dissenting:
Seattle requires the Chief of Police to grant a parade permit to anyone who applies for one. SMC 11.25.020.1 The Chief of Police has authority only to modify the parade’s place, time, and proposed line of movement or march “in the interest of vehicular or pedestrian traffic safety.” Id. Because Seattle defines “parade” as always involving some “closure of streets to prevent a conflict with the regular flow of vehicular traffic,” SMC 11.14.410, anyone with a parade permit is entitled to some use of the city streets. Seattle’s routine effort to coordinate parade activities with public safety concerns is a garden-variety content-neutral time, place and manner restriction. And yet the majority holds that the routine authority to reroute a march for vehicular and pedestrian safety is actually a grant of standardless discretion to deny First Amendment rights which must be struck down as facially unconstitutional.2 Maj. Op. at 801-03. Because this conclusion is not supported by Supreme *804Court precedent or our case law, I must respectfully dissent.
A
“[I]n order to regulate competing uses of public forums, [local governments] may impose a permit requirement on those wishing to hold a march, parade, or rally.” Forsyth County v. Nationalist Movement, 505 U.S. 123, 130, 112 S.Ct. 2395, 120 L.Ed.2d 101 (1992); see also Santa Monica Food Not Bombs v. Santa Monica, 450 F.3d 1022, 1036 (9th Cir.2006).
[E]ven in a public forum the government may impose reasonable restrictions on the time, place, or manner of protected speech, provided the restrictions are justified without reference to the content of the regulated speech, that they are narrowly tailored to serve a significant governmental interest, and that they leave open ample alternative channels for communication of the information.
Ward 491 U.S. at 791, 109 S.Ct. 2746 (internal quotation marks omitted). In addition, a licensing scheme “must not delegate overly broad discretion to a government official.” Santa Monica Food Not Bombs, 450 F.3d at 1036. A licensing scheme does not vest unbridled discretion in government officials when it is guided by “narrowly drawn, reasonable and definite standards,” Forsyth County, 505 U.S. at 133, 112 S.Ct. 2395 (internal quotation marks omitted), that render an official’s decision “subject to effective judicial review.” Thomas v. Chicago Park Dist., 534 U.S. 316, 323, 122 S.Ct. 775, 151 L.Ed.2d 783 (2002).
The Coalition contends the Seattle ordinance is facially unconstitutional because it grants the city “unbridled discretion” to deny expressive activity. On its face, the Seattle ordinance gives the Chief of Police no discretion to deny, or even to condition, a permit. Rather, the ordinance requires the Chief of Police to grant every permit request. The Coalition bases its claim that the ordinance is facially invalid on the seemingly modest amount of discretion granted to the Chief of Police: the authority to modify only “the place and hour of formation, the proposed line of movement or march, and the scheduled starting time” and only “in the interest of vehicular or pedestrian traffic safety.” SMC 11.25.020.3 According to the Coalition, the ordinance’s traffic safety standard does not meet the Supreme Court’s requirements *805that a licensing scheme contain adequate standards to constrain an official’s discretion.
In my view, the Seattle ordinance is far removed from a grant of unbridled discretion. As noted above, the Chief of Police must grant all parade permits and may modify the direction of a parade only on the ground of traffic safety. This ground is “reasonably specific and objective, and do[es] not leave the decision to the whim of the administrator.” Thomas, 534 U.S. at 324, 122 S.Ct. 775 (internal quotation marks omitted). A court or jury is capable of evaluating whether police officers based traffic safety decisions on objective factors such as the officer’s prior experience with such situations or on-the-ground observations of emergent conditions, or were swayed by their personal feelings or prejudices. In an as-applied challenge to discriminatory enforcement of the Seattle ordinance, a plaintiff may introduce evidence and testimony as to the absence of objectively based traffic safety concerns and raise the inference that the officials modified a parade permit for illegitimate discriminatory reasons. Indeed, this point is illustrated by the history of this litigation. The Coalition brought an as-applied challenge to the Seattle ordinance in district court, arguing that Seattle was making modifications to the permit based on the messages of the marchers, rather than “in the interest of vehicular or pedestrian traffic.” SMC 11.25.020. Although the parties ultimately settled the as-applied challenge, the record provides no indication that the Coalition was hampered in making its case by a lack of objective and defined standards against which to test the constitutionality of the city’s conduct. Given that the traffic safety standard in the Seattle ordinance is sufficiently objective and defined to render city officials’ decisions “subject to effective judicial review,” Thomas, 534 U.S. at 323,122 S.Ct. 775, the ordinance does not vest unbridled discretion in the Chief of Police.
The majority’s conclusion to the contrary is not supported by the Supreme Court decisions that have invalidated permit schemes on a facial unbridled discretion theory. In Forsyth County, for instance, the Supreme Court invalidated an ordinance requiring a parade permit applicant to pay a fee for certain costs prior to the issuance of a permit, where “[t]he decision how much to charge for police protection or administrative time — or even whether to charge at all — [was] left to the whim of the administrator.” 505 U.S. at 133, 112 S.Ct. 2395. Similarly, in Plain Dealer, the Court struck down a city ordinance that allowed the mayor to condition the grant of a permit on, among other things, “any other terms and conditions deemed necessary and reasonable by the Mayor.” 486 U.S. at 753-54, 108 S.Ct. 2138 (internal quotation marks omitted). Finally, in Shuttlesworth v. City of Birmingham, the Supreme Court determined that an ordinance was unconstitutional as written because it lacked any measurable, objective standard to guide official discretion. 394 U.S. 147, 150-51, 89 S.Ct. 935, 22 L.Ed.2d 162 (1969). Members of the governing body “were to be guided only by their own ideas of ‘public welfare, peace, safety, health, decency, good order, morals or convenience.’ ” Id. at 150, 89 S.Ct. 935. All of these cases involved broad and subjective standards that made officials’ decisions essentially unchallengeable. By contrast, the standard in the Seattle ordinance, “vehicular or pedestrian traffic safety,” is considerably more objective and defined. Indeed, it more closely resembles the ordinance upheld in Thomas, which granted park officials authority to deny access to the park only for a limited number of reasons, including that the use “would present an unreasonable *806danger to the health or safety of the applicant, or other users of the park, of Park District Employees or of the public.” 534 U.S. at 319 n. 1,122 S.Ct. 775.
The majority asserts that the Seattle ordinance vests too much discretion in government officials because the ordinance lacks two procedural safeguards: First, the ordinance does not require administering officials to state their reasons for undertaking a modification; and second, the ordinance does not provide an administrative review process to challenge modifications on a case-by-case basis. Maj. Op. at 801-02. While these procedures were included in ordinances the Supreme Court upheld against unbridled discretion challenges, see Thomas, 534 U.S. at 324, 122 S.Ct. 775, the Court has never suggested that such requirements are necessary components of a licensing scheme. In Southern Oregon Barter Fair v. Jackson County, we explicitly rejected the argument that specific procedural safeguards, such as provisions for prompt judicial review of permit denials, were required in order for a licensing scheme to withstand a facial challenge. 372 F.3d 1128, 1136-38 (9th Cir.2004).
Nor would a requirement that a content-neutral time, place and manner restriction contain specific procedural safeguards be reasonable, because such procedures may not make sense in every context. Here, for example, decisions regarding permit modifications often occur on the ground, where police are forced to rapidly respond to emergent and unpredictable conditions such as traffic and weather. Officers at the scene of a parade cannot do their jobs properly and at the same time be obliged to provide an explanation for every tactical decision or an opportunity for administrative appeal.
Indeed, Thomas itself does not place any special weight on the procedures included in the ordinance at issue in that case, but rather focuses on whether the standards guiding government officials’ exercise of discretion are sufficiently narrow. In analyzing the provisions of the specific ordinance at issue, Thomas mentions the procedures relied upon by the majority, but focuses on the grounds on which officials could deny a permit, concluding that the standards “are reasonably specific and objective, and do not leave the decision to the whim of the administrator.” 534 U.S. at 324, 122 S.Ct. 775; see also Ward, 491 U.S. at 794, 109 S.Ct. 2746 (upholding an ordinance that allowed technicians at a concert to adjust the volume of the amplification without requiring a post hoc justification, despite the Court’s recognition that the “officials implementing [the ordinance] will exercise considerable discretion”); S. Or. Barter Fair, 372 F.3d at 1138-39 (holding that an ordinance requiring permits for certain mass gatherings was facially valid even without a provision for prompt judicial review of permit denials or other procedural safeguards, because the ordinance contained adequate standards to render the administrators’ decisions subject to effective judicial review).
In sum, neither Supreme Court precedent nor our own case law supports the majority’s elevation of procedural safeguards to central importance in determining whether an ordinance grants officials unfettered discretion. In striking down the Seattle ordinance for failing to incorporate procedural measures, the majority has lost sight of the Court’s ultimate question: whether the Seattle ordinance “contain[s] adequate standards to guide the official’s decision and render it subject to effective judicial review.” Thomas, 534 U.S. at 323, 122 S.Ct. 775. Because the traffic safety standard in the Seattle ordinance is sufficiently defined and objective — certainly as objective as the “unreasonable danger to health or *807safety” standard upheld in Thomas — the ordinance does not vest unbridled discretion in the Chief of Police. The presence or absence of additional procedural safeguards cannot change this conclusion.
B
The Seattle ordinance not only adequately constrains the Chief of Police’s discretion, but easily meets the other requirements for a valid time, place, and manner restriction.
First, the Coalition does not dispute that the Seattle ordinance is content-neutral. See Maj. Op. at 797-98. Second, the ordinance is “narrowly tailored to serve the government’s legitimate content-neutral interests,” Ward, 491 U.S. at 798, 109 S.Ct. 2746, namely traffic safety. To be narrowly tailored, the regulation “need not be the least restrictive or least intrusive means” of serving the government interest. Id. Instead, it must “promote[ ] a substantial government interest that would be achieved less effectively absent the regulation.” Id. at 799, 109 S.Ct. 2746 (internal quotation marks omitted). There is no doubt that the government has a significant interest in promoting vehicular and pedestrian safety. See Heffron v. Int’l Soc’y for Krishna Consciousness, Inc., 452 U.S. 640, 650, 101 S.Ct. 2559, 69 L.Ed.2d 298 (1981) (“[I]t is clear that a State’s interest in protecting the safety and convenience of persons using a public forum is a valid governmental objective.” (internal quotation marks omitted)); ACORN v. City of Phoenix, 798 F.2d 1260, 1267 (9th Cir.1986) (“[Mjore so than with sidewalks or parks, courts have recognized a greater governmental interest in regulating the use of city streets.” (internal quotation marks omitted)). Seattle’s ordinance requires officials to issue permits to all applicants subject to modifications necessary to protect this substantial interest in pedestrian and vehicular safety. Because the ordinance addresses traffic safety issues “without ... significantly restricting a substantial quantity of speech,” One World, One Family Now v. Honolulu, 76 F.3d 1009, 1014 (9th Cir.1996) (alteration in original) (internal quotation marks omitted), that does not implicate traffic safety issues, it meets the narrow tailoring requirement.
Finally, the ordinance “leaves open ample alternatives for communication.” Santa Monica Food Not Bombs, 450 F.3d at 1037. The Coalition asserts that by allowing police to reroute parades from the street to the sidewalk, Seattle does not leave open ample alternatives for communication. The majority similarly asserts that the Chief of Police’s authority to change the direction of a parade or march gives the Chief of Police “the discretion to ‘permit or deny expressive activity, “namely, a street march.”’” Maj. Op. at 796 (quoting Plain Dealer, 486 U.S. at 755, 108 S.Ct. 2138). I disagree. In my view, the ordinance leaves open ample alternatives for communication even though the Chief of Police may require the parade to march partially on the sidewalk. “[T]he First Amendment does not guarantee the right to communicate one’s views at all times and places or in any manner that may be desired.” Menotti v. City of Seattle, 409 F.3d 1113, 1138 (9th Cir.2005) (internal quotation marks omitted). Instead, “[t]he First Amendment requires only that the government refrain from denying a reasonable opportunity for communication.” Id. (internal quotation marks omitted). Here, the Seattle ordinance allows marchers to “reach[ ] their intended audience,” One World One Family Now, 76 F.3d at 1014, because, whether they are on streets or on the sidewalks, marchers are still visible from the streets. Although the marchers may prefer complete access to *808the streets because it makes their message more visible, the constitution does not require that speakers have access to the most effective mode of expression. Id.; see also Menotti, 409 F.3d at 1138 (holding that an ordinance prohibiting protests against the World Trade Organization in an area with greatest access to conference delegates left open ample alternative channels of communication because the protestors could make their protests “visible and audible to delegates, even if not as proximate as the protestors might have liked”).
This conclusion is consistent with the rulings of two of our sister circuits, which have held that sidewalks can be a reasonable alternative to the streets. In Stonewall Union v. City of Columbus, the Sixth Circuit upheld the constitutionality of a Columbus parade ordinance that imposed a fee on applicants for a parade permit. 931 F.2d 1130, 1137 (6th Cir.1991). In rejecting the claim that the ordinance violated the constitutional rights of protesters who could not afford the fee, the court held that “the availability of the sidewalks and parks provides a constitutionally acceptable alternative for indigent paraders.” Id.; see also Sullivan v. City of Augusta, 511 F.3d 16, 43-45 (1st Cir.2007) (upholding an Augusta licensing scheme that imposed a fee for parades because although a sidewalk march might “seem less appealing to some protestors than a street march, it nonetheless provides a prominent route along major thoroughfares for dissemination of a message”).
C
In sum, the Seattle ordinance requires the Chief of Police to grant a permit, subject only to modifications based on “objective,” “narrowly drawn, reasonable and definite standards,” Forsyth, 505 U.S. at 133, 112 S.Ct. 2395 (internal quotation marks omitted). Because Seattle’s parade-friendly ordinance is an ordinary content-neutral time, place, and manner restriction that does not vest unbridled discretion in the Chief of Police, I respectfully dissent from the majority’s determination that it is facially invalid under the First Amendment.
. The ordinance states:
No person shall conduct or participate in a parade upon any street or alley in the City without first submitting a written notification to the Chief of Police and obtaining a permit from the Chief of Police to do so. Upon written notification to the Chief of Police, the Chief of Police shall grant a permit. So that preparations for traffic regulation can be made, the written notification for permit shall state the place and hour of formation, the proposed line of movement or march, the scheduled starting time, and the names of the persons having charge or control of the parade, and the name of the sponsoring agency, if any. Such written notification shall be delivered to the Chief of Police at least forty-eight (48) hours before the parade is scheduled to begin: Provided, that the forty-eight (48) hour time limit for written notification may be waived by the Chief of Police if, at the time the written notice is submitted, the Chief of Police anticipates being able to make reasonable preparations for the parade within less time than forty-eight (48) hours. The Chief of Police may modify the place and hour of formation, the proposed line of movement or march, and the scheduled starting time in the interest of vehicular or pedestrian traffic safety.
. As a threshold matter, I doubt the Coalition may properly bring a facial challenge against the ordinance. Because the ordinance does not give the Chief of Police the discretion to permit or deny parade licenses, it does not grant the type of unbridled discretion that has previously caused the Supreme Court to make an exception to its general disapproval of facial challenges. See City of Lakewood v. Plain Dealer Pub. Co., 486 U.S. 750, 757, 108 S.Ct. 2138, 100 L.Ed.2d 771 (1988). Rather, the Seattle ordinance grants the Chief of Police limited discretion which "is of an entirely different, and lesser, order of magnitude,” Ward v. Rock Against Racism, 491 U.S. 781, 794, 109 S.Ct. 2746, 105 L.Ed.2d 661 (1989), *804and which does not give rise to the twin evils of self-censorship and inadequate judicial review that are at the center of the Court’s rationale for allowing facial challenges on an unbridled discretion theory. See Plain Dealer, 486 U.S. at 757, 108 S.Ct. 2138. However, even assuming the majority is correct in allowing a facial challenge to go forward, I would hold that the Coalition’s challenge fails on the merits. See Ward, 491 U.S. at 794, 109 S.Ct. 2746.
. The majority has extracted from the record several examples of occasions when the Seattle police rerouted marches to the sidewalk based on the size of the march. There has been no finding that such incidents are representative of Seattle's implementation of the ordinance. Nevertheless, even assuming it is proper to consider such isolated examples in a facial challenge, these incidents support Seattle's position that its ordinance does not grant police unbridled discretion to deny expressive activity for illegitimate reasons. Regardless of the terminology the police informally used in describing their decision to reroute certain marches, the evidence identified by the majority demonstrates that the police allowed each of the proposed marches at issue to go forward. Moreover, the police rerouted marchers to the sidewalk based on the size of the march, a content-neutral criterion that is reasonably related to vehicular and pedestrian safety concerns (i.e., a police officer could reasonably determine that a small number of marchers is less visible to oncoming traffic) and which would be readily subject to review and challenge in court.