Measuring CEQA Transportation Impacts: Replacing LOS with VMT?

California’s planning policymakers are deep in debate regarding the Governor’s Office of Planning and Research’s (OPR) proposal to replace Level of Service (LOS) with a new metric, Vehicle Miles Traveled (VMT). OPR proposes to replace LOS, which focuses only on delays to the movement of cars, with VMT, which analyzes the entire lengths of car trips from a project. VMT reflects a legislative intent to focus on more modern day concerns, such as “promotion of public health through active transportation, and reduction of greenhouse gas emissions” (SB 743, Section 1). If the proposal is adopted, automobile delay measured solely by LOS would not be considered a significant impact under CEQA.

The proposal has received both praise and criticism. Many planners argue that VMT is easier to model and produces a more accurate assessment of the environmental impact of travel generated by a project. Opponents of the proposal are worried about how it may conflict with existing local plans that utilize LOS thresholds and if it will increase existing work loads for local jurisdictions. In particular, local jurisdictions will be required to measure regional average VMT for all land uses, since the new Appendix G checklist questions would require a comparison between project VMTs and regional average VMT by land use.

For more information about the proposal, please visit this website.

The OPR has extended the deadline for public comments to November 21, 2014.