Reconsidering Level-of-Service (LOS)

LOS Reform: It’s About Mobility, Stupid!

How we regard mobility as a general issue and policy goal will determine how we embark on appropriate enhancements for non-motor mobility. Because capital improvements are costly and emerge from a political process of resource allocation, City Council must sign on. But evaluating new bike facilities on the basis of LOS (that is, to what extent a facility will affect or inconvenience motorists) is not only a mis-measure of the problem; it likely means that proposed improvements will undergo a time-consuming environmental review.

Like many tools, LOS is a tool designed to accomplish a specific purpose. But like many tools, LOS is also encumbered by a legacy application that may not fit today’s needs. Today we’re framing the urban mobility issue in terms of moving people and not merely vehicles, which suggests that LOS alone may not be an appropriate measure of project or policy impact. By moving beyond the mechanistic aspect of vehicular flow, LOS reformers reframe urban transportation problems in terms of mobility opportunity.

The active transportation community brings LOS reform to the table because we must consider mobility broadly when evaluating a project for net new transportation impacts. For that bike lane or road diet, for example, we could ask, Does it provide an identifiable benefit to overall mobility? Does that offset somewhat slowed traffic? (The latter is an often-recommended safety enhancement, by the way, but under LOS it would count as a negative net impact.)

That’s why the transportation advocacy community has sought to re-frame of the debate from traffic demand management to mobility broadly conceived. In the past, transportation practices literally marginalized people who bike to the unsafe edge of the road. We want to broaden indicators like LOS to account for improvements that create a more livable and sustainable city.

Academics, too, are questioning biases that blinker planners to new approaches to mobility challenges. A memorable critique in this regard was advanced by academic Donald Shoup at UCLA, who noted the “high cost of free parking” in his book by that name. According to Shoup, motorists alone enjoy the benefit, yet it’s an expense that imposes a cost upon everyone. By mandating minimum parking requirements and attaching no price to public parking, Shoup said, we over-provide parking capacity while precluding more cost-effective mobility measures like transit or active transportation enhancements.

LOS Reform Now!

The movement for LOS reform is proceeding along a couple of tracks: either broaden the metric to include non-motor modes of travel, which seems like something we would want to measure if we’re to understand quantitatively the relationship between projects, policies, and the movement of people; or else subordinate LOS in the environmental review process to pull back and look more broadly at mobility as a multi-dimensional concern.

San Francisco has taken the latter approach, as suggested by the city’s position as detailed in Automobile Level of Service: A Liability for Health and Environmental Quality [pdf]. San Jose, on the other hand, is working within the existing LOS framework but relaxing the standards somewhat to help avoid mandatory environmental review for mobility-enhancing improvements that fall short of review in the broader mobility context.

The need for LOS reform came to the foreground in 2006 when San Francisco planners found their proposed bike improvements put on the back burner for five years pending resolution of a lawsuit over this very issue, for example. Read more in the San Francisco Bicycle Coalition’s primer on problems with LOS.

In City of Los Angeles, too, DOT’s program for larger bike improvements hit the yellow flag when officials became concerned that legal challenges under CEQA might mire projects in legal limbo. As a result, the road diet that would improve the travel experience of many road users falls by the wayside.

The Atlantic piece, The Transportation Planning Rule Every City Should Reform, gets to the heart of the problem by honing in on the costly and lengthy environmental review required of even small projects like bike lanes because they are presumed to inconvenience one class of road users – motorists. The standards by which improvements are evaluated using LOS under CEQA can make the difference between timely and cost-effective mobility solutions versus continuing the status quo and the increased congestion it promises.

From a policy perspective, then, LOS reform is really about matching the practice of transportation planning and engineering to sustainable transportation policies, which are often already on the books, as the Atlantic’s Jaffee noted. Jaffe’s piece is worth a read as a general overview of the issue, and as a reminder that health, safety, sustainability and livability, have emerged as key issues.


We need to question the practices of transportation planners because their toolbox is unprepared to address the magnitude of the congestion problem. We want new standards and practices that get people moving, not simply that increase vehicular traffic. After all, we’re topped-out on capacity. But we’re also bottomed-out on mitigation measures. Dedicated turn lanes and timed signals move motor traffic incrementally more efficiently. Programs seek to shift commuters to off-peak hours, but non-traditional scheduling (as embraced by Beverly Hills in the ‘9-80’ program) seem counterproductive because they don’t ameliorate today’s work-housing spatial mismatch. Instead flex time makes commuting as many as 60 miles each more convenient.

The transportation planning toolbox desperately needs restocking. It’s not well-suited to the post-auto era and it actually stands in the way of retooling our cities for an environmentally-sustainable future. In this regard, San Francisco’s effort to rejigger the process represents a significant acknowledgment by policymakers there that the current transportation planning toolbox isn’t serving our larger policy goals particularly well. Unless like Beverly Hills the goal is increased vehicular throughput.