CSAC Comments on Proposal to Change Transportation Impact Analysis
As we previously reported, the Governor’s Office of Planning and Research issued a revised proposal to quantify the transportation impacts of projects based on vehicle miles travelled (VMT) instead of level of service (LOS), which is a measure of traffic congestion. CSAC submitted comments on the revised proposal on Monday focusing on the potential difficulties of implementing the change from LOS to VMT statewide.
The revised proposal included multiple beneficial changes from earlier drafts. Local agencies will have up to two years to implement the change in their analysis of the transportation impacts of plans and land use projects. The technical appendix of the proposal also allows for greater flexibility in rural areas outside of metropolitan planning organizations (MPOs), by recommending that agencies determine the significance of VMT impacts on a case-by-case basis, rather than through a specific numerical threshold. Finally, the revised proposal’s approach to identifying projects unlikely to have a significant impact on VMT, including projects with very low numbers of new trips and transportation projects that do not add capacity, represents an improvement over the previous draft.
Despite these improvements, CSAC has continued concerns about the ability to feasibly mitigate VMT impacts for projects in communities with limited transportation networks. In addition to this overarching concern, CSAC argued for parity between recommended thresholds of significance for city and unincorporated area projects in MPO counties, as well as other technical changes. CSAS is also calling for additional resources and technical assistance, which will be necessary for counties to adapt to the new methodology, to be made available for local governments during the two-year phase-in period.
We would appreciate any further comments and concerns from counties, as the proposal will go through at least one more comment period when it is submitted to the Natural Resources Agency to go through the formal rulemaking process.