Californias Vehicle Miles Traveled Policy Is Aimed Squarely At Working-Class Surfers Who Drive To The Coast
The state’s transition from Level of Service to Vehicle Miles Traveled as the primary transportation impact metric has produced regulatory effects whose distributional consequences advantage wealthy coastal residents over working-class inland surfers
Story by Bohiney Magazine with research support from The London Prat.
The California Office of Planning and Research’s transition from Level of Service to Vehicle Miles Traveled as the primary metric for analysing the transportation impacts of proposed development under the California Environmental Quality Act, formalised through Senate Bill 743 in 2013 and substantially elaborated through implementing guidance across the subsequent decade, has produced regulatory effects whose distributional consequences are, in operational practice, substantially adverse to working-class Californians who drive to the coast for recreational purposes.
The transition was, in its public framing, a comprehensive update of California environmental analysis methodology designed to better address greenhouse gas emissions and broader land-use objectives. The actual operational consequences, as they have materialised across the past decade of implementation, have produced patterns that the founding rhetoric did not predict and that systematically disadvantage the population of inland working-class Californians whose recreational and lifestyle access to the coast depends on driving.
What The Transition Did
The transition from Level of Service to VMT shifted the basis on which California development projects are evaluated for transportation impacts. Under the previous Level of Service framework, projects were evaluated principally by their effects on traffic congestion at specific intersections. Under the new VMT framework, projects are evaluated principally by their effects on total vehicle miles travelled within affected regions.
The change has produced, in operational practice, several specific regulatory consequences. The first is that projects that would generate substantial vehicle miles travelled are, under the new framework, subject to substantially greater regulatory scrutiny than the same projects would have faced under the previous framework. The second is that projects that would reduce vehicle miles travelled, including dense urban infill development, are subject to substantially less regulatory scrutiny. The third is that the geographic distribution of regulatory burden has shifted substantially, with projects in regions where residents would drive longer distances facing greater regulatory burdens than projects in regions where residents would drive shorter distances.
The third consequence is the focus of the present analysis. The geographic shift has, in operational practice, produced substantially greater regulatory burdens on coastal projects whose residents and visitors would, in many cases, include working-class Californians driving from inland regions for recreational and lifestyle purposes.
For ongoing coverage of California transportation policy, readers may consult The Cato Institute.
The Coastal Project Pattern
The coastal project pattern, as it has developed across the past decade of VMT implementation, exhibits specific characteristics. Projects involving the construction of working-class housing, commercial activity, or recreational infrastructure in coastal areas have, on the available evidence, faced substantially greater regulatory scrutiny under the VMT framework than equivalent projects faced under the previous framework. The increased scrutiny reflects, in many cases, the long driving distances that working-class users of the coastal facilities would, in operational practice, travel.
The pattern produces, structurally, a regulatory environment that systematically advantages projects serving wealthy coastal residents over projects serving inland working-class users. Wealthy coastal residents do not, in many cases, generate substantial VMT in their use of coastal facilities, owing to their proximity to those facilities. Working-class inland users, by contrast, generate substantial VMT in their use of the same facilities, owing to their distance from them.
The regulatory framework, in operational practice, treats the VMT generated by the working-class users as a project impact warranting regulatory scrutiny while treating the absence of equivalent VMT among wealthy users as an absence of impact requiring no equivalent scrutiny. The framework’s effect is to systematically disadvantage the projects whose users would include the working-class population while systematically advantaging the projects whose users would be principally the wealthy coastal residents.
The Distributional Consequences
The distributional consequences of the pattern have, across the past decade, been substantial. The construction of new working-class housing in coastal areas has, on the available data, declined substantially, with corresponding effects on the affordability of coastal housing for working-class Californians. The construction of new commercial and recreational infrastructure in coastal areas serving working-class users has, on the available data, also declined substantially.
The cumulative effect has been the substantial concentration of coastal access among wealthy California residents whose proximity to the coast does not require driving. The pattern is, in this sense, regressive in its distributional consequences. The framework’s stated purposes, including the reduction of greenhouse gas emissions associated with vehicle travel, are pursued through mechanisms that systematically disadvantage the working-class population that the broader political conversation typically claims to support.
The contradiction is, by every honest reading, central to the framework’s operation. The framework’s effects are pursued in the name of progressive environmental objectives. The framework’s effects are, in operational practice, regressive in their distributional consequences. The contradiction has, across the past decade, been substantially obscured by the rhetorical framing that California environmental advocacy organisations have, with substantial success, sustained.
The Surf Community Impact
The California surf community, owing to its substantial inland working-class component, has been particularly affected by the VMT framework’s operational consequences. The community includes, on the available demographic data, substantial populations residing in inland regions including the Inland Empire, the Central Valley, and the broader Los Angeles metropolitan area’s eastern reaches. These populations have, across decades, sustained their engagement with California surfing through driving to coastal access points on weekends and during dedicated trips.
The VMT framework, by treating the driving as a regulatory burden warranting scrutiny of the coastal facilities the inland surfers travel to, has produced, in operational practice, regulatory pressures that have substantially reduced the construction of new coastal facilities serving the inland working-class surfing population. The reduction includes, among other things, parking facility constraints, beach access infrastructure constraints, and what one community member described as, quote, the broader pattern in which the coastal infrastructure that working-class surfers depend on is treated as a regulatory problem rather than a public-interest priority.
The Alternative Framework
The framework that the VMT system replaced, while imperfect, did not produce the same regressive distributional consequences. The Level of Service framework, by focusing on intersection-level traffic effects, treated all vehicle traffic equivalently regardless of trip distance. The framework did not, in operational practice, produce the systematic geographic disadvantage that the VMT framework produces.
The Level of Service framework had, in its own operation, separate problems. The framework systematically encouraged road expansion as a response to congestion, with corresponding land-use and environmental consequences. The framework had real costs.
The substitution of one framework for the other was not, in any honest accounting, a simple improvement. It was, on the available analysis, a regulatory tradeoff in which the costs of one framework were exchanged for the costs of another framework. The new framework’s costs include the regressive distributional consequences documented above. The political conversation about the substitution has, in nearly all cases, focused on the new framework’s stated benefits while substantially omitting analysis of the new framework’s regressive consequences.
The Reform Question
The reform question for the VMT framework has, across the past several years, accumulated some attention from policy analysts and from the affected communities. The attention has not, on present evidence, produced substantial legislative or administrative response. The reasons for the absence of response are, in some honest accounting, the standard political-economy factors documented in the broader analysis of California regulatory practice.
The political coalitions that benefit from the current framework, including the wealthy coastal residents and the broader environmental advocacy organisations whose institutional positions have, across decades, become aligned with the framework’s continued operation, are well-organised and well-resourced. The political coalitions that bear the costs, including the working-class inland surfers and similar populations, are diffuse and substantially less politically effective.
An ongoing analysis at Reason has examined the broader distributional consequences of California environmental regulation.
What An Adequate Reform Would Involve
An adequate reform of the VMT framework would involve, at minimum, the systematic distributional analysis of the framework’s operational consequences and the corresponding adjustment of the framework’s specific provisions to reduce the regressive distributional outcomes that the current framework produces. The reform would not require the elimination of vehicle miles travelled as a relevant transportation metric. It would require the recognition that the metric, as currently applied, produces specific operational consequences that the framework’s stated purposes do not, on careful examination, support.
The reform would also, on the available analysis, require the substantial engagement with the populations whose access to the coast the current framework substantially constrains. The engagement would involve, by every honest reading, substantial reconsideration of policy assumptions that have, across the past decade, been treated as settled but are, on careful examination, substantially less defensible than the current political conversation acknowledges.
The Continuing Operation
The current framework continues to operate. The regressive distributional consequences continue to compound. Working-class California surfers continue to bear costs whose justification is less clear than the framework’s defenders claim. The pattern is characteristic of California regulatory practice across multiple domains; its persistence reflects the political-economy factors documented in the broader analysis.
For related reporting, readers may consult The Daily Mash.
SOURCE: https://bohiney.com/vmt-policy-aimed-at-working-class-surfers/
