CSAC Bulletin Article

OPR Issues Revised Proposal for Analyzing Transportation Impacts Under CEQA

January 22, 2016

This week the Governor’s Office of Planning and Research (OPR) issued a revised proposal for amending the CEQA Guidelines as they relate to the analysis of transportation impacts pursuant to SB 743 (Steinberg, 2013). Among other goals, SB 743 sought to promote infill development, which has often been burdened with costly mitigation measures for transportation improvements under CEQA, even in settings where residents or workers at a development enjoy access to transit and proximity to other amenities that would tend to reduce their need to drive.

The proposal would not change the ability of local jurisdictions to condition development proposals based on the circulation element of the General Plan, or other local policies related to congestion. Updates to such plans and ordinances, however, would have to be analyzed based on their impacts to vehicle miles travelled under the new proposed CEQA guidelines. The full proposal is available online here.

CSAC staff has only had time for a cursory review the proposal, but a few important points, including some that are consistent with earlier CSAC requests, already stand out:

  • Vehicle Miles Travelled (VMT) remains the proposed replacement metric for Level of Service. Fifteen percent below regional average VMT is recommended as the threshold of significance for projects with transportation impacts.
  • Consistent with CSAC’s requests, implementation will be optional for the first two years. OPR states that they will monitor performance during this time period and potentially suggest changes to the CEQA guidelines or technical guidance.
  • The guidance addresses comments regarding the availability of VMT data and models, pointing out that analysis under CEQA should be reviewed in the light of what is “reasonably feasible.” Moreover, OPR points to the availability of at least some data in areas outside of metropolitan areas from the Caltrans Statewide Travel Demand Model.
  • Caltrans has created a webpage that allows lead agencies to access data from the California Statewide Travel Demand Model for particular geographic areas. OPR also included example case studies of project analysts using the new methodology as an appendix to the revised proposal.

OPR has requested comments on the proposal, which must go through a formal rulemaking process at the Natural Resources Agency before going into effect, by February 29. CSAC staff will review the proposal in greater depth, but would appreciate hearing any comments or concerns counties may have by Friday, February 19.

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