Action alert: Attend the workshop on November 3 in Sacramento to speak up in support of VMT and against LOS as a measure of environmental impact. The amount of driving is what’s bad for the climate — and the community — not whether cars are delayed.
Getting rid of LOS: It’s no loss
We’ve written about Level of Service (LOS) before, and here’s a reminder: LOS measures how much a development project will slow down cars. Until now, the California Environmental Quality Act (CEQA) used LOS to evaluate new projects. This is pretty backwards: slowing down cars is not necessarily a negative impact on the environment.
That’s why SB 743 passed last year. The new law eliminates LOS as the focus of CEQA’s transportation analysis. Traffic congestion is no longer the barometer for environmental impacts on transportation. Instead, projects such as bike lanes, bus rapid transit, and infill development – which create healthier, greener communities and reduce greenhouse gas emissions – could be encouraged and supported by the CEQA review process.
But SB 743 doesn’t take effect immediately. The state’s Office of Planning and Research (OPR) was charged to develop a new methodology to replace LOS; this methodology must “promote the reduction of greenhouse gas emissions, the development of multimodal transportation networks, and a diversity of land uses.”
Introducing VMT (finally!)?
Drumroll please! OPR recently released draft guidelines recommending a new way to measure transportation impacts: Vehicle Miles Traveled (VMT).
(Comments on the new guidelines are due by Nov 21: see below for how to comment.)
What does this change mean?
It means that if we’re analyzing the transportation impacts of a new project, say infill development, we ask: Does this project result in more vehicle miles traveled? That is, more driving? For most infill development, we don’t need fancy modeling to tell us that the answer is no! With VMT as the new metric, it means the projects we want to see – more bike lanes, transit-oriented development, and transit – will be easier to build!
ClimatePlan strongly supports OPR’s proposed metric because it’s the best thing for California. California laws AB 32 and SB 375 are leading the way toward a healthier and more sustainable future, but they can’t be effective unless other state plans and processes support them. OPR’s proposed metric does just that.
Making the guidelines effective
ClimatePlan also has a few recommendations about how the proposed methodology can support development that meets California’s sustainability goals:
First, we recommend that OPR provide more clarity and guidance for Section 15064.3, “Determining the Significance of Transportation Impacts; Alternatives and Mitigation Measures,” to ensure projects do not face additional litigation. One of the biggest claims from opponents is that these guidelines will create additional litigation – clear and detailed text will reduce the risk of litigation and ensure the right types of projects are incentivized.
Second, these guidelines should promote real VMT reductions. Currently, the draft proposes defining a project as potentially having a “significant impact” if it results in VMT that is higher than the regional average. Making the regional average the threshold for VMT encourages marginal change at best, and won’t be enough to meet SB 375 targets or AB 32 goals. OPR needs to develop a threshold that aligns with AB 32 and SB 375 to meet the state’s sustainability goals.
There are many misconceptions swirling about these guidelines. For information that corrects some of the myths out there, check out:
– Updating Transportation Impacts Analysis in the CEQA Guidelines (by Office of Planning and Research)
– Frequently Asked Questions Regarding the Preliminary Discussion Draft of Guidelines Implementing Senate Bill 743 (by Office of Planning and Research)
– Setting the record straight on the Governor’s CEQA reform proposal (by Amanda Eaken, Deputy Director of Sustainable Communities at Natural Resources Defense Council)
– Misleading Attacks on California’s New Transportation Analysis Under CEQA (by Ethan Elkind, Associate Director of the Climate Change and Business Program at UC Berkeley)
ClimatePlan is currently working with our partners to submit comments to ensure this section of CEQA is strong and aligns with our state planning priorities.
Comment! (by Nov 21)
We encourage you to submit comments supporting OPR’s new metric, and supporting effective greenhouse-gas reductions to fight climate change!
Read the draft and submit comments by email (CEQA.Guidelines@ceres.ca.gov) by November 21.
Once OPR staff reads and incorporates the new comments, we expected revised guidelines out in early 2015.