PCL and others urge Governor Brown to finalize regulations to implement SB 743 to unburden urban infill projects

October 13, 2017
Governor Edmund G. Brown
State Capitol
Sacramento, CA 95814

Re: Finalizing the Senate Bill 743 Guidelines and Applying Them Statewide

Dear Governor Brown,

We submit this letter on behalf of the undersigned organizations. Our organizations were strong supporters of Senate Bill 743 (Steinberg, 2013), which directed the Governor’s Office of Planning and Research (OPR) to change how transportation emissions under the California Environmental Quality Act (CEQA) are analyzed. Specifically, SB 743 replaced the Level of Service (LOS) “auto delay” analysis for determining a project’s transportation impacts with a more appropriate Vehicle Miles Traveled (VMT) metric and potentially eliminates this review altogether for infill projects close to major transit.

LOS disproportionately burdens infill projects and related infrastructure by privileging automobile traffic over pedestrians, bicyclists, and transit riders. VMT represents a far more accurate measure to determine transportation impacts and will ensure that CEQA review better aligns with the state’s larger environmental and land use policy goals, particularly to encourage infill. Given the centrality of this change to achieving the state’s goals on land use under Senate Bill 375 (Steinberg, 2008) and climate change under Senate Bill 32 (Pavley, 2016), we encourage applying this metric statewide to all projects, particularly all transportation projects. Furthermore, VMT analysis is generally more straightforward to complete than calculating LOS, which makes the environmental review process less resource-intensive.

Yet the process of finalizing the guidelines has been unreasonably delayed. SB 743 required OPR to circulate draft guidelines by July 1, 2014. The draft elicited extensive comments from stakeholders, including the organizations represented here, and OPR issued revised guidelines in January 2016 that addressed many of the requested changes. However, those of us who care about this important change to state law have been waiting for almost two years for these revised guidelines to be certified.

We respectfully request that you urge your administration to finalize these long-overdue guidelines immediately. Every day represents a missed opportunity to lift the burden of outdated and inefficient CEQA review on environmentally advantageous projects. California can wait no longer.


Curt Johansen, Chairman, Council of Infill Builders

Amanda Eaken, Transport. & Climate Dir., Natural Resources Defense Council

Bryn Lindblad, Associate Director, Climate Resolve

Jeremy Madsen, Chief Executive Officer, Greenbelt Alliance

Brian Hanlon, Executive Director, California YIMBY

Stuart Cohen, Executive Director, TransForm

Howard Penn, Executive Director, Planning & Conservation League

Maria Sipin, Advisory Board Co-Chair, Multicultural Communities for Mobility

Mark Vallianatos, Director, LAplus

Chanell Fletcher, Director, ClimatePlan

Emilia Crotty, Executive Director, Los Angeles Walks

Jonathan Matz, Cal. Sr. Policy Manager, Safe Routes to School National Partnership

Naomi Iwasaki, Deputy Director, Investing in Place

Colin Parent, Interim Executive Director, Circulate San Diego

Wesley Reutimann, Executive Director, Bike San Gabriel Valley

Christy Zamani, Executive Director, Day One