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On August 6, 2014, the Governor’s Office of Planning and Research (“OPR”) released a Notice of Availability of a Preliminary Discussion Draft of Changes to the California Environmental Quality Act (“CEQA”) Guidelines Related to SB 743 (Steinberg, 2013; “Preliminary Discussion Draft”). These updates are geared towards the evaluation of transportation impacts under CEQA.

Traffic studies used in CEQA documents have historically focused on the impact of projects on traffic flows. By focusing solely on delay, environmental studies have typically required projects to build bigger roads and intersections to mitigate for traffic impacts. However, under the current practice, potential impacts generated by congestion relief mitigation measures are typically not considered as part of the CEQA compliance process for a project.

To bridge the perceived gap in transportation analysis, SB 743 requires OPR to amend the CEQA Guidelines (Title 14 of the California Code of Regulations) to provide an alternative to the level of service methodology for evaluating transportation impacts. Under SB 743, the focus of transportation analysis will shift from the reduction of driver delay to the reduction of greenhouse gas emissions, creation of multimodal networks and promotion of a mix of land uses.

The Preliminary Discussion Draft reflects the information and research contained in OPR’s Preliminary Evaluation of Alternative Methods of Transportation Analysis (December 2013), as well as comments received on that evaluation. OPR proposes to add a new section 15064.3 to the CEQA Guidelines to provide new methods of measuring transportation impacts. The proposed new section 15064.3 contains several subdivisions:

  • Subdivision (a): Purpose – Setting forth the purpose of section 15064.3 and outlining items to consider (such as project effects on the amount and distance of automobile travel, project effects on transit and non-motorized travel, etc.) when analyzing a project’s potential environmental impacts related to transportation.
  • Subdivision (b): Criteria for Analyzing Transportation Impacts – Outlining specific criteria for determining the significance of transportation impacts. This section is further subdivided into: (1) vehicle miles traveled (“VMT”) and land use projects, (2) induced travel and transportation projects, (3) safety, and (4) methodology.
  • Subdivision (c): Mitigation and Alternatives – Identifying several potential mitigation measures and alternatives and including a cross reference to Appendix F. Subdivision (c) also explicitly provides that the section does not limit any public agency’s ability to condition a project pursuant to other laws.
  • Subdivision (d) Applicability – Outlining a phased approach of section 15064.3 implementation to allow lead agencies time to familiarize themselves with the new procedures of the section.

    The most significant change that OPR proposes is to amend CEQA Guidelines, Appendix F by providing suggestions of potential mitigation measures and alternatives that might reduce a project’s VMT.  New VMT Mitigation Measures include: (a) improving or increasing access to transit; (b) increasing access to common goods and services, such as groceries, schools, and daycare; (c) incorporating affordable housing into the project; (d) improving the jobs/housing fit of a community; and (e) incorporating neighborhood electric vehicle network. The Appendix F revisions also address the potential evaluation of a project alternative that relocates a project to an area of the region exhibiting below average VMT.

    In developing the Preliminary Discussion Draft, OPR consulted with a wide variety of affected stakeholders, including local governments, metropolitan planning organizations, state agencies, developers, transportation planners and engineers, environmental organizations, transportation advocates, academics, and others. OPR now seeks public review and comment of the Preliminary Discussion Draft.

    A copy of the Preliminary Discussion Draft is available at:

    All comments should be submitted by October 10, 2014 to

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