San Francisco Planning Commission opens review of Auto LOS, weighing trip‑based and health‑focused alternatives

The San Francisco Planning Commission on July 12 held an informational hearing on whether to replace automobile level‑of‑service (LOS) — the longstanding A‑to‑F congestion metric used in CEQA transportation analyses — with measures better tied to multimodal performance and public health.

Transportation Authority Senior Planner Rachel Hyatt told the commission the Authority has recommended an alternative based on auto trips generated by projects and is developing quantitative thresholds and a roadmap for adoption. "We can, as a local agency, define for ourselves how we measure transportation impact in San Francisco," Hyatt said, arguing an auto‑trips metric would better align CEQA with the city's Transit First policy.

The Department of Public Health urged metrics tied to health outcomes. "Auto LOS doesn't measure any environmental impact. It measures delay," said Dr. Rajeev Bhatia, medical director for occupational and environmental health. Bhatia described street‑level models of traffic air pollution and a pedestrian quality index his team is developing, and said measures should reflect access and safety rather than vehicle speed or delay.

The Bay Area Air Quality Management District advised caution about substituting LOS for direct air‑quality measurements. David Birch of the District said LOS appears in current guidelines only in relation to localized carbon monoxide hotspots and outlined existing screening triggers — for example, increases in CO pounds per day or traffic growth above 10% — that prompt further modeling. "LOS is not a CEQA air quality threshold in and of itself," Birch said.

Planning Department staff member Bill Wiecko summarized the department's practical concerns: any replacement must be based on substantial evidence, preserve a clear nexus for mitigation, be administratively implementable, and be defensible in court. He described the Transportation Authority's work to date and noted the legal and operational complexity of translating auto‑trip concepts into thresholds and mitigation programs.

Members of the public and stakeholder organizations overwhelmingly urged change, saying LOS has blocked bike lanes, bus rapid transit and other projects that reduce vehicle dependence. Advocates and planning groups — including the San Francisco Bicycle Coalition, SPUR, the Association of Bay Area Governments and speakers from Park Merced — described how LOS can stall infill housing and active‑transportation projects by triggering expensive environmental review. Dave Snyder of SPUR urged the Commission to set staff deadlines and to move decisively so CEQA guidance does not continue to stall projects.

Opponents warned of unintended consequences. Rob Anderson, a party to litigation over the city's bicycle plan, said lowering car throughput risks creating hardship for drivers and for Muni if lanes are repurposed. Several commissioners voiced similar concerns about balancing livability goals with economic impacts, visitor traffic and the need for reliable transit capacity.

Commissioners directed staff to continue working with the Transportation Authority, the Department of Public Health and the City Attorney; staff and TA officials said a draft final report would go to TA's citizen advisory committee in September and to the Authority's board in October. The Commission asked staff to return with briefings and recommended the Transportation Authority involve Planning Commission members as the report is finalized.

The hearing produced no formal motions or votes. Commissioners closed the public comment period after a lengthy exchange and scheduled follow‑up engagement with agency staff and the Transportation Authority as the Authority completes peer review and final recommendations.