Response to the CAO's Financial Impact Statement for Measure HLA

UPDATE: On Friday, February 16, 2024, the CAO released a last minute, even more misleading report, claiming the cost has now gone up to $3.1B! The main reason he claims for the increase is the repair of 9’ sidewalks compared to 6’ sidewalks; nothing in the Mobility Plan requires sidewalk repair, and therefore HLA does not require sidewalk repair. The arguments below stand, and we call on the CAO to stop playing politics with the lives of Angelenos. Read our call to action from that day.

The City Administrative Officer wrote this summary for his stated financial impact of Measure HLA:

The CAO’s cost estimate is exaggerated and misleading:

The CAO estimate does not provide any source for their cost estimates, but we can examine the similar Mobility Plan 20235 implementation cost report submitted to the LA City Council in November 2023 to understand their analysis:

1. More than half the CAO’s cost estimate is for sidewalk repair, which is not required by the Mobility Plan, and therefore not required by HLA.

2. Notwithstanding this expense not being required by HLA, the City already has a $1.4B budget to repair sidewalks over 30 years thanks to the Willits Settlement; saddling the cost of repairing sidewalks on the ballot measure is misleading, and untrue, and this represents more than half the cost the CAO estimates.

3. For the Pedestrian Enhanced Network, the CAO assumes exaggerated maximal costs. The City has never completed a comprehensive citywide sidewalk assessment, so it is assumed the whole network must be upgraded to meet ADA standards: “since the overall condition of the sidewalks is unknown, the total estimated cost to remediate the sidewalks is $1.4 billion assuming all 560 miles in the PED needs repair.” The City, obviously, will not need to repair every foot of sidewalk on the pedestrian network as many portions of sidewalks are already in good condition.

4. Measure HLA saves money in the long term. If the goal of the City is to implement its own Mobility Plan 2035, then it makes sense to do it during repaving, when the street has to be restriped and redesigned anyway. Otherwise, the City would have to go back later, tear up the street and redo it.

5. The CAO’s cost estimate assumes that the entire Mobility Plan 2035 has to be implemented by 2035; while we would love to see that, nothing in Measure HLA dictates that the City has to implement their own Mobility Plan by any specific date.

6. The CAO report assesses the cost of implementing the Bicycle Networks between $1 - $1.3 billion at around $2 million per mile. This is nearly 10x the cost of what LADOT says it spends per mile of bike lanes. View a full breakdown here.

7. The CAO doesn’t even attempt to give a cost to implement the Neighborhood Enhanced Network, Vehicle Enhanced Network, or the Transit Enhanced Network. These are all made up of low cost improvements.

   1. The NEN would likely be made up of low cost speed improvements similar to the existing Slow Street program; this means paint, signage, and plastic bollards. 

   2. The VEN would largely be made up of cheap and already funded signal improvements and signage changes (changing parking to off-peak, etc.).

   3. The TEN would improve the installation of bus lanes which are funded by Metro Los Angeles and bus shelters (an existing newly funded program).

8. The City currently spends tens of millions of dollars per year paying out to victims of traffic violence, in some cases, more than it budgets towards safer streets. If we implement the Mobility Plan, we would save the City money on litigation costs, in addition to saving lives.

Every year more than 300 people die on our streets and thousands are permanently injured because we haven’t invested in safe infrastructure. We are bearing the burden of decades of underinvestment and poor planning on LA streets. While we believe the CAO estimate is significantly inflated, even $2.5 billion over 10 years for safer streets, cleaner air, and less traffic would be a valuable investment. For comparison, it is less than NYC’s planned spending of $4 billion just on vision zero over the next 10 years (a city with fewer miles of streets) where investments have successfully reduced traffic fatalities. The bottom line is the City Council passed the Mobility Plan 2035 back in 2015 and the City has barely implemented any of it. It should not be sticker shock to keep Angelenos safe when crossing the street, and the cost should not be misrepresented to voters.

Response to the CAO's report on the cost of Mobility Plan 2035 implementation

In June of 2023, the Transportation Committee adopted a Budget Recommendation asking the City Administrative Officer to report on the cost of implementing the City’s Mobility Plan 2035, with a focus on bicycle and pedestrian facilities. This included implementing the Bicycle Enhanced Network (protected bike lanes), the Bicycle Lane Network (unprotected bike lanes), and Pedestrian Enhanced Districts.

Last week, the City Administrative Officer Matthew Szabo produced a report outlining the cost. It’s important to have an honest conversation about cost, given Healthy Streets LA is on the ballot in March, which would force the City of Los Angeles to implement the Mobility Plan 2035 anytime it repaves a street.

There are several issues with the CAO’s report, and we break them down here:

1. The City passed the Mobility Plan 2035 in 2015. Given we are 8 years in and the city has done just 3% of the planned facilities and is only now getting around to talking about what it would cost to implement shows how deeply unserious the City actually is in implementing the plan.

2. The CAO is giving the City too much credit. In the table below, he credits miles of bike lanes that were implemented before the Mobility Plan 2035 was even adopted that were included in the plan. It’s a sleight of hand trick that makes the City look far better on progress. The truth is that it has only implemented 3.4% of the Bicycle Lane Network since 2015.

3. LADOT is estimating “community engagement” per project to be between $96,000 and $462,000. Our City loves doing outreach, primarily over bike lanes. Projects that add parking (and, sometimes, even remove bike lanes to add diagonal parking), road space, and other car infrastructure rarely have much outreach. But when it comes to bike lanes, LADOT has an arbitrary outreach requirement; sometimes this just means mailing businesses and residents along a specific corridor telling them a project is happening. Sometimes it includes months or even years of community meetings before a council office will sign off. The City is also obligated to do a traffic study anytime a car lane is being reallocated for another use under the Fix The City settlement.

Our city could save a lot of money on outreach, and speed up implementation of bike lanes, if it set a reasonable, and short outreach period for projects. It’s insane to spend up to $500,000 on just having a conversation on if we should implement a project on the mobility plan already passed by City Council.

4. In the cost estimate, the initial range of $2.9 - $3.28B includes street resurfacing; but the City resurfaces about 500 miles per year anyway — putting that cost on the Mobility Plan 2035 is silly. The whole point of Healthy Streets LA is to force the City to implement the plan during repaving that it’s doing anyway; this would save money.

The second estimate excludes street resurfacing, but includes LADOT’s inflated Community Engagement estimates, which includes up to $80,000,000 in engagement (just to see if we should save lives and implement a plan we already adopted!)

Having said all of that, even if we take the City’s high end estimate of $3.28B to fully implement the plan, and divide that by the 12 years left until 2035, that comes out to $273M/year. The City’s total budget for FY23-24 is 13.15B. In other words, to make walking, biking, and transit more attractive, and save lives on our streets, the cost is only 2% of our budget per year, even at the high end.

5. There are multiple issues with the CAO’s analysis of the Pavement Preservation Program:

1. The CAO says that while there is existing funding for repaving (the “Pavement Preservation Program”) and upgrading curb ramps, that if the city has to implement the Mobility Plan, that funding will be less available for repaving or curb ramps. He’s specifically pitting pedestrians against cyclists and transit users; this is a false choice.

2. He says that if LADOT has to implement the Mobility Plan 2035 during repaving, LADOT’s community outreach will delay the resurfacing work. It is true that StreetsLA can resurface a street with little fanfare, while LADOT does have to do community outreach (according to the CAO, which can take up to “over a year”). However, this can be mitigated by standardizing outreach, and not overdoing it. We should not be asking permission to save lives and make our city more multimodal on a plan that Council has already passed.

3. This is where the CAO shows his bias against safer streets. He claims that the “unintended consequence of realigning these funds is that [repaving] could slow down to a point where the overall City street system deteriorates, resulting in less safe streets and higher costs to maintain those streets.” Did you get that? If we implement the mobility plan, the streets might be less safe (!?).

6. The CAO says that “should the Sidewalk Repair Program funds be reallocated to implement the Mobility Plan 2035, that it will need to be “coordinated” with the Bureau of Engineering to ensure that the City continues to meet its obligations under the Willits Settlement”

Again, the CAO is pitting the interests of pedestrians against cyclists and transit riders. This is a false choice —and the Mobility Plan 2035 would implement safety improvements for all road users—including pedestrians.

Overall, it’s good that the City—eight years after passing the Mobility Plan 2035—is finally looking at what it would cost to actually implement.

With respect to Healthy Streets LA, the measure is cost neutral. HSLA doesn’t tell the City when or where to repave. It simply says that when you repave, you have to implement the Mobility Plan’s 2035 elements, which could include traffic calming on residential streets, bus lanes, or bike lanes, for example.

We hope that the City recognizes the importance of keeping vulnerable road users safe, and building out safe networks of corridors for pedestrians, cyclists, transit riders, and drivers. Our status quo is untenable, and we need to take urgent action to save lives and keep our city livable.

Thoughts on the City's version of Healthy Streets LA

Healthy Streets LA at City Council in August 2022

Last August, after we successfully led a grassroots coalition that collected more than 100,000 signatures for Healthy Streets LA (which would require the City of Los Angeles to implement its Mobility Plan 2035 anytime it repaves a street) and qualified the measure for the ballot, there was a showdown at City Council.

Council had two options under the charter:

1 — Adopt Healthy Streets LA as law immediately (what we wanted)
2 — Push Healthy Streets LA to the next ballot and allow voters to decide (March 2024)

While we pushed hard behind the scenes, we only got to seven votes that would’ve supported adopting it straight away, one vote shy of what we needed. Then Council-President Nury Martinez’s campaign against adoption didn’t help. Nury created a false narrative that our measure was inequitable, and rallied other organizations behind her position. She did this while simultaneously promising that the City would do its own version of Healthy Streets LA, which she said would make up for perceived deficiencies in our measure.

Below is a detailed analysis of the City’s progress and their own version of Healthy Streets LA since last summer. TLDR? Jump to our conclusions here.

The first moving clause of Nury’s version asked that the City Attorney prepare within 15 days an ordinance based on Healthy Streets LA; essentially, to carbon copy ours. Despite Council taking action June 29, 2022, the City Attorney did not produce a draft ordinance until August 7, 2023 — close to a year after the original deadline.

The next moving clause made total sense to us — the City has LADOT, StreetsLA and the Bureau of Engineering all working on and in the street, often without coordination. Additionally, projects would be improved if they included not only street repaving with the Mobility Plan’s bike and bus lanes, but also new street lighting, street furniture, trees, repaired sidewalks, etc.

This moving clause was a response to what Nury believed were equity deficits in our measure. Despite this clause asking for a report back in 60 days, over a year later the City has yet to produce a plan or build any prioritization of equity into their draft ordinance or repaving schedule. There is no sign of local hire, community engagement, or departmental coordination, ideas we support. Equity has always been a guiding principle within Streets For All and nothing listed here conflicts with our measure, which is simply triggered by the repaving schedule. Our goals include improving equity — including prioritizing resources for underserved communities — and including projects that holistically improve streets beyond what can be done with street repaving. HSLA is a bare minimum enforcement mechanism — when the City repaves a street, it would be required to follow its own Mobility Plan, and implement pedestrian improvements, bike lanes, and bus lanes approved in the Plan. These interventions would save lives of vulnerable road users — critical after we passed a two decade high of pedestrian deaths last year. We want to be more ambitious and go beyond the Mobility Plan in the future — but the first step is making sure the City actually follows the Plan they’ve already adopted..

The next moving clause called for the creation of a multi-year work plan from the (still unformed and unplanned for) “Unified Project Coordination Office,” prioritizing the High Injury Network and low-income, transit-dependent residents. We support focusing on the HIN and on low-income, transit-dependent residents — whether the city is implementing HSLA or its own version. But we're disappointed that, a year after the motion was approved, the City has not included prioritizing HIN or transit-dependent Angelenos in its version, nor has it included or moved in any way to actually create the Unified Project Coordination Office, or given any indication that it’s actually going to do so.

The next moving clause was about developing a funding plan for Mobility Plan implementation. We have yet to see any funding plan, or any indication the City is even working on one. One of the reasons why we kept our measure simple, and tied Mobility Plan implementation to repaving, is that there is hardly any cost to implementing bike and bus lanes if the street is being repaved already, since it has to be restriped and can simply be striped differently to add a bike or bus lane. We strongly support adding elements like improved sidewalks, trees, street furniture, and lighting to street overhauls — but those things are much more expensive than just repaving, and require additional funding.

The final moving clause asked the City to create a dashboard to track progress, which is built into our measure, and something we believe is essential to transparency.

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So where are we at today? Let’s examine the draft ordinance just released by City Attorney Hydee Feldstein Soto:

The purpose is to implement the Mobility Plan during repaving, which tracks with ours. Our eyebrows did go up upon seeing “emergency vehicles” specifically called out — LAPD and LAFD often block progressive road design in the name of "public safety” — despite the fact that those same emergency services would actually be more efficient with many of the Plan’s elements, especially bus lanes. In the narrow streets and alleys of old cities throughout the world, people having heart attacks still get ambulance service, and fires still get put out. It’s a false choice to have to choose between safer streets or efficient emergency services.

In our version, any repaving project over 1/8 of a mile is included — the City Attorney changed this to 1/4 of a mile (despite Council’s direction to match what we had). While this may sound inconsequential, it’s not. There are many resurfacing projects that are over 1/8 of a mile but under 1/4 of a mile that, while short, plug key gaps in the bike lane network.

Two examples (of many) of why the City’s version is problematic:

1. Sepulveda between Fiume Walk and Valley Vista is being repaved this fiscal year. Only one block and just over 1/8 of a mile, it would extend the existing Sepulveda bike lanes under the 405 and give cyclists a way to safely connect to Valley Vista. This would be ignored in the City’s version.

2. Westwood between Wellworth and Lindbrook is being repaved this fiscal year and is 1/5 of a mile. A bike lane currently on Westwood ends at Wellworth, and doing this 1/5 of a mile portion would get the bike lane past Wilshire Blvd and into Westwood Village, close to UCLA. It plugs a key gap, but would be ignored under the City’s version.

The other problem is that the City Attorney attempts to exclude “slurry seal” work — our version doesn’t. Slurry seal is sort of a “light” version of repaving, but it still requires the City to restripe a street afterwards. It’s often used on residential streets, many of which are part of the Mobility Plan’s Neighborhood Enhanced Network. We did the math, and out of the 28 miles of Neighborhood Enhanced Network streets being repaved this year, 9.4 are over 1/8 of a mile, but only 1.6 are over 1/4 of a mile. In other words, even if the City didn’t exclude slurry seal, the City’s version would ignore over 80% of the opportunities to implement traffic calming on residential streets due to the 1/4 of a mile exclusion. You can see how many streets this would exclude using StreetsLA’s own map here.

When defining “standard elements” it was interesting that the City Attorney didn’t simply say “the improvements in the Mobility Plan” but said that it’s the improvements that the Board of Public Works, Director of City Planning and General Manager designate for inclusion in a Project.” In other words, if any of those entities don’t “designate” an improvement to be included in a Project, then it’s excluded, and a bike or bus lane is ignored. This is the first “out” the City has given itself, and it’s a big one.

The next section basically states that the City needs to implement the Mobility Plan during repaving. This part is clean and to the point.

This next section is a doozy. It basically says that the General Manager of LADOT and Director of City Planning — in “consultation” with LAPD, LAFD, and the City Attorney (three entities often hostile to bike and bus lanes in the first place) — can “revise” Mobility Corridors. In other words, they’re usurping City Council’s authority over the Mobility Plan and taking it for themselves. It’s a dangerous precedent to set that City departments can change the City’s General Plan without Council, and especially dangerous to put it in the hands of LAPD, LAFD, and this City Attorney (who has implied the City shouldn’t be at fault for pedestrian deaths even if the City has failed to implement its own Vision Zero or Mobility Plan 2035 plans).

Here, the ordinance states that the General Manager of LADOT, the Director of City Planning, and the Board of Public Works (which, historically, has had nothing to do with Mobility Plan implementation), in consultation with the City Attorney (why does the City Attorney get a say in which elements should be included in a Project?), shall establish which “Standard Elements” (which can already be modified easily) should be included in a Project.

Translated: multiple city departments, and the City Attorney, can determine what to include (or not include). Given the City’s abysmal history in Mobility Plan implementation (3% in seven years = 200 years to implement the plan fully), this makes it more obvious that this ordinance is not a serious attempt to actually implement the Mobility Plan during repaving, but a squishy, grey area ordinance that gives the City many outs to not do so.

We support doing community outreach, but we’ll also note that “outreach” has sometimes been used to kill many good bike, bus, and pedestrian projects across the city for decades. Outreach has often favored well-off Angelenos over those who ride buses, bike, and walk. Sometimes outreach processes have allowed a few loud opponents to outweigh broad community support.

We don't trust that involving three city departments — LADOT, City Planning, and the Board of Public Works — and a bike and bus lane hostile City Attorney in setting outreach requirements that truly support the Council's approved Mobility Plan's equity, safety, environment, and non-motorized mobility goals. In a worse case scenario, these entities could create a bureaucratic and NIMBY prescription to set the outreach bar so high that projects never meaningfully advance. Even without this multi bureaucratic system — today, life saving projects are often delayed. For example, the bike and pedestrian safety improvements on Adams Blvd planned since 2017 took four years to get approved by the council office, in the name of more “outreach.” The formula set out here will make this worse.

The next provision creates a dashboard to help the general public track progress, something Healthy Streets LA also has. However, it then states that the City won’t start following its Mobility Plan during repaving until the dashboard is live. To show good faith, the City could have started implementing its Mobility Plan during repaving after the August 2022, like Council claimed it wanted to do. It didn’t, and it’s been business as usual, with the City ignoring most of the Mobility Plan during repaving. Now the City is giving itself another year (or more) to continue ignoring its own plan during repaving (assuming it meets its own timeline in creating the dashboard; we’re not optimistic given it’s missed every other deadline it’s set for itself during this process).

THAT is the City’s appeal process if they ignore their own Mobility Plan during repaving. This appeals process is complicated, convoluted, and results in a delay of at least six months before you can sue the City for noncompliance. This is yet another roadblock in holding the City accountable, and a process that the average Angeleno will be unlikely to perform — it requires someone to spend an enormous amount of time and energy. The process should be dramatically simplified and modernized.

In our version, if the City ignores its Mobility Plan during repaving, any Angeleno can sue the City and a judge can order the City to redo the street correctly. The person that sued can get their attorney fees paid for by the City if they win.

In the City’s version, you can also sue the City — after you go through their exhausting and long appeals process — but you aren’t entitled to your attorney fees. In other words, in the City’s version, only wealthy people will be in a position to hold the City accountable. In our version, anyone can do it and not have to pay to hold the City accountable.

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So what is our overall take on the City’s version? It’s full of holes, exceptions, and bureaucracy, and is not an attempt to actually implement the Mobility Plan during repaving; it’s an attempt to look like it’s doing something, while actually continuing to mostly ignore the Mobility Plan. It also does not address any of the equity additions Nury had promised, nor does it establish a centralized office of coordination, or provide for a multi year funding plan.

In other words, it’s not nearly good enough. We have raised more than $2,000,000 to get our ballot measure across the finish line this spring. Our polling shows an overwhelming number of Angelenos are sick of the status quo — and will support Healthy Streets LA at the ballot box. If you’re ready for change, join us! You can stay up-to-date, volunteer, donate, and get involved on our website.

See you at the ballot box.

Did La Sombrita get too much shade?

Last Thursday, the Los Angeles Department of Transportation held a press conference with Councilmember Eunisses Hernandez and representatives from KDI, a design consultancy firm, to launch “La Sombrita,” a prototype of a device that was supposed to provide a bit of shade (as its name implies) as well as lighting for bus riders as night.

Almost immediately, the backlash was fierce. People accused the city of wasting taxpayer money, of creating things that don’t actually solve anything, and of performative acts instead of real solutions. A sheet of perforated metal became the symbol of consultancies running wild and a city celebrating incompetence.

It’s not as bad as it looks. We have confirmed that no taxpayer money was spent on the project; it was entirely grant funded, and that the prototype itself actually cost around $2,000, not the “under $10,000” reported. While La Sombrita isn’t the answer, we do want to recognize a city department that went outside of their comfort zone to find a creative solution to a very real problem — most bus stops across Los Angeles lack shelters (only 26% have shelters according to a recent UCLA study). We need to take bus shelters seriously, and not just in better off areas where the advertising makes it worth it for a private company to pay for the facility.

Death by a thousand bureaucratic cuts. As KDI explained in a subsequent tweet thread, while they designed a larger device with no holes that likely would have provided more shade, the city’s own bureaucracy sprung into action and started forcing changes to the project: “to avoid permit and multi-agency coordination, it had to be less than 24” wide, maintain 4 foot clearance, be entirely on the pole, be durable, and be removable.” The holes were added so the device could stand up to strong wind and not bring the pole down with it. Does this make the end result more useful? No, but it explains how we got to this.

It’s good that LADOT is willing to try new things. LADOT is sometimes criticized for following older, bureaucratic standards that sometimes prevent progressive solutions to transportation or public space problems. To their credit, they have started to change (for example, LADOT’s 10’ lane width standard, is narrower than Caltrans’, and they routinely narrow lanes and add limit lines with every repaving project, which slows drivers down; they also have good day lighting standards at intersections). Do we want a city department to be scared to try new things for fear of a public outcry? In this instance, we think a tweet and maybe blog post would have been sufficient as opposed to a press event with a City Councilmember and top LADOT leadership.

We need things that we can deploy quickly at scale. The city is desperate for solutions. Shade at bus stops. Sidewalks that aren’t broken. Trees. Bike and bus lanes. Many of these things have absurd timelines to implement and require multiple city agencies to sign off. They also often lack dedicated funding sources. It’s smart for a department to try and find solutions that the city can afford even in a hard budget year and deploy quickly at scale — even if La Sombrita falls short. We want to give space to city agencies willing to try new things and think outside the normal, bureaucratic way of doing things. Frankly, we need more of that thinking, because eventually we’ll get real solutions at scale quicker than we otherwise would. While this project was hampered by city regulation, here’s the thing: the city controls the regulations, and city council should act to streamline them. Just like we quickly sprung up outdoor dining on public space nearly overnight to help restaurants survive the COVID pandemic, we could provide a similar, highly streamlined process so that a city agency could install bus shelters – much faster, and for a much lower cost.

The now viral photo of La Sombrita from KDI’s tweet

Streets for All recommendations for the CD6 Special Election

The CD6 special election to replace Nury Martinez is about a month away.

Imelda Padilla and Marisa Alcaraz both responded to the Streets for All supplemental questionnaire with confident endorsements of Healthy Streets LA, physical improvements for safer streets for walking and biking (including restoring the protected bike lane on Van Nuys Bl), and better bus infrastructure. However, neither candidate demonstrated the passion and knowledge for the transformational change we feel is needed.

While we couldn’t quite get to a full endorsement, we are jointly recommending Imelda Padilla and Marisa Alcaraz for CD6. Both would be a positive step forward in building a safer CD6 for all road users.

Read the responses to our supplemental questionnaire:

• Marisa Alcaraz

• Imelda Padilla

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You can read the full primary questionnaire responses from: Isaac Kim, Imelda Padilla, Marco Santana, Antoinette Scully, Douglas Sierra.