LAAEP CEQA Seminar: Impacts Under SB 743

1. Is LOS Obsolete?
How SB 743 May Change CEQA
Transportation Practice in California

2. “All truth passes through three stages. First, it is
ridiculed. Second, it is violently opposed. Third, it
is accepted as being self-evident.”
- Arthur Schopenhauer, German Philosopher
“All CEQA changes pass through three stages.
First, they are ridiculed. Second, they are legally
opposed. Third, they are accepted after being
validated by the courts.”
- Ronald T. Milam, Fehr & Peers Philosopher

3. Regulatory
changes
Have occurred but will
continue to evolve
(especially technical
practices)…
SB 375
AB 32
SB 97
SB 226
SB 743

4. What is LOS?
To a driver: LOS A
To an economist: LOS F
To a driver: LOS F
To an economist: LOS A

5. Analysis of infill
development
using LOS

6. Analysis of infill
development
using LOS
Relatively little
vehicle travel loaded
onto the network

7. Analysis of infill
development
using LOS
Relatively little vehicle
travel loaded onto the
network
…but numerous LOS
impacts

8. Analysis of
greenfield
development
using LOS

9. Analysis of
greenfield
development using
LOS
Typically three to four
times the vehicle travel
loaded onto the network
relative to infill
development

10. Analysis of greenfield
development using
LOS
Typically three to four
times the vehicle travel
loaded onto the network
relative to infill
development
…but relatively few
LOS impacts
Traffic generated by the project
is disperse enough by the time
it reaches congested areas that
it doesn’t trigger LOS
thresholds, even though it
contributes broadly to regional
congestion.

11. • LOS is predominant
transportation impact measure
• Typical LOS analysis represents
only the driver perspective
• LOS mitigation usually requires
expansion of the network
• LOS mitigation generates
impacts to other modes and
the environment
• Physical mitigation may not
even be possible in urban
setting, leading to unavoidable
impacts and SOCs
Consequences of Current Practice

12. • Promote GHG reduction
• Promote multimodal transportation networks
• Promote diversity of land uses
• Eliminate auto delay/LOS as significance criteria
Mobility
Accessibility
What SB 743 Proposes to Do

13. Understanding the thresholds:
• Significant if greater VMT than regional average for
land use type
• Or increase in VMT compared to existing
• How much discretion will lead agencies have?
Development
Project VMT
Regional average for
similar land use types
Proposed Section 15064.3 (b)(1) - Development
Project VMT

14. VMT by Land
Use Type
How should it be
calculated?

15. Residential VMT
What’s acceptable?
Source: SACOG

16. Understanding the thresholds:
• Not significant if within ½ mile of existing major transit
stop or along existing high quality transit corridor
• How much discretion will lead agencies have?
Proposed Section 15064.3 (b)(1) - Development Project
Location

17. Understanding the thresholds:
• Not significant if consistent with SCS
• Or equivalent reduction in VMT
Proposed Section 15064.3 (b)(1) - Land Use Plan/SCS
Consistency

18. Understanding the thresholds:
• Significant if increased roadway capacity induces
additional travel
Proposed Section 15064.3 (b)(2) –
Transportation Projects Induced Travel
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General Purpose lanes vs.
Managed or Auxiliary lanes

19. Proposed Section 15064.3 (b)(3) - Local Safety
Copyright: <aref='http://www.123rf.com/profile_leaf'>leaf / 123RF Stock Photo</a>
Understanding the thresholds:
• Consider localized effect on safety

20. Timeline for Adoption & Interim Actions
• When will the guidelines be finalized?
• When do jurisdictions need to adopt their
own criteria for VMT & safety?
• Why it is important to address VMT in CEQA
documents ahead of adoption?

21. Actions During Interim – Project VMT
• Prepare VMT estimate:
 Use a spreadsheet/sketch model;
 Estimate average trip length
using travel demand model;
 Or estimate average trip length
using CHTS/cell phone/GPS data
• Compare average trip
lengths to regional average
• Compare VMT per capita to
existing
• Require trip reduction as
mitigation

22. Actions During Interim – Plan
Consistency
• Review General Plan assumptions for land use growth
& circulation
• Review growth
assumptions in MPO
model as a means to
assess SCS
consistency

23. Actions During Interim –Safety
• Key questions to answer:
 Are there any collision “hotspots” around the
project
 Will the project aggravate an existing safety
issue?
 Will the project create a new safety issue?
• Driveway locations
• Conflicts with pedestrians or cyclists
• Design standards

24. Thanks!
Tom Gaul, Principal
t.gaul@fehrandpeers.com

25. ‘Sketch’ Model VMT Methods

26. Source: Calthorpe
UrbanFootprint – VMT Module

27. VMT = Volume x Distance

28. Boundary VMT Method
• Traffic count based
estimate (speed not a
factor)
• Estimate depends on
traffic count coverage
and quality
• Only captures VMT on
jurisdiction’s roadways
• Citrus Heights =
1,000,110 daily VMT
(weekday)

29. Travel Model VMT Method
• Traffic volume and
speed based estimate
• Volumes derived from
trips generated by land
uses or activities
• Estimate depends on
model form, limits, and
data quality
• Can capture VMT
multiple ways
• Citrus Heights =
1,397,340 daily VMT
(weekday)

30. VMT Validation
UrbanFootprint

31. VMT Apples vs. VMT Oranges
Trip Length Estimates
Average Trip Length by
Trip Purpose
HBO HBS HBW
CalEEMod 7.50 7.30 10.80
VMT Spreadsheet Model 7.22 7.22 12.54
MPO Travel Forecasting Model 7.26 7.26 5.87
Notes:
HBO = Home-Based Other
HBS = Home-Based Shopping
HBW = Home-Based Work

32. VMT Threshold Example
Yolo County General Plan

33. Comparison of Daily Vehicle Miles by
Land Use Pattern

34. 2035 Daily VMT for Yolo County
New General Plan Policy:
Add a VMT Threshold

35. Relationship of Freeway LOS, Speed, and CO2
Emissions Factors
With VMT, Speed Matters….