CEQA CHANGES AND THE IMPLEMENTATION OF SB 743
The introduction of Senate Bill 743 (SB 743) marks a transformative shift in the way transportation impacts are analyzed under the California Environmental Quality Act (CEQA). Signed into law in 2013, this legislation has redefined the framework for assessing transportation impacts by moving away from traditional metrics, such as Level of Service (LOS), and prioritizing a new approach aligned with statewide sustainability goals.
A pivotal element of SB 743 is the elimination of auto delay, LOS, and similar measures of vehicular capacity or traffic congestion as the primary criteria for determining significant transportation impacts under CEQA. Historically, these metrics emphasized vehicle flow efficiency, which often led to prioritizing roadway expansions and other car-centric infrastructure. While effective in reducing localized traffic congestion, this approach inadvertently encouraged urban sprawl, increased greenhouse gas emissions, and created barriers to the development of sustainable, walkable communities.
The legislative changes introduced by SB 743 are designed to address these issues. By shifting focus from traffic delay to broader objectives such as promoting infill development, reducing greenhouse gas emissions, and enhancing public health through active transportation, SB 743 seeks to align transportation planning with California’s ambitious climate and sustainability targets.
Changes to Congestion Management Laws
SB 743 includes significant amendments to existing congestion management laws, giving cities and counties more flexibility in their approach to managing traffic impacts. Specifically, the law allows local jurisdictions to effectively opt out of LOS standards in areas governed by Congestion Management Plans (CMPs). This change is particularly relevant in regions like Orange County, where CMPs have historically guided traffic management and planning decisions.
Under the new framework, jurisdictions are encouraged to adopt alternative metrics that better reflect the environmental and social goals embedded in state policy. The Governor’s Office of Planning and Research (OPR) has played a central role in guiding this transition. In December 2018, OPR released its final recommended guidelines for implementing SB 743, following extensive consultation with public agencies, stakeholders, and the general public.
Vehicle Miles Traveled (VMT) as the Preferred Metric
One of the most significant outcomes of the SB 743 implementation process is the adoption of Vehicle Miles Traveled (VMT) as the preferred metric for assessing transportation impacts. Unlike LOS, which measures the efficiency of vehicle movement through intersections and along roadways, VMT focuses on the total distance traveled by vehicles as a result of a proposed project.
This shift in focus has several advantages. By prioritizing VMT, agencies can evaluate how a project contributes to broader transportation and land use goals, such as reducing car dependency, promoting transit-oriented development, and minimizing environmental impacts. VMT analysis encourages compact, mixed-use development patterns that shorten travel distances and support active transportation modes like walking and cycling.
For land use projects, VMT has become the standard metric for determining transportation-related impacts under CEQA. However, for transportation infrastructure projects, lead agencies retain some flexibility in selecting their preferred metric, provided their choice is supported by substantial evidence and complies with CEQA guidelines.
Implications for Local Jurisdictions
The implementation of SB 743 does not preclude local jurisdictions from continuing to analyze LOS or other traditional metrics for purposes outside of CEQA compliance. For instance, cities and counties may still use LOS for general plan consistency, impact fee programs, corridor studies, or congestion mitigation efforts. However, these metrics can no longer serve as the sole basis for determining significant impacts under CEQA.
This dual approach allows jurisdictions to balance the requirements of SB 743 with their local transportation planning needs. While VMT analysis is required for CEQA review, LOS and other metrics may be integrated into non-CEQA processes to ensure a comprehensive assessment of a project’s transportation impacts.
Developing Local Thresholds of Significance
A key component of SB 743 implementation is the development of locally tailored thresholds of significance for VMT analysis. According to CEQA Guidelines Section 15064.7(b), lead agencies are encouraged to adopt thresholds of significance through a public review process supported by substantial evidence. These thresholds provide a consistent framework for evaluating project impacts and ensure compliance with CEQA requirements.
The City of Anaheim, for example, has developed specific Traffic Impact Analysis (TIA) Guidelines to outline the steps for complying with the new VMT-focused CEQA expectations. These guidelines provide a clear roadmap for project proponents, detailing the methodology, data requirements, and thresholds of significance that must be used in VMT analysis.
Stakeholder Engagement and Ongoing Updates
Given the evolving nature of CEQA requirements and transportation planning practices, ongoing engagement with stakeholders is essential. The City of Anaheim and other jurisdictions are committed to reviewing and updating their TIA guidelines as needed to reflect changes in state law, emerging best practices, and feedback from the public and industry professionals.
Consultants and project proponents are strongly encouraged to engage with local agencies early in the development process to ensure their analyses align with the most current guidelines. This proactive approach helps streamline the review process and ensures that transportation impacts are accurately assessed and effectively mitigated.
Statewide Goals and the Broader Impact of SB 743
The implementation of SB 743 represents a paradigm shift in transportation planning, with implications that extend beyond individual projects to influence broader patterns of development and mobility. By prioritizing VMT as the standard metric for CEQA transportation analysis, the state is signaling a commitment to fostering sustainable, multimodal transportation systems that reduce environmental impacts and enhance quality of life.
This transition aligns with California’s broader climate and sustainability goals, including the reduction of greenhouse gas emissions to 40% below 1990 levels by 2030 and achieving carbon neutrality by 2045. By encouraging compact, transit-oriented development and reducing car dependency, VMT analysis supports these objectives while promoting healthier, more livable communities.
SB 743 has fundamentally changed the way transportation impacts are evaluated under CEQA, replacing traditional LOS-based analyses with a VMT-focused approach that prioritizes sustainability and public health. While the transition presents challenges for local jurisdictions and project proponents, it also offers an opportunity to rethink transportation planning in ways that align with California’s long-term goals.
By adopting VMT as the standard metric for CEQA transportation analysis, SB 743 paves the way for more sustainable, equitable, and resilient communities. Local jurisdictions, including the City of Anaheim, are leading the charge in implementing these changes, providing clear guidelines and support to ensure a smooth transition. As these efforts continue, the principles of SB 743 will play a crucial role in shaping the future of transportation and land use planning across the state.
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