Public Comment

University of California Long-Range Development Plan (LRDP) increases the number of employees and students dramatically but does nothing new to shift them out of their automobiles. The result will obviously be gridlock, but UC’s Environmental Impact Report (EIR) takes advantage of a technical change in California environmental law that lets it ignore the congestion that the plan will create.

According to the EIR, the number of UC students and employees will increase by a bit more than 20% (Table 15-7), and the amount of automobile traffic generated will also increase by about 20% (Tables 15-4 and 15-9). All the added cars would obviously make Berkeley’s streets more dangerous for everyone, would worsen traffic congestion throughout the city, and would create gridlock at a number of intersections in downtown,

Until recently, the EIR would have had to analyze the effect of all these extra trips on congestion, which planners call the Level of Service (LOS) of intersections. But a recent law, SB743 passed in 2013, says that EIRs must now analyze the Vehicle Miles Traveled (VMT) that projects generate rather than the Level of Service at nearby intersections.  

Environmentalists supported this change, because developers used to analyze Level of Service and then mitigate traffic congestion by widening streets. It would be much better for them to analyze Vehicle Miles Traveled and mitigate traffic with policies that reduce automobile travel.  

Unfortunately, the law that was finally passed includes a huge loophole. If a project has per capita VMT that is 15% less than the regional average, VMT is not considered a significant impact and does not have to be mitigated. The regional average includes remote suburbs with very high levels of per capita VMT, so virtually all projects in denser parts of the Bay Area, such as Berkeley and San Francisco, are bound to be more than 15% below the regional average. Even though UC’s Long Range Development Plan will generate a huge amount of added traffic, that traffic is not a significant impact as defined by law, so UC is doing nothing about it.  

Though UC is not analyzing it, it is clear to those of us who have looked at past EIRs that this added traffic will cause gridlock at peak hours at a number of intersections in downtown Berkeley. Traffic engineers call it “F level of service,” with frequent stops, with vehicles waiting for the vehicle in front of them to move before they can move, with traffic backing up to the point where it blocks cross-streets, and with unpredictable travel times, since people do not know how long they will be stuck in traffic jams.  

There are ways to mitigate this problem, called Transportation Demand Management (TDM). For example, commute allowances are very effective: charge more for parking, give commuters an extra cash allowance to pay for the higher parking cost, and let them keep the cash if they do not drive, to give them a financial incentive to carpool or shift to other modes. That is just one among many possible TDM measures. Yet UC is planning to keep its current TDM measures but not to add any new ones.  

UC is no longer required by law to mitigate congestion, but it could if it chose to. Environmental law has also changed so developers do not have to consider a project’s impact on parking; but even though they are not required to by law, UC has analyzed the impact of their plan on parking and will provide enough parking for all the projected new commuter automobiles. Yet they are oblivious to the fact that their commuters will have a miserable time crawling through gridlocked traffic to get to the parking they are providing, and will miss appointments and classes because of unpredictable travel times.  

Even if UC does not care about their plan’s impact on the state’s efforts to control global warming, even if they do not care about its impact on the safety of Berkeley’s pedestrians and bicyclists (including their own students), even if they do not care about clean air, even if they care only about the automobile commuters they are diligently providing parking for, they should have enough sense to realize that those automobile commuters will be miserable unless they do something to reduce traffic congestion.  

They are not required by law to reduce traffic. But they must reduce traffic if they want the transportation system to work.  

The greatest irony is that UC is calling this plan “green” because it will improve the campus environment by moving parking from campus to the city streets at the edge of campus. If they want to be green, they have to do something to reduce the amount of traffic they create, rather than protecting their own campus while they dump more traffic than ever on the rest of Berkeley.  

(UC is accepting comments until April 21. Send comments to planning@berkeley.edu and include “Draft EIR Comments: 2021 LRDP and Housing Projects #1 and #2” in the subject line.)