California Senate Bill 743

On September 27, 2013, California Governor Jerry Brown signed SB 743 into law and started a process that changes transportation impact analysis as part of CEQA compliance. These changes will include elimination of auto delay, level of service (LOS), and other similar measures of vehicular capacity or traffic congestion as a basis for determining significant impacts for land use projects and plans in California.

Further, parking impacts will not be considered significant impacts on the environment for select development projects within infill areas with nearby frequent transit service. According to the legislative intent contained in SB 743, these changes to current practice were necessary to more appropriately balance the needs of congestion management with statewide goals related to infill development, promotion of public health through active transportation, and reduction of greenhouse gas emissions.

January 2019

The Natural Resources Agency has 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.”

To aid with implementation, OPR has produced an updated December 2018 Technical Advisory.  New 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

An Introduction to 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.


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.

How does SB 743 apply to my project?

Curious about how to navigate your Land Use or Transportation Project, or General Plan through SB 743? We’ve developed flow charts to help – click below for more.


New VMT Mitigation Resources

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 any of the following VMT mitigation services:


CEQA Mitigation Strategy Development and Monitoring

Local and Regional TDM Ordinance Development and Monitoring

Employer TDM Program Development and Monitoring

Knowledge Sharing Opportunities


Shifting from Maintaining LOS to Reducing VMT

March 1, 2019
Los Angeles, CA

Cast Studies of Analysis and Mitigation
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


UC Berkeley Tech Transfer Course

April 3-4, 2019
Orange County, CA

TE-60 VMT Metrics Policy Application
& Technical Analysis for SB 743 Compliance 

Presented by:
Ron Milam, AICP, PTP, Director of Evolving the Status Quo | Fehr & Peers
Antero Rivasplata, AICP, Technical Director | ICF International

News & Insights

How Can VMT Impact Mitigation Evolve?

“Mitigating VMT impacts is challenging especially in suburban and rural environments where travel choices are limited.  In response, policy analysts and researchers have been investigating new mechanisms for VMT impact mitigation.  “An Analysis of Vehicle Miles Traveled Banking and Exchange Frameworks” that was recently published by U.C. Berkeley is a useful resource for understanding how VMT impact mitigation can evolve.

read more

10 Things to Know About Implementing SB 743

OPR Releases Update to CEQA Guidelines …on Evaluating Transportation Impacts in CEQA Implementing Senate Bill 743   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…

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Planning with SB 743

Highlighting recent projects in San Francisco and Los Angeles where planning involved adhering to SB 743.

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Multimodal Safety: The New Kid on the Block?

Traffic safety has not been a traditional topic of focus under CEQA. Well, that’s about to change due to SB 743.

read more

Where the New Guidelines Apply (TPAs in California)

Text of Proposed New Section 15064.3 (b)(1) Vehicle Miles Traveled and Land Use Projects. A development project that results in vehicle miles traveled exceeding an applicable threshold of significance may indicate a significant impact. Generally, development projects that locate within one-half mile of either an existing major transit stop or a stop along an existing high quality transit corridor may be presumed to cause a less than significant transportation impact. Similarly, development projects that decrease vehicle miles traveled in the project area compared to existing conditions may be considered to have a less than significant transportation impact.

Click image to enlarge

The SACOG map layers were developed using data from the SACMET Metropolitan Transportation Plan / Sustainable Community Strategy (MTP/SCS) model provided by the Sacramento Area Council of Governments. MTC layers were developed using modified GIS data provided by the Metropolitan Transportation Commission. SCAG and SANDAG map layers are displayed as received courtesy of Southern California Association of Governments and the San Diego Association of Governments. Note that this information is subject to change as transit networks are modified over time. The current data reflects 2018 conditions.

Common Questions about SB 743

What does SB 743 not do?
This question may be more important to some agencies than what SB 743 does.  This statement is particularly true for cities or counties that feel that continued use of vehicle LOS is an important part of their transportation analysis process.  In these communities, vehicle LOS analysis in CEQA documents has achieved the desired outcomes of the jurisdiction and they want to know if they will have to change their process due to SB 743. While a definitive answer won’t be possible until the final CEQA Guidelines are adopted, we do know that SB 743 did not change laws related to general plans, police powers granted to cities and counties by the State constitution, the subdivision map act, or traffic impact fee programs. As such, no changes have occurred for jurisdictions wanting to use vehicle LOS to size roadways in their general plan or determine nexus relationships for their impact fee programs.  They can also continue to condition projects to build transportation improvements through the entitlement process in a variety of ways, such as using general plan consistency findings.


If anything, the potential loss of vehicle LOS (and similar measures) in CEQA could reinforce the importance of general plans and supporting implementation methods (such as impact fee programs) as the primary means for defining a jurisdiction’s policy approach to transportation.  As the importance of general plans increases, it is worth noting that many general plan circulation elements were developed without consideration of capital and O&M financial constraints.  These constraints often become apparent in subsequent project-level environmental reviews, frequently leading to significant and unavoidable impact findings because the jurisdiction does not have financial mechanisms that generate sufficient funding to build all of the circulation element improvements. Jurisdictions may also find themselves in this situation if the traffic impact fee necessary to fully fund the circulation element exceeds a reasonable level that could be supported within the development marketplace.


Ideally, the general plan would establish vehicle LOS expectations (and commensurate development levels) based on the amount of infrastructure the jurisdiction could afford to build, operate, and maintain.  Development projects consistent with this type of general plan would require little (or no) vehicle LOS impact analysis, but instead could focus on issues such as multi-modal siteaccess and parking provision to comply with applicable design standards.  This could substantially reduce the effort required in typical CEQA transportation impact studies.  In order to achieve this outcome, jurisdictions may need additional resources to update their general plans and transportation financing programs, which is an issue for further discussion.
What are the suggested Methods for estimating project VMT under SB 743?

MXD 2.0 accounts for the difference in trip generation between conventional suburban development and location efficient, mixed use projects.   It is the product of research sponsored by US EPA and the Transportation Research Board, including analysis of regional travel surveys and verification through case studies and field data.  It provides substantial evidence in support of adjustments to ITE trip rates for development projects whose design, content and location verifiably reduce traffic generation. The EPA MXD research examined travel survey data from 239 mixed-use developments across the US and identified the quantifiable trip reducing effects of a series of “D” factors:  development density, diversity of uses, design of multimodal access and circulation, distance from transit, destination accessibility, development scale, and demographic characteristics of residents and workers.  Its accuracy was verified through traffic counts at over twenty development sites in California and elsewhere. The EPA MXD method was peer reviewed by the American Society of Civil Engineers, the San Diego Association of Governments and the region’s traffic engineers, and other organizations. In separate research, TRB Report NCHRP 684 collected mode-specific access data at three substantial mixed use development sites and identified factors affecting traffic generation including mix of land uses and their proximity to one another. The two sets of research results were then combined into a single MXD 2.0 method described in an APA Planning Advisory Service.  Supported by evidence from 266 sites across the U.S., MXD 2.0 explains 97% percent of the variation in trip generation among mixed use developments.  It all but eliminates the ITE traffic overestimation, more accurately assessing the impacts of mixed use projects and related forms of infill, compact, and transit-oriented development. MXD 2.0 trip generation estimates can be translated into project VMT using any of the following sources of trip length data:

  • Residential and non-residential trip length information from the regional MPO for the traffic analysis zone in which the project is located.
  • US EPA Smart Location Database estimates of worker trip length for the Census Block Group in which the project is located.
  • The Urban Footprint scenario planning tool, used in the Statewide Vision California study supported by the California Strategic Growth Council and presently undergoing focused implementation in the Sacramento, Los Angeles and San Diego regions.

CAPCOA Quantification The California Air Pollution Control Officers (CAPCOA) report Quantifying Greenhouse Gas Mitigation Measures provides procedures for calculating the VMT and GHG effects of 50 project-level transportation strategies.  Compared with the MXD 2.0 method, the CAPCOA calculations do not as effectively account for development form and location (density, diversity, design, distance from transit, destination accessibility, development scale and demographics).  However, the CAPCOA effectiveness estimates for the remaining forty-plus strategies can be applied in conjunction with the MXD trip reduction estimates to account for a broad variety of project characteristics and mitigation strategies, including:

  • Affordable and below market rate housing
  • Bike and pedestrian network improvements
  • Electric vehicle parking
  • Parking pricing and supply limits
  • Voluntary and required commute trip reduction programs
  • Ride-sharing and car-sharing programs
  • Subsidized or discounted transit
  • Telecommuting and alternative work schedules
  • Transit access and system improvements
  • Road pricing/management

The CAPCOA report provides step-by-step instructions on each measure, allowing the calculations to be readily applied in spreadsheet form.  It also provides important guidance on combining the effects of different strategies without double-counting and on insuring the total VMT effect is within bounds shown to be achievable in different California urbanization and transit availability settings.

Are there recent publications on how to forecast VMT?

Fehr & Peers contributed to the Handbook for Estimating Transportation Greenhouse Gases for Integration into the Planning Process published by FHWA last year. 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.

Click here to go to the handbook

Key CEQA Changes in the Draft SB 743 Guidelines

VMT as Predominant Measure

Using VMT, for CEQA analysis, will change the focus of transportation impact studies especially with regards to mitigation. LOS impact analysis concentrated mitigation on expanding the external transportation network to accommodate new projects. SB 743 compliant studies that identify potential VMT impacts will likely focus on how to modify the project to minimize VMT.

  • LOS prohibited as the sole basis for impact significance immediately when guidelines take effect.
  •  Appendix G modified to recognize new focus on transportation impacts related to VMT, transit and active modes, and traffic study.
Induced Travel

The addition of general purpose highway or arterial lanes in urban areas may generally indicate a significant impact due to induced travel effects. Managed lanes, transit, bicycle, and pedestrian transportation projects generally not expected to result in significant transportation impacts.

VMT Thresholds

Development projects that result in automobile VMT per capita greater than 15% below existing (i.e. baseline) city-wide or regional values for similar land use types may indicate a significant impact. Development projects that locate within one-half mile of either an existing major transit stop or a stop along an existing high quality transit corridor generally may be considered to have a less than significant transportation impact. Development projects that result in net decreases in VMT, compared to existing conditions, may be considered to have a less than significant transportation impact. Land use plans consistent with an SCS or that achieve similar reductions in VMT as projected to result from the SCS generally may be considered to have a less than significant impact. Key consideration: Will the ‘threshold guidance’ in the Technical Advisory be construed by the courts as state required thresholds?


In addition to project effects on VMT, lead agencies may also consider localized effects on transportation safety. Including safety has implications for tort liability risk and significant findings after mitigation. If an agency pursues the addition of safety to their CEQA transportation impact analysis, these factors should be considered.


Multimodal Safety – The New Kid on the Block? Traffic safety has not been a traditional topic of focus under CEQA. Well, that may change due to SB 743. The new law is elevating safety in CEQA transportation impact analysis and could accelerate the evolution of safety analysis along the way. So, what exactly happened? Click here for more.

Additional Research on LOS

MovingBeyondLOSCvr_ReducedTransportation  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.

Download iBook at iTunes
Click to view paper online
Contact the author: Ron Milam

If you'd like more insight on SB 743...