Transportation Analysis per CEQA

VMT Policy

The City has adopted a policy establishing vehicle miles traveled (VMT) as the appropriate metric for evaluating transportation-related impacts under CEQA. To learn more, click here.

  • Adopting Resolution (link)
  • Staff report with attachments (link)
  • Presentation slides (link)

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 2018, the Govenor's 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 the change in how transportation-related impacts must be evaluated, 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 have been held for a Planning Commission recommendation on and City Council adoption of the new VMT Policy that removes automobile delay as a significant impact on the environment and replaces it with a VMT threshold for all CEQA environmental determinations. The VMT Policy also establishes VMT thresholds of significance, screening criteria, Transportation Demand Management (TDM) strategies, and a VMT Mitigation Banking Program.


The City with assistance from the transportation consulting firm, Kimley-Horn and Associates, has developed 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 in state law.

State Guidance

In 2020, Caltrans adopted its guidance under SB 743. The department’s Transportation Analysis Framework and Transportation Analysis for CEQA provide guidance for assessing induced travel impacts from prospective projects on the State Highway System. Another document, the Transportation Impact Study Guide, provides guidance for Caltrans’ comments to land-use authorities. 

Caltrans-OPR SB 743 Implementation Working Group

In 2021, the SB 743 Implementation Working Group was formed to provide stakeholders from the public, private and non-governmental sectors a collaborative opportunity to contribute to the advancement of the State’s climate, health and mobility goals through the successful implementation of SB 743. The working group is led collaboratively by Caltrans and OPR.

Housing and VMT Mitigation

Caltrans has recently provided guidance that partial funding of affordable housing projects may be considered a mitigation measure for reducing VMT. More specifically, a project sponsor can take “credit” for mitigation they purchase as long as there is no "double counting" and it can be shown that but for the contribution, the affordable housing project would not have been developed. For more information on the subject, visit Caltrans website and the July 2022 Caltrans SB 743 Program Mitigation Playbook.

Page last updated on September 28, 2022.