Analyzing the impacts of a Complete Bicycle Network

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The City has prepared and certified an Environmental Impact Report (EIR) on the San Francisco Bicycle Plan to satisfy a Superior Court ruling handed down in November 2006. Until we assemble and certify an adequate CEQA environmental review on the whole Bike Plan, and adopt that Bike Plan, we're not allowed to make any further physical improvements for bicycles in the city. So how much adverse environmental impact can a plan for better biking be expected to cause? And can it really cost the better part of a million dollars and two years or more to find out?

First, some quick CEQA catch up (see CEQA at a Glance). Under CEQA, most projects must be reviewed for their potential environmental impact, and that review carried out and reported as a public information process, as an tool for decision-making by legislators and policymaking bodies. The quintessence of CEQA is the EIR process, the fullest expression of the CEQA principles of environmental significance and public information, although not every project is obliged to undergo a full EIR treatment.

Where it appears possible or likely that a project could have significant environmental impacts, the "lead agency" reviewing the project (in San Francisco, the Planning Department) prepares an Initial Study, assessing a checklist of environmental concerns (e.g., dirty air) and thresholds of significance (e.g. how many parts per million of carbon monoxide per hour). If that Initial Study indicates probable significant environmental impacts for the project, the agency must prepare an EIR. If the Initial Study shows that no EIR is necessary, the agency must prepare a Negative Declaration. If the project would have significant environmental impacts, but those impacts may be mitigated to a level of less than significant, then the agency must prepare a Mitigated Negative Declaration.

In the case of the Bike Plan, the City is moving forward with an EIR without waiting for an Initial Study, to establish the strongest and fullest CEQA clearance of the Bike Plan and the project that it describes so we can dig into implementing that plan (once the EIR is complete) without further legal doubt as to its environmental effects.

An EIR is a formally-defined thing under CEQA, but it's a fairly flexible definition, if a bit lawyerly and opaque. The EIR starts with a formal declaration of the project, just what is being proposed. In the case of the SF Bike Plan, the project is to improve the continuity, safety, and utility of the official citywide bicycle route network over the next five years by way of physical roadway enhancements, as well as establishing policies to support increased bicycling safety and utility throughout the city. The specific bike network enhancements are spelled out in the Network Improvement Document, a long list of bike lane additions and route improvements developed in the Bike Plan Update process and reaching into every corner of the city, and the policies are spelled out in the Policy Framework Document.

The EIR will describe existing conditions for the project's setting, and of course the EIR will consider and discuss environmental impacts the project might cause, directly or indirectly. The EIR will focus on the project's significant environmental effects, mitigation measures, and a range of alternatives, including a "no project" alternative that analyzes what the environmental impact would be if the project weren't implemented. In the case of the Bike Plan, it's conceivable that the "no project" alternative would result in worse environmental conditions than any of the project alternatives!

Not every conceivable alternative to a project has to be considered, only a reasonable range of potentially feasible alternatives that will foster informed decision-making and public participation.

As well as analyzing possible significant environmental impacts, the EIR contains a statement briefly indicating the reasons that various possible significant effects of a project were determined not to be significant and were therefore not discussed in detail in the EIR. The project's cumulative impacts will be studied in consideration of other projects causing related impacts when the project's incremental effect is cumulatively considerable, and economic or social information may be included in an EIR or may be presented in whatever form the agency desires, although economic or social effects of a project shall not be treated as significant effects on the environment.

Once the Draft EIR has been completed it will be opened to public review for a period (generally 45 days) during which anyone, with an interest in the project, whether individual, agency, or organization, may comment on the Draft EIR. After the public comment period has ended, the lead agency evaluates and responds to comments received. If comments result in significant modification to the Draft EIR it is revised and recirculated, otherwise the comments and responses are added to the Draft EIR and the Final EIR is issued. The Final EIR will go to the Planning Commission for Certification (which can be appealed to the Board of Supervisors) after which the Bike Plan, with its certified EIR, will go to the Board of Supervisors for approval, and then on to the Mayor for his signature.

Finally a Notice of Determination is filed by Planning which closes the whole saga. If no one appeals the Bike Plan's approval within 30 days, the EIR is done and adequate, and we're back to striping bike lanes in a big way for the next several years.

related info:

• Citywide Bike Network — the SF Bike Plan and the lawsuit that's holding it up
• CEQA at a glance
• Auto LOS reform