Vehicle Miles Traveled (VMT) City Policy

On November 6, 2024, the City of Morgan Hill adopted Resolution No. 24-039 approving a citywide Vehicle Miles Traveled (VMT) policy regarding the City's implementation of State Senate Bill (SB) 743 transition from Level of Service (LOS) to 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.

Morgan Hill Adopted VMT Screening Criteria

Screen Type

Screening Criteria

Project Size 

Projects that generate less than 110 average daily trips (when estimating trips generated by a project, Institute of Transportation Engineers (ITE) guidelines or local surveys of trip generations need to be reviewed and approved by the City of Morgan Hill; such analysis will need to account for trip generation of all uses on the project site when calculating the total number of daily trips)


Locally Serving Retail 

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


Affordable Housing 

100% affordable residential development (or the residential component of a mixed-use development)


Active Transportation Projects

Transportation projects that promote active transportation (such as transit, bicycle, and pedestrian facilities)


Morgan Hill Adopted VMT Thresholds of Significance

Land Use

Thresholds of Significance

Residential

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

Proposed "VMT per Capita (Morgan Hill Threshold)" Map (to be revised)

VMT per Capita (Morgan Hill Threshold) Map

Proposed "VMT per Employee (Morgan Hill Threshold)" Map (to be revised)

VMT per Employee (Morgan Hill Threshold)

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

Previous Meetings/Workshops

What is VMT?

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. 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) .

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.