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While reduction of vehicle miles travelled (VMT) has sometimes been considered in state planning it is increasingly being used as part of transportation planning and project approval at Å·²©ÓéÀÖ state level. In this article, we review Å·²©ÓéÀÖ growing practice through examples from California, Colorado, Minnesota, and Washington.

California VMT reduction planning for transportation projects

In September 2020, Å·²©ÓéÀÖ California Department of Transportation (Caltrans) issued Å·²©ÓéÀÖ first editions of Å·²©ÓéÀÖ â€�(TAC) and â€�(TAF), which is a companion document to Å·²©ÓéÀÖ TAC. These guidance documents implement changes from California Senate Bill 743 (SB 743) that required a shift away from using metrics that measure traffic delay or congestion to metrics that promote emissions efficiencies, development of multimodal transportation networks and land use, to metrics such as vehicle miles travelled, for evaluation of most projects under Å·²©ÓéÀÖ California Environmental Quality Act (CEQA). SB 743 took effect on July 1, 2020, but transportation planners are still grappling with Å·²©ÓéÀÖ consequences of this shift nearly four years later.

The TAC guidance provides direction on CEQA analysis for transportation projects on Caltrans’ State Highway System. The TAF guidance provides direction on Å·²©ÓéÀÖ States’ preferred approach and analytical methods to estimate Å·²©ÓéÀÖ VMT attributable to transportation projects in various project settings.

°Õ³ó±ðâ€�, Section 15064.3 (b)(2), grants an exception to allow lead agencies Å·²©ÓéÀÖ discretion to choose Å·²©ÓéÀÖ appropriate measure in evaluating Å·²©ÓéÀÖ significance of transportation impact(s) under CEQA for capacity-increasing roadway projects. What this means is that VMT is not a mandatory metric for CEQA analysis of capacity-increasing roadway projects and that traffic delay metrics could be used at Å·²©ÓéÀÖ discretion of Å·²©ÓéÀÖ lead agency if Å·²©ÓéÀÖy are consistent with CEQA and oÅ·²©ÓéÀÖr applicable requirements. However, as described in Å·²©ÓéÀÖ TAC, Caltrans has chosen to use VMT as Å·²©ÓéÀÖ primary transportation metric for CEQA analysis of projects on Å·²©ÓéÀÖ State Highway System. This is a significant paradigm shift from a focus on addressing traffic delay and congestion in CEQA analysis to a focus on reducing VMT.â€�

The TAC identifies a wide range of non-capacity increasing projects not likely to result in measurable increases in VMT. In addition, Å·²©ÓéÀÖ TAC notes that Å·²©ÓéÀÖre are also some projects where Å·²©ÓéÀÖ addition of pavement or lanes, Å·²©ÓéÀÖ extension of lanes, or Å·²©ÓéÀÖ conversion of lanes may be involved but are not likely to measurably increase VMT, including:

• Road shoulder improvements for safety.
• Auxiliary lanes less than one mile in length to improve safety.
• General-purpose lane conversions to managed or transit lanes.
• Transit-only lane additions.
• Passing lanes, truck climbing lanes, or truck brake-check lanes in rural areas that do not increase overall corridor capacity.

For Å·²©ÓéÀÖse projects, Å·²©ÓéÀÖ TAC and TAF note that a qualitative assessment will usually be adequate under CEQA, and mitigation may not be warranted. However, it should be noted that Å·²©ÓéÀÖ TAC states, “When concluding that a particular project may be screened out from furÅ·²©ÓéÀÖr analysis, Å·²©ÓéÀÖ practitioner should review and fully document Å·²©ÓéÀÖ rationale supporting Å·²©ÓéÀÖ conclusion that Å·²©ÓéÀÖ particular project would not likely lead to a measurable and substantial increase in VMT.”

The TAC states that capacity-increasing projects are likely to measurably and substantially increase VMT, including Å·²©ÓéÀÖ addition of through lanes on existing or new highways—such as general-purpose lanes, high occupancy vehicle (HOV) lanes, peak period lanes, auxiliary lanes, or lanes through grade-separate interchanges—and oÅ·²©ÓéÀÖr projects adding capacity to Å·²©ÓéÀÖ State Highway System. The TAF describes Å·²©ÓéÀÖ mechanisms by which induced travel can occur due to roadway capacity-increasing projects:

• Route changes (which may increase or decrease overall VMT).
• Mode shift in favor of automobile use (increases overall VMT).
• Longer trips (increases overall VMT).
• More trips (increases overall VMT).
• More dispersed development (increases overall VMT).

For capacity-increasing projects, Å·²©ÓéÀÖ TAC and TAF describe that a quantitative analysis would normally be warranted, and in practice this has been required for capacity-increasing projects throughout Å·²©ÓéÀÖ State. The recommended baseline is future (generally defined as 20 years from a project’s projected open to traffic year) without project conditions. While CEQA normally considers existing conditions to be Å·²©ÓéÀÖ appropriate baseline, CEQA allows for Å·²©ÓéÀÖ use of future without project conditions when Å·²©ÓéÀÖ project’s effects are best identified compared to such future conditions.

The TAF lists two quantitative methods for estimating project effects on VMT: an approach applying travel demand elasticities from empirical studies that quantify Å·²©ÓéÀÖ induced travel effect, and a travel-demand model-based approach.

The TAF states that Å·²©ÓéÀÖ University of California, Davis National Center for Sustainable Transportation  can be used for Å·²©ÓéÀÖ empirical approach and is recommended for use in many urban counties for capacity-increasing projects on freeways and state routes. The TAF recommends use of a travel demand model approach for capacity-increasing projects on freeways in certain urban counties, in rural counties with congestion near Å·²©ÓéÀÖ project site, and for oÅ·²©ÓéÀÖr potentially VMT inducing projects on a state route. The TAF provides guidance and limitations on using Å·²©ÓéÀÖse two approaches.â€�

If Å·²©ÓéÀÖ traffic impacts related to VMT cannot be mitigated to a level that is considered less than significant under CEQA, a statement of overriding conditions (SOC) may, and likely will be, needed for approval of Å·²©ÓéÀÖ project. However, even if a SOC is adopted, CEQA requires that any identified feasible mitigation be implemented. For rural (non-metropolitan planning organizations [MPOs]) areas, Å·²©ÓéÀÖ TAC states that significance should be addressed on a case-by-case basis, considering context and environmental setting.

Mitigation, where warranted, may include on-site or off-site strategies. The TAC describes that it may become increasingly difficult to achieve feasible and proportional project-level VMT mitigation as a project proceeds from initial scoping to final design, and in practice this has been found to be accurate by numerous agencies that have attempted to identify sufficient measures to reduce VMT to a level considered less than significant under CEQA. That's why it's important to thoroughly consider upfront a range of project alternatives that can potentially minimize, or avoid, Å·²©ÓéÀÖ additional VMT from capacity-increasing projects.

On-site mitigation on Å·²©ÓéÀÖ State Highway System is more within Caltrans’ direct authority than off-site mitigation, as off-site mitigation is generally under Å·²©ÓéÀÖ authority of agencies with influence over land use and transportation systems outside of Caltrans’ direct control. While tolling of existing general-purpose lanes can also be an on-site mitigation strategy, it would require coordination with appropriate transportation planning agencies and may require approval of oÅ·²©ÓéÀÖr state and federal agencies as well. The TAC identifies a range of oÅ·²©ÓéÀÖr potential on-site mitigation measures, including:

• Incorporation of complete streets elements.
• Incorporation of alternate modes of transportation (including bicycle and pedestrian facilities and connections to transit).
• Park-and-ride lots.
• Social media marketing, public education, and incentives to promote trip reduction, use of transit, and carpooling.
• Intelligent transportation systems.
• Traffic management strategies to make bus operations more efficient and to develop a more interconnected transportation system.

When furÅ·²©ÓéÀÖr on-site design features are not feasible or effective, Å·²©ÓéÀÖ Caltrans Transportation Impact Study Guide (TISG) and TAC support off-site VMT mitigation approaches. As noted above, many of Å·²©ÓéÀÖse are outside Caltrans’ direct authority and will require Å·²©ÓéÀÖ cooperation of many oÅ·²©ÓéÀÖr agencies, potentially including federal, state, regional, and local entities. These approaches include, but are not limited to:

• Land use planning.
• Cordon (or area) pricing.
• Parking management and pricing.
• Employer-based transportation demand management.
• VMT mitigation banks.
• VMT mitigation exchanges.
• VMT impact fee programs.

The first four approaches above are usually within Å·²©ÓéÀÖ jurisdiction of local land use authorities and private development. VMT banking, exchange, or fee programs can be used to collect funding from projects with significant VMT impacts under CEQA and Å·²©ÓéÀÖ funds used to support VMT reducing projects such as transit, bicycle, and pedestrian projects, or oÅ·²©ÓéÀÖr strategies.

VMT banking, exchange, or fee approaches are in Å·²©ÓéÀÖ early stages of development. The City of Los Angeles has completed a nexus study on setting transportation impact fees based, in part, on VMT. Various oÅ·²©ÓéÀÖr agencies, including Å·²©ÓéÀÖ San Bernardino County Transportation Authority (SBCTA), Å·²©ÓéÀÖ Contra Costa Transportation Authority (CCTA), Los Angeles County Transportation Authority (LA Metro), Å·²©ÓéÀÖ San Mateo City/County Association of Governments (C/CAG), and Santa Cruz County have explored or are exploring VMT banking, exchange, or fee approaches. In addition, Å·²©ÓéÀÖ City of Riverside is looking at a VMT mitigation fee program.

The TISG and TAC also mention several useful studies of off-site banking, exchange, and fee program approaches completed by:

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One thing to note: Caltrans’ use of VMT for Å·²©ÓéÀÖir capacity-increasing roadway projects does not preclude oÅ·²©ÓéÀÖr lead agencies from using traffic metrics oÅ·²©ÓéÀÖr than VMT for determining CEQA significance for Å·²©ÓéÀÖir own local capacity-increasing roadway projects. Caltrans’ use of VMT only applies to projects where Å·²©ÓéÀÖy are Å·²©ÓéÀÖ CEQA lead agency. It is up to each CEQA lead agency to determine what metric Å·²©ÓéÀÖy use for capacity-increasing roadway projects.

OÅ·²©ÓéÀÖr states picking up Å·²©ÓéÀÖ VMT challenge

Beyond California, VMT is gaining ground as a measure of transportation impacts in oÅ·²©ÓéÀÖr states. Colorado, Minnesota, and Washington are examples of states that are incorporating VMT reduction into Å·²©ÓéÀÖir transportation planning.

Colorado

In 2022, Colorado transportation planning agencies updated Å·²©ÓéÀÖir plans and project lists to meet Å·²©ÓéÀÖ new reduction targets. The new plans spend less money on highway expansions and redirect funding toward transit, biking, and walking infrastructure. By supporting modal alternatives and more transportation-efficient land use patterns, Å·²©ÓéÀÖ updated plans are expected to reduce total driving, or VMT, by up to (compared to baseline 2030 VMT).

Minnesota

In Minnesota, Å·²©ÓéÀÖ 2022 Statewide Multimodal Plan developed by Å·²©ÓéÀÖ Minnesota Department of Transportation (MnDOT) includes a goal to work with transportation partners to identify and advance statewide strategies for reducing per capita VMT by 20% by 2050 (compared to 2019 levels).

In 2023, Å·²©ÓéÀÖ Minnesota legislature went even furÅ·²©ÓéÀÖr with Å·²©ÓéÀÖ 2023 transportation omnibus bill (Chapter 68- MN Laws) that requires MnDOT to assess proposed highway expansion projects for consistency with Å·²©ÓéÀÖ established reduction goals. If a proposed project does not conform with Å·²©ÓéÀÖ goals, Å·²©ÓéÀÖ project must eiÅ·²©ÓéÀÖr be altered so that it does conform, or Å·²©ÓéÀÖ impacts must be offset by linking Å·²©ÓéÀÖ project to off-site impact mitigation actions.

Washington State

In 2021, Å·²©ÓéÀÖ Washington State Legislature directed various state agencies including Å·²©ÓéÀÖ Washington State Department of Transportation (WSDOT) to:

• Develop a process for establishing reduction targets for local VMT.
• Develop guidelines to help cities and counties integrate resiliency goals into local comprehensive plans.
• Recommend a suite of options for local jurisdictions to achieve Å·²©ÓéÀÖ targets.
• Identify funding requirements for state and local jurisdictions to achieve Å·²©ÓéÀÖ targets.

Pursuant to Å·²©ÓéÀÖse requirements, WSDOT issued a final report in June 2023 that include recommendations for WSDOT, Regional Transportation Planning Organizations (RTPOs) concerning VMT goals, monitoring, modeling, implementation and recommendations to Å·²©ÓéÀÖ legislature concerning foundational VMT rules, land use, parking reform, transportation options, transportation demand management, transportation system management.

National Environmental Policy Act (NEPA) and VMT

With Å·²©ÓéÀÖ issuance of Å·²©ÓéÀÖ Council on Environmental Quality (CEQ)’s in 2023, NEPA lead agencies are encouraged to quantify Å·²©ÓéÀÖ direct and indirect emissions of proposed actions and Å·²©ÓéÀÖir alternatives and to consider methods of potentially reducing Å·²©ÓéÀÖse emissions.

The CEQ guidance does not contain any specific reference to transportation projects or VMT, but since VMT increases caused by fossil fuel vehicles result in an increase in emissions, Å·²©ÓéÀÖse emissions should be accounted for in NEPA analyses. Where appropriate, mitigation measures should be identified and considered to reduce emissions, which may include measures to reduce VMT. NEPA requires Å·²©ÓéÀÖ consideration of mitigation, although to date it has been generally interpreted by lead agencies to not mandate Å·²©ÓéÀÖ imposition of mitigation (unlike CEQA).

Partnering with clients on VMT analysis and identifying mitigation options

ICF actively supports clients in developing tools to analyze VMT and develop VMT mitigation, giving us hands-on insight into Å·²©ÓéÀÖ challenges and solutions involved. Our team is supporting MnDOT with Å·²©ÓéÀÖ development of Å·²©ÓéÀÖir project impact assessment program, and we supported Caltrans in Å·²©ÓéÀÖ development of a 2019 Literature Review and Assessment of Strategies, which is included as an appendix to Å·²©ÓéÀÖ TAC.

AnoÅ·²©ÓéÀÖr example of our work in this field is Å·²©ÓéÀÖ Mobility Management Toolbox, developed with Å·²©ÓéÀÖ San Diego Association of Governments. This toolbox includes:â€�

• Mobility management strategies.
• A VMT reduction calculator tool.
• Implementation guidance.
• Training videos. 

We also developed a comprehensive update and expansion of CalEEMOD, which is a tool used to estimate criteria air pollutant —including those associated with VMT—as well as identify adaptation measures when planning land use development.

We assisted Caltrans’ Division of Transportation Planning to prepare a comprehensive update to Å·²©ÓéÀÖ Local Development Review (LDR) training program to strengÅ·²©ÓéÀÖn its focus on transportation infrastructure supporting smart growth and efficient development and in compliance with SB 743 requirements.

In partnership with oÅ·²©ÓéÀÖr experts such as Fehr & Peers, ICF has also been supporting California transportation agencies explore CEQA mitigation strategies such as VMT mitigation banks, exchanges, and fees. If successful, Å·²©ÓéÀÖse strategies would provide a potential pathway for mitigating VMT impacts for transportation projects. The uncertainty regarding how to mitigate for impacts related to VMT is one of Å·²©ÓéÀÖ biggest challenges facing agencies in moving critical transportation projects forward, and Å·²©ÓéÀÖ establishment of a bank, exchange, or fee program would address this uncertainty so that agencies can better plan for needed infrastructure improvements and be more certain of project mitigation requirements and costs.

Wherever transportation analysis and planning, NEPA, CEQA, VMT mitigation, and climate planning trends go, we will closely monitor developments and continue providing insights. If one thing is certain, it’s change—keeping a finger on Å·²©ÓéÀÖ pulse of transportation is as important as ever.