HomeMy WebLinkAboutD-3 Staff Report - SB 743 VMT AdoptionPUBLIC HEARING/SCHEDULED ITEM
D-3
TO: HONORABLE MAYOR AND MEMBERS OF THE CITY COUNCIL
VIA: SERGIO GONZALEZ, CITY MANAGER
FROM: MATT MARQUEZ, ECONOMIC AND COMMUNITY DEVELOPMENT
DIRECTOR
DATE: JUNE 15, 2020
SUBJECT: PUBLIC HEARING - RESOLUTION OF THE CITY COUNCIL FINDING THAT
THE ACTION IS NOT A PROJECT SUBJECT TO CEQA AND ADOPTING THE
PROPOSED VEHICLE MILES TRAVELLED THRESHOLDS OF SIGNIFICANCE.
BACKGROUND:
Changes in state law encourage the City to adopt new CEQA thresholds of significance for
transportation impacts of land use projects. For the purposes of CEQA these changes will modify how
the City evaluates land use and transportation projects for transportation impacts. Specifically, the City
is required to use Vehicle Miles Travelled (VMT) instead of Level of Service (LOS) as the metric to
evaluate transportation impacts of land use and transportation projects in CEQA documents, such as
Environmental Impact Reports. Outside of the CEQA process, the City can choose to continue to
evaluate projects using the LOS metric under the City’s General Plan and in accordance with the City’s
general police power. Based on guidance provided through an implementation process led by the San
Gabriel Council of Governments, new CEQA transportation impact thresholds have been prepared for
consideration by the City Council. This report summarizes the State mandate that requires the shift from
LOS to VMT, encourages local governments to adopt local CEQA thresholds, discusses the City staff
recommendations, and includes a Resolution to adopt the new CEQA transportation thresholds.
On September 27, 2013, Governor Jerry Brown signed SB 743 into law and started a process intended
to fundamentally change how transportation impact analysis is conducted as part of the CEQA review
of land use and transportation projects. SB 743 eliminates LOS as the basis for determining
transportation impacts under CEQA and requires the use of VMT instead. The State is shifting the
focus of CEQA traffic analysis from measuring a project’s impact on automobile delay (LOS) to
measuring the amount and distance of automobile travel that is attributable to a project (VMT). The
State’s goal in changing the metric used to determine significant transportation impacts is to encourage
land use and transportation decisions that reduce greenhouse gas emissions, encourage infill
development, and improve public health through active transportation.
APPROVED
CITY COUNCIL
6/15/2020
Thresholds of Significance – Vehicle Miles Traveled
June 15, 2020
Page 2 of 5
RECOMMENDATION:
Staff recommends that the City Council take the following actions:
1) Open the Public Hearing, receive public testimony, close the public hearing; and 2)Adopt Resolution No. 2020-C29 recommending that the City Council find that the action is
exempt from the California Environmental Quality Act (CEQA) and adopt the proposed
thresholds of significance.
ANALYSIS:
CEQA and Thresholds of Significance
CEQA requires jurisdictions to review the impact a project would have on the existing environment, to
disclose those impacts to the public and decision makers, and to reduce those impacts to the maximum
extent feasible through mitigation, project alternatives, and conditions of approval. CEQA establishes
four categories of environmental impacts:
1. No impact
2. Less than significant impact
3. Less than significant impact with the adoption of mitigation measures (a way of reducing an
impact’s effect)
4. Significant unavoidable impacts
A threshold of significance is the point at which an impact moves from less than significant to
significant. CEQA defines a significant impact as “a substantial, or potentially substantial, adverse
change in the environment.” To determine what that means for the 18 areas studied in a CEQA
document, an agency may adopt defined thresholds of significance. In relation to traffic, the City, for
many years, has used LOS to determine if a project would create a significant impact.
Traffic Analysis & Level of Service
Under the LOS methodology, the focus of most of the traffic analysis is on a project’s impact on
intersections and roadway segments near the land use or transportation project site. This analysis
compares how the existing intersection or roadway segment functions in comparison to how it will
function when the project is complete. At the heart of this analysis is how an intersection or street
segment should function. To analyze this, engineers look at the intersections’ and roadway segments’
level of service (LOS). LOS, in its simplest form, is a ratio of an intersection’s or roadway segment’s
volume to its capacity. If the volume of traffic exceeds the intersection’s capacity, one would expect to
find traffic delays. If the capacity exceeds volume, one expects to find an absence of congestion. LOS
does not take into consideration traffic signal timing, so while an intersection’s volume to capacity ratio
could demonstrate significant capacity, the timing of the intersection could result in congestion.
Existing Thresholds of Significance
The City’s existing thresholds of significance rely on LOS and are adjusted to the unique character of the
City and the street’s context within the network. The existing thresholds develop a more sensitive
approach to traffic planning so that streets with different purposes, functions, and in different
neighborhoods have different thresholds. Staff still believes that this approach is valid. While it cannot
be used for CEQA anymore, the City can continue to use these thresholds outside of CEQA. Further,
Thresholds of Significance – Vehicle Miles Traveled
June 15, 2020
Page 3 of 5
because LOS thresholds are part of the City’s existing General Plan, the City can continue to examine
LOS in the land use context, and can require that improvements be installed if a project would degrade
LOS to a level that is unacceptable. Therefore, staff is recommending that these thresholds be adopted
as an official policy by the City Council.
The Movement Toward VMT
The move away from LOS and toward VMT is related to a movement that started in Portland, Oregon in
1971 and slowly was recognized by the U.S. Department of Transportation in 2010. This movement,
called Complete Streets, was championed by a coalition of organizations including the Association of
American Retired Persons, professional organizations overseeing the design of streets (including the
American Planning Association, the American Society of Landscape Architects, and Institute of
Transportation Engineers), and the National Association of Realtors. A complete street is a street
planned, operated, and maintained to enable safe, convenient, comfortable travel for users of all ages and
abilities regardless of whether the user is using a wheelchair, walking, bicycling, driving, or riding on
public transit.
In September of 2013, the California State Legislature adopted Senate Bill (SB) 743. This law set the
State down a course of measuring a project’s environmental impact not by its creation of congestion, but
by whether and how much it increases total VMT. VMT is the number of miles all vehicles travel, and it
is the State’s goal to reduce VMT and thereby reduce air pollution and greenhouse gas emissions.
The legislation was spurred by occasions where the CEQA analysis concluded that a project would have
a negative effect on the environment even though the purpose of the project was to improve the
environment. In a notable case, the City of San Francisco wanted to replace a traffic lane with a bicycle
lane. This project would be expected to have a positive effect on the environment because it would
reduce pollution and greenhouse gas emissions. However, because the change would result in additional
automobile congestion, opponents to the bicycle lane argued that there would be a significant
environmental effect.
While SB 743 changes the focus of traffic analysis to reducing VMT, it also does not prohibit cities from
using LOS standards for infrastructure or General Plan planning purposes. SB 743 reorients CEQA
away from traffic congestion and toward the negative environmental effects of automobile trips (air
pollution and greenhouse gas emissions) thus refocusing CEQA on the environment.
VMT Discussion Points
While State law now requires cities to use VMT methodology, the City retains discretion to develop a
VMT threshold of significance that is tailored to the City, should the City decide to adopt a local
threshold of significance. The bullets below highlight these points and provide staff’s
recommendation.
Screening Out Certain Types of Projects:
• Screening Out Projects – The State allows cities to filter or “screen out” local serving projects
so that they do not have to prepare a traffic study to look at VMT impacts. The idea behind
this is that since the land use project will serve the local population, the project is likely
reducing the need for people to drive further away and thus are reducing VMT. City staff is
recommending adopting a list of local service projects that is consistent with the State’s Office
Thresholds of Significance – Vehicle Miles Traveled
June 15, 2020
Page 4 of 5
of Planning and Research’s (OPR) guidance, plus a few additions. This list includes new retail
buildings up to 50,000 square feet in floor area, parks, public K-12 schools, day care centers,
churches, public parking, hospitality uses/hotels, medical uses, and the like. The list also
includes projects generating less than 110 daily trips; this includes 11 single-family units, 16
multi-family units, 10,000 square feet of office space, and 15,000 square feet of industrial
space. For a full list of projects that could potentially be screened from VMT analysis, see
Exhibit B of the attached Resolution. The City can adopt a lower number of daily trips or
projects of a small size; but higher thresholds must be supported by substantial evidence.
• Screening Out Projects in Low VMT Areas – The State allows cities to filter out regions of the
City that are already considered “low VMT” traffic analysis zones (TAZs). The rationale here
is that the area likely already has a good mix of uses and adding additional uses in this area
provides for less trips and bundling of trips. Staff is recommending to be consistent with OPR
guidance to screen out residential and office projects located in low VMT areas. Low VMT is
defined as 15 percent below the Baseline VMT metrics.
• Screening Out Projects in Transit Priority Areas (TPA) - The City staff recommendation is to
be consistent with OPR guidance to screen out projects in Transit Priority Areas, which are
defined as an area within ½-mile of a major transit stop that is existing or planned, if the
planned stop is scheduled to be completed within the planning horizon year. Per section 21099
of the Public Resource Code, a major transit stop is defined as a site containing an existing rail
transit station or the intersection of two or more major bus routes with a frequency of service
interval of 15 minutes or less during the morning and afternoon peak commute periods.
• Screening Out Affordable Housing – The City staff recommendation is to be consistent with
OPR guidance to screen out affordable housing developments or affordable housing units
within mixed-use developments pursuant to Sections 15183.3 and 15332 of Title 14 of the
California Code of Regulations.
Conducting the VMT Analysis
• Setting a Baseline VMT - The Baseline VMT is defined as the average VMT for the area
represented by SGVCOG Subarea as measured by VMT per capita, VMT per employee, or
VMT per service population. A project’s VMT will be compared to the baseline VMT when
determining potential significant impacts. The City can choose different baselines including
the City’s existing VMT, a subarea of the SGVCOG, the SGVCOG or the SCAG region. Staff
recommends choosing the SGVCOG Subarea as the baseline. This City selected a baseline that
is characteristic of its location in the SCAG region
• When a VMT Impact Becomes Significant (Land Use Plans) – The City staff recommendation
is to be consistent with OPR guidance and set a threshold such that significant impacts will
occur if the VMT per service population for the land use plan exceeds 15 percent below the
baseline VMT.
Thresholds of Significance – Vehicle Miles Traveled
June 15, 2020
Page 5 of 5
• When a VMT Impact Becomes Significant (Land Use Projects) – Significant impacts will occur
if a land use project generates VMT (per capita, per employee, or per service population)
higher than 15 percent below the baseline VMT.
• When a VMT Impact Becomes Significant (Transportation Projects) – Significant impacts will
occur if the projects result in a net increase in VMT.
ENVIRONMENTAL REVIEW
The VMT Thresholds are not a project within the meaning of Public Resources Code, section 21065 and
State CEQA Guidelines, section 15378. The VMT Thresholds would not lead to a direct or a reasonably
foreseeable indirect change in the physical environment. The VMT Thresholds are an administrative
activity of the City. Specifically, the VMT Thresholds provide guidance to property owners, project
developers, applicants, and proponents for determining the significance of transportation impacts of land
use projects under CEQA. The VMT Thresholds do not approve any specific development and would
not lead to any particular physical change to the environment. Thus, the VMT Thresholds are not a
project under Public Resources Code, section 21065 and State CEQA Guidelines, section 15378 (b)(5).
For these reasons, the VMT Thresholds are not subject to further environmental review under CEQA.
FISCAL IMPACT
There would be no fiscal impact related to this item.
Prepared by: Reviewed by:
Matt Marquez Marco Martinez
Economic and Community Development Director City Attorney
Fiscal Reviewed by: Reviewed and Approved by:
Talika M. Johnson Sergio Gonzalez
Director of Administrative Services City Manager
Attachments:
1.Resolution No. 2020-C29
2.Resolution Exhibits
a.Exhibit A –VMT Baselines and Thresholds of Significance
b.Exhibit B – Screening Out Projects by Type
3.VMT Impact Analysis Methodologies Assessment
Page 1 of 3
RESOLUTION NO. 2020-C29
A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF
AZUSA ADOPTING “VEHICLE MILES TRAVELED”
THRESHOLDS OF SIGNIFICANCE FOR PURPOSES OF
ANALYZING TRANSPORTATION IMPACTS UNDER THE
CALIFORNIA ENVIRONMENTAL QUALITY ACT AND
FINDING THE SAME NOT A PROJECT SUBJECT TO THE ACT
WHEREAS, the California Environmental Quality Act Guidelines (“CEQA
Guidelines”) encourage public agencies to develop and publish generally applicable
“thresholds of significance” to be used in determining the significance of a project’s
environmental effects; and
WHEREAS, CEQA Guidelines section 15064.7(a) defines a threshold of significance
as “an identifiable quantitative, qualitative or performance level of a particular environmental
effect, noncompliance with which means the effect will normally be determined to be
significant by the agency and compliance with which means the effect normally will be
determined to be less than significant”; and
WHEREAS, CEQA Guidelines section 15064.7(b) requires that thresholds of
significance must be adopted by ordinance, resolution, rule, or regulations, developed
through a public review process, and be supported by substantial evidence; and
WHEREAS, pursuant to CEQA Guidelines section 15064.7(c), when adopting
thresholds of significance, a public agency may consider thresholds of significance adopted
or recommended by other public agencies provided that the decision of the agency is
supported by substantial evidence; and
WHEREAS, Senate Bill 743, enacted in 2013 and codified in Public Resources Code
section 21099, required changes to the CEQA Guidelines regarding the criteria for
determining the significance of transportation impacts of projects; and
WHEREAS, in 2018, the Governor’s Office of Planning and Research (“OPR”)
proposed, and the California Natural Resources Agency certified and adopted, new CEQA
Guidelines section 15064.3 that identifies vehicle miles traveled (“VMT”) – meaning the
amount and distance of automobile travel attributable to a project – as the most appropriate
metric to evaluate a project’s transportation impacts; and
WHEREAS, as a result, automobile delay, as measured by “level of service” and
other similar metrics, generally no longer constitutes a significant environmental effect under
CEQA; and
WHEREAS, the City’s project review process will retain “level of service” analysis
to ensure consistency with the General Plan and compliance with the City programs;
Attachment 1
Page 2 of 3
WHEREAS, CEQA Guidelines section 15064.3 goes into effect on July 1, 2020,
though public agencies may elect to be governed by this section immediately; and
WHEREAS, the City of Azusa, following a public hearing process, wishes to adopt
VMT Thresholds of Significance (“VMT Thresholds”) that would apply to projects in the
City of Azusa that are subject to CEQA; and
WHEREAS, the VMT Thresholds of Significance are supported by substantial
evidence set forth in the record of proceedings for the item, including but not limited to the
June 15, 2020, City Council staff report and technical memoranda in support of the VMT
Thresholds.
NOW, THEREFORE, BE IT RESOLVED by the City Council of the City of
Azusa as follows:
Section 1. In its capacity as lead agency, the City Council has evaluated the
proposed VMT Thresholds to determine whether the VMT Thresholds are subject to
environmental review under Public Resources Code, section 21000 et seq.: “CEQA”. The
City Council for the City of Azusa hereby finds and determines that the VMT Thresholds are
not a project within the meaning of Public Resources Code, section 21065 and State CEQA
Guidelines, section 15378. The VMT Thresholds would not lead to a direct or a reasonably
foreseeable indirect change in the physical environment. The VMT Thresholds are an
administrative activity of the City. Specifically, the VMT Thresholds provide guidance to
property owners, project developers, applicants, and proponents for determining the
significance of transportation impacts of a project under CEQA. The VMT Thresholds do
not approve any specific development and would not lead to any particular physical change
to the environment. Thus, the VMT Thresholds are not a project under Public Resources
Code, section 21065 and State CEQA Guidelines, section 15378(b)(5). For these reasons,
the VMT Thresholds are not subject to further environmental review under CEQA.
Section 2. Based upon substantial evidence set forth in the record of proceedings,
including but not limited to the June 15, 2020, City Council Staff Report on the VMT
Thresholds, as well as the technical memoranda prepared in support of the City of Azusa’s
VMT Thresholds, the City Council hereby adopts the VMT thresholds of significance
attached as Exhibit A and the list of screening out projects attached as Exhibit B.
Section 3. This Resolution shall take effect immediately upon its adoption by the
City Council, and the Clerk of the Council shall attest to and certify the vote adopting this
Resolution.
Section 4. The documents and materials that constitute the record of proceedings
on which these findings are based are located at City Hall for the City of Azusa, located at
213 E. Foothill Blvd., Azusa, California, 91702. The City Clerk is the custodian of the
record of proceedings.
Page 3 of 3
Section 5. Staff is directed to file a Notice of Exemption with the County of Los
Angeles within five (5) working days of approval of the VMT Thresholds.
PASSED, APPROVED and ADOPTED this 15th day of June, 2020.
Robert Gonzales
Mayor
ATTEST:
Jeffrey Lawrence Cornejo, Jr.
City Clerk
STATE OF CALIFORNIA )
COUNTY OF LOS ANGELES )ss.
CITY OF AZUSA )
I HEREBY CERTIFY that the foregoing Resolution No. 2020-C27 was duly
adopted by the City Council of the City of Azusa at a regular meeting thereof, held on the
15th day of June 2020, by the following vote of the Council:
AYES: COUNCILMEMBERS:
NOES: COUNCILMEMBERS:
ABSENT: COUNCILMEMBERS:
Jeffrey Lawrence Cornejo, Jr.
City Clerk
APPROVED AS TO FORM:
Best Best & Krieger, LLP
City Attorney
EXHIBIT A
City of AZUSA VMT Baselines and Thresholds of Significance
Consistent with State CEQA guidelines section 15064.3, the City of Azusa has adopted the
project baselines and thresholds of significance set forth in Table 1 below to guide in
determining when a project will have a significant transportation impact.
Table 1
Project Type Thresholds
Land Use Plan 1)Project Impact: A significant impact would occur if
the VMT rate for the plan would exceed 15 percent
below the applicable baseline VMT rate.
2) Cumulative Project Effect: A significant impact
would occur if the project increases total regional
VMT compared to cumulative no project conditions.
Land Use Project 1)Project Impact: A significant impact would occur if
the VMT rate for the project would exceed 15
percent below the applicable baseline VMT rate.
2) Cumulative Project Effect:
A significant impact would occur if the project
increases total regional VMT compared to
cumulative no project conditions.
Retail Project (over 50,000
square feet) 1)Project Impact: A significant impact would occur if
the VMT rate for the project would exceed 15
percent below the applicable baseline VMT.
2) Cumulative Project Effect: A significant impact
would occur if the project increases total VMT in the
study area compared to baseline conditions.
Transportation Project A significant impact would occur if the project causes a net
increase in total regional VMT compared to baseline
conditions, opening year no project conditions, or cumulative
no project conditions.
All land use and
transportation projects A significant impact would occur if the project is inconsistent
with the RTP/SCS.
Notes: 1) Baseline VMT rate is defined as the SGVCOG Subarea per applicable service population.
2) Baseline may be changed pending updates to the SCAG RTP model
Attachment 2
EXHIBIT B
City of Azusa - Screening Out Projects By Type
OPR identified local serving project types that may be presumed to have a less than significant
impact absent substantial evidence to the contrary. Local serving retail projects (less than 50,000
square feet) generally improve the convenience of shopping close to home and have the effect of
reducing vehicle travel. Azusa will screen out the following projects.
The following uses are presumed to have a less than significant impact (absent substantial
evidence to the contrary) as their uses are local serving in nature:
• Local serving retail (retail establishments less than 50,000 square feet in size)
• Local-serving K-12 schools
• Local parks
• Day care centers
• Local-serving retail uses less than 50,000 square feet, including:
o Gas stations
o Banks
o Restaurants
o Shopping Center
• Local-serving hotels (e.g. non-destination hotels),
• Student housing projects on or adjacent to a college campus
• Local-serving assembly uses (places of worship, community organizations)
• Community institutions (public libraries, fire stations, local government)
• Affordable, supportive, or transitional housing
• Assisted living facilities
• Senior housing (as defined by HUD)
• Local serving community colleges that are consistent with the assumptions noted in
• the RTP/SCS
• Public Parking*
• Hospitals or similar medical uses
• Projects generating less than 110 daily vehicle trips. This generally corresponds to
the following “typical” development potentials:
o 11singlefamilyhousingunits
o 16 multi-family, condominiums, or townhouse housing units
o 10,000 sq. ft. of office
o 15,000 sq. ft. of light industrial
o 63,000 sq. ft. of warehousing
o 79,000 sq. ft. of high-cube transload and short-term storage warehouse
*Public parking is not included in the Office of Planning & Research list.
TECHNICAL MEMORANDUM
Date: May 4, 2020
To: Participating SGVCOG Member Cities
From: Jolene Hayes, AICP
Subject: SGVCOG SB 743 VMT Impact Analysis Methodologies Assessment
OC20-0715
This technical memorandum presents recommended Senate Bill 743 (SB 743) vehicle miles of travel (VMT)
analysis methodologies for the participating SGVCOG member cities. Methodologies are included for VMT
impact screening and for full impact analysis for projects that do not screen out. Lead agencies have the
discretion to select their own thresholds presuming they provide substantial evidence to support their
selection.
The remainder of this memo is organized as follows.
•Section 1 – Project Screening for Land Use Projects
•Section 2 – VMT Analysis Methodology for Land Use Projects
•Section 3 – VMT Analysis Methodology for Land Use Plans
•Section 4 – VMT Analysis Methodology for Transportation Projects
•Section 5 – Significance Threshold Options
•section 6 – Next Steps
Section 1 – Project Screening for Land Use Projects
Lead agencies may choose to use an impact screening method to streamline land use project review for
VMT impacts. If a project does not pass an initial screening test, a full impact analysis is warranted. The
following describes the available screening criteria pursuant to California Environmental Quality Act (CEQA)
guidance provided by the Office of Planning and Research (OPR).
1. Project Type Screening
OPR identified local serving project types that may be presumed to have a less than significant impact
absent substantial evidence to the contrary. Local serving retail projects (less than 50,000 square feet)
generally improve the convenience of shopping close to home and has the effect of reducing vehicle
travel; therefore, these projects may be screened out if a community opts to adopt this screening criteria.
Attachment 3
Participating SGVCOG Cities May 4, 2020
2 | Page
A community may select a threshold that is less than 50,000 square feet, but it may not adopt a size
higher than 50,000 square feet as a screening criteria.
In addition to local serving retail, the following uses can also be presumed to have a less than significant
impact (absent substantial evidence to the contrary) as their uses are local serving in nature:
• Local-serving K-12 schools
• Local parks
• Day care centers
• Local-serving retail uses less than 50,000 square feet, including:
o Gas stations
o Banks
o Restaurants
o Shopping Center
• Local-serving hotels (e.g. non-destination hotels)
• Student housing projects on or adjacent to a college campus
• Local-serving assembly uses (places of worship, community organizations)
• Community institutions (public libraries, fire stations, local government)
• Affordable, supportive, or transitional housing
• Assisted living facilities
• Senior housing (as defined by HUD)
• Local serving community colleges that are consistent with the assumptions noted in the RTP/SCS
• Projects generating less than 110 daily vehicle trips 1
o This generally corresponds to the following “typical” development potentials:
11 single family housing units
16 multi-family, condominiums, or townhouse housing units
10,000 sq. ft. of office
15,000 sq. ft. of light industrial 2
63,000 sq. ft. of warehousing2
79,000 sq. ft. of high-cube transload and short-term storage warehouse2
1 This threshold ties directly to the OPR technical advisory and notes that CEQA provides a categorical exemption for existing facilities, including additions to existing structures of up to 10,000 square feet, so long as the project is in an
area where public infrastructure is available to allow for maximum planned development and the project is not in an
environmentally sensitive area. (CEQA Guidelines, § 15301, subd. (e)(2).) Typical project types for which trip
generation increases relatively linearly with building footprint (i.e., general office building, single tenant office
building, office park, and business park) generate or attract an additional 110-124 trips per 10,000 square feet.
Therefore, absent substantial evidence otherwise, it is reasonable to conclude that the addition of 110 or fewer trips
could be considered not to lead to a significant impact.
2 Threshold may be higher depending on the tenant and the use of the site. This number was estimated using rates from ITE’s Trip Generation Manual (10th Edition).
Participating SGVCOG Cities May 4, 2020
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o Alternatively, a VMT threshold could be developed based on a ‘dwelling unit equivalent’
measure similar to impact fee programs. OPR estimated that non-residential uses could
generate 110 daily trips based on a maximum project exemption size of 10,000 sq. ft.
Using the California Household Travel Survey (CHTS) trip lengths produces a VMT
equivalent for 10,000 sq. ft. for CA of 836 VMT. The California average household
generates approximately 41.6 VMT per day, which equates to about 20 residential units
using a ‘dwelling unit equivalent.’
2. Transit Priority Area (TPA) Screening
Projects located within a TPA 3 may be presumed to have a less than significant impact absent substantial
evidence to the contrary. Appendix A identifies the TAP’s located within the SGVCOG. This presumption
may not be appropriate if the project:
1. Has a Floor Area Ratio (FAR) of less than 0.75;
2. Includes more parking for use by residents, customers, or employees of the project than required
by the City (if the City requires the project to supply parking);
3. Is inconsistent with the applicable Sustainable Communities Strategy (as determined by the lead
agency, with input from the Metropolitan Planning Organization); or
4. Replaces affordable residential units with a smaller number of moderate- or high-income
residential units.
3. Low VMT Area Screening
Residential and office projects located within a low VMT generating area may be presumed to have a less
than significant impact absent substantial evidence to the contrary. In addition, other employment-related
and mixed-use land use projects may qualify for the use of screening if the project can reasonably be
expected to generate VMT per resident, per worker, or per service population that is similar to the existing
land uses in the low VMT area.
For this screening, the regional Southern California Association of Governments (SCAG) 2016 Regional
Transportation Plan model was used to measure VMT performance for individual jurisdictions and for
individual traffic analysis zones (TAZs). TAZs are geographic polygons similar to Census block groups used
to represent areas of homogenous travel behavior. Total daily VMT per service population (population plus
3 A TPA is defined as a half-mile area around an existing major transit stop or an existing stop along a high-quality transit corridor per the definitions below.
Pub. Resources Code, § 21064.3 - ‘Major transit stop’ means a site containing an existing rail transit station, a ferry
terminal served by either a bus or rail transit service, or the intersection of two or more major bus routes with a
frequency of service interval of 15 minutes or less during the morning and afternoon peak commute periods.
Pub. Resources Code, § 21155 - For purposes of this section, a ‘high-quality transit corridor’ means a corridor with
fixed route bus service with service intervals no longer than 15 minutes during peak commute hours.
Participating SGVCOG Cities May 4, 2020
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employment) was estimated for each TAZ. Those TAZs that perform at or below the jurisdictional (City,
SGVCOG Subarea, SGVCOG, County, or SCAG) average of total VMT per service population under base year
(2012) conditions are considered low VMT areas for purposes of this memo. Individual lead agencies may
choose a different baseline threshold to define their low VMT areas, but this screening criteria should be
consistent with their impact thresholds. This presumption may not be appropriate if the project land uses
would alter the existing built environment in such a way as to increase the rate or length of vehicle trips.
Selection of the final VMT baseline and thresholds will be reflected in screening maps and the screening
tool.
Section 2 – VMT Analysis Methodology for Land Use
Projects
Projects not screened through the steps above should complete VMT analysis and forecasting through
the most current version 4 of the SCAG RTP travel demand model to determine if they have a significant
VMT impact. This analysis should include “project generated VMT” and “project effect on VMT” estimates
for the project TAZ (or TAZs) under the following scenarios:
• Baseline Conditions - This data is available from the SCAG RTP travel demand model. Typically
baseline conditions align with the project’s Notice of Preparation (NOP). Baseline VMT for the
year of the NOP can be interpolated between VMT estimates calculated using the base and future
year models.
• Baseline With Project Conditions – This condition represents the “project generated VMT” and is
determined by adding the project land use either to the project TAZ or a new separate TAZ. A full
model run would be performed and VMT changes would be isolated for the project TAZ and
across the full model network. The model output must include reasonableness checks of the
production and attraction balancing to ensure the project effect is accurately captured. If this
scenario results in a less-than-significant impact, then additional cumulative scenario analysis may
not be required.
• Cumulative No Project Conditions - This data is available from the SCAG RTP travel demand
model.
• Cumulative With Project Conditions – This condition represents the “project effect on VMT” and is
determined by adding the project land use either to the project TAZ or a new separate TAZ. The
addition of project land uses should be accompanied by a reallocation of a similar amount of land
use from other TAZs, especially if the proposed project is significant in size such that it would
change other future developments. Land use projects will generally not change the cumulative
no project control totals for population and employment growth. Instead, they will influence the
land use supply through changes in general plan land use designations and zoning. If project
4 Note – At the time of the publishing of this memorandum, SCAG was preparing to publish a new 2020 RTP/SCS version of the travel demand model. Once finalized, the latest version of the SCAG model available should be
utilized for all forecasting activity.
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land uses are simply added to the cumulative no project scenario, then the analysis should reflect
this limitation in the methodology and acknowledge that the analysis may overestimate the
project’s effect on VMT.
VMT Methods
The SCAG RTP travel demand model provides three methods for calculating VMT. For the Baseline With
Project Conditions the Production/Attraction (PA) Method and Origin/Destination (OD) Method are
considered the most appropriate method for calculating “project generated VMT”. For the Cumulative With
Project Conditions, the Boundary Method is considered the most appropriate method for calculating
“project effect on VMT”.
It is the decision of the lead agency to identify which “project generated VMT” and “project effect on VMT”
method of calculating VMT is to be used for land use projects. Descriptions of each method for calculating
VMT is described in further detail below.
1. Production/Attraction VMT
The Production/Attraction (PA) Method for calculating VMT sums all weekday VMT generated by trips with
at least one trip end in the study area. The PA Method is completed after the fourth (out of five) loops of
assignment in the travel demand model, while trips are still tracked by trip purpose. (Note, the trips at this
stage are person trips that need to be converted to vehicle trips for VMT estimate). Productions are land
use types that generate trips (residences) and attractions are land use that attract trips (employment).
The PA Method allows project VMT to be evaluated based on trip purpose which is consistent with OPR
recommendations in the Technical Advisory. For example, a single-use project, such as an office building,
could be analyzed based only on the commute VMT, or home-based work (HBW), VMT per employee.
However, PA matrices do not include external trips that have one trip end outside of the model boundary
(IX-XI trips), and therefore do not include those trips in the VMT estimates. Because of this, PA VMT
estimates do not include all trips and therefore will be inconsistent with VMT estimates provided in other
chapters of the EIR, such as the Air Quality section for greenhouse gas impact analysis. This approach also
only works for individual uses and is not recommended for mixed-use projects as the internalization
between uses is not captured in the estimates.
2. Origin/Destination VMT
The Origin/Destination (OD) Method for calculating VMT sums all weekday VMT generated by trips with at
least one trip end in the study area. The OD Method is completed after the fifth and final loops of
assignment in the travel demand model. Origins are all vehicle trips that start in a specific traffic analysis
zone, and destinations are all vehicle trips that end in a specific traffic analysis zone.
The OD Method accounts for all trips, including external trips that have one trip end outside of the model
boundary (IX-XI trips), and therefore provides a more complete capture of all travel within the study area;
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however, the SCAG model cannot keep track of trips by trip purposes separately in this format. This
methodology estimates VMT consistent with VMT estimates in Air Quality, Greenhouse Gas, Noise and
Energy sections of an EIR.
3. Boundary Method VMT
The Boundary Method is the sum of all weekday VMT on a roadway network within a designated boundary.5
Boundary Method VMT includes all trips, including those trips that do not begin or end in the designated
boundary. This is the only VMT method that captures the ‘project effect on VMT’, including how projects
may influence VMT generation of nearby zones and cut-through and/or displaced traffic. This is evaluated
in the cumulative year for land use projects.
VMT Metrics
VMT should always be normalized based on the number of residents and employees present in the zone,
City, or regional area for comparative purposes to determine impacts. The following presents the metrics
to normalize VMT. The metrics used in the VMT analysis are dependent upon the method in which the VMT
is calculated. Therefore, there is no direct decision for the lead agency to choose a metric, rather the choice
of the methodology will dictate the metric which is to be used.
Total VMT per service population
Total VMT per service population includes the VMT generated divided by the population and employment
in a given area (TAZ, City, or sub-region). The total VMT per service population can be presented using
either the PA or OD Method. Total VMT per service population would also be presented when calculating
VMT using the Boundary Method.
An important note regarding service population is the calculation includes the employment and population
coded into the travel demand model. This calculation excludes VMT-generating groups such as visitors,
patients, guests and students. Each project should consider if it is appropriate to add VMT-generating
groups to its service population.
Home-based VMT per resident
Home-based VMT per resident includes the VMT generated only by home-based work and home-based
other productions divided by the population in a given area (TAZ, City, or sub-region). This method can
only be calculated from PA VMT and does not include trips with one trip end outside of the model. Zones
without any residential uses will generate zero home-based VMT per resident.
5 OPR recommends against using “arbitrary” boundaries such as City or County lines, however the model-wide results would include all six counties in the model. The addition of a single project in such a large area would be negligible.
The only way to distinguish between no project and plus project results to determine the effect on VMT is to set a
boundary at a scale where the effect on VMT from an individual project can be measured. Therefore, Fehr & Peers
recommends the City or sub-regional level boundary would be an appropriate scale for this methodology.
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Home-based work VMT per worker
Home-based work VMT per worker includes the VMT generated only by home-based work attractions
divided by the number of employees in a given area (TAZ, City, or sub-region). This method can only be
calculated from PA VMT and does not include trips with one trip end outside of the model. Zones with no
commercial uses will generate zero home-based VMT per worker.
Land Use Project VMT Analysis Methodology Summary
The table below summarizes the differences in the available VMT methods for calculating “project generated
VMT”. As “project effect on VMT” is only calculated using the Boundary Method, it was not included in this
summary of differences.
Aspect of VMT Analysis Production/Attraction (PA) Origin/Destination (OD)
Trip Type/Purpose
Can separate VMT by trip purpose, including truck VMT Trip purposes include: Home-based-work (commercial uses) and Home-based (residential uses) OPR recommends isolating VMT by trip purpose
Cannot separate VMT by trip purpose
Trips Outside of Model Boundary Excludes trips that start or end outside the model boundary
Includes trips that start or end outside the model boundary OPR recommends including trips that start or end outside model boundary and avoiding “truncating” trip lengths
Consistency with other EIR Sections VMT in the transportation chapter of the EIR will be inconsistent with VMT presented in other chapters VMT in the transportation chapter of an EIR will be consistent with VMT presented in other chapters
Mitigation Applicability
Certain TDM measures such as telecommuting are only applicable towards reductions in home-based-work VMT. Isolating VMT by trip purpose Is helpful when applying reductions for mitigation measures
Applying a mitigation measure that apply to certain trip purposes will be challenging and require extra calculations
Project Type Most beneficial for single use commercial projects such as office and retail, due to ease in calculation of mitigation reductions Most appropriate metric for mixed use projects
Metric Options
Can be presented as: Total VMT per Service Population Home Based VMT per Resident Home Based Work VMT per Worker
Can be presented as: Total VMT per Service Population
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Section 3 – VMT Analysis Methodology for Land Use
Plans
Land use plans are not subject to screening and require specific VMT analysis. Land use plans should be
tested for significant impacts under cumulative conditions using the same cumulative threshold options (or
lead agency thresholds) as the land use projects. These thresholds require modeling the land use plan
changes in the SCAG model to determine VMT impacts. To capture the project effect on VMT, the same
cumulative year population and employment growth totals should be used model-wide.
Section 4 – VMT Analysis Methodology for
Transportation Projects
Use of VMT as an environmental impact metric for transportation projects is discretionary under the Section
15064.3(b)(2) of the updated CEQA Guidelines.
Source: http://resources.ca.gov/ceqa/docs/2018_CEQA_FINAL_TEXT_122818.pdf
If a lead agency wants to use VMT, it is important that the analysis methodology and the forecasting account
for any induced vehicle travel effects. The SCAG model can be used to perform this analysis, but it should
be tested for induced vehicle travel sensitivity. The analysis should also account for potential increases in
trip generation and changes in long-term land use patterns that may occur due to induced vehicle travel.
These effects are not directly included in the SCAG model, but its inputs and parameters can be modified
to include additional sensitivity, or off-model analysis methods such as the use of research-based elasticities
can be used to measure regional VMT changes associated with changes in lane-miles associated with
proposed projects. The following resources should be consulted for induced vehicle travel recommended
analysis practices.
• OPR Technical Advisory (http://opr.ca.gov/docs/20190122-743_Technical_Advisory.pdf)
• Closing the Induced Vehicle Travel Gap Between Research and Practice, Transportation Research
Record: Journal of the Transportation Research Board, Volume 2653, 2017
(https://trrjournalonline.trb.org/doi/pdf/10.3141/2653-02)
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Using VMT as a transportation project impact metric would allow for a variety of transit, bicycle, and
pedestrian projects to be presumed to have a less than significant impact. Smaller roadway network
modifications such as intersection restriping could also be presumed to have a less than significant impact.
Roadway capacity expansion projects are the types of projects that can increase vehicle travel and VMT by
changing people’s travel behavior including making new vehicle trips and making longer vehicle trips. If a
lead agency treated transportation projects similar to land use projects in the above case studies, then a
potential threshold option would be to consider any increase in baseline (or cumulative no project) total
VMT per service population within the jurisdiction or region as a significant impact.
Section 5 – Significance Threshold Options
Lead agencies have discretion to set their own thresholds of significance. Options for significance
thresholds are presented in the tables below. For project generated VMT, the SGVCOG cities will need to
decide which jurisdictional average to compare to (City, Subarea, SGVCOG, County or SCAG) and which
threshold. These four options allow the cities to distinguish between PA or OD method and would be
applied to both base year and cumulative year conditions.
Project Generated VMT Threshold Options
Threshold Significant Impact Method Scenarios
Option 1 – OPR Guidance 15% Below Existing
A significant impact would occur if the addition of a project to
the base year model causes its corresponding TAZ to generate daily home-based production VMT per resident or daily home-based-work attraction VMT per employee or daily total VMT per service population (VMT per Res/Emp/SP) more than 15 percent below the applicable jurisdictional average under baseline conditions.
PA/OD Base Year Cumulative Year
Option 2 – ARB GHG Goals 14.3%
Below Existing
A significant impact would occur if the addition of a project to
the base year model causes its corresponding TAZ to generate
daily VMT per Res/Emp/SP more than 14.3 percent below the
applicable jurisdictional average under baseline conditions.
PA/OD Base Year
Cumulative Year
Option 3 – Better than General Plan Buildout
A significant impact would occur if the addition of a project to
the base year model causes its corresponding TAZ to generate
daily VMT per Res/Emp/SP more than the applicable
jurisdiction average under General Plan buildout conditions.
PA/OD Base Year Cumulative Year
Option 4 – Better than Existing
A significant impact would occur if the addition of a project to
the base year model causes its corresponding TAZ to generate
daily VMT per Res/Emp/SP above the applicable jurisdictional
average under baseline conditions.
PA/OD Base Year Cumulative Year
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For project effect on VMT, it is typically most appropriate for development projects to utilize the Boundary
method to measure if Citywide VMT/SP increases with the project.
Project Effect on VMT Threshold Options
Threshold Significant Impact Method Scenarios
Increase Citywide
A significant impact would occur if the addition of a project to
the cumulative year model causes an increase to its citywide
daily VMT per SP above the applicable jurisdictional average
without the project under baseline conditions.
Boundary Cumulative Year
Section 6 – Next Steps
The cities should review this memorandum along with Thresholds Assessment memorandum and make
selections regarding which methodology and thresholds options are preferred for CEQA transportation
analysis. A thresholds and methodology decision checklist is provided in Appendix A to help guide the
decision-making process.
Appendix A – VMT Thresholds and
Methodology Decision Checklist
Topic Area Decision Notes
STEP 01Project Screening Criteria: Daily Trip Threshold
Yes – Include
•How many trips per day?
•Instead of trip-based, VMT-based
No – Do not include
OPR recommends a threshold of 110 daily trips for project screening. This is based on the number of trips generated by 10,000 sf of office space. As trips are only one component of VMT, this screening criteria should be carefully considered. Alternatively, a screening threshold based on VMT could be applied.
STEP 02Project Screening Criteria: Land Use Types
Any changes (subtractions or additions) to current list:
•Local serving retail (50 ksf or less)
•K-12 Public School
•Daycare/Childcare/Pre-K
•Affordable housing
•Student Housing
•Community Institutions (Public Library, Firestation, Local Government)
Any land use types that are local serving in your community should be considered for this screening.
List changes here:
STEP 03 Project Generated VMT Methodology: PA or OD
PA – Productions/Attractions
OD – Origin/Destination
Both – PA when single use and OD when mixed use
PA method can isolate trip purpose, but does not account for trips with one trip end outside the model boundary. OD method cannot isolate trip purpose, but does include all trips including those with one trip end outside the model boundary. Both methods can be identified in the TIA guidelines, with the selection of method based on if the project is of a single land use type (PA) or mixed use (OD).
STEP 04 VMT Methodology: Benchmarks
City
SGVCOG
The City must choose the appropriate boundary for a regional benchmark for impacts on project generated VMT and project effect on VMT.
STEP 05 Project Generated VMT Methodology: Threshold Options
OPTION 1 – Rely on the OPR Technical Advisory Thresholds (15% Below Existing)
OPTION 2 – Set Thresholds Consistent with Lead Agency Air Quality, GHG Reduction, and Energy Conservation Goals (14.3% Below Existing)
OPTION 3 – Set Thresholds Consistent with RTP/SCS Future Year VMT Projections by Jurisdiction or Sub-Region (Better than General Plan Buildout)
OPTION 4 – Set Thresholds Based on Baseline VMT Performance (Better than Existing)
STEP 06 Level of Service (LOS)Include – intersection or roadway LOS analysis as part of the City’s TIA Guidelines, although this analysis would not be used to determine CEQA impacts
Do not include any LOS analysis in the City’s TIA Guidelines
SGVCOG Participating CitiesVMT Thresholds and Methodology Decision Checklist
Note:The Project Effect on VMT will use the the Boundary Method by default.
SCAG
SGVCOG Subarea