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

The City of Morgan Hill is currently working with TJKM Transportation Consultants (TJKM) 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). 

To learn more about VMT, scroll to the bottom of this page.

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) and recommended that new projects should reduce VMT by 15%.

Lead agencies have discretion to deviate from OPR's recommended 15% reduction in VMT by developing and adopting their own, or relying on thresholds recommended by other agencies, “provided the decision of the lead agency to adopt such thresholds is supported by substantial evidence.” (Id. at subd. (c); Save Cuyama Valley v. County of Santa Barbara (2013) 213 Cal.App.4th 1059, 1068.) Substantial evidence means “enough relevant information and reasonable inferences from this information that a fair argument can be made to support a conclusion, even though other conclusions might also be reached.” (Id. at § 15384; Protect the Historic Amador Waterways v. Amador Water Agency (2004) 116 Cal.App.4th 1099, 1108-1109.)

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.

City Council Hearing

The Morgan Hill City Council conducted a public hearing on the proposed Vehicle Miles Traveled (VMT) Policy on September 6, 2023 and directed Staff to conduct a cost analysis, timeline, and limited research on a Trip Reduction Ordinance, or similar item, and to revisit the VMT Screening Criteria. Staff is to present the findings before the City Council in three to six months. To view the City Council September 6, 2023 meeting and materials, please visit the Agenda Portal (html).

Planning Commission Hearing

The Morgan Hill Planning Commission conducted a public hearing on June 27, 2023 and made a recommendation to the City Council to approve the proposed Vehicle Miles Traveled (VMT) Policy. To view the Planning Commission meeting and materials, please visit the Agenda Portal (html).

TJKM Analysis

Following the City Council's direction, the City entered into an agreement with TJKM to provide VMT Screening Criteria and substantial evidence to deviate from OPR's Technical Advisory to reduce the VMT for new development by 15% by proposing Thresholds of Significance.

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 TJKM team based on substantial evidence.

Land use

Recommended Thresholds of Significance


VMT per capita does not exceed the City of Morgan Hill's baseline VMT per capita

Office & Industrial

VMT per employee does not exceed the City of Morgan Hill's baseline VMT per employee

All Other Uses

(includes commercial/retail uses over 50,000 square feet)

No net increase in total VMT within the City of Morgan Hill

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 six types of screens proposed by TJKM for the City of Morgan Hill as identified in the below figure:

Screen Type

Recommended Screening Criteria

Project Size

  • Projects that generate less than 110 average daily trips

Locally Serving Retail

  • Retail projects that are less than 50,000 square feet (includes fast-food/quick-serve restaurants) 

Low VMT Area

  • Residential and employment projects located within a low VMT generating area (the Low VMT Area screen is equal to the City of Morgan Hill’s average home-based VMT per resident or VMT per employee, depending on the type of project)

Transit Proximity

  • Projects located within Transit Priority Areas or High Quality Transit Corridors (located within half a mile radius of an existing or planned major transit stop)

Affordable Housing

  • 100% affordable residential development (or the residential component of a mixed-use development) 
Active Transportation
  • Transportation projects that promote active transportation (such as transit, bicycle, and pedestrian facilities)

TJKM has prepared the following memorandums identifying the methodology to establish transportation impact analysis goals, objectives, and recommendations for VMT-based CEQA analysis.

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Previous Meetings/Workshops

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).

To learn the basics on how VMT is calculated please view the following short video, "What is VMT?":

For a more detailed explanation of VMT please watch the following video:

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:

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

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.