CEQA's New Method for Measuring Traffic Impacts

LOS ANGELES—CEQA has a new method for measuring traffic impacts, and it could mean a lengthier process for developers who aren't in the know—or it could mean a smoother CEQA process, depending on your level of optimism. CEQA currently measures traffic impacts using the “level of service” metric, but later this year or early next year, the method is changing to a “vehicle miles traveled” method. For unaware developers, this might mean a lengthier CEQA process if the wrong method is used; however, it could also mean the developers can reduce their environmental impact by reducing the number of vehicles traveling to and from a project. To find out more about the new method and how it will affect developers, we sat down with Scott Birkey, a partner at Cox, Castle & Nicholson for an exclusive interview.

GlobeSt.com: How have transportation impacts been revised under CEQA?

Scott Birkey: The new direction is called VMT, or “vehicle miles traveled.” This is the direction that the state, under some new legislation, has been pushing us to. It is actually a little known secret that there has always been a preference to vehicle miles traveled because it looks at the amount of vehicles traveling for a given area or for a given amount of time. So, [it looks at] how many vehicles are on the road at any given moment. There are all sorts of questions about how to do that modeling. For example, what is the region and how do you put boundaries around the scope of that? There are a lot of questions still to be answered, but the idea is that if you VMT as your way of analyzing that, then the fix is to change your project in a way that it does not generate as many trips. That turns the traffic impacts into a trip generation issue. One way to think about this and the reason that I think of it as a real game changer is because it is now less about fixing problems by addressing roadway segments miles away from a project. It is now about the project itself. This is a whole different paradigm shift and something that we should be paying a lot of attention to.

GlobeSt.com: What was the former method for evaluating traffic impacts?

Birkey: As it is currently done under CEQA, you have to measure traffic impacts as part of your environmental quality act. We had been evaluating traffic impacts for years now using a “level of service” metric. This metric essential measures the amount of delay that each vehicle experiences at an intersection or a roadway segment. That has all kinds of ripple effects for environmental issues. That whole idea of waiting at an intersection as the result of a project makes it so that to mitigate those impacts, you might be fixing an intersection that is miles away from your project. Those are the sorts of changes that don't directly impact your project. They are really a way of dealing with spillover effects from the project.

GlobeSt.com: Is this a less effective method of measuring traffic impacts?

Birkey: No, although it depends on who you are talking to. What is a little strange is that the average person on the street doesn't think about a project in terms of how many trips it is generating. When passing a new development, people are most concerned about how many more cars are going to be driving through the same intersection and how much longer they are going to wait. That concept is an LOS concept. From our perspective, we are looking at how the average person thinks about this as a way of evaluating impacts. That is different in many ways from what is it that a traffic engineer would be thinking about. There is a real debate out in the industry in terms of evaluating traffic impacts under CEQA. I think that the direction that the state is moving in is a real game changer. As the new policies are rolled out, people are going to start to see that this is going to affect them.

GlobeSt.com: When will this new method come into effect?

Birkey: The office of planning and research is still working on the new CEQA guidelines for the implementation of VMT. We have heard that they will come out later this year or the beginning of next year. It is not in effect yet and won't be until they finalize their guidelines, but it is coming and agencies are looking at ways of implementing it already. It is an issue that most new applicants working on an EIR are concerned about. It is an issue even now.

LOS ANGELES—CEQA has a new method for measuring traffic impacts, and it could mean a lengthier process for developers who aren't in the know—or it could mean a smoother CEQA process, depending on your level of optimism. CEQA currently measures traffic impacts using the “level of service” metric, but later this year or early next year, the method is changing to a “vehicle miles traveled” method. For unaware developers, this might mean a lengthier CEQA process if the wrong method is used; however, it could also mean the developers can reduce their environmental impact by reducing the number of vehicles traveling to and from a project. To find out more about the new method and how it will affect developers, we sat down with Scott Birkey, a partner at Cox, Castle & Nicholson for an exclusive interview.

GlobeSt.com: How have transportation impacts been revised under CEQA?

Scott Birkey: The new direction is called VMT, or “vehicle miles traveled.” This is the direction that the state, under some new legislation, has been pushing us to. It is actually a little known secret that there has always been a preference to vehicle miles traveled because it looks at the amount of vehicles traveling for a given area or for a given amount of time. So, [it looks at] how many vehicles are on the road at any given moment. There are all sorts of questions about how to do that modeling. For example, what is the region and how do you put boundaries around the scope of that? There are a lot of questions still to be answered, but the idea is that if you VMT as your way of analyzing that, then the fix is to change your project in a way that it does not generate as many trips. That turns the traffic impacts into a trip generation issue. One way to think about this and the reason that I think of it as a real game changer is because it is now less about fixing problems by addressing roadway segments miles away from a project. It is now about the project itself. This is a whole different paradigm shift and something that we should be paying a lot of attention to.

GlobeSt.com: What was the former method for evaluating traffic impacts?

Birkey: As it is currently done under CEQA, you have to measure traffic impacts as part of your environmental quality act. We had been evaluating traffic impacts for years now using a “level of service” metric. This metric essential measures the amount of delay that each vehicle experiences at an intersection or a roadway segment. That has all kinds of ripple effects for environmental issues. That whole idea of waiting at an intersection as the result of a project makes it so that to mitigate those impacts, you might be fixing an intersection that is miles away from your project. Those are the sorts of changes that don't directly impact your project. They are really a way of dealing with spillover effects from the project.

GlobeSt.com: Is this a less effective method of measuring traffic impacts?

Birkey: No, although it depends on who you are talking to. What is a little strange is that the average person on the street doesn't think about a project in terms of how many trips it is generating. When passing a new development, people are most concerned about how many more cars are going to be driving through the same intersection and how much longer they are going to wait. That concept is an LOS concept. From our perspective, we are looking at how the average person thinks about this as a way of evaluating impacts. That is different in many ways from what is it that a traffic engineer would be thinking about. There is a real debate out in the industry in terms of evaluating traffic impacts under CEQA. I think that the direction that the state is moving in is a real game changer. As the new policies are rolled out, people are going to start to see that this is going to affect them.

GlobeSt.com: When will this new method come into effect?

Birkey: The office of planning and research is still working on the new CEQA guidelines for the implementation of VMT. We have heard that they will come out later this year or the beginning of next year. It is not in effect yet and won't be until they finalize their guidelines, but it is coming and agencies are looking at ways of implementing it already. It is an issue that most new applicants working on an EIR are concerned about. It is an issue even now.