Level of Service (LOS) to Vehicle Miles Traveled (VMT) Transition

As of Fall 2021, this transition is largely complete. Please visit the Congestion Management Program Technical Resources page for key Vehicle Miles Traveled resources and use the Santa Clara Countywide VMT Evaluation Tool.

In 2013, the State of California passed Senate Bill (SB) 743, which mandates that jurisdictions can no longer use automobile delay – commonly measured by Level of Service (LOS) – in transportation analysis under the California Environmental Quality Act (CEQA). The State has issued guidelines calling for the use of a broader measure called Vehicle Miles Traveled (VMT)...

As of Fall 2021, this transition is largely complete. Please visit the Congestion Management Program Technical Resources page for key Vehicle Miles Traveled resources and use the Santa Clara Countywide VMT Evaluation Tool.

In 2013, the State of California passed Senate Bill (SB) 743, which mandates that jurisdictions can no longer use automobile delay – commonly measured by Level of Service (LOS) – in transportation analysis under the California Environmental Quality Act (CEQA). The State has issued guidelines calling for the use of a broader measure called Vehicle Miles Traveled (VMT), which measures the total amount of driving over a given area. These changes become mandatory on July 1, 2020.

The State’s intent in making this switch is to promote:

  • The reduction of greenhouse gas emissions
  • The development of multimodal transportation networks (i.e., networks that serve a variety of users including pedestrians, bicyclists, transit riders and drivers)
  • A diversity of land uses (i.e., neighborhoods and cities with housing, jobs, shops and services in close proximity to each other)

Cities and counties around the state are in the process of transitioning from LOS to VMT in their policies and practices.

As the Congestion Management Agency (CMA) for Santa Clara County and through its Congestion Management Program, VTA has a statutory role to work with its Member Agencies (the 15 cities and towns in Santa Clara County, as well as the County of Santa Clara) on issues related to land use and transportation.  As part of this role, VTA is working with its Member Agencies on the transition from LOS to VMT.

Objectives

The goal of this effort is to steer VTA through the LOS-to-VMT transition process in its CMA and CEQA Lead Agency roles, and play a leadership role in guiding Member Agencies in their implementation efforts.

VTA staff, with input from its Member Agencies, has identified the following objectives for VTA’s LOS-to-VMT transition efforts:

  • Take a leadership role: Be a leader on SB 743 implementation in Santa Clara County, in the Bay Area, and around the State
  • Move Santa Clara County in an overall progressive and pragmatic direction: Work with Member Agencies to encourage a shift away from the use of LOS in CEQA, CMP and local agency practices as soon as possible, recognizing that LOS will still be used in certain situations.
  • Reform VTA’s practices, focusing on CMA and CEQA Lead Agency roles in the near term: Work with Member Agencies to promote the use of VMT and multimodal analysis within the CMP, and change VTA’s CEQA thresholds for its own projects.
  • Provide countywide data and tools: Provide Santa Clara County-specific data that Member Agencies can use in setting VMT thresholds, and develop tools for evaluating project VMT and VMT reductions for land use projects.

It is important to note that the changes to CEQA called for in SB 743 are separate from the state laws that govern Congestion Management Programs. The state CMP statutes still reference the use of LOS standards in Congestion Management Programs. It is possible that the CMP statutes may be updated to more closely align with SB 743 in coming years.

Resources

Other Resources

Timeline

Title
Implementation Preparation
Phase Date Range
-
Title
SB 743 signed into law
Milestone Date
Title
Governor’s Office of Planning and Research issues revised guidance on implementing SB 743
Milestone Date
Title
VTA begins LOS-to-VMT transition effort with its Member Agencies
Milestone Date
Title
Implementation
Phase Date Range
-
Title
VTA provides baseline VMT data for Santa Clara County
Milestone Date
Title
VTA releases countywide web-based VMT Evaluation Tool for land use projects
Milestone Date
Title
Mandatory statewide adoption date when agencies must switch from LOS to VMT in CEQA
Milestone Date
Title
VTA provides documentation on countywide VMT Evaluation Tool
Milestone Date
Title
VTA releases Version 2 of countywide VMT Evaluation Tool and updated documentation
Milestone Date