In anticipation of the change to VMT, the San Gabriel Valley Council of Governments (SGVCOG) undertook the SGVCOG SB 743 Implementation Study to assist with answering important implementation questions about the methodology, thresholds, and mitigation approaches for VMT impact analysis in its member agencies. The study includes the following main components:
- Analysis Methodologies Memorandum: Identification of potential thresholds that can be considered when establishing thresholds of significance for VMT assessment and recommendations of analysis methodologies for VMT impact screening and analysis.
- Mitigation Memorandum: Types of mitigation that can be considered for VMT mitigation.
- VMT Evaluation Tool: A web-based tool that can be used for VMT screening and mitigation recommendation.
The City of Covina utilized the information produced through the Implementation Study to adopt a methodology and significance thresholds for use in CEQA compliance. As noted in CEQA Guidelines Section 15064.7(b) below, lead agencies are encouraged to formally adopt their significance thresholds, which is a key part of the SB 743 implementation process.
(b) Each public agency is encouraged to develop and publish thresholds of significance that the agency uses in the determination of the significance of environmental effects. Thresholds of significance to be adopted for general use as part of the lead agency’s environmental review process must be adopted by ordinance, resolution, rule, or regulation, and developed through a public review process and be supported by substantial evidence. Lead agencies may also use thresholds on a case-by-case basis as provided in Section 15064(b)(2).
The City has produced these Transportation Study (TS) Guidelines to outline the specific steps for complying with the new CEQA expectations for VMT analysis and the applicable general plan consistency requirements related to Level of Service (LOS).
It should be noted that CEQA requirements change as the CEQA Guidelines are periodically updated and/or legal opinions are rendered that change how analysis is completed. As such, the City will continually review their guidelines for applicability, and consultants should contact the City to ensure that they are applying the City’s most recent guidelines for project impact assessment.
CEQA Changes
Since the last TS Guidelines update completed by the City, SB 743 was signed into law. A key element of this law is the elimination of auto delay, LOS, and other similar measures of vehicular capacity or traffic congestion as a basis for determining significant environmental impacts. This change is intended to assist in balancing the needs of congestion management with statewide goals related to infill development, promotion of public health through active transportation, and reduction of greenhouse gas emissions.
SB 743 includes amendments to current congestion management law that allow cities and counties to effectively opt-out of the LOS standards that would otherwise apply in areas where Congestion Management Plans (CMPs) are still used. Further, SB 743 required OPR to update the CEQA Guidelines and establish criteria for determining the significance of transportation impacts. In December 2018, OPR released their final recommended guidelines based on feedback from the public, public agencies, and various organizations and individuals. OPR recommended VMT as the most appropriate measure of project transportation impacts for land use projects and land use plans. For transportation projects, lead agencies may select their own preferred metric but must support their decision with substantial evidence that complies with CEQA expectations. SB 743 does not prevent a city or county from continuing to analyze delay or LOS outside of CEQA review for other transportation planning or analysis purposes (i.e., general plans, impact fee programs, corridor studies, congestion mitigation, or ongoing network monitoring).
Level of Service Policy
The City has vehicle LOS standards that local infrastructure will strive to maintain. The LOS standards apply to discretionary approvals of new land use and transportation projects. Therefore, these TS guidelines also include instructions for vehicle LOS analysis consistent with City requirements.
Our Services are available throughout LA County including Covina city with Zipcode 91722.