Our March 13 story about San Francisco’s replacement of traffic congestion as an environmental impact with the number of vehicle miles traveled that a new project is expected to generate (VMT), elicited an interesting comment:


What’s impossible to measure, and has skirted any CEQA [California Environmental Quality Act] study, is the increased traffic from Uber (14,000 drivers by its own admission), Lyft (ditto), Chariot (privatizing Muni), tech buses, and all manner of poverty-gig deliveries: Postmates, TaskRabbit, Munchery, Caviar, Sprig, InstaCart, Breeze, OrderAhead, SpoonRocket, Lugg, WorkGenius, Eat24, Instawash, etc., not to mention Amazon one-hour delivery, Safeway, and on and on.

Rich folks can stay in the condo and own no car, while a Shanghai-like cesspool of traffic roars below. Crave a cup of gourmet yogurt? Poor saps will underbid each other for the privilege of double-parking in gridlock and rushing it to your lobby in hopes of a tip.

I know this is slightly off topic, but this is what’s really happening on the streets of SF.

Uber driver blocks the bike lane on Valencia
Uber driver blocks the bike lane on Valencia

It seemed right on topic to me, and I forwarded Ragazzu’s remarks to 48 hills editor Tim Redmond. He emailed back:

I can tell you from personal experience that there are many thousands more cars on the city streets thanks to Uber. I can’t even ride my bike home on Valencia, where there’s a bike lane, on a Friday or Saturday night because the Ubers block the bike lane and swerve in and out of traffic.

This is a nice irony. Many of the same organizations that support the replacement of traffic congestion as an environmental impact by vehicle miles traveled—Greenbelt Alliance, TransForm, the Natural Resources Defense Council—also laud Uber and other so-called transportation network companies (TNCs) for potentially reducing millions of single-occupancy vehicle car trips and greenhouse gas emissions. Now it turns out that the TNCs are not only clogging San Francisco’s streets—that’s fine by these groups—but also blocking bicycle lanes—presumably not fine by them.

Is Ragazzu right? Are the single-occupancy vehicle car trips made by Uber et al., along with those made by “gig-poverty” delivery services, not subject to the California Environmental Quality Act, our state’s premier environmental law?

I asked Chris Ganson, the staffer at the Governor’s Office of Planning and Research, who’d conducted a February webinar about the state-mandated switch to VMT, how VMT is calculated for transportation network companies such as Uber and Lfyt, and for app-based delivery services such as Muncerhy, Instacart, and Amazon one-day delivery.

Ganson replied:

For how VMT is measured in San Francisco, I would recommend reaching out to the planning staff who are operationalizing this change there. A person to start with might be Wade Wietgrefe wade.wietgrefe@sfgov.org, who has been working to developing their implementation to VMT in CEQA.

I forwarded Ganson’s reply to Wietgrefe. The next day I got an email from Planning Department Communications Manager Gina Simi saying that Wietgrefe and San Francisco Director of Environmental Planning Sarah Jones had asked her to tell me, astonishingly, that the traffic generated by TNCs and app-based delivery services is not a CEQA issue, which is to say, it is not potentially subject to an Environmental Impact Report and lawsuit.

The Environmental Planning division of the Planning Department assesses the environmental impacts of projects/approvals/legislation that are proposed by private sponsors and/or City departments for approval.  The activities you mention, such as TNCs or app-based delivery services, are not subject to permits or approvals for their operations.  Therefor CEQA is not part of the equation for their operations in that we have no basis to assess their impacts under CEQA.  If a company that provides such services is seeking some sort of approvals in the future that are connected to their operations, we would try to calculate the VMT that would result.

So Ragazzu is right.

And in a follow-up email Simi not only confirmed my understanding that right now, the Planning Department doesn’t know how many vehicle miles traveled these companies are generating, but added that “government agencies that do regulate them are having a hard time getting the companies to share data in order to estimate vehicle miles.”

Simi also said that the San Francisco County Transportation Authority is participating in a study led by UC Berkeley’s Safe Transportation Research and Education Center as to whether transportation network companies add or reduce vehicle trips “onto the network” in San Francisco and other cities in the U.S. I’ve asked both agencies for more information about the study.

Among the issues here: Do TNCs encourage people to stop driving cars – or do they encourage people to stop using transit? Walk around San Francisco any weekend and you get plenty of evidence for the latter: Young people who not long ago would have taken a bus or BART home from a restaurant or bar now rely almost entirely on Uber or Lyft. That’s clogging the streets and hurting the environment.

Meanwhile, San Francisco Assemblymembers David Chiu and Phil Ting are supporting AB 828, which would exempt TNC drivers from needing commercial license plates, by “exclud[ing] from the definition of ‘motor vehicles’” any vehicle that is

  • operated in connection with a transportation network company that is
  • operated for passenger service only and is limited to seven passengers excluding the driver;
  • operated exclusively by the person to whom the vehicle is registered or insured;
  • not a paratransit vehicle not operated for public transit services;
  • not operated for school bus services.

According to the analysis provided to the State Assembly, the bill’s author, State Senator Jim Beall, representing the 15th State Senate District (Silicon Valley) and chair of the Senate Committee on Transportation and Housing, says that encouraging TNCs “reduces vehicle trips, total vehicle miles driven and the carbon emissions that contribute to climate change.”

AB 828’s other supporters include the Los Angeles Chamber of Commerce, Lyft, Uber, the Metropolitan Transportation Commission (like the TNCs, a non-union shop), the Orange County Business Council, the Planning and Conservation League, SPUR, and the San Francisco Chamber of Commerce.

Opponents include the Sacramento Taxi Workers Alliance, the San Jose Taxi Drivers Association, the San Francisco Taxi Workers Alliance, and the California Labor Federation.