Top Ten Things to Know About SB 743
1. OPR recommended VMT as the most appropriate measure of transportation impacts.
2. Screening is allowed to quickly evaluate potential VMT impacts based on the location of a land use project being in close proximity to an existing major transit stop, a stop along an existing high quality transit corridor, or in a low-VMT generating area.
3. The new CEQA Guidelines sections created by SB 743 go into full effect statewide on July 1, 2020 although lead agencies may elect to opt-in immediately.
4. Lead agencies must make at least three decisions to implement the new CEQA Guidelines:
1) Select a VMT methodology.
While Proposed Section 15064.3(b)(4) gives lead agencies discretion to choose the most appropriate methodology, the companion Technical Advisory (TA) adds requirements.
a. VMT refers to the amount and distance of automobile travel. The definition of an automobile refers to passenger vehicles and light trucks. However, VMT may include commercial vehicles (i.e., heavy-duty trucks) for modeling convenience. This allowance is important because VMT analysis associated with air quality, energy, and GHG impacts already uses VMT generated by all vehicles (see TA Page 3 for details).
b. The VMT methodology should not truncate trips at political or model boundaries. The full extent of trip lengths should be captured.
c. The VMT methodology used to set thresholds should be similar to the methodology used to analyze projects.
2) Select significance thresholds.
SB 743 did not authorize OPR to set thresholds, but it did direct OPR to develop Guidelines “for determining the significance of transportation impacts of projects[.]” (Pub. Resources Code, § 21099(b)(2).) OPR’s guidelines are contained in the TA and include specific thresholds for land use projects, land use plans, and transportation projects. OPR’s recommended thresholds for VMT impacts are largely connected to GHG reduction. Since the legislative intent for SB 743 included objectives to encourage infill and promote active transportation, other significance criteria and threshold may be appropriate to consider (i.e., mode split). Lead agencies should also consider if changes are needed to their current transportation impact thresholds related to transit, active transportation, and safety. Final VMT thresholds may require reduction beyond those recommended by OPR given the substantial evidence included in the ARB Mobile Source Strategy (MSS). The MSS states that current Regional Transportation Plan/Sustainable Communities Strategies (RTP/SCSs) do not provide sufficient VMT reduction to achieve statewide GHG and air pollution reduction goals. An additional 15 percent reduction in total 2050 VMT under the RTP/SCSs is needed.
3) Determine feasible mitigation measures.
Reducing VMT requires modifying the project or adding transportation demand management (TDM) strategies to the project. Project modifications could include a variety of built environment changes such as modifying specific D variables. The Ds includes key variables such as land use density, land use diversity, street design (intersection density), regional accessiblity to destinations, distance to transit, and development scale.
5. Land use projects such as local serving retail may be presumed to have a less than significant VMT impact. Other transportation impacts may occur related to safety or the pedestrian, bicycle, and transit systems.
6. Transportation projects that reduce VMT, such as pedestrian, bicycle and transit projects, may be presumed to have a less than significant VMT impact. Other transportation impacts may occur related to safety or the pedestrian, bicycle, and transit systems.
7. Lead agencies have discretion in which measure to use to evaluate roadway, including highway, capacity projects, provided that any such analysis is consistent with the requirements of CEQA and any other applicable requirements. This recent change is intended to allow agencies to continue using vehicle level of service (LOS) to analyze the impacts of roadway capacity expansion projects.
8. Vehicle LOS may continue to be used for all projects as part of transportation planning or entitlement review. This includes regional transportation plans, general plans, specific plans, impact fee programs, corridor studies, transportation development studies, and individual land use projects.
9. Induced vehicle travel effects of roadway capacity expansion projects should be analyzed as part of VMT impact analysis. Induced vehicle travel effects may also influence the expected performance of roadway capacity expansion projects and should be considered as part of planning and design studies.
10. A project’s short-term and long-term effects on VMT should be analyzed. This simple statement has multiple meanings. First, the VMT analysis should include ‘project’ and ‘cumulative’ impacts. This is typically defined as analyzing ‘baseline plus project’ and ‘cumulative plus project’ conditions. In addition, the VMT analysis should include estimates of ‘project generated VMT’ and the ‘project’s effect on VMT’. The difference in measurement is intended to recognize that some projects such as retail land use changes can generate new VMT from the project site but also decrease community-wide VMT when the effect on the neighboring area is considered. Even residential projects can reduce long-term VMT depending on a community’s jobs-housing balance and match when considering the project’s effect on VMT.