Senate Bill (SB) 743 was signed into law in 2013, with the intent to better align California Environmental Quality Act (CEQA) practices with statewide sustainability goals related to efficient land use, greater multi-modal choices, and greenhouse gas reductions. Starting July 1, 2020, SB 743 will be implemented statewide, are you ready?
SB 743 fundamentally changes the way we assess land use and transportation projects under CEQA. Specifically, it eliminates vehicular congestion, traditionally expressed as Level of Service (LOS), as the operative metric for identifying transportation impacts. In its place, SB 743 identifies Vehicle Miles Traveled (VMT) as the key impact criterion under CEQA.
Why VMT?
VMT measures the number and length of trips on a typical daily per capita basis. VMT is a useful indicator of overall land use and transportation efficiency, where the most efficient system is one that minimizes VMT by encouraging shorter vehicle trip lengths, more walking and biking, or increasing the use of carpooling and transit. Reducing per capita VMT will reduce per capita emissions, including Greenhouse Gas, in line with State Air Quality and Climate Change goals.
VMT can be challenging to calculate since personal travel is not limited by jurisdictional boundaries. Measuring VMT requires estimating or measuring the full trip-length of individual trips by trip purpose, regardless of how far away from a study area that trip begins or ends. For this reason, regional travel demand models, “big data,” and household travel surveys that are not limited by local jurisdictional boundaries are the preferred tools to estimate VMT under SB 743.
What about CEQA Impacts? Mitigation?
Local agencies still have the discretion to determine an appropriate screening method and a threshold for their respective jurisdictions. The only definitive answer in the CEQA Guidelines (Section 15064.3) is that a project’s effect on automobile delay (i.e., congestion) shall not constitute a significant environmental impact.
The CEQA guidance for determining the significance of transportation impacts focuses on land use and transportation projects, leaving other types of projects, such as non-transportation related public works and infrastructure projects, unmentioned.
Guidance is provided for both screening a project and developing quantitative thresholds for determining significance. For example, if a project meets specific “smart growth” criteria, it may be presumed to have a less than significant VMT impact with no further analysis needed. The Governor’s Office of Planning and Research Technical Advisory for SB 743 generally recommends a 15% reduction in VMT per capita as an appropriate impact threshold under CEQA. However, GHD’s experience is that the application of this guidance varies between jurisdictions, based on urban form, geography, demographics, and available transportation choices.
VMT estimates are assessed against statewide, regional, or local averages. It is critical, therefore, that agencies carefully consider and establish baseline averages that reflect the travel behavior of their residents and employees. This baseline will be the measuring stick for all future projects to be assessed against. Given that traditional congestion-based mitigation strategies will no longer be appropriate under CEQA, a key challenge for all local agencies will be identifying appropriate mitigation for VMT reductions and developing funding mechanisms to prioritize and deploy them.
What about Congestion? Safety?
Despite the statewide shift to VMT under CEQA, many agencies have a desire to maintain traditional transportation performance measures like LOS. Under SB 743, communities can retain performance standards that address congestion, safety, and traffic flow as part of their general plan policies, impact fee programs (per the California Mitigation Fee Act), or impact study guidelines.
GHD will work with your agency to ensure development project impact studies continue to measure metrics that reflect the concerns and day-to-day transportation experiences of your staff and constituents. Although CEQA impacts and mitigations will focus on VMT, congestion and safety improvements required to maintain your communities’ service standards can continue to be tied to land development as part of transportation impact fee programs and projects’ conditions of approval.
How can GHD help?
Our Transportation Planners and Engineers have proven experience helping Counties and Cities throughout California, navigate the shift to SB 743. This includes:
- Establishing VMT Baselines, Screening, & Thresholds
- Developing Project Level VMT Sketch-Planning Tool
- Crafting Impact Study Guidelines and Circulation Element Policies (VMT, LOS, Safety)
- Developing VMT Mitigation Framework
- Generating Stakeholder Support
For more information, please contact Todd Tregenza | E: todd.tregenza@ghd.com or Jake Hudson | E: jake.hudson@ghd.com.
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CEQA | Technical Advisory on Evaluating Impacts in CEQA | CEQA Statutes and Guidlines | SB 743 Updates