I wrote up an L.A. Streetsblog news story about the Planning Commission meeting where I presented this… for general information go there (and, for serious gluttons who’re interested in my take on the evolving city bike plan… I’ve written what seems like an ongoing serial – maybe read one or more of these: 2Nov2010 and 9Oct2009 and 4Jun2009.) I am going to try to explain the chart again here – for the first time in writing. I figured I should make the chart, because for my testimony I would have only two minutes to try to get across a complex legal issue in the plan.
The chart applies to bike lane projects. These are on-street facilities – just a painted line designating a 5-foot lane for bikes. The lanes that run alongside car traffic. Examples in L.A. include Silver Lake Boulevard, Venice Boulevard, Reseda Boulevard and others.
For future bike lane projects, some are easy and some are more difficult. Easy ones involve just adding a new stripe and lane without removing anything from cars (or in some cases narrowing existing car lanes slightly, and/or removal of small amounts of parking.) More difficult bike lane projects remove one or more car travel lanes (or remove large amounts of on-street parking.) The continuum from easy to difficult is shown as the central horizontal line in the middle of the chart.
The draft plan has ~550 miles of future bike lane projects. These are divided up into two categories: ~50 miles of “future” lanes and ~500 miles of “further study” lanes. The plan states that the “future” lanes are ready to go right away without additional analysis and that the “further study” lanes are “speculative” and “may ultimately be deemed infeasible” and “will require additional analysis … pursuant to the California Environmental Quality Act (CEQA).” Hence the plan draws a line between easy, cheap, ready projects vs. expensive, time-consuming possible projects. That line is represented by the vertical dotted line on the left side of the middle of the image.
Bike lane projects are relatively cheap – essentially the cost of paint (and some engineering.) The city estimates them at $28,000.00 per mile – though when they’re done in conjunction with resurfacing, they’re much cheaper than that. If the city performs a full Environmental Impact Review (EIR) under CEQA, then it can spend a half-million to a million dollars on the project – making it an order of magnitude more expensive.
Where the city draws the line (between non-EIR and EIR bike lane projects) can dramatically alter how much the plan costs, and how long it takes to be implemented. If the line is drawn too far to the left, implementation becomes very expensive and time-consuming. (On the other hand, if the line is drawn too far to the right [emphatically not the issue here], the city could be over-ambitious and potentially risk lawsuits from drivers.)
The place where the city stated they drew the line was that any project that removed a car travel lane would “require” CEQA analysis. The vertical dotted line represents where the non-EIR/EIR line was proposed in the new plan – 50 cheap project miles on the left, 500 difficult expensive project miles on the right.
What was insulting to me was that the plan, purporting to be the city’s guiding document for making things better for cyclists, was drawing this line at a more difficult point than the current city practice. There’s no official line that says when a bike project needs an EIR (and to my knowledge the city has never done an EIR specfically for a bike project) but there are projects that the city does today that remove car-travel lanes to add bike lanes. These aren’t common, but the city has done about a dozen that I am aware of – recently including Myra Avenue, Wilbur Avenue, San Pedro Street, and Hoover Street. These projects that the city does cheaply and easily today would have been made more difficult under the proposed draft plan. On my chart I showed the existing city practice as a vertical dotted line.
I think Icovered it ok in 2 minutes… I had to go fast to fit all this in… but I mainly reiterated that the draft plan would make it more difficult, more expensive and more time-consuming to implement new bike lanes.
I included this text on the back side of the yellow flier:
Bike Plan Comments re: Environmental Review
Joe Linton linton.joe [at] gmail.com – 4 November 2010
Biggest poison pill (of many) in the draft bike plan: Revising the city’s CEQA threshold to make bike lane implementation more difficult than today.
Language in plan: (bold added)
– p.94 ch 5 “Potential lanes are considered speculative at the present time. … Potential lanes may ultimately be deemed infeasible.”
– p. 96 ch 5 “Bicycle lanes identified as Potential will require additional analysis (particularly impacts on traffic) pursuant to the California Environmental Quality Act (CEQA)”
– continuing p. 96 ch 5 “the [CEQA] analysis may determine that the originally selected roadway is not well suited for a bicycle lane and alternative roadways within the general corridor will be considered.”
Essentially this says: for a ~$100K project, the city will spend ~$1M and at least a year studying, before implementation or may deciding not to implement anything. While some projects may require CEQA, the LADOT currently does similar bike lane projects without any CEQA review – so, the plan establishes a new, more difficult threshold for bike lane projects, making them more expensive and more time-consuming.
– Establish a strict CEQA threshold using specific quantifiable objective targets. Using quantifiable defensible targets can protect the city from CEQA lawsuits.
– For plan-designated streets that meet the threshold, the city commits to implementing lanes without full environmental review – based on the threshold establishing that the project will not have significant environmental impacts. For plan-designated streets that exceed the threshold, the city can require full CEQA review.
– The devil is in the details; if the quantifiable threshold is set too difficult, it will inhibit implementation, possibly worse than the current draft plan. Threshold analysis would need to not result in “throwing the baby out with the bathwater” – for example, a single busy intersection at one end should not disqualify an entire 5+mile long designated bikeway.
– Current national standards that support complete streets would suggest thresholds similar to the following national practices:
o 4-to-3 “Road Diets” (implementing bike lanes by reducing four car lanes to three – going from 2 travel lanes in each direction to 1 travel lane in each direction, with a center turn lane) can generally be done without significant adverse effects on car travel for streets with ADT (Average Daily Traffic) of 20,000 or less.
o A single travel lane can generally support 1000 peak hour car trips.
– Actual threshold will require professionals (planners and engineers) to set these levels. It would be worthwhile to consult with folks (outside LADOT) who have experience with implementing bike lanes.
Luckily they city is backing off of this apect of the plan. The morning of the commission meeting they decided to eliminate the two categories (future vs. further study) – something cyclists had been asking for about a year and a half. So, the main problem I was bringing up was resolved. Yay! Though a few other issues remain.
I was happy to see Barbara Romero, a City Planning Commissioner (and a friend of mine from work on parks along the Los Angeles River) holding up my chart in this group photo.