
What can other states learn from California’s shift to better measure how streets move people
In 2013, the State of California passed legislation that makes a dramatic change in how the state measures the performance of their streets. Rather than use the traditional level of service (LOS) measure that focuses far too narrowly on moving as many cars as fast as possible — regardless of the context or needs of a street — California’s Office of Planning and Research (OPR) is shifting to an alternative of measuring vehicle-miles traveled (VMT).
In this first post of a six-post series only for T4America members, Transportation for America will walk through the change from LOS to VMT, highlight the opinions of a variety of leaders on this issue and discuss the implications for California’s transportation system and potential implications nationwide.

Note: moving away from level of service (LOS) was one of the key recommendations detailed in our new state policy report, released in January 2016. Don’t miss that helpful resource.
In 2013, Governor Jerry Brown signed into law SB 743, eliminating the use of LOS for projects within designated transit priority areas (TPAs). As Streetsblog LA reported in 2013, SB 743 was a compromise between interests who wanted the full elimination of LOS in California and advocates pushing for the full and immediate elimination of LOS as a requirement for any project. But, because most urban areas fall within the state-defined parameters of a TPA, the enactment of SB 743 means that LOS is largely eliminated for urban projects.
Additionally, SB 743 authorized Governor Brown to develop a new way of measuring traffic impacts of major projects statewide and based the new way on total VMT rather than intersection congestion. (1) This will change how development projects are analyzed and scored in traffic impact studies and thus the type of development projects that California supports.
What this means
In short, instead of measuring whether or not a proposed project will make it less convenient to drive, (CalTrans) will now measure whether or not a project contributes to other state goals, like reducing greenhouse gas emissions, developing multimodal transportation, preserving open spaces, and promoting diverse land uses and infill development. (2) It is expected that this change will make it easier to build transit projects, as well as bicycle and pedestrian-friendly infrastructure.
But perhaps a larger change will be the type of development the law now encourages. Instead of encouraging sprawl that goes against California’s own environmental goals, these new guidelines will encourage development that moves California to a more sustainable transportation system. (3)
Status of Draft Guidelines
In August 2014, OPR released draft guidelines proposing to substitute VMT for the LOS metric (as authorized by SB 743). Under the draft guidelines, California no longer considers bad LOS a problem that needs fixing under the California Environmental Quality Act (CEQA). (4)
On January 20th 2016, OPR released the final draft of the changes to CEQA. The January 20th release signals the 45-day initial public comment period before finalizing the proposal and submitting to the California Natural Resources Agency to begin the formal rulemaking process under the Administrative Procedure Act. The regulations are anticipated to be effective statewide in 2019. (5)
Final Guidelines
The final guidelines are very similar to the draft guidelines with only slight changes. In the final proposal, OPR continues to recommend replacing LOS with VMT as the primary metric for analyzing a project’s transportation impacts, including the presumption that projects near transit (1/2 mile or less) should be presumed to cause a less than significant transportation impact and that transportation projects which add lane miles may result in induced vehicle travel. (6) In a big win for smart growth advocates, the guidelines emphasize that effects on automobile delay do not constitute a significant environmental impact. (7)
The new guidelines would remain optional for a two-year period following adoption, but would apply statewide to all development projects by 2019. (8)
Draft Guideline Rules on Impact Analysis
The final guidelines contain significant changes on the types of triggers needed to spur an environmental impact statement. Divided into three categories; land use projects, residential projects and office projects, all triggers are established at below a commonly accepted baseline level. The new proposal attempts to streamline the implemention of SB 743, with recommendations regarding significance thresholds, for required traffic analyses of development projects. (9)
These new threshold guidelines mean that development projects that will significantly increase the amount of automobile traffic that will be required to undergo rigorous environmental impact statements to ensure that they are compliant with California’s statewide greenhouse gas law.
Citations:
- Newton, D. and Curry, M. (2014, August 7th). California Has Officially Ditched Car-Centric ‘Level of Service’. LA Streetsblog. Retrieved February 1st from /http://la.streetsblog.org/2014/08/07/california-has-officially-ditched-car-centric-level-of-service/
- Newton, D. (2016, January 22nd). State Releases Proposed Rules That Would Finally End LOS in Enviro. Law. Streetsblog California. Retrieved February 1st from http://cal.streetsblog.org/2016/01/22/state-releases-proposed-rules-that-would-finally-end-los-in-environmental-law/
- Ibid 2
- Ibid 2
- Ibid 3
- Lathom and Watkins LLP. (2016, January 26th). California Governor’s Office Releases Updated CEQA Guidelines Proposal on SB 743 Implementation. Retreived 2016/2/01 from http://www.lexology.com/library/detail.aspx?g=b070fa40-a4ff-4ce1-a6db-f2bd104cce31
- Ibid 5
- Ibid 5
- Ibid 5