Gov. Brown Releases New Guidelines for Measuring Transportation Impacts Under California Environmental Quality Act

New Guidelines Reduce Key Barriers for Sustainable Transportation Projects and Infill Development, but Preserve Status Quo for Polluting Highway Projects

SACRAMENTO — California Governor Jerry Brown’s Office of Planning and Research has issued new guidelines for evaluating transportation impacts under the California Environmental Quality Act (CEQA) in accordance with SB 743 (Steinberg, 2013).

The guidelines make the following key changes:

  • Land use, public transit, and bike and pedestrian projects would no longer be evaluated under CEQA according to how much vehicle delay the projects cause.
  • These projects would instead be evaluated under the metric of vehicle-miles traveled (VMT) to determine whether there are significant environmental impacts. Projects that reduce VMT would be deemed to have no significant environmental impact from transportation.
  • Construction or expansion of streets and highway would be exempt from this change. The lead agency in charge of the project would have the discretion to use either VMT or vehicle delay (measured by Level of Service) analyses.

Following is a statement from Amanda Eaken, director of Transportation and Climate at the Natural Resources Defense Council:
“These guidelines help California combat climate change by making it easier to build the types of transportation and land use projects that reduce emissions. Exempting highway projects from this otherwise strong new standard significantly undermines the benefits that the state is trying to deliver. More highways simply induce more driving, which leads to greater pollution.”

Following is a statement from Matthew Baker, director of Policy at the Planning and Conservation League:
“Level of Service is an outdated metric for measuring travel-modes and has been a barrier to active transportation and transit-oriented infill development. The VMT-based methodology proposed by these SB 743 guidelines will be a great step forward for building more sustainable communities in California, however, exempting highway expansion from this new review standard is also significant step back.”

Following is a statement from Bryn Lindblad, associate director of Climate Resolve:
“For too long the Level of Service metric has encouraged sprawl development and road widening, which has enabled increases in transportation-related greenhouse gas emissions, rather than promoting more compact, transportation-efficient, multi-modal development patterns, which would align with our State climate goals. These guideline changes are a step in the right direction in that they remove barriers for the good kind of transit-oriented development, but they fall short of providing the analysis that is needed to critically consider the merits (or lack thereof) of sprawl-inducing highway projects. Vehicle miles traveled analysis is most needed on those kinds of projects, which means that further changes to these guidelines are needed yet.”

Following is a statement from Joshua Stark, state policy director of TransForm:
“The outdated Level of Service metric had, for years, slowed and obstructed vital projects that communities need to effectively combat congestion, improve air quality, and reduce our climate pollution.  In ending this metric for infill, transit, and biking and walking infrastructure, California takes yet another step toward addressing some of our state's most pressing problems," said Joshua Stark, State Policy Director for TransForm.  "Then-Senate pro tem Steinberg showed great leadership and a sincere understanding of and hope for California's future in authoring this important piece of legislation, and we are excited that, with these guidelines, communities will finally be able to benefit from it.”

Following is a statement from Chanell Fletcher, director of ClimatePlan: 
“Removing Level of Service as a significant transportation impact will facilitate greater investments in infill and transit-oriented development to promote walking, bicycling, and transit use. Ultimately, these guidelines could make our communities safer, healthier, and more equitable places to live. For that to happen, the guidelines must also provide high-level recommendations to mitigate the potential for gentrification and displacement to facilitate rather than hinder affordable housing production across the state, especially in areas that need it most.”

SB 743 (Steinberg) established that vehicle delay—measured by Level of Service (LOS)—is not an appropriate indicator of transportation-related environmental impacts. (Air quality, noise and safety remain part of the CEQA analysis of projects.) Instead, the Governor’s Office of Planning and Research has affirmed that Vehicle Miles Traveled (VMT) better reflects the true environmental impacts and has recommended it as the replacement to vehicle delay (LOS).

With respect to transportation, projects that increase VMT are environmentally harmful and projects the reduce VMT are environmentally beneficial. The replacement of the LOS metric with VMT corrects an unintended consequence of CEQA that was penalizing sustainable projects, like infill housing, light rail and bike lanes that might increase vehicle delay at one local intersection, but reduce polluting vehicle trips at the community and regional scale.

Benefits of replacing LOS with VMT include: improved public health; more investment in our downtowns and Main Streets; more transportation options, including biking, walking and transit; opportunities for increasing housing supply that lowers prices; and relieved pressure on farmland and habitats.


About ClimatePlan
ClimatePlan’s mission is to advance policies and programs to address the relationship between land use policy and climate change, and leverage the resources and partnerships necessary to realize more sustainable and equitable development throughout California. ClimatePlan envisions a healthier and more vital California that supports sustainable and equitable communities, preserves iconic landscapes, and significantly reduces greenhouse gas emissions. Visit us at and follow us on Twitter @ClimatePlan

About Climate Resolve
Climate Resolve’s is a Los Angeles-based nonprofit organization that focuses on local solutions to global climate change, and works to achieve outcomes that bestow multiple benefits. We work to make California more equitable, just, livable, prosperous, and sustainable today and for generations to come by inspiring people at home, at work, and in government to reduce climate pollution as well as prepare for climate impacts. We fundamentally believe that climate solutions must benefit all, especially people with low incomes who are most affected by climate change and least able to defend against its impacts.

About the Natural Resources Defense Council
The Natural Resources Defense Council (NRDC) is an international nonprofit environmental organization with more than 3 million members and online activists. Since 1970, our lawyers, scientists, and other environmental specialists have worked to protect the world's natural resources, public health, and the environment. NRDC has offices in New York City, Washington, D.C., Los Angeles, San Francisco, Chicago, Bozeman, MT, and Beijing. Visit us and follow us on Twitter @NRDC.​

About the Planning and Conservation League
For 50 years, the Planning and Conservation League has worked at the nexus of land use and transportation planning advocacy to protect and restore California’s natural environment, and to promote and defend the health and safety of Californians.

About TransForm
TransForm is California's leading advocate for great transportation choices and walkable, affordable communities. TransForm has offices in Oakland, Sacramento, and San Jose.