Background on Senate Bill 743 and Transportation Impact Analysis (TIA)
Senate Bill 743 (SB 743), signed into law in 2013 by the Governor of California, significantly changed how transportation impacts are analyzed and identified in California Environmental Quality Act (CEQA) documents. This legislation required a shift in metrics used for assessing transportation impacts. Previously, level of service (LOS)—a measure of traffic congestion and delay—was the predominant metric. SB 743 directed the Office of Planning and Research (OPR) to explore alternative metrics that better align with the state’s environmental and transportation goals.
By December 2018, OPR released the final guidelines for analyzing transportation impacts, recommending Vehicle Miles Traveled (VMT) as the primary metric for assessing transportation impacts in CEQA documents. The Natural Resources Agency finalized the rulemaking process to update CEQA guidelines the same year, mandating that, by July 2020, all lead agencies across California must adopt VMT as the primary transportation impact metric for land use projects.
This transition reflects a broader strategy aimed at reducing greenhouse gas (GHG) emissions, encouraging infill development, and promoting active transportation methods. LOS, which focuses on vehicle delay, does not directly address these goals, often prioritizing roadway expansions that can lead to increased vehicle travel and urban sprawl.
City of Fountain Valley's Proactive Approach
Anticipating this significant regulatory shift, the City of Fountain Valley conducted an SB 743 Implementation Study to address key questions regarding VMT analysis. This comprehensive study evaluated methodologies, thresholds, and mitigation strategies to prepare the City for the transition to VMT. The study consisted of three key components:
- Thresholds Evaluation Memorandum: This document explored potential VMT thresholds of significance that the City could adopt, outlining how these thresholds align with CEQA requirements and local goals.
- Methodologies Memorandum: Various methods for estimating VMT were assessed, detailing their respective advantages and disadvantages. This analysis ensured that the City selected approaches suitable for its specific land-use and transportation context.
- Mitigation Memorandum: This component outlined potential strategies to mitigate VMT impacts, providing options to address significant impacts identified in project evaluations.
Adoption of Significance Thresholds
CEQA Guidelines Section 15064.7(b) encourages public agencies to formally adopt thresholds of significance for determining environmental impacts. These thresholds, developed through a public review process and supported by substantial evidence, offer transparency and consistency in environmental evaluations. While thresholds can also be determined on a case-by-case basis, adopting general thresholds provides a more predictable framework for developers and decision-makers.
The City of Fountain Valley’s efforts to define and adopt VMT thresholds mark a critical step in implementing SB 743. These thresholds provide clear guidance on how transportation impacts are assessed and ensure that projects align with the City’s goals for sustainable growth and environmental stewardship.
City of Fountain Valley’s Transportation Impact Analysis (TIA) Guidelines
To build on the SB 743 Implementation Study, the City developed updated Transportation Impact Analysis (TIA) Guidelines. These guidelines outline the steps required to conduct transportation impact analyses using the VMT methodology while addressing consistency with the General Plan. Recognizing that CEQA requirements and methodologies evolve, the City plans to periodically review and revise its guidelines to ensure compliance with the latest legal, regulatory, and technical standards.
The Role of Level of Service (LOS)
Although VMT is now the primary CEQA metric for transportation impacts, LOS remains relevant for local planning purposes. The City of Fountain Valley’s General Plan includes policies related to LOS, establishing standards for maintaining adequate transportation infrastructure and mitigating congestion. These policies apply to discretionary approvals of new land use and transportation projects.
The City Engineer retains the authority to request both LOS and VMT analyses for proposed projects, depending on the context. For example, LOS analysis may be necessary for evaluating General Plan consistency or assessing local roadway capacity, while VMT analysis is required for CEQA compliance.
Guidelines Structure and Organization
The TIA Guidelines provide a structured approach to assessing transportation impacts, ensuring consistency with local and state requirements. The document is organized into the following sections:
- Introduction: Outlines the purpose and scope of the guidelines.
- Need for Transportation Impact Study: Explains when a TIA is required and its role in the development review process.
- Transportation Assessment for General Plan Consistency: Describes how to evaluate projects for compliance with General Plan policies, including LOS analysis.
- CEQA Assessment - VMT Analysis: Details the steps and methodologies for assessing VMT impacts under CEQA.
- CEQA Assessment - Active Transportation and Public Transit Analysis: Addresses how to evaluate impacts on non-vehicular transportation modes.
- Transportation Impact Analysis Format: Provides guidance on the structure and content of TIA reports.
State Law Requirements for Land Use and Circulation
California law requires a strong connection between a General Plan’s Land Use Element and Circulation Element, ensuring that development intensity aligns with transportation infrastructure capacity. As part of this requirement, a TIA is essential for evaluating how proposed land use changes will affect existing and future circulation systems. The analysis must demonstrate compliance with CEQA and the Congestion Management Program (CMP), as well as the City’s local policies and guidelines.
Evolving Role of TIA in CEQA
Historically, TIAs were primarily prepared to analyze transportation impacts under CEQA, with a strong focus on LOS. However, with the passage of SB 743, the purpose of a TIA has expanded. While VMT analysis is now the primary metric for CEQA transportation impact assessments, LOS analysis may still be required for non-CEQA purposes, such as evaluating consistency with General Plan goals or congestion management programs.
The updated TIA Guidelines provide a roadmap for incorporating both VMT and LOS analyses into project evaluations, ensuring that all relevant factors are considered in the development review process.
Key Changes Under SB 743
SB 743 represents a paradigm shift in transportation planning and impact analysis. By eliminating LOS and similar metrics from CEQA significance determinations, the law aims to reduce the environmental impacts of transportation systems. VMT analysis supports this goal by promoting strategies such as infill development, enhanced public transit, and active transportation, all of which contribute to reducing vehicle travel and greenhouse gas emissions.
Under SB 743, cities and counties can opt out of LOS standards in areas covered by Congestion Management Plans (CMPs), including Orange County. However, jurisdictions may continue to use LOS for non-CEQA purposes, such as impact fee programs or corridor studies.
Conclusion
The City of Fountain Valley’s updated TIA Guidelines reflect the transformative changes brought about by SB 743, prioritizing VMT as the key metric for transportation impact analysis under CEQA. By combining VMT analysis with LOS evaluations for General Plan consistency, the City ensures a comprehensive approach to transportation planning that balances local infrastructure needs with statewide environmental goals. As CEQA requirements and best practices continue to evolve, the City remains committed to updating its guidelines to reflect the latest standards and support sustainable development.
Our Services are available throughout City of Fountain Valley with Zipcode 92708, 92728