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 Hearing -    Public Notice (PDF)

This notice is to advise the public the Morgan Hill City Council will conduct a public hearing to receive input on the proposed Vehicle-Miles-Traveled (VMT) Screening Criteria and Thresholds of Significance as stated above. The City Council meeting will be held via video conference and is open to the public. All interested persons may participate and be heard by joining the video conference at: https://bit.ly/MHCityCouncilMeeting or by calling into the meeting at (669) 900-9128 and entering the Webinar ID: 873 3200 8380

 CITY COUNCIL MEETING

DATE: Wednesday, June 23, 2021
TIME: 7:00 p.m.
LOCATION: Video Conference
Weblink: https://bit.ly/MHCityCouncilMeeting
Phone: (669) 900-9128 Webinar ID: 873 3200 8380

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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:

  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.

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 e-mail or by telephoning (408) 310-4635.