. When road diets are proposed–something we all want–that generally triggers a review.

    The “expensive consultants” Planning used, who recommended the CEQA review, were Wilbur Smith Consulting, who worked on the Oakland and San Francisco bicycle master plans, as well as CHS Consulting Group, who worked on the San Francisco bicycle master plan.

    Even if accidental, this counts as learning from the experiences of other cities.

    There are plenty of issues about which we can legitimately nag at the City, but making accusations without doing some basic research first destroys our credibility.

    If we want this plan to succeed, we should do what we can to forestall NIMBYism.
    Even Portland still has pushback against bike projects and has cancelled a couple recently, and, as was brought up in the BPIT meeting, San Francisco’s plan was stalled for nearly four years by a NIMBY lawsuit.

  10. Joe,

    Thanks for posting the exemption guidelines. Do you have the significance thresholds handy as well? I read the exemption you cited as allowing the addition of bicycle lanes to an existing road right of way, not a carte-blanche exemption to alter an existing road configuration for the purposes of adding bike lanes. I suspect that City staff is reading it the same way I am.

    In other words, adding a bike lane is an exempt action, but removing a travel lane or parking are not.

    Our challenge to their environmental review process is more about the question of significance thresholds rather than categorical exemption. For example, increasing the number of parking spaces that can be removed before an impact becomes potentially significant would shift many projects into a lesser degree of environmental review. Likewise, changing LOS metrics to include some kind of multimodal LOS rather than just delay per driver could mean that a project that degrades auto-LOS but improves multimodal LOS (such as a road diet) could also be considered less than significant.

    My understanding of how Long Beach gets around CEQA is that they implement a pilot project, then use the pilot period to study the “potential” impacts, i.e. whether or not they actually occur. That skips the need for expensive consultants to make debatable predictions because instead you have a defensible set of data supporting the change (or supporting modification as the case may be). Anytime the environmental review would be costlier than the project, this ought to be the approach.

    I share your frustration with using environmental laws to hold up projects that ultimately benefit the environment, but here’s where I’d focus our energy:

    1) Aggressive use of “pilot” projects to document impacts from various projects.
    2) Revisit the CEQA thresholds to be as loose as justifiable based on pilot data. I.e., just how many parking spaces can be removed before impacts are deemed significant? Or, what is the largest volume of vehicles that can be accommodated after a road diet before delays are deemed significant?

    These targeted criticisms of staff’s proposed process will be ultimately more successful than blanket opposition to environmental review.

    As always, thanks for all you do,

  11. I see no mention in those guidelines for the removal of a car lane. That is, I don’t see where in the City’s CEQA guidelines there is a “threshold” for a lane to be removed triggering a Categorical Exemption, MND, or an EIR.

    What is the “threshold”? The threshold is the reason small side streets in Los Feliz in front of million dollar homes have speed humps, but the side street in front of my house in Lincoln Heights is unmaintained and intentionally configured to be dangerous for pedestrians and kids playing in the street: political will.

    The city has pulled lanes and calmed traffic from lots of streets over the years, usually after tons of citizen complaints and a big stink about safety and property values.

    The “threshold” is the political fear that removing a lane on a Secondary Highway, or a Major Highway, will cause heads to roll and op-eds to be written that will hurt the departments in charge of the lane removal.

    Never mind that the LADOT and Planning do enough to smear their own names without having bike lanes thrown in to the mix to make them look even worse.

    That is why, after reading Joe’s post, I realized that once again the only way forward is by kicking, screaming, and generally being unpleasant and loud about it. They have their “threshold” and we have ours.

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  13. Goes to show that plan development and adoption is “easy” – the hard part is in this implementation and “mission accomplished” can’t be claimed for quite a while. Good caution for us in the South Bay as we push forward on plan adoption the summer/fall.

  14. Josef, section L: Transportation of the City’s CEQA Thresholds Guide states the following threshold for changes to the street system. There is a significant impact if:

    V/C ratio increase >0.040 if final LOS* is C
    V/C ratio increase >0.020 if final LOS* is D
    V/C ratio increase >0.010 if final LOS* is E or F

    where V = volume and C = capacity of the intersection, and “final LOS*” is the predicted future LOS at the intersection. This is on page L.1-3.

    This is undoubtedly a carcentric nonsense threshold, but you’re wrong in saying that there is no threshold to remove a travel lane. It’s bullshit – yes – but it’s still a legally binding document.

    I think the proper response is for the BPIT to report Every Single Week on progress towards changing the city’s CEQA guidelines. We should also be carefully examining the travel demand models and seeing if they make the mistake many such models make, which is to assume that vehicle trips are always going to go up, linearly, forever into the future.

    If we don’t change these, we will spend millions on studies just to meet the bare minimum of the CEQA law.

  15. I am so god damned happy that you wrote that response Herbie. Now we have the magic threshold for environmental review with a lane removal. Eric B.’s suggestion to “pilot project” things sounds like the most reasonable solution now.

  16. I’m glad that was helpful! I’m going to wonk out more in the hopes that it continues to be helpful:

    Also, to clarify – under CEQA, we can still do projects that have “significant” impacts. The law requires EIRs for these projects, but says nothing about whether or not they can proceed. The purpose of CEQA is to inform local decision makers about the environmental impacts of their actions, not to determine the actions themselves.

    Another clarification is that every city can set its own local threshold for traffic impacts. Auto intersection LOS, which the City of LA uses, is pretty much the worst metric out there. It’ll always lead to road widening mitigations and paint traffic calming and road diets as environmental terrorists.

    So, I can think of a number of reasons other cities have been able to remove travel lanes, and there’s no reason we can’t make all of them apply to LA:

    1) they found streets with excess capacity where removing a lane wouldn’t impact LOS or whatever their local metric is. I suspect this is the case for many of the Long Beach projects, like 3rd and Broadway protected bike lanes. Those were on one-way streets that had like 5 lanes each, so I can imagine they had some room to shrink. (I think the use of pilot projects is more about nonstandard designs under AASHTO, not about CEQA).

    2) they’ve adopted a more progressive local metric for traffic impacts, like multimodal LOS or auto trips generated (SF uses auto trips generated)

    3) even when their projects did have significant impact under CEQA and their local threshold, they documented it according to the letter of the CEQA law and then proceeded anyway (This describes basically every huge development that has ever been built in LA).

    4) All of the “impacts” are based on predictions about the future, which comes from travel demand models. So I can imagine that other cities’ travel demand models do things like:

    4a) project that growth in travel will be accommodated by alternative modes, because that is their overarching transportation investment and transit-oriented development strategy (SF does something like this I bet);

    4b) account for mode shifts when we improve transit services and build out bike networks. all of this makes the resulting predictions about intersection LOS measures not quite as severe.

    As far as I know in LA, the travel demand model is controlled by and inherited from SCAG, but also as far as I understand, LA can ask SCAG to modify the model to account for local policies. I think this is a lever we should be pulling and pulling now.

    I think we continue to bang hard on the goal of 40 miles per year. It’s up to LADOT and the Department of City Planning to work the wonky carcentric kinks out so we can get there. A strategy of EIRs in the short term and more overarching progressive transportation policy changes (like using ATG instead of auto LOS) in the long term – makes sense to me. But I don’t really care how they do it, as long as they consistently hit the 40 miles / year target.

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  18. Herbie,

    Where is it written that LA uses SCAG’s travel demand model?

    By the way, you dun goofed because now every time I have a CEQA-bike question I am going to backtrace your email and bug you.

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  20. Right at the top of the City’s CEQA Guidelines there is this:

    “Would the project cause an increase in traffic which is substantial in relation to the existing traffic load and capacity of the street system (i.e., result in a substantial increase in either the number of vehicle trips, the volume to capacity ratio on roads or congestion at intersections)?”

    So, let’s take a street like North Figueroa Street and remove a through lane.

    Does this increase the numbers of cars using the street? No.

    Does this increase the number of vehicle trips? No.

    What is affected? The “volume to capacity” ratio of the street.

    The capacity of this particular street is 30,000 to 50,000 cars per day. Most intersections on this street will be lucky to see 20,000 trips per day. Only the intersections near freeway entrances get close to 30,000 trips per day.

    So, we’ve got a street with a lot 10,000 cars worth of headroom on it.

    Now all we need are the models these guys use to plug their own numbers into and see what is really happening.

    I sincerely doubt that “congestion” is going to ruin LA’s streets once we install bike lanes. Car traffic is not an unstoppable leviathan – it is made up of individuals, and we are notorious for changing our minds and using other modes or skipping trips with our cars when it is inconvenient to use them.

    I’d like to see how traffic is modeled in LA’s backrooms.

  21. If anyone would like to see the City’s guidelines to filling an environmental impact report (and other stuff) with the City, check out the (now defunct) Environmental Affairs Department’s web-page:

    In the City’s CEQA Thresholds manual, it laughable that this is being applied to a car lane removal to install a bike lane. The entire document is written to apply to the construction of buildings.

    There is even a section for Transportation Demand Management (i.e. strategies for eliminating car trips within a project area). Here is my favorite passage:

    TDM Measures reduce single occupancy vehicle (SOV) trips and encourage ridesharing and transit use. Individual measures and actions which could be included in a TDM plan include the following:


    – Encourage non-vehicle modes, such as bicycling, walking, or telecommuting;

  22. If you can’t beat ’em join ’em. Anyone want to start a consulting firm with me? Why let the folks in Portland make all the big bucks? Wait, I’m wasting precious billable minutes posting this comment . . .

  23. Regarding SCAG controlling the travel demand model, I can’t find anywhere that that’s written. It’s my understanding that because SCAG is the regional transportation planning body, it writes the models. Since transportation crosses city and county boundaries, project impacts have to be modeled across boundaries, too, and none of the cities or counties own a model that does that. The general term for SCAG is an MPO, or Metropolitan Planning Organization, and these are federally mandated middlemen that make sure federal money is doled out in a regionally coordinated manner. I found the wikipedia entry on MPOs helpful, although I was hoping for it to confirm that MPOs do modeling, but it didn’t. It might be a California-specific thing.

    I know for some huge projects like NBC Universal the City of LA will require a custom travel demand model for the EIR, which is hugely expensive in my understanding. But for bike lanes and the kind of thing we’re talking about I think they just feed it into the regular model.

    And yeah, the whole CEQA guidelines document is clearly written with development of new buildings in mind. It makes no sense when applied to bike lanes. (And come to think of it, also makes no sense when applied to buildings). Reapportioning the roadway to make biking safe and comfortable has a positive environmental impact, and we all know it…

    Herbie “making CEQA bike-friendly is my middle name” Huff

  24. Herbie, SCAG has a region wide travel demand model. It covers the 38,000 square miles of the region. IIRC it is a four step model, but they are moving towards an activity based model (which will better account for bicyclists). Because the area is so large, the transportation analysis zones are fairly large, and it measures movement between zones (not within them). Great from a large regional perspective, but not at a local perspective.

    Each county within the region is required to have a model that looks at that local level. Their models are required to be consistent with SCAG’s model. There is a modeling task force that meets regularly to make sure everything is consistent.

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