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Commissioners,
Thank you for taking action last night to move forward several of CRTP’s suggestions for safe and sustainable
transportation improvements to the Circulation Element. Deprioritizing level of service, charging for downtown parking, and other changes you made to the Element are well supported by research in the field. We look forward to your discussion of other topics of concern, including public transit improvement, Class IV bikeways, and roadway functional
classification, when you return to these topics at an upcoming meeting. Now that you have deprioritized level of service (LOS) and specified that it should be used only as an indicator of efforts to slow traffic and encourage mode shift, there are a number of other places in the Element which should be amended for consistency. Many of these are identified in the Commissioner‐proposed edits which you didn’t get to discuss last night. For example, several other places in the Element refer to “unacceptable [vehicular] delay” or “deficient operation” of intersections or streets, which are concepts that doesn’t make sense following your decision last night. These terms
apply only when an agency has adopted a specific “acceptable” LOS, and streets or intersections fall below it, triggering
plans for vehicular capacity increases ‐ a debunked strategy and exactly the opposite of the approach that the
Commission and city staff articulated last night.
Most worryingly, the old LOS approach is also still reflected in the project list found at Table T‐5, where “LOS deficiency”
or “circulation improvement” (which mean the same thing in this context) is listed as the primary or only reason for 5 of
the 11 projects. I do not doubt that city staff and consultants would consider safety and multimodal access when
designing these projects, but the fact that the primary or only motivation is to reduce vehicular delay and increase LOS is
very troubling. Deprioritizing LOS should mean that these projects are either: (a) removed from the Circulation
Element (and Capital Improvement Plan) entirely; or (b) if staff believe that improvements in these same locations are
still necessary for safety or active transportation access, the projects should be re‐scoped/re‐characterized in that
manner, without reference to LOS.
Although I have not been able to locate a copy, it also appears from the description that Appendix A is entirely focused
on capacity “improvements” to address LOS “deficiencies,” despite this being contrary to your decision last night and the
city’s stated approach to LOS.
It’s important to recognize that while the city has wisely disavowed the practice of adding more lanes to streets or
highways (a policy already reflected in the Circulation Element), adding more through lanes is not the only way to
increase vehicular capacity. Turn lanes, roadway extensions, channelization, and roundabouts are other common ways
to increase capacity, and are all reflected in the Circulation Element plans. Just like adding through lanes, none of these
will actually work to decrease congestion in the long term. And more importantly, almost all of them will decrease
safety. (The possible exception is roundabouts, which have well‐documented safety benefits for car occupants, but
which can actually decrease safety for people walking, biking and rolling if not designed specifically for their protection.)
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In order to prioritize safety and low‐carbon modes of transportation and to deprioritize LOS in keeping with last
night’s decision, we ask that you remove from the Circulation Element other references to LOS “deficiencies” and to
any need for vehicular “circulation improvements,” along with removing any projects or plans that are motivated only
or primarily by LOS “deficiency” concerns.
Finally, I also feel it is important to address staff’s contention last night that sometimes LOS improvements are necessary
to prevent traffic diversion or “leakage” onto other city streets. While this seems like common sense, it may not be
accurate. Research has shown that even actively removing vehicular capacity (e.g., lane reduction) usually does not
result in significant traffic diversion. And if diversion is still a concern, it can be mitigated with traffic calming or even
barrier/diverters on the potential alternate routes ‐ if an alternate route is just as slow because of stop signs, speed
bumps, narrow widths, winding path of travel, etc., few people will choose to divert.
Thank you.
Colin
On Fri, Apr 7, 2023 at 2:58 PM Colin Fiske wrote:
Commissioners,
CRTP submits the following comments on the draft General Plan Circulation Element which you will be reviewing on
Tuesday:
1. Remove “level of service” (LOS) or other measures of vehicular delay or congestion from all policies, projects
and priorities. It is well established in the transportation planning literature that responding to delay or
congestion by increasing capacity does not work ‐ it eventually just causes more people to drive, leading back
to the same congestion (and more emissions). Furthermore, the temporary reduction in delay that can be
achieved is actually dangerous, because increased speeds result in more crashes, deaths and serious injuries.
Arcata has mostly abandoned the idea of building more roads and more lanes, thankfully. But the General Plan
still describes streets with any congestion as “deficient” or “unacceptable” and has many policies and projects
that attempt to increase capacity in other ways in response to vehicle delay. Just like adding more lanes, any
other attempt to increase capacity just won’t work, and for the same reason ‐ reduced delay is itself what
induces more driving. Thus, managing for LOS is both ineffective and incompatible with the city’s other goals of
decreasing the amount of driving and increasing the amount of walking, biking, rolling and transit use.
2. Prioritize slow, safe design for all users on all city streets. The General Plan still uses the “functional
classification” rubric to categorize some streets as collectors or arterials, whose main goal is to move traffic
rather than to provide access to destinations or provide a safe public space. Exactly because of this approach,
arterials in Arcata (and throughout the country) are the most dangerous roads, where serious crashes are
highly concentrated. There is no city street in Arcata (aside from a few rural roads) that is not lined with homes,
businesses, and other destinations, and is not used by people for a wide variety of activities. Denying this
reality has deadly consequences. We ask that you stop using the invented concept of collectors and arterials in
the Circulation Element and adopt policies to design all roads for safety and low speed.
3. Provide Class IV bikeways on major streets. Class IV bikeways are protected by a physical vertical barriers.
There are currently no Class IV bikeways in Arcata (or in Humboldt County). But if we want to increase biking,
we need to build them. Research shows that they not only improve safety for bicyclists and drivers, they also
are required for most people to feel comfortable enough to actually bike on busy streets. The Circulation
Element should reflect the need for Class IV bikeways in its policies, maps and plans.
4. Commit to improving public transportation as rapidly as possible. Just like faster roads can cause people to
drive more, better transit service can cause more people to ride and improve the lives of transit‐dependent
people. Since these outcomes are necessary to meet climate, equity and transportation goals, the city should
commit to improving transit, not just maintaining the status quo. As part of this commitment, the Circulation
Element should commit to exploring all‐electric microtransit service to complement the fixed‐route buses, and
to exploring merging AMRTS with HTA for greater coordination and efficiency.
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5. Include a policy to pilot a Slow Streets program. The current Circulation Element unnecessarily restricts the
possibility of closing neighborhood streets to through‐traffic, despite this being a popular and successful safety
and revitalization measure in many other communities. Instead, the Circulation Element should commit to
launching a pilot program to do just that on certain city streets. The Element could also include a policy
promoting School Streets as well.
6. Begin charging for parking downtown. The Circulation Element should include a policy to begin charging for
downtown parking. Free public parking is a subsidy and incentive for driving, which is incompatible with the
city’s equity, climate and transportation goals. Furthermore, free parking leads to inefficient use and inflated
demand, which results in constant requests for more parking in a never‐ending cycle. New smart meters can be
programmed to adjust pricing dynamically according to demand, to maximize parking utilization while
minimizing the subsidy. Revenues can be used to support public transit, active transportation, or other public
amenities. We also note that charging for parking downtown is a measure in the draft regional Climate Action
Plan.
Regarding the proposed K/L Street couplet, the staff report for Tuesday accurately conveys CRTP’s position. However,
in light of our comments above, I would add a couple more details:
 It is possible to redesign K Street as envisioned in the current draft Gateway Plan ‐ bringing it down to a 1‐lane,
1‐way street ‐ without building out L Street, if the city chooses not to prioritize LOS, as noted above.
Southbound traffic would still many other streets to choose from. We would support this option.
 Even if K Street remains 2‐way, much more can be done to improve safety than is reflected in the options in the
staff report. If parking lanes are removed, for example, there would be plenty of room for Class IV protected
bikeways (which are needed on this street). Stop signs can be added to calm traffic regardless of the
“warrants.” Even speed bumps/humps/pillows are possible if the city chooses to prioritize low speed and safety
over capacity on this “arterial” street.
Thank you for your consideration.
‐‐
Colin Fiske (he/him)
Executive Director
Coalition for Responsible Transportation Priorities