Here’s your quiz for today:
If Tim Lewis Communities, the Roseville-based residential developer and BFF (best financial friend) of Council members Malia Vella and Marilyn Ezzy Ashcraft, is allowed to build its proposed 589-unit project featuring a 14-story high rise on the former Encinal Terminals site, the project will have (pick one):
- Significant and unavoidable transportation impacts.
- Less than significant transportation impacts.
If you picked either one of these choices, you’d be wrong – and you’d be right, too. Both statements are true – it just depends on which section of the draft Environmental Impact Report you read.
We’ll get to the finer points of transportation impact analysis in a moment, but we want to begin with a more fundamental question: Given all of the new development projects already approved by the Planning Board and/or Council, does it make any sense to worry about the incremental impact on traffic congestion of one more project like Encinal Terminals?
First, the background.
We know that any new development project will put more vehicles on Alameda streets. Indeed, we know just how many additional trips the traffic engineers, using the so-called ITE standards, estimate a particular project will generate. Here’s a chart we put together from the published data:
|Project||A.M. Peak Trips||P.M. Peak Trips||Total Additional Trips|
|Del Monte Warehouse||279||383||3,861|
We also know where the traffic engineers believe these vehicles will be going to or coming from: the crossings over the Estuary. According to the published data,
- 56 percent of the new trips to or from the Boatworks project, and 55 percent of the new trips to or from 2100 Clement, will travel over the Park Street bridge;
- 10 percent of the new trips to or from both Boatworks and 2100 Clement will travel over the Fruitvale Avenue bridge;
- Between 50 and 60 percent of the new trips to or from Alameda Landing, 60 percent of the new trips to or from Marina Shores, and 43 percent of the new trips to or from the Del Monte Warehouse, will travel through the Posey-Webster tube.
(Unfortunately, we were unable to find similar trip distribution data for Alameda Point.)
Council and/or the Planning Board already have approved each of these projects. (Caveat: The approval for the Boatworks project involved a design that has been superseded.) So even without Encinal Terminals, the green-lighted developments are projected to produce a total of 66,806 new trips (4,855 during morning rush hour and 6,731 during the evening rush hour) on Alameda streets – and the majority of the vehicles will be joining the queue at one of the Estuary crossings.
There are other projects in the pipeline, not just Encinal Terminals, that will boost these totals. Catellus has presented preliminary plans for the last phase of Alameda Landing that include 445 new housing units and 150,000 square feet of commercial space. Pacific Shops, Inc., has submitted a draft master plan for 670 new housing units and 150,000 square feet of commercial and maritime space at the site of the Alameda Marina. And let’s not forget Shipways and North Housing, two other sites where development is likely to occur. At this point, no trip generation or distribution data is publicly available for any of these projects.
The Encinal Terminals project itself, of course, will generate additional traffic: according to the draft EIR, a total of 4,438 new trips, of which 236 will occur during a.m. peak hours and 393 during p.m. peak hours. Of the new trips, 43 percent will go through the tubes and six percent apiece will go over the Park Street and Fruitvale Avenue bridges.
And so we return to our question: Given the volume of additional trips already expected to result from approved development projects (not to mention those in the planning pipeline or in someone’s pipe dream), will the extra trips produced by Encinal Terminals make any material difference to traffic conditions along the northern waterfront? If traffic will be bumper-to-bumper anyway, there would seem to be little reason to care about a few more cars at the end of the line. It’s like going to the doctor when you’re experiencing excruciating pain. Does it really matter whether it’s an “8” or a “9” on a scale of 1-to-10?
Yet the City continues to try to quantify the incremental impact on transportation of every new development project. Indeed, CEQA would seem to require no less. The problem is, the methods commonly used for this purpose provide information whose reliability and usefulness are questionable.
Historically, the transportation impacts of a proposed development have been evaluated using the “Level of Service” method, which estimates the “control delay” during morning and evening peak hours at various intersections with and without the project. Each intersection gets a letter grade from “A” (no delay) to “F” (a delay of greater than 80 seconds). A project is considered to have a “significant” impact if it causes an intersection to “degrade” to Level E or F or it increases traffic volumes by three percent or more at an intersection already operating at Level E or F.
It is this method that underlies the finding that the Encinal Terminals project will have “significant and unavoidable” transportation impacts. As a result of the project, one intersection – Buena Vista and Entrance Street – is projected to go from “C” to “F” during a.m. peak hours in 2020 (and, apparently, to exceed the three-percent threshold during p.m. peak hours in that year). The project also will create an unacceptable increase in traffic volume at that intersection during p.m. peak hours in 2035. In addition, another intersection – Atlantic Avenue and Challenger Street – is expected as a result of the project to suffer “significant” increases in traffic volume during both a.m. and p.m. peak hours in 2035.
At first glance, the LOS approach looks pretty scientific. But no one trusts it. Not the members of the Planning Board. (At the March 27 meeting, Board chair Kristoffer Koster declared that his own personal experience belied the “A” grade – i.e., no delay – given to the intersection of Buena Vista Avenue and Grand Street.) Not City planning staff. (At the meeting, Assistant Community Development Director Andrew Thomas used words such as “ridiculous” and “completely inadequate” to describe the LOS method.) And not the preparers of the draft EIR, which observes:
LOS has historically proven to be an inadequate measure in Alameda because residents experience delays [at] certain intersections, yet the LOS analysis indicates that the level of service at that intersection is adequate. The delay that is being experienced is the result of downstream congestion, not a result of the intersection design or the volume of cars moving through the intersection.
But it is the environmentalists who have criticized the LOS method most strenuously – for the very good reason that, being a process designed to estimate traffic delay, LOS doesn’t truly measure the impact of a development project on the environment, particularly air quality and energy consumption. The politicians have acknowledged the criticism and legislated a response. Senate Bill 743, signed into law in 2013, will result in new CEQA guidelines requiring local agencies to assess the transportation impact of a proposed development by measuring “Vehicle Miles Traveled” rather than LOS.
Under the VMT method, the traffic engineers estimate the number of vehicles traveling to and from the project and the average number of miles traveled per vehicle. They then divide the product of those numbers by the total population of the project to come up with a “VMT per capita” figure. A project is considered to have a “significant” impact if it exceeds both the existing city household VMT per capita minus 15 percent and the existing regional household VMT per capita minus 15 percent.
The draft EIR includes a VMT analysis, and that analysis underlies the finding that the Encinal Terminals project will have less than a significant impact on transportation. The draft candidly admits that the City of Alameda already has a lower VMT per capita than the region (and that the northern waterfront already has a lower VMT per capita than the rest of the City). Nevertheless, the regional and citywide numbers (minus 15 percent) establish the benchmark. And, according to the draft EIR, the VMT per capita for the Encinal Terminals project comes in below one of them (the adjusted regional VMT per capita) and is “comparable” to the other (the adjusted citywide VMT per capita). (If you’re interested, the numbers are 12.3, 12.7, and 12.0, respectively.) Since the test is whether a project exceeds both benchmarks, the draft finds that the transportation impact of the Encinal Terminals project can’t be deemed “significant.”
The Merry-Go-Round lacks the credentials to evaluate the legitimacy of the VMT method as a means of assessing environmental impacts or the reasonableness of the assumptions used to compute VMT for Encinal Terminals. But we do note that the VMT approach does not tell the public what many Alamedans want to know: the effect the project will have on traffic congestion. Indeed, the premise of the method seems to be that questions such as this are irrelevant to an environmental analysis.
Nevertheless, people keep asking those questions. Indeed, at the end of the March 27 meeting, Planning Board member Lorre Zuppan implored Mr. Thomas to find some way to come up with reliable data on traffic impact. Her Board colleague, Sandy Sullivan, chimed in that it shouldn’t be too hard to estimate how long it takes to get from Point A to Point B, with and without a project, since CalTrans apparently is able to do it for the freeways. Mr. Thomas, as always, listened respectfully, but he wasn’t persuaded: whatever analytical method was used, he said, “you’d find the exact same conclusion: It’s slow now; adding more housing presumably will add more cars, which will it make it slow-er. . . . [E]very single analysis we do comes to that basic conclusion.”
Now, if we had been sitting on the dais, we might have followed up: So if the planners already know the conclusion, why bother to do any traffic-impact study at all? Instead, the Planning Board (and Council) members could simply assume that the project before them – whatever its size or mix of uses – would make traffic congestion worse. They could forget about whether “transportation demand management” would make cars magically disappear from the streets. And then they could focus on whether the project would promote any important public policy. (We can’t help but relate that one of the public speakers on March 27 offered a novel reason for building more housing in Alameda: to allow people now living in states that voted for Donald Trump to move to a more enlightened community.) If it does, approve it – despite the traffic impacts. If it doesn’t, turn it down – but not because of the traffic impacts.
Our suggested process surely would save staff time and shorten Planning Board and Council meetings. But we can’t imagine any of our local transportation experts, actual or self-anointed, endorsing it. What would licensed professional engineer Eugenie Thomson and Planning Board guru John Knox White do if they no longer had any occasion to write op-ed pieces claiming that the other didn’t understand traffic issues? So we suspect that, even if LOS is interred, VMT will remain an acronym for the planners to throw around for some time to come.
Alameda Landing: 2011-10-24-fehr-peers-transportation-report
Alameda Point: 4c_traffic (final)
Marina Shores: Marina Cove II initial study & MND
Eagle Avenue: 2015-11-09 Ex. 4 to staff report to P.B. – TJKM Letter
Encinal Terminals: Draft SEIR