• New CEQA, New Opportunities

New CEQA, New Opportunities

On December 28, 2018, the CEQA (California Environmental Quality Act) world changed forever. Virtually the entire CEQA Appendix G has been revised. 

“Two specific changes can really advance infill and transit-oriented development (TOD), as well as Complete Streets projects,” says MIG’s Michelle Gibbs, Senior Planner/Biologist. Take advantage of them! 

In response to Senate Bill 743 (SB 743) and smart growth planning principles, new rules will:

  • Make vehicle miles traveled (VMT) the metric for determining the significance of transportation impacts. This replaces the traditional level of service (LOS) metric.
  • Create and clarify CEQA exemptions for TOD, Infill Development, and Complete Streets improvements (such as bicycle parking, bicycle-share facilities and bicycle lanes, pedestrian crossings, and street trees and other similar improvements that do not create additional automobile travel lanes).

“The proposed changes will require agencies to rethink development impact fee programs, their General Plan policies regarding transportation and circulation, and thresholds of significance for transportation impacts in CEQA documents,” Gibbs says. 

Local and Regional Agencies: You will need to re-tool your Travel Demand Models, as well as thresholds of significance and impact analyses for Regional Transportation Plans/SCSs. You will also now have more CEQA exemptions to consider for applications to infill and TOD projects. And you’ll need to ensure that administrative records reflect the rationale for selection and use of these exemptions in a legally defensible manner. 

Developers: This change will likely smooth the way for developers to plan and construct infill and TOD projects using the new CEQA exemptions. Developers might want to incorporate new or enhanced transit facilities or features that lower vehicle miles traveled into project designs to qualify for the new exemptions and/or to avoid transportation impact fees.

Here are some of the specific tasks to consider when you transition to the new regulations:

  • Develop new or revise existing policies and standards for lead agencies to transition from use of LOS to VMT.
  • Develop revised transportation development impact fee structures utilizing the VMT metric.
  • Develop CEQA thresholds of significance for transportation impacts using the VMT metric, incorporating the use of environmental standards, and remaining consistent with GHG targets.
  • Evaluate cumulative impacts under the new rules.
  • Update your General Plan and a lead agency’s procedures for implementing new requirements in response to changes in CEQA.
  • Standardize procedures for assembling the required legally defensible documentation, and identify standards to support the appropriate application of CEQA Exemptions for infill and TOD.
  • Train staff and provide outreach and engagement for the community and/or decision-makers regarding the proposed changes.
  • Consult with public transit agencies, which is now required for projects within ½ mile of public transit facilities.

“With these CEQA changes, we can make better places with more choices for people and reduce their impact on the natural environment,” Gibbs concludes.

As experts in CEQA compliance, General Plans and Specific Plans, and leaders in the planning and design of infill development, TOD and Complete Streets projects, MIG is the go-to firm for helping agencies and the development community understand, navigate and take advantage of the new CEQA Guidelines. View some MIG case studies:


Michelle Gibbs is an expert in CEQA/NEPA documentation and permitting, with extensive experience in combining natural resources management with TOD, mixed-use and infill development to provide affordable housing, enhance recreational opportunities, and protect our open spaces, rivers and streams, sensitive resources, and scenic beauty.