The Feds Want to Reform the Cult of “Level of Service”

FHWA is trying to encourage states and localities to move away from using Level of Service. Cartoon by Andy Singer, via PPS.
The old way of making transportation decisions prioritized the movement of cars above all. The Federal Highway Administration will encourage local agencies to shift to other methods. Cartoon: Andy Singer via Project for Public Spaces

“What you measure is what you get,” the saying goes.

That’s certainly true for transportation policy. And for a very long time one metric has reigned supreme on American streets: “Level of Service,” a system that assigns letter grades based on motorist delay. Roughly speaking, a street with free-flowing traffic gets an A while one where cars back up gets an F.

Level of Service, or LOS, is what traffic engineers cite when they shut down the possibility of transitways or bike lanes. It also leads to policy decisions like road widenings and parking mandates. Even environmental laws are structured around the idea that traffic flow is paramount, so they end up perpetuating highways, parking, and sprawl. Because if the top priority is to move cars — and not, say, to improve public safety or economic well-being — the result is a transportation system that will move a lot of cars while failing at almost everything else.

The good news is that there’s a growing recognition inside some of the nation’s largest transportation agencies that relying on LOS causes a lot of problems.

Just last week, the state of California introduced a new metric to replace LOS in its environmental laws. Instead of assessing how a building or road project will affect traffic delay, California will measure how much traffic it generates, period. Car trips, not car delays, will be the thing to avoid. This is likely to have the opposite effect of LOS, leading to more efficient use of land and transportation infrastructure.

Change is afoot at the federal level too. Officials at the Federal Highway Administration are looking at how they can spur changes like California’s LOS reform in other places.

Barbara McCann of the Policy office of the Secretary at U.S. DOT told Streetsblog that her agency has been charged with reviewing internal policies that are an obstacle to better biking and walking. “LOS is something that has come up with that,” she said.

Barbara McCann, director of the office of safety, energy, and the environment at the secretary's office of U.S. DOT. Photo: Barbara McCann
Barbara McCann of the Policy Office of the Secretary for Transportation at U.S. DOT. Photo: Barbara McCann

Despite what you may have been told, “there is no federal mandate for Level of Service,” she said. The federal government has never compelled state and local governments to emphasize LOS above all. But Level of Service is a deeply ingrained engineering convention. Transportation planners might not be attuned to the value judgments inherent to LOS, or to its flaws.

What FHWA can do is accelerate the adoption of alternatives to LOS. Over the next year or so, McCann says, the agency plans to actively encourage state and local policy makers to consider different performance measures.

As a first step, FHWA will soon release a case study about a local agency that is moving away from using LOS. Then the agency will develop a peer-to-peer exchange, where cities and states can share ideas and experience about shifting to other metrics.

Finally, as required by the 2012 federal transportation bill, MAP-21, FHWA is working on a whole new set of performance measures for American transportation agencies. The law specifies, for the first time, that states DOTs should track how they perform in terms of safety and environmental protection. The law requires state agencies to set goals and report progress toward meeting them.

One of the big unknowns is how the federal performance measures will define “congestion,” which is one of the metrics state DOTs will have to assess. The law does not specify that congestion must be assessed using LOS, but federal regulators could decide to do that — and if they do, not much will change. A much better option would be to use a metric closer to what California is doing — traffic generation, not driving delay.

The rule-making period is currently in progress, and McCann said she can’t discuss details during that time.

  • Gary Nelson

    Interesting that USDOT/FHWA claims they have never imposed a LOS standard. Like benefit-cost it does not exist as a regulatory standard but is an implicit criterion. Unless “congestion” is ignored completely, unless the implicit benefits of “travel time saved” are ignored, and unless the technical design criteria via AASHTO and the Highway Capacity Manual are discarded, LOS will persist. The same lack of explicit criteria in the USC/CFR for LOS will make it difficult to define exactly what is to be changed legally or methodologically.

    Further, where does VMT get us? In the CA case, the issue is what highway capacity is required for a development and its trip generation. As a regulation on development, VMT vs. LOS can encourage trip-generation and modal efficiency. But USDOT/FHWA does not deal with the “land use” end but with the traffic imposed by any and all development. What exactly are they going to control via VMT criteria? If VMT applies as a metric on MPOs, they similarly have in most cases no control of VMT in trip generation, although there may be some weak modal-investment leverage. Unless we face up to a general land-use/transport regulation in all urbanized areas (highly unlikely) I suspect the proposed policy is nugatory.

  • SZwartz

    Beware of that for which you ask.

    The mega-developers want to use bogus data to assert that Bike Lanes going to TODs will reduce number of vehicle trips and similar foolishness, e.g. more people will use subways. The reality is looking different.

    In Los Angeles, TODs greatly increase and concentrate cars in the areas near the TODs. The fact that people who live in TODs seldom use the subway and seldom use a bike for commuting has been accumulating since 2000. Because almost everyone who moves into a TOD brings at least one car and uses that car, the number of car trips INCREASES near TODs. They also make the LOS worse in that area — that is a double whammy to the TOD.

    The developers foolishly counter with the argument that if they do not construct parking spaces, people cannot have cars in TODs and that will reduce traffic. Instead, they say, people will use Uber etc. That argument is absurd as using Uber turns each auto trip into two (2) trips. The Uber driver has to drive to and from the TOD in addition to the 2 trips to take you somewhere and bring you back home. Agin, both measures become worse — if you bother to measure anything at all.

    Whether one measures LOS or not, people know what it is from their own experience and we know what happens when LOS fall to F — people move away. A major factor in CD 13’s losing so many residents between 2000 and 2010 that it ceased to be a legal council district is that traffic congestion became so horrible that people packed up and left. The terrible schools and rising crime were contributing factors, but traffic congestion and lack of parking were cited as the top reasons.

  • thielges

    It sounds as if you are describing a transient situation. Place a TOD in the middle of a sea of sprawl and residents will still want to drive even if a small proportion of their destinations are transit-distant. But continue to build up TOD and associated transit and those reasons to drive dissipate. A good full service grocery within walking distance can make a large reduction in auto trips for example.

    Patience. Reversing sprawl cannot occur overnight.

  • SZwartz

    I have seen zero support for your theory. Instead as the traffic gets worse, more people move away. That is how CD #13 ceased to quality as a legal council district within 10 years of the subway opening and the Projects being built.

    Some social theories and land owners wants to force people to live in highly dense projects. For decades, the vast majority of Americans reject that option.

    Putting a grocery store near a home does not reduce the number of groceries a person needs to buy. I live within walking distance of two major super markets and I have for 45 years, but the main one I use is driving distance. There are factors other than proximity that go into deciding where to shop. I certainly do not want some developer working out a deal with Safeway and then my being stuck with Safeway when I prefer Ralphs. Besides, I cannot carry $150 of groceries without my car and I do not plan to stop daily because I have walk home carrying my shopping bag.

    There is nothing wrong with Sprawl, bu there is something wrong with placing high dense projects near the center of a circular urban area. if we were to construct Bunker Hill or Century City, they should be on the periphery and not near the center. Put a park at the center with low density residential areas and put the offices on the outside of the area — if you need a high rise.

  • Jame

    I haven’t spent much time in LA, so I don’t know how it works. But you can’t just put up housing and a grocery store and think that people will walk there. I live in an old school TOD neighborhood. Used to be on the streetcar route when we had one. This means that essentially the 3-4 block radius of where the train was is pretty dense, above 10k where I live. The streetcar ran into a fully formed commercial district. There is a grocery store, drug store, dozens of shops and restaurants and the like. Post office, dry cleaners and dentists are all represented on the “Ave.” As a result, a lot of people walk very often. There isn’t much parking, which gives you another incentive not to drive. There are also plenty of people who live within a block of the commercial district.

    When going to the Ave most of my neighbors walk. Even the ones that are 60+. It is an easy way for them to go. I ride my bike, and bike to other further places. I also have many neighbors who do not drive and do not have cars. Many drive rarely during the week, they take a commuter bus to work. Walk to the nearby errands. Suddenly their car sits in the garage for most of the week.

    It is also important to note that the walk is generally pleasant. There are people walking, tree lined streets. Most streets are fairly narrow and the cars aren’t speeding by.

    Building a TOD that works is about the ecosystem around it. You can’t just put housing next to a train station and expect it to work.

    Now my city is trying to recreate that similar streetcar feeling closer to the train stops. Some train stops happen to follow the original streetcar route, so it is really just eliminating surface parking and putting up housing. Useful amenities are already established and in walking / biking distance.

  • kagi

    “I cannot carry $150 of groceries without my car “

    Unless you’re buying $150 worth of toilet paper all at once, I seriously doubt that. I can easily carry 50lbs of groceries on my bike with two baskets on the rear rack and a box on top of it; for more than that, I use a cargo trailer that holds up to 200 pounds. And I haven’t even paid up for a cargo bike. You could definitely do your shopping by bike. Lots of people around the world do.

  • SZwartz

    I do not know where you are located, but LA is doing what you say should not be done. It tears down parts of old neighborhoods and constructs TODs. To them TOD is a buzz word and some many people prefer buzz words over thinking, that the developer find it easy to con the public.

    You make a good point that real TODs develop naturally. Ever several blocks, people need services. I live within walking distance of two supermarkets drugs and other shops. It has been that way since I moved in over 45 years ago and by then all those stores were established.

    Parking is still essential. While I can walk, I cannot carry $150 of groceries and need a car. If I buy only dog food, it is within walking distance and when I was young, I would like to carry 50 lbs home on my shoulder as exercise, but I am decades older and i do need the car.

    All the stores with ample parking do very well. The TOD which said we do not need parking as people will walk and use the subway is a gigantic disaster. After 12 year, only one retail space is rented — a a bank. What was on the corner before? A bank. So they spend millions of dollars and destroyed a beautiful corner lot and all we gained was a bank which he already had — but the previous bank had a parking lot and was full service. This bank has a couple parking spots and is limited service.

    People do not deal rationally with cars. Density is the problem, not the cars. Math tells us that if you want office buildings and high rises, they need to be on the periphery. That way the same number of high rises do not create traffic congestion.

  • Jame

    We don’t need to build every housing structure with 2-3 parking spaces per unit. Not every housing place is for every person. Some housing units can have more parking, some can have less. If you need parking, you should get a place that comes with parking. If you don’t need parking, you should have to buy a place with parking. 90% of housing units have parking. A few units without won’t decrease the supply of parking.

  • SZwartz

    “A few units without won’t decrease the supply of parking.”

    Apparently, you are not familiar with the relationship between the ideas of “decrease” and “fewer.” Fewer parking spaces will decrease the supply of parking spaces.

  • Jame

    We are generally “over parked.” There was a study of residential parking across many neighborhoods in my city, in focused on multiunit buildings. The net was 30% of the parking remained unused all day, primarily overnight when generally people need their parking. It varied by neighborhood, but rarely was the parking over 85% full anywhere. A similar study is in the works for LA. We have plenty of supply that could be used more efficiently.

    Why should we require huge amounts of parking in a building when the one across the street is only utilizing 50% of its parking?

  • SZwartz

    Your city is not LA. If you were a doctor, you would refuse to give heart medication to patient #2 because patient #1 did not have a heart condition.

    We have done parking studies in LA and as far bak of Controller Laura Chick it was established that lack of parking was a the #1 or #2 problem — the other issue that alternated with lack of parking as # 1 or #2 problem was traffic congestion.

    Garcetti thought he could force people to use the subway. Thus, the Metro Apartment on S/W corner of Hollywood and Western was grossly deficient in parking. As a result. 1/4 of its retail space is rented after 12 years, while the Ralph’s complex across the street, which was untouched by Garcetti, has ample parking and it is always full.

    Once Garcetti’s anti-parking zealotry took hold, he made such a nightmare of his council district 13, so many people simply moved away, that his district ceased to qualify as a legal council district. We have see what a mixture of TODs with deficient parking has done — it literally destroyed CD 13.

    While not constructing off street parking saves a few million for the developer, the city loses millions of tax dollars forever. The city gives these project millions of dollars in tax breaks claiming that we will recoup all the money via sales taxes. It will be 1,000 years before we come close to breaking even on the Metro Apartments if we rely on the sales tax from its sole tenant — a bank.

  • Jame

    I don’t know the specific intersection you are discussing, but the market conditions based on a specific intersection cannot be globally applied across the entire city. They are adding “TOD” to my closest train station right now. In anticipation they ended up reducing the number of parking spaces by about 2 dozen, in the final tally. And before the new parking structure was created parking was impacted even more.

    What happened in reality over the 3 year period that parking was very constrained? The number of daily users of the station increased, and more people took transit, walked or biked over to the station. The development will be light on the parking when it opened, and target many low to moderate income people who do not drive. The neighborhood already has a current population of about 25% transit only people.

    As for your example? Why can’t the Ralph’s share its parking. Is it always full? What are the nearby neighborhood conditions? It sounds like the Ralph’s is a typical strip mall configuration. Which sounds like a generally unworkable neighborhood. When there are too many strip malls no one wants to walk. It sounds like this TOD was in a vacuum. An island of walkability in a sea of car infrastructure. It may even be out of place and out of scale for the neighborhood.

    There is an older TOD project in my city that has been open a decade. It is partly successfully, but also challenging. It didn’t catalyze walkability into the existing neighborhood. It fronts a conventional strip mall. It hasn’t appreciated a ton. But the surrounding neighborhood is more vibrant now. More people are walking around. And while it isn’t a walkers paradise, less people are driving to the train station. And more people are biking there from further flung neighborhoods. Some of the strip mall is leased to non-profits and such, but it is pretty full and leased up. It took a few years to find traction. It also has good useful anchors: grocery store, drug store and neighborhood serving retail.

    There is a formula to successful TOD, but it sounds like the project you are referencing isn’t working.

    I like in Oakland, and Oakland is pretty similar to LA in terms of layout and neighborhood topology. It has many similar challenges as part of the greater Bay Area, so there are some applicable lessons to LA.

  • SZwartz

    It really is not possible to have a discussion about facts which derive from specific locations when you do not know anything about the locations. I could explain it to you in 10,000 words and they would be gross inadequate to your taking a 10 minute walks around Hollywood and Western.

    If you think Oakland is anything like LA, then you know nothing about LA. Oakland has 55 sq miles, LA has almost 500 sq miles, Oakland has about 391,000 and LA has 3,900,000 people. The to describe LA and Oakland are “entirely different.”

  • Jame

    These things are very neighborhood centric. And in terms of form, cities of all sizes can take lessons from others. Oakland and LA have very similar layouts and street grids even though it is not the same scale.

  • SZwartz

    Yes, and if rocks were apples, then I would go to a gravel pit to make a apple pie.

    The entire point of fix rail transit is SCALE. Beyond 5 mi radius, it won’t work. Take out a piece of paper and diagram it for yourself.

  • Jame

    The answer is different, station location is very specific to the region or city. But most importantly, insuring the station is actually useful.

    TOD fails, particularly around commuter rail stations, if they assume that every trip is going to be made on that train. Riding the train isn’t practical to get groceries, go to the post office or dry cleaner. Or any of the trips you make multiple times a week. The train station itself is irrelevant. You need to build a good neighborhood. And that really means the stuff within a 10-15 minute walk needs to be useful. It sounds like in this case, the .75 mile radius sucks. Outside of the train station.

    Transit is important. But you can’t build a neighborhood assuming every trip requires transit. The on the ground experience within 10-15 walk of the station is most important. But the destination for the neighborhood is not the train. It is the amenities. There needs to be a useful nucleas of activity.

    My neighborhood, and many other ones close to commercial districts work because there is a nucleas of useful stuff that many people live in quick walking distance to. This works for people in cars too. That is why malls are popular. One trip for lots of stuff. But instead of thinking mall and parking lot, the design needs to assume people on foot are making multiple stops. And they are coming from close in.

  • SZwartz

    I went to Google maps to see if it would help, but it is worthless. They load so much unwanted garbage onto the map site that it is impossible to see anything.

    This intersection was constructed in the 1920’s and had an excellent balance of stores and residences. It was very walkable when I moved in in 1970. I live about 3 blocks away in a completely R-1 area, but I it was very common for me to walk to these stores.

    Back then, the intersection was dangerous and seedy, but I was young and rather large, so it did not bother me. In the mid 1970’s, the city put in protective zoning for this part of Hollywood and the improvement was fantastic. Then, the corrupt developers moved in and deterioration set in again.

    After the subway station was open and the Metro Aprts were built on top, crime became a serious problem and the area was much less walkable because they closed down the stores to make room for development. While I can walk to Ralphs, I tend to drive for the reasons you mention. Also once gets inside the R’s complex, it is safe.

    The only thing the TOD brought was crime. After years of fighting, we stopped a TOD and they built a reasonable size PetCo and Marshalls rather than $110 Million monstrosity.

    All the good things of which you speak were here decades before the TOD came. We did not have “color” in that we had one of the city’s oldest “dirty bookstores,” but as far as I know, it never caused any problems.

    If we had had a nice L shopping Center with plenty of parking where the built the Metro Apts, that would have been good. The merchants need the parking — the reality is that they cannot survive based on foot traffic. If foot traffic would do it, 75% of the Metro retail would not be vacant after 12 years.

    The US Bank is a training bank and the flow of customers is low — I think that is probably good for a training bank. It reduces the stress on the newbees so that they can learn without oo much pressure.

  • Doug Wedel

    I agree. That’s called quaxing. It is often a question of learning how. Saying you need a car to shop is a myth long held by car culture, that has long ago been debunked. Even beds, large screen tv’s, etc, can be transported across town by bike.

  • Doug Wedel

    Density is the problem, not the cars.

    I seriously want to quote this line. It’s hilarious.

    I also want to quote your idea that high rises ought to be on the periphery of suburbia instead of the other way around.

  • SZwartz

    So quote them. Whose stopping you? Just do it in context.

  • neroden

    My city does not permit developers to “buy up properties and neglect them” — they get really mad about that.

  • SZwartz

    You are lucky. When CIM Group pulled this stunt with its Hollywood-Western project, it took a local TV expose which then embarrassed the City Attorney enough that they the city was forced to take action. In LA, the general practice is to allow large developers create a nightmare of blight so that the neighbors will approve almost anything just to get rid of the trash, the rats, the gangs, and the drug users.

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