It can sound like a simple step, to end Level of Service (LOS) metrics in CEQA transportation analysis. The more conceptually elegant Vehicle Miles Traveled (VMT) metric is easy to welcome in the abstract, with its incentives for shared and active transportation, its arguably simpler calculation methods, its potential to realign CEQA analysis with state climate protection law – and most of all, its escape from the addictive spiral of induced demand for broad, free-flowing highways that, under the logic of LOS analysis, always need widening again.

But in early August the Governor's Office of Planning and Research (OPR) published a detailed discussion draft setting out an alternative transportation impacts metric in compliance with last year's SB 743 mandate. And alongside the big-picture discussions of environmentally conscious innovation, the technical arguments began.

The Governor's Office of Planning & Research is a month late in issuing its final recommendation on whether to replace "level of service" as the measurement of significant transportation impacts in transit priority areas under the California Environmental Quality Act. But there's not much mystery: OPR has sent clear signals that it is going to propose replacing LOS with vehicle miles traveled, or VMT.