Transportation Analysis per CEQA

Background on CEQA Transportation Analysis

With the adoption of the Sustainable Communities and Climate Protection Act of 2008 (Senate Bill 375), the state made its commitment to encourage land use and transportation planning decisions that help reduce greenhouse gas emissions and vehicle miles traveled, as required by the California Global Warming Solutions Act of 2006 (Assembly Bill 32).

On September 27, 2013, Gov. Jerry Brown signed California Senate Bill 743, which determined that new practices are needed for evaluating transportation impacts under the California Environmental Quality Act, also known as CEQA, that are “better able to promote the state’s goals of reducing greenhouse gas emissions and traffic-related air pollution, promoting the development of a multimodal transportation system, and providing clean, efficient access to destinations.” Helping move that process forward, SB 743 added Chapter 2.7, Modernization of Transportation Analysis for Transit-Oriented Infill Projects, to Division 13 (Section 21099) of the Public Resources Code (PRC).

PRC Section 21099(b)(1) requires the Office of Planning and Research, the state’s long-range planning and research agency, to develop revisions to the CEQA Guidelines establishing criteria for determining the significance of transportation impacts of projects within transit priority areas that promote the “…reduction of greenhouse gas emissions, the development of multimodal transportation networks, and a diversity of land uses.” PCR Section 21099(b)(2) states that upon adoption of the revisions to the CEQA Guidelines, automobile delay, as described solely by level of service or similar measures of vehicular capacity or traffic congestion, shall not be considered a significant impact on the environment under CEQA.

New CEQA Guidelines

Since December 2013, the Office of Planning and Research (OPR) and the Natural Resources Agency published several documents to implement Senate Bill 743 and the associated CEQA Guidelines:

The documents indicate that the primary consideration in transportation environmental analysis should be the amount and distance that the project might cause people to drive. Accordingly, the state proposes that the level of service ("LOS") metric be replaced with a vehicle miles traveled ("VMT") metric. The revised CEQA Guidelines also set an effective date of July 1, 2020. Any EIRs and negative declarations circulated for public review after July 1, 2020, are required to consider VMT when determining whether a project may cause a significant impact.

Local Actions

Given the negative effects the results of environmental impact analysis can have on beneficial projects in town and that the change is imminent statewide, the City of Watsonville, as Lead Agency under CEQA, has taken steps to implement this change per SB 743. On March 3, 2020, an informational presentation was given to the Planning Commission on the matter.  Public hearings for a Planning Commission recommendation on and City Council adoption of a new policy that removes automobile delay as a significant impact on the environment and replaces it with a VMT threshold for all CEQA environmental determinations is anticipated for June 2020.


The City with assistance from the transportation consulting firm, Kimley-Horn and Associates, is developing a VMT Evaluation Tool to help developers and planners understand the environmental impact of the vehicle trips generated by projects.

Additional Information and Resources

Helpful resources are available at OPR’s SB 743 web page, which contains the latest Technical Advisory and narrated presentations explaining key points from the Technical Advisory: 

It also contains a California Air Resources Board document connecting VMT with climate targets found in state law.

Page last updated on April 3, 2020.