LOS Out, VMT In – Changes to CEQA Analysis

SB 743: Change from LOS to VMT for CEQA Transportation Analysis

Today’s prevailing metric for measuring traffic and transportation in the California Environmental Quality Act (CEQA) is LOS, or Automobile Level of Service. LOS measures delay at individual local intersections and on individual highway segments through traffic studies that estimate the number of trips generated and where they will go, and then overlaying those trips with existing traffic. However, LOS often fails to correctly analyze transportation impacts. For example, LOS often has a bias against infill development because of a “last-in development” problem. Infill development loads relatively little traffic onto the regional network, however LOS methodology adds traffic generated by infill development to existing traffic, triggering LOS thresholds defined in General Plans and Congestion Management law. Maintaining these LOS thresholds creates additional maintenance burden, exacerbates regional congestion, and inhibits transit and active transport. This often results in reducing the project size or relocating a project to worse places for development.

Aerial view of a freeway intersection in Los Angeles

Beginning on January 1, 2020, CEQA Guidelines will implement SB 743, a new metric for CEQA transportation analysis. VMT, or Vehicles Miles Traveled, refers to the amount and distance of automobile travel correlated to a project. Under SB 743, delay would no longer be an impact under CEQA as a project’s effect on automobile delay does not constitute a significant environmental impact.  Opportunities/benefits in shifting from LOS to VMT include removing a key barrier to infill development, streamlining transit and active transportation project, reducing infrastructure capital and maintenance costs, and attacking regional congestion more effectively.

At Altum, our Environmental Planning staff has been regularly attending seminars and trainings to learn about changes to CEQA to prepare for future projects. We strive to fully understand these new regulations and adjust our analysis, so we may continue to provide high quality documentation to our clients.

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