Over the last five years, the City of Los Angeles has prepared for a paradigm shift in how transportation impacts will be evaluated through the landmark California Environmental Quality Act.


For decades, the transportation impacts of all projects subject to CEQA - including housing developments, sporting venues, and transportation infrastructure - have been evaluated by the metric "Level of Service," or LOS, a measure of automobile traffic congestion at signalized intersections surrounding a project site.  Any project determined to have a significant impact on LOS is required to provide mitigation measures, most frequently in the form or road widenings to increase vehicular throughput.

But by July 1, 2020, all California cities - including Los Angeles - are required to update their transportation impact analysis from LOS to Vehicle Miles Traveled (VMT).  Rather than treating traffic congestion faced by drivers as an environmental impact, this new metric instead considers the act of driving itself as the environmental impact. 

VMT is calculated by multiplying the number of vehicle trips that a proposed development will generate by the estimated number of miles driven per trip.  But while LOS often required wider roads as a mitigation measure, projects expected to induce significant increases in VMT will be able to mitigate their impacts through measures such as car-sharing services, unbundled parking, improved transit, and enhanced pedestrian and bicycle infrastructure.

The change from LOS to VMT was mandated by the legislation SB 743, which was signed into law by former Governor Jerry Brown in 2013.  In Los Angeles, the transition is being jointly led by the Departments of City Planning (LADCP) and Transportation (LADOT), which have worked for the last five years to draft a framework for the city to evaluate projects through VMT.

LADCP and LADOT, in collaboration with the consulting firm Fehr and Peers, have updated the city's travel demand forecasting (TDF) model with trip generation rates collected from affordable housing, market-rate housing, office, and mixed-use developments through a variety of data sources - including cell phone and navigation-based location services.  The revised TDF model serves as the foundation of a publicly-accessible VMT Calculator, which was created to evaluate new developments.  Any project expected to generate 250 or more daily trips will be evaluated for VMT impact.

Though the State of California has made its own recommendation for the CEQA impact threshold for VMT - specifically, 15 percent below the existing VMT per capita of the region - the size and diversity of the City of Los Angeles necessitates a more nuanced approach.

With that in mind, LADOT and LADCP have recommended that the expected VMT of a proposed development should be compared to the average VMT per capita of other projects within the same Area Planning Commission boundary.  The average VMT per capita in the jurisdictions of the city's seven Area Planning Commissions are enumerated in the table below.

Should a project exceed the impact criteria threshold for their respective APC areas, potential mitigation measures include:

  • reduced or "unbundled" parking;
  • neighborhood shuttles;
  • transit subsidies;
  • education programs to discourage automobile use;
  • employer-sponsored vanpools and rideshare programs;
  • car share programs;
  • bike share or other shared mobility devices;
  • improved bicycle infrastructure;
  • traffic-calming improvements; and
  • pedestrian network improvements.

The arrival of VMT also portends important changes to how land use plans - including the 35 Community Plans of Los Angeles - are evaluated through CEQA.  A staff report to the City Planning Commission notes that in future land use plans, potential mitigation measures for VMT could include "reallocation of future land use development to increase density in transportation-efficient locations," such as those in close proximity to bus and rail lines, as well as to services and employment districts.

Development around transit has become a contentious issue as Metro continues to build out new rail and bus rapid transit lines across Los Angeles County.  The new Expo Line Transit Neighborhood Plan brought this matter into focus last year, with pro-housing advocates decrying the plan as unambitious and those opposed to growth seeking to strip away increases in density.  Not long after the adoption of the Expo TNP, opponents filed a lawsuit seeking to overturn the plan.

State legislators have since started to weigh in on the matter, most notably San Francisco Senator Scott Wiener, who has introduced a bill which would allow for the construction of four- and five-story apartment buildings near rail stations, even when local zoning regulations forbid such projects.

LADOT and LADCP are set to report to the City Planning Commission tomorrow on the transition from LOS to CEQA.  After that point, the Departments expect that the policy change will be considered by City Council Committees in Spring 2019.  This will be followed by a nearly one-year phase-in period ending with the July 2020 deadline for the adoption of the VMT metric.