California Senate Bill 743
An evolutionary change to transportation impact analysis.
Conventional approaches to transportation impact analysis tend to focus on vehicle level of service (LOS) and similar metrics related to vehicle delay. This focus explains how land use and transportation projects affect driving instead of how those projects change the amount of driving that will occur. While changes to driving conditions that increase travel times are an important consideration for traffic operations and management, these changes do not fully describe environmental effects associated with fuel consumption, emissions, and public health.
SB 743 changes the focus of transportation impact analysis in CEQA from measuring impacts to drivers, to measuring the impact of driving. The change is being made by replacing LOS with vehicle miles of travel (VMT) and providing streamlined review of land use and transportation projects that will help reduce future VMT growth. This shift in transportation impact focus is expected to better align transportation impact analysis and mitigation outcomes with the State’s goals to reduce greenhouse gas (GHG) emissions, encourage infill development, and improve public health through more active transportation.
In January 2019, the Natural Resources Agency finalized updates to the CEQA Guidelines including the incorporation of SB 743 modifications. The Guidelines changes were approved by the Office of Administrative Law and are now in effect. Specific to SB 743, Section 15064.3(c) states, “A lead agency may elect to be governed by the provisions of this section immediately. Beginning on July 1, 2020, the provisions of this section shall apply statewide.”
Introducing VMT as the New Metric of Analysis
What is VMT?
For those new to VMT analysis, this short video explains a few basic components of VMT. We routinely analyze VMT for air quality and greenhouse gas impact analysis. SB 743 adds VMT to the transportation impact analysis of CEQA documents. If you find this helpful, let us know what other VMT related information you’d like to see in this format.
SB 743 Implementation
While SB 743 implementation is still evolving, a variety of public, private, and institutional entities have contributed to creating implementation resources and addressing the key implementation questions. Fehr & Peers has developed implementation guidance including recommendations on forecasting methodology, thresholds, mitigation strategies, and annotated flowcharts to outline the critical steps and choices for public agencies.
Essential Implementation Questions
All lead agencies will need to answer the following SB 743 implementation questions:
1. What is the preferred methodology for estimating and forecasting VMT considering that this metric is a required input for air quality, energy, GHG, and now transportation impact analysis in CEQA?
– If the lead agency wants to follow the OPR Technical Advisory recommendations, what travel forecasting model will be used to estimate baseline VMT for citywide or regional averages?
– How will the lead agency ensure that project-scale VMT analysis is consistent with the methodology used to estimate thresholds?
2. What are the significance thresholds for VMT impacts under ‘baseline’ and ‘cumulative’ conditions?
– Does the lead agency accept the OPR Technical Advisory recommendation that land use projects and plans within metropolitan planning organization (MPO) areas can achieve a 15 percent reduction in VMT per capita or per worker compared to existing conditions?
3. Does the lead agency want to take advantage of VMT impact screening?
– Will VMT impact screening be allowed for residential and employment land uses based simply on location within a transit priority area (TPA) or low-VMT generating area?
– Will screening also be allowed for local-serving retail projects consisting of less than 50,000 square feet?
4. What mitigation does the lead agency consider to be feasible for VMT impacts?
– If TDM is used, how will the lead agency verify its effectiveness over time since many TDM programs are building tenant dependent?
Where do the guidelines apply (TPAs in California)?
Text of New Section 15064.3 (b)(1) Land Use Projects. Vehicle miles traveled exceeding an applicable threshold of significance may indicate a significant impact. Generally, projects within one-half mile of either an existing major transit stop or a stop along an existing high quality transit corridor should be presumed to cause a less than significant transportation impact. Projects that decrease vehicle miles traveled in the project area compared to existing conditions should be presumed to have a less than significant transportation impact.
Click image to enlarge
How does SB 743 apply to my project?
What are effective methods of mitigation?
An important part of VMT impact analysis under SB 743 is finding effective methods of mitigation. The CAPCOA Quantifying Greenhouse Gas Mitigation Measures is a common reference guide to VMT reduction strategies relying on built environment changes and transportation demand management (TDM) strategies. While this is a popular guide, it was produced in 2010 and reflected even older research. Fehr & Peers has completed a comprehensive review of published research through 2017 and is available to assist with VMT mitigation services including: CEQA Mitigation Strategy Development and Monitoring, Local and Regional TDM Ordinance Development and Monitoring, Employer TDM Program Development and Monitoring.
Will disruptive trends influence SB 743 implementation?
Forecasting VMT involves uncertainty,
Land use and transportation network decisions are a small part of future VMT. Disruptive mobility trends including internet shopping and autonomous vehicles (AVs) will have a much larger influence on VMT.
and understanding potential risks.
Including the influence of disruptive trends on VMT is essential when selecting analysis methods and especially in setting impact thresholds. Agencies have a risk of setting unattainable expectations for VMT reduction without first considering how VMT is likely to change due to disruptive forces beyond their control.
Analyzing disruptive trends can help.
Fehr & Peers has developed the TrendLab+ tool and AV modeling tests to quickly assess the potential effects of disruptive trends on VMT. This is an essential starting point for any agency making decisions about VMT analysis methods and impact thresholds.
OPR's December 2018 Technical Advisory
The new OPR Technical Advisory details include:
- Specifications for cumulative analysis
- Clarity that consistency with an RTP/SCS does not necessarily lead to a less than significant impact (the ARB SB 150 Report provides evidence substantiating this position)
- Highlighting the importance that VMT impact thresholds align with all three statutory goals: “the reduction of greenhouse gas emissions, the development of multimodal transportation networks, and a diversity of land uses”
- Adding consideration of ‘displacement’ when analyzing redevelopment projects
- Applying project level VMT impact thresholds to general plans
Caltrans SB 743 Implementation
What does SB 743 not do?
Knowledge Sharing Opportunities
March 1, 2019
Los Angeles, CA
Cast Studies of Analysis and Mitigation
under CEQA Guidelines Implementing SB 743
Presented by a group of attorneys, transportation planners and
transportation consultants with extensive experience in the field,
including Ron Milam, AICP, PTP, Director of Evolving the Status Quo of Fehr & Peers
April 3-4, 2019
Orange County, CA
TE-60 VMT Metrics Policy Application
& Technical Analysis for SB 743 Compliance
Ron Milam, AICP, PTP, Director of Evolving the Status Quo | Fehr & Peers
Antero Rivasplata, AICP, Technical Director | ICF International
Click links below to view presentations.
CEQA – The Year in Review, CEQA Guidelines 2018 Amendments (December 2018)
UCSD Extension Course: Navigating SB 743 Implementation (September 14, 2017)
VMT Metrics Application & Analysis for SB 743 Compliance (June 7, 2017)
LOS to VMT: VMT Calculation Tools and Setting Thresholds (May 4, 2017)
VMT Metrics Application & Analysis for SB 743 Compliance (April 23, 2017)
What’s the Recipe for SB 743 Implementation? (October 23, 2016)
SB 743 Legislative Intent vs CEQA Practice (October 4, 2015)
Important findings from the implementation work have revealed that simply analyzing the VMT generated by a project is insufficient to identify potential significant impacts and that TDM mitigation effectiveness cannot be guaranteed since it is often building-tenant dependent.
Fehr & Peers contributed to the Handbook for Estimating Transportation Greenhouse Gases for Integration into the Planning Process published by FHWA in 2013. FHWA describes the publication as “..a handbook designed to provide information on how to analyze on-road greenhouse gas emissions at the state and regional level, and how to incorporate those analyses into transportation planning efforts.” The handbook is actually quite a bit more than that because it also includes substantial detail on how to forecast VMT given its importance in mobile GHG emissions. Key information includes step by step calculations and summary strengths and weaknesses for each VMT forecasting method.
Transportation impact analyses in California have largely focused on auto LOS, which measures transportation network performance only from a driver’s perspective. This document, authored by Fehr & Peers Principal Ron Milam, explains the limitations of this traditional analysis approach and provides additional methods for a more complete analysis.