Vehicle Miles Traveled (VMT) Impact Analysis Guidelines
Introduction
Senate Bill 743 (SB 743), signed into law in 2013, introduced a shift in how transportation impacts are analyzed under the California Environmental Quality Act (CEQA). A key element of SB 743 is the elimination of automobile delay and Level of Service (LOS) as the sole basis for determining CEQA transportation impacts. Instead, the most recent CEQA guidelines, released in December 2018, recommend vehicle miles traveled (VMT) as the most appropriate metric for assessing transportation impacts of land use projects. While SB 743 mandates this change for CEQA evaluations, cities and counties may still choose to analyze LOS or delay for other planning purposes, such as general plans, studies, or network monitoring.
This document provides recommendations for determining VMT impact thresholds and mitigation measures for various land use projects requiring a Transportation Impact Analysis (TIA). The guidelines are largely based on the Western Riverside Council of Governments (WRCOG) Implementation Pathway Study, which outlines methodologies for VMT screening and impact assessment. Agencies may choose to modify these guidelines based on local conditions and policy objectives. Additional details regarding the WRCOG Implementation Pathway Study can be found at: Fehr & Peers WRCOG SB 743 Study.
VMT Analysis Methodology
For SB 743 compliance, a VMT analysis should be conducted for land use projects when deemed necessary by the Traffic Division. A VMT analysis applies to projects that have the potential to increase average VMT per unit of measurement compared to the City’s baseline average. VMT per capita, per employee, or per service population provides a transportation efficiency metric to determine transportation impact. Using this efficiency metric allows for a direct comparison between a project’s impact and the overall travel behavior of the city.
Project Screening for VMT Analysis
Three types of screening may be applied to determine whether a project requires a detailed VMT analysis:
1. Transit Priority Area (TPA) Screening
Projects within a designated TPA are generally presumed to have a less than significant VMT impact, provided there is no substantial evidence to the contrary. However, this presumption is not applicable if the project:
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Has a Floor Area Ratio (FAR) of less than 0.75;
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Includes more parking than required by local ordinances;
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Is inconsistent with the applicable Sustainable Communities Strategy (SCS); or
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Replaces affordable housing units with a smaller number of market-rate units.
A TPA is defined as an area within a half-mile of a major transit stop or a high-quality transit corridor. A major transit stop includes rail stations, ferry terminals, or intersections of two or more high-frequency bus routes (with intervals of 15 minutes or less during peak hours).
2. Low VMT Area Screening
Residential and office projects located in areas with low VMT generation may be presumed to have a less than significant impact, provided there is no evidence to the contrary. Other employment-related and mixed-use developments may also qualify if they generate VMT per resident, per worker, or per service population similar to surrounding uses.
The WRCOG area uses the RIVCOM travel demand model to assess VMT performance at the jurisdictional and Traffic Analysis Zone (TAZ) levels. A project’s eligibility for this screening can be determined by using the WRCOG screening tool: WRCOG VMT Screening Tool.
3. Project Type Screening
Certain land uses are presumed to have a less than significant VMT impact because they serve local populations and reduce vehicle trips. Examples include:
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Local-serving retail under 50,000 square feet;
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Local-serving K-12 schools;
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Daycare centers;
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Local-serving gas stations;
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Local-serving banks;
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Local-serving hotels;
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Student housing;
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Affordable housing projects;
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Local-serving community colleges consistent with regional plans;
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Projects generating fewer than 110 daily vehicle trips (e.g., 11 single-family homes, 16 multifamily units, 10,000 square feet of office space, or 15,000 square feet of light industrial space).
VMT Analysis for Non-Screened Developments
For projects that are not screened out, a full VMT analysis is required. This analysis should use the RIVCOM model to compare project-generated VMT with city and regional baselines. The following scenarios must be analyzed:
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Baseline Conditions – Existing VMT conditions within the city or project area.
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Baseline Plus Project – Evaluates how the project influences travel behavior relative to existing conditions.
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Cumulative No Project – Future VMT conditions without the project, based on regional growth projections.
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Cumulative Plus Project – Evaluates how the project contributes to future VMT compared to cumulative conditions without the project.
Total VMT and VMT per unit of measurement should be reported for transportation impact analysis, as well as for air quality, greenhouse gas emissions, and energy assessments.
CEQA VMT Impact Thresholds
A project is considered to have a significant VMT impact if it meets either of the following conditions:
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The project-generated VMT per unit exceeds the city’s average baseline VMT per unit;
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The cumulative project-generated VMT per unit exceeds the city’s baseline VMT per unit.
Additionally, the project’s effect on VMT is considered significant if:
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The baseline citywide or subregional VMT per service population increases with the project;
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The cumulative citywide or subregional VMT per service population increases with the project.
For roadway projects, a VMT impact occurs if the project increases citywide or subregional VMT compared to the General Plan Roadway network assumptions.
VMT Mitigation Measures
If a project is found to have a significant VMT impact, mitigation measures should be implemented. Available options include:
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Modifying the Project’s Built Environment – Incorporating land use and design changes to reduce VMT, such as:
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Increasing density;
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Enhancing pedestrian and bicycle infrastructure;
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Reducing parking supply.
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Implementing Transportation Demand Management (TDM) Strategies – Encouraging alternative transportation modes and reducing reliance on single-occupancy vehicles. Example TDM measures include:
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Providing transit subsidies;
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Implementing rideshare or carpool programs;
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Offering telecommuting options.
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Participating in a VMT Mitigation Program – If available, projects can offset their VMT impacts through:
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Paying into a regional VMT mitigation fund;
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Contributing to VMT banking or exchange programs that fund offsite VMT reduction projects.
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WRCOG has identified effective TDM strategies suitable for the region, available at: TDM Strategies Evaluation.
Conclusion
SB 743 represents a fundamental shift in transportation impact analysis by prioritizing VMT over traditional LOS metrics. These guidelines provide a structured approach to screening projects for VMT analysis, assessing their impacts, and identifying appropriate mitigation measures. By adopting these methodologies, cities can align with CEQA requirements while promoting sustainable land use and transportation planning.
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