In response to SB 743, which eliminated Level of Service (i.e., congestion) as a Significant Impact under CEQA, the State adopted Vehicle Miles Traveled (VMT) as the primary metric for evaluating transportation impacts. The purpose of the law was to make it possible for higher density development to take place, as part of the State’s efforts to reduce the growth of VMT and GHGs. One of the most important parts of implementing SB 743 was modifying transportation analysis to include for the first time the element of induced demand. Induced demand is the counter-intuitive reason why widening highways produces higher volumes of traffic within several years of construction. It is the principle that underlies the statement “You can’t build your way out of congestion.
In response to SB 743, Caltrans issued its Transportation Analysis Framework and the companion, Transportation Impacts Analysis under CEQA, available here. While these documents pertain specifically to the State Highway System, they and other resources on that site provide useful guidance for transportation agencies responding to SB 743 and induced demand. TRANSDEF submitted comments criticizing Caltrans for failing to acknowledge that its historic role as highway builder inherently conflicts with the State’s goal of reducing VMT.
Regional Transportation Plan Guidelines
TRANSDEF has been active in a Working Group of the California Transportation Commission that updates the state’s official Regional Transportation Plan Guidelines. Starting in 2007 with an update in response to AB 32, the Group drafted Climate Change-Responsive RTP Guidelines to accommodate the requirements of SB 375. The 2017 RTP Guidelines saw a serious backlash against this document by the Metropolitan Planning Organizations, to which TRANSDEF responded with comments on the 2016 Draft and a stinging critique of where the update process was heading.
The California Transportation Plan
In October 2020, TRANSDEF submitted its comments on the Draft 2050 California Transportation Plan. The Plan is the first-ever document by Caltrans that, to our knowledge, did not establish congestion relief as a primary goal. That makes it a groundbreaking effort that sets forth a very much-needed new vision for transportation for our State.
Caltrans issued its draft update of the California Transportation Plan, CTP 2040, in 2015. TRANSDEF was very laudatory in its comments. As the plan went through the review process, however, the draft plan was taken down from the official CTP 2040 site, never to be seen again. By the time the Final CTP 2040 was approved in 2016, much of the text on reducing GHG emissions had been stripped out. TRANSDEF’s comments acknowledged that the Plan represented a significant cultural shift for Caltrans, but criticized the final document for failing to provide an action plan for an 80% reduction in GHGs. In its later comments on the draft Guidelines for the CTP Update process, TRANSDEF accused Caltrans of intentionally violating SB 391, the law that direct the CTP to plan for the needed 80% reduction in GHGs.