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examine induced growth impacts under CEQA. (See generally, Pub. Resources Code, §§ 21065 [defining
“project” under CEQA as an activity as causing either a direct or reasonably foreseeable indirect physical
change], 21065.3 [defining “project-specific effect” to mean all direct or indirect environmental effects],
21100, subd. (b) [required contents of an EIR].) For any project that increases vehicle travel, explicit
assessment and quantitative reporting of the amount of additional vehicle travel should not be omitted
from the document; such information may be useful and necessary for a full understanding of a project’s
environmental impacts. (See Pub. Resources Code, §§ 21000, 21001, 21001.1, 21002, 21002.1
[discussing the policies of CEQA].) A lead agency that uses the VMT metric to assess the transportation
impacts of a transportation project may simply report that change in VMT as the impact. When the lead
agency uses another metric to analyze the transportation impacts of a roadway project, changes in
amount of vehicle travel added to the roadway network should still be analyzed and reported.
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While CEQA does not require perfection, it is important to make a reasonably accurate estimate of
transportation projects’ effects on vehicle travel in order to make reasonably accurate estimates of GHG
emissions, air quality emissions, energy impacts, and noise impacts. (See, e.g., California Clean Energy
Com. v. City of Woodland (2014) 225 Cal.App.4th 173, 210 [EIR failed to consider project’s
transportation energy impacts]; Ukiah Citizens for Safety First v. City of Ukiah (2016) 248 Cal.App.4th
256, 266.) Appendix 2 describes in detail the causes of induced vehicle travel, the robust empirical
evidence of induced vehicle travel, and how models and research can be used in conjunction to
quantitatively assess induced vehicle travel with reasonable accuracy.
If a project would likely lead to a measurable and substantial increase in vehicle travel, the lead agency
should conduct an analysis assessing the amount of vehicle travel the project will induce. Project types
that would likely lead to a measurable and substantial increase in vehicle travel generally include:
• Addition of through lanes on existing or new highways, including general purpose lanes, HOV
lanes, peak period lanes, auxiliary lanes, or lanes through grade-separated interchanges
Projects that would not likely lead to a substantial or measurable increase in vehicle travel, and
therefore generally should not require an induced travel analysis, include:
• Rehabilitation, maintenance, replacement, safety, and repair projects designed to improve the
condition of existing transportation assets (e.g., highways; roadways; bridges; culverts;
Transportation Management System field elements such as cameras, message signs, detection,
or signals; tunnels; transit systems; and assets that serve bicycle and pedestrian facilities) and
that do not add additional motor vehicle capacity
• Roadside safety devices or hardware installation such as median barriers and guardrails
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See, e.g., California Department of Transportation (2006) Guidance for Preparers of Growth-related,
Indirect Impact Analyses, available at
http://www.dot.ca.gov/ser/Growth-
related_IndirectImpactAnalysis/GRI_guidance06May_files/gri_guidance.pdf.