Level-of-Service (LOS) to Vehicle-Miles-Traveled (VMT)

The City of Morgan Hill is working with Nelson\Nygaard Consulting Associates, Inc. regarding the City's implementation of State Senate Bill (SB) 743 transition from Level-of-Service (LOS) to Vehicle-Miles-Traveled (VMT) as the metric for transportation analysis under the California Environmental Quality Act (CEQA).

On September 27, 2013, Senate Bill 743 (Steinberg) was signed by then Governor Jerry Brown, requiring the Governor’s Office of Planning and Research (OPR) to amend the California Environmental Quality Act (CEQA) Guidelines, to develop alternative metrics to replace the use of vehicular “Level of Service” (LOS) for evaluating transportation impacts, and to provide alternative criteria for evaluating transportation impacts to promote the reduction of greenhouse gas emissions, the development of multimodal transportation systems, and a diversity of land uses.

The SB 743 legislation required that local jurisdictions shift from use of LOS for CEQA review of vehicle movement impacts (delay) to a method that assesses the distance of vehicle travel attributed to a project or use. This shift focuses review to regional traffic and reducing greenhouse gas (GHG) emissions, rather than vehicle impacts on the local roadway network. As a result, traffic delay is no longer considered a significant impact under CEQA. With OPR’s December 2018 ‘Technical Advisory on Evaluating Impacts in CEQA,’ the method selected to assess distance of vehicle travel is Vehicle-Miles-Traveled (VMT).

City Council Direction

At the June 2, 2021, Morgan Hill City Council Meeting, the City Council directed City Staff to pursue a VMT model in order to deviate from the Valley Transportation Authority (VTA) Santa Clara Countywide VMT Evaluation Tool and/or to provide substantial evidence to deviate from the Governor's Office of Planning and Research (OPR) Technical Advisory which recommends a 15% threshold of significance reduction from existing VMT.

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Previous Meetings/Workshops

June 2, 2021 City Council Meeting: informational presentation regarding SB 743, the transition from LOS-to-VMT, and proposed VMT Screening Criteria and Thresholds of Significance .
August 11, 2020: the Planning Commission made a recommendation to approve the proposed VMT Screening Criteria on a 4-3 vote.
June 23, 2020 Planning Commission meeting: defining Goals, Objectives, and VMT Thresholds of Significance.
April 28, 2020 Planning Commission meeting: review of existing policies, VMT tools, and case studies.
March 10, 2020 Planning Commission meeting: informational presentation regarding SB 743 and VMT.

Memorandums

Tasks 1-3 Memo: SB 743 Implementation – Review of Existing Policies, VMT Tools, and Case Studies: This memo reviews existing policies, VMT tools, and case studies.
Task 4 Memo: Defining Goals, Objectives, and VMT Thresholds of Significance: This memo establishes transportation impact analysis goals and objectives and recommendations for VMT-based analysis.
Addendum to Task 4 Memo and Response to Planning Commission: This memo is a response to requests from the Planning Commission for more information on the following: Travel Demand Model Inputs and Results, VMT Mitigations, Existing Retail Gross Leasable Areas, Plan Bay Area, and VMT Analysis of Sample Projects.

What is VMT?

VMT measures the amount and distance of vehicle travel attributed to a project or use. Specifically, VMT focuses on determining the origin and destination of travel patterns. Unlike LOS, VMT does not assess the local vehicle trips from a project or the project’s traffic impacts on a local intersection or road/highway segment. Rather, VMT assesses the effects of the project on regional traffic and use of transit and non-motorized travel. VMT is not a new methodology; it has been used for many years in CEQA documents in estimating pollution (air quality impacts), GHG emissions, and energy consumption. VMT is typically calculated using a travel demand model, which estimates the total number and length of vehicle trips to and from a given geographic area, such as transportation analysis zones (TAZs).

Using VMT metrics for the transportation impact analysis allows the development of screens, VMT-maps, and VMT calculation tools to simplify the process for City of Morgan Hill staff as well as the public. Unlike the existing LOS-based process, VMT analysis for most projects does not have to be recalculated for each project. The process is divided into three phases:

Screening – to determine if a project can be filtered out of the VMT-based transportation analysis required for CEQA.
VMT Assessment – determine project VMT, compare to thresholds of significance to determine if there is a significant environmental impact.
VMT Mitigation – to mitigate VMT impacts for projects with VMT that is higher than the threshold.

VMT Screening Criteria

The Governor’s Office of Planning and Research (OPR) recommends streamlining CEQA review of projects to identify areas where less detailed environmental review can be presumed. There are four types of screens proposed by Nelson\Nygaard for the City of Morgan Hill:

Small projects
Low-VMT areas
Near transit stations
Affordable housing

Screen Type	Recommended Screening Criteria
Small Projects	Single-family detached housing of 15 units or less; OR Single-family attached or multi-family housing of 25 units or less; OR Office of 10,000 square feet of gross floor area or less; OR Industrial project of 30,000 square feet of gross floor area; OR Project generating 110 trips a day or less for other land use
Local Serving Retail	50,000 square feet of total gross floor area or less
Location-based screening for Residential Projects	Location: In an area with low (below the threshold) VMT per capita Density: A density of 20 units per acre or greater; or the maximum allowed if zoned at a lower density than 20 units per acre Parking: No more than the minimum number of parking spaces required Displacement: Does not replace affordable residential units with a smaller number of moderate- or high-income residential units Consistent with Plan Bay Area, the applicable Sustainable Communities Strategy (as determined by the lead agency, with input from the Metropolitan Transportation Commission)
Transit proximate location screening for residential, employment, and retail	Location: In an area within a half mile of a major transit stop or high-quality transit corridor Density: A residential land use minimum density of 20 units per acre or greater, or the maximum allowed if zoned at a lower density than 20 units per acre. Employment land use minimum gross floor area ratio (FAR) of .5 or greater, or the maximum allowed if zoned at a lower density than .5 FAR Parking: No more than the minimum number of parking spaces required Displacement: Does not replace affordable residential units with a smaller number of moderate- or high-income residential units Consistent with Plan Bay Area, the applicable Sustainable Communities Strategy (as determined by the lead agency, with input from the Metropolitan Transportation Commission)
Restricted Affordable Residential Projects or Components	City-wide: 100% deed-restricted affordable housing (exception for the manager’s unit(s)); affordability must extend for a minimum of 55 years for rental homes or 45 years for for-sale homes. Affordability for this purpose is restricted to households making 80% or less of the area’s median income OR Below average VMT areas: Projects that are 80% affordable for very low income OR 50% affordable for extremely low income Additionally: On-site manager unit(s) and non-residential components exempted from affordability requirement Parking: no more than the minimum number of parking spaces required

VMT Thresholds of Significance

The City of Morgan Hill has the authority to set thresholds of significance, as the lead agency for land use projects within the City’s boundaries. The below Figure provides a summary of thresholds of significance for the City of Morgan Hill recommended by the Nelson\Nygaard team based on an assessment of state guidance, existing precedence, and a review of the City’s General Plan and Economic Development Blueprint. Land uses not included in the table would be assessed on a case-by-case basis using a methodology approved by the Development Services Director.

Land use	Recommended Thresholds of Significance
Residential	15% below existing average VMT per capita for the City of Morgan Hill
Employment – Office	15% below existing regional¹ average VMT per employee
Employment – Industrial	Existing regional average VMT per employee
Retail – Regional	Net increase in total regional VMT
Hospitality/Tourism	Case by case depending on the type of hospitality project
Medical	Case by case depending on the type of facility
¹Santa Clara County is considered the region when analyzing employment land use in Morgan Hill

Can LOS still be used?

Although SB 743 prohibits the use of LOS as a metric used to analyze transportation impacts in CEQA, and traffic delay is no longer considered a significant impact, cities can still use LOS to inform local analysis, such as traffic operations and traffic signal timing needs. During the development process, LOS analysis can be required outside of CEQA as per the City’s General Plan. Project conditions of approval can require changes to the project, transportation demand management (TDM) strategies, or other measures to address LOS analysis outside of CEQA. However, project conditions of approval cannot induce vehicle travel or increase VMT, both of which are impacts that conflict with SB 743.

Contact Information

For additional information, contact Principal Planner Adam Paszkowski via email or call 408-310-4635.