This is a follow-on to my Wednesday post on the CEQA Guidelines update/reform: CEQA VMT reform has a fatal flaw.

Four organizations spoke at the hearing:

• Climate Resolve (Ella): spoke against exemption, spoke about equity and displacement, mentioned request to Caltrans to use VMT instead of LOS
• City of San Jose: spoke against transportation exemption, apparently submitted letter signed by other cities but I didn’t catch which ones; San Jose recently adopted VMT as their measure for transportation and development (Streetsblog Cal: San Jose Becomes Fourth California City to Adopt VMT as Metric for Traffic Impacts)
• Coalition for Clean Air: spoke to reducing VMT as the best path to reducing emissions
• California Bicycle Coalition (Linda): spoke about equity and displacement issues, on need to monitor and determine consistency, spoke against exemption

And I spoke, the sole citizen speaker:

• I reject the language in 15064.3, Subdivision (b)(2), which exempts transportation from any requirement to use VMT rather than LOS.
• Overall, the changes will affect development in a positive way, encouraging infill and discouraging greenfield development, however, transportation drives greenfield development drives rather than greenfield development driving transportation, so the overall benefit will be much lessened by the transportation exemption.
• Transportation is the largest single contributor to greenhouse gas emissions in California (about 39%), but this language does little to address transportation
• The draft guidelines specifically say “this provision does not prohibit capacity expansion.” But capacity expansion is the largest single contributor to exist and future emissions. This is exactly the issue that most needs to be solved
• In the Sacramento region, nearly every county and city will continue to use LOS rather than VMT, with the possible exception of Sacramento city and Davis. Even the discussion of a possible change had most transportation ‘professionals’ and politicians up in arms.
• Though it did not talk about it, the draft clearly contravenes the intent of the legislature in SB 743, which was to kill LOS.

I hope that there is enough opposition on the transportation issue that the agencies will come back with a better proposal, but if not, the legislature will have to come back to the issue again. If this exemption stands, the state cannot possibly meet its greenhouse gas reduction targets.