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Can We Align VMT and LOS Analysis and Mitigation? Assessing Implementation of Senate Bill 743 - This presentation will discuss key findings from research conducted for Caltrans in 2024 to investigate how local governments (cities and counties) are implementing California’s Senate Bill 743, adopted in 2013 to eliminate traffic delay as a basis for analyzing and mitigating transportation-related impacts of development projects and plans as called for under the California Environmental Quality Act (CEQA). The law represents a sea change in transportation impacts analysis under CEQA, which until then had been focused on analyzing and mitigating traffic delay using automobile level of service (LOS) standards and metrics. The use of LOS had come under criticism for reasons such as increasing the cost of infill development and inducing more auto-dependency. SB 743 called for a performance metric better suited to achieving the state’s climate and sustainability policy goals, and pursuant to SB 743, automobile LOS was eliminated as an impact for examination under CEQA, and replaced with vehicle miles traveled (VMT). Lead agencies—those with primary permit approval authority over a given development project or plan— were required to begin complying by July, 2020.
The LOS-to-VMT shift was expected to create potential challenges for transportation planners, given the often-limited resources of local governments and the uncertain synergies or conflicts that could arise between LOS and VMT standards and mitigation measures, given that most jurisdictions were expected to continue using LOS standards as part of the permitting and planning process. With those concerns in mind, our research explored how California’s cities and counties are implementing SB 743 and whether and how they are continuing to use LOS.
Based on a survey of local planning directors in California, administered in Spring, 2024, our research found that more than four-fifths of localities are continuing to apply LOS standards on an “off-CEQA” basis in the permitting process for individual development projects, as well as in community-level plans and policies. Most respondent localities reported that using both VMT and LOS at both the project- and plan-level has not created conflicts, but collectively, the survey findings also confirmed that implications of SB 743 vary by community type. For many, the expected pattern is occurring, in which the type and location of development projects requiring mitigation has shifted to lower-density localities, and within localities, to lower-density, less transit-proximate parts of town. The reported combined costs to developers seeking permits, to pay for analysis and mitigation for both VMT and LOS, is reported to be about the same as pre-SB 743 costs for addressing LOS alone, but a significant share (26%) of localities deems the combined costs to be much higher. Regression analysis indicated that combined costs tend to be lower in denser and more urban localities, corresponding to expectations about which sorts of development are most likely to be streamlined during CEQA review under SB 743 (low-VMT infill development, in particular), and which can be expected to require more mitigation (high-VMT, low-density, outlying, car-dependent development, in particular). Mitigation strategies reported as effective in reducing VMT and also improving LOS include improving active travel facilities, supporting mixed-use development, and relaxing parking requirements; these strategies can be deemed “best practices” for aligning VMT and LOS objectives.
