CC - Item 4A - Establishing the Traffic Threshold of Significance for CA Environmental Quality Act to Vehicle Miles Traveled Rather than Level of ServiceROSEMEAD CITY COUNCIL
STAFF REPORT
TO: THE HONORABLE MAYOR AND CITY COUNCIL
FROM: GLORIA MOLLEDA, CITY MANAGER, M
DATE: JUNE 9, 2020
SUBJECT: ADOPTING RESOLUTION NO. 2020-22 ESTABLISHING THE TRAFFIC
THRESHOLD OF SIGNIFICANCE FOR CALIFORNIA
ENVIRONMENTAL QUALITY ACT (CEQA) TO VEHICLE MILES
TRAVELED (VMT) RATHER THAN LEVEL OF SERVICE (LOS)
SUMMARY
Changes in State law require the City to adopt new CEQA thresholds of significance for
transportation impacts. For the purposes of CEQA these changes will modify how the City
evaluates projects for transportation impacts. Specifically, the City is required to use Vehicle
Miles Traveled (VMT) instead of Level of Service (LOS) as the metric to evaluate transportation
impacts 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. Based on
guidance provided through an implementation process led by the San Gabriel Council of
Governments, City staff has prepared new CEQA transportation impact thresholds for
consideration by the City Council. This report summarizes the State mandate that requires
modifying CEQA thresholds, discusses City staff's recommendations, and includes a draft
Resolution to adopt the new CEQA transportation thresholds.
BACKGROUND
The City approved a Memorandum of Agreement (MOA) with the San Gabriel Valley Council of
Governments (SGVCOG) to participate in the San Gabriel Valley Regional VMT Analysis Model,
along with 25 other cities in the San Gabriel Valley. After receiving requests from a majority of
San Gabriel Valley cities to lead a regional effort to assist cities in complying with these VMT
requirements, the San Gabriel Valley Council of Governments conducted a comprehensive
Request for Proposals (RFP) process. As a result, Fehr and Peers was selected as the most qualified
firm to provide professional consultant services to complete the San Gabriel Valley Regional VMT
Analysis Model. Upon completion of the Model, Staff will utilize it to analyze project -related
VMT to determine whether transportation impacts from proposed developments will constitute a
significant environmental impact under the California Environmental Quality Act (CEQA).
AGENDA ITEM 4.A
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June 9, 2020
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The San Gabriel Valley VMT analyses effort analyzed existing traffic conditions in the region to
arrive at a baseline standard from which to determine significance thresholds for future land use
and transportation projects. It will result in recommendations for establishing methodology,
thresholds, and technical tools and procedures for CEQA analysis and transportation impacts of
land use and transportation projects and plans in local jurisdictions within the San Gabriel Valley.
Changes in State Law
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 projects. SB 743 eliminates Level of Service (LOS) as the basis for determining
transportation impacts under CEQA and requires the use of Vehicle Miles Traveled (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 a
significant transportation impact is to encourage land use and transportation decisions that reduce
greenhouse gas emissions, encourage infill development, and improve public health through active
transportation.
DISCUSSION
CEQA and Thresholds of Significance
CEQA requires jurisdictions to review the impact a project would have on the existing
environment and to disclose those impacts to the public and decision makers and as a result address
those impacts deemed significant. 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 adopts defined thresholds of significance. In relation to traffic, the
City for many years has implemented the use of a Level of Service (LOS) methodology as used
by the County of Los Angeles to determine if a project would create a significant impact.
Traffic Analysis & Level of Service
The focus of most traffic analysis is on a project's impact on nearby intersections and roadway
segments. This analysis compares how the existing intersection or roadway segment functions in
comparison to how it will function when a project is complete. At the heart of this analysis, is
how an intersection or street segment should function. To analyze this, engineers and/or planners
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June 9, 2020
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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.
Existing Thresholds of Significance
The City's existing thresholds of significance rely on LOS criteria. Staff believes that this
approach is still valid for analyzing local impacts to intersections in proximity to proposed projects.
While the LOS analysis cannot be used for CEQA anymore, the City can choose to continue to use
these thresholds outside of CEQA. Therefore, staff is recommending that these thresholds be
adopted as an official policy by the City Council.
The Movement Toward VMT
In September of 2013, the California State Legislature adopted Senate Bill (SB) 743. This law
sent 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 vehicle miles traveled. Vehicle miles
traveled (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. While SB 743 changes the focus of traffic analysis to reducing VMT, it does not
prohibit cities from setting LOS standards in its General Plan for infrastructure 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 adopt VMT thresholds there are still some points on which
the City has some discretion. The bullets below highlight these points and provide staff's
recommendation.
• Screening Out Projects — The State allows cities to filter or "screen out" local serving
projects so that they do not require a traffic study to look at VMT impacts. The idea behind
this is that since they serve the local population, they are likely reducing the need for people
to drive further away and thus are reducing VMT. City staff is recommending adopting a
list of local serving project types that are consistent with the state's Office of Planning and
Research's (OPR) guidance. This list includes new retail buildings that are less than 50,000
square feet in floor area, local parks, K-12 schools, day care centers, churches and such.
The list also includes projects generating less than 110 daily trips, which nominally
translate to projects such as 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 see
Attachment B. The City can adopt a lower number of daily trips or projects of a smaller
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June 9, 2020
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size; but higher thresholds are not allowed.
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 and/or shorter trips and bundling of trips. Staff is
recommending that to be consistent with OPR guidance to screen out residential and office
projects located in low VMT areas. Low VMT is defined as areas of the City where the
VMT falls below the City's adopted threshold of significance (see maps in Attachment Q.
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 be
defined as locations within half -a -mile of a transit stop or station with a minimum of 15 -
minute headways during peak commute hours. Currently there are no TPAs in the City
of Rosemead, but over time as transit service changes or increases, portions of the City
may fall into a TPA.
• 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.
• Setting a Baseline VMT - The Baseline VMT is defined as the average VMT for the area
represented by the San Gabriel Valley Council of Governments (SGVCOG), 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 VMT
rates for the SGVCOG as the baseline VMT.
• When a VMT Impact Becomes Significant (Land Use Plans) — The City staff
recommendation is to be consistent with OPR guidance, significant impacts will occur if
the VMT per service population for a land use plan exceeds 15 percent below the baseline
VMT.
• When a VMT Impact Becomes Significant (Proiects) — The City staff recommendation is
to be consistent with OPR guidance, significant impacts will occur if a 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) — The City staff
recommendation is to be consistent with OPR guidance, significant impacts will occur if
the projects result in a net increase in VMT.
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June 9, 2020
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STAFF RECOMMENDATION
That the City Council adopt the attached Resolution No. 2020-22 and find that the action is exempt
from CEQA and adopt the proposed thresholds of significance.
ENVIRONMENTAL ANALYSIS
The adoption of new local CEQA thresholds of significance for transportation impacts and the
adoption of new Local Transportation Assessment Guidelines will not have a significant
environmental impact and are exempt from CEQA pursuant to Section 15308 of Title 14 of the
California Code of Regulations because the two actions are undertaken by the City for the
protection of the environment. The revised CEQA thresholds will be compliant with State mandate
(SB 743) and will be used in a regulatory process (CEQA process) that involves procedures for
the protection of the environment. Accordingly, the City Council will consider the
recommendation to find the Resolution exempt from the environmental review requirements of
CEQA pursuant to Section 15308 of Title 14 of the California Code of Regulations.
FISCAL IMPACT — None
STRATEGIC PLAN IMPACT
The adoption of the attached resolution 2020-22 falls under the City's "key organizational goals"
of enhancing public safety and quality of life by reducing air pollution and greenhouse gas
emissions as well as Strategy 3: Beautification and Infrastructure.
PUBLIC NOTICE PROCESS
This item has been noticed through the regular agenda notification process, which includes a public
hearing notice published in the newspaper on May 30, 2020, and postings of the notice at five (5)
public locations. Native American Tribes have been noticed in accordance with Senate Bill 18
(Traditional Tribal Cultural Places).
Prepared by: Submitted by:
Jana Robbins, Director of Traffic Engineering
And Planning, Transtech
Christoplier Daste, Director of Public Works
NE
. oLupo, Director of
Community Development
City Council Meeting
June 9, 2020
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ATTACHMENTS
A. Resolution No. 2020-22
B. List of Projects that can be Screened Out based on Type
C. Low VMT Areas including Transit Priority Areas (3 maps)
Additional Resources
Exhibit 1: What is VMT? (Video)
Exhibit 2: FAQ — Evaluating Transportation Impacts in CEQA
Exhibit 3: Summary of Lead Agency Decisions, Options, and Recommendations
Attachment A
Resolution No. 2020-22
RESOLUTION NO. 2020-22
A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF
ROSEMEAD, COUNTY OF LOS ANGELES, STATE OF
CALIFORNIA, ADOPTING "VEHICLE MILES TRAVELED"
THRESHOLDS OF SIGNIFICANCE FOR PURPOSES OF
ANALYZING TRANSPORTATION IMPACTS UNDER THE
CALIFORNIA ENVIRONMENTAL QUALITY 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
RESOLUTION NO. 2020-22
Page 2of3
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 Rosemead, following a public review process consisting of a
staff presentation before the City Council, wishes to adopt the VMT thresholds of significance
for determining the significance of transportation impacts.
SECTION 1. City staff recommends that the City Council find that the adoption of new local
CEQA thresholds of significance for transportation impacts and the adoption of new Local
Transportation Assessment Guidelines will not have a significant environmental impact and
are exempt from the CEQA pursuant to Section 15308 of Title 14 of the California Code of
Regulations because the two actions are undertaken by the City for the protection of the
environment. The revised CEQA thresholds will be compliant with a State mandate (SB 743)
and will be used in a regulatory process (CEQA process) that involves procedures for the
protection of the environment. Accordingly, the City Council will find the Resolution exempt
from the environmental review requirements of CEQA pursuant to Section 15308 of Title 14
of the California Code of Regulations.
SECTION 2. City staff recommends that the City Council adopt the VMT thresholds of
significance as shown in Table 1 on the following page.
SECTION 3. Certification. The City Clerk shall certify to the adoption of this resolution and
hereafter the same shall be in full force and effect.
PASSED, APPROVED, AND ADOPTED this 9tn day of June, 2020.
Sandra Armenta, Mayor
APPROVED AS TO FORM: ATTEST:
Rachel Richman, City Attorney Ericka Hernandez, City Clerk
RESOLUTION NO. 2020-22
Page 3 of 3
VMT Baselines and Thresholds of Significance
Consistent with State CEQA guidelines section 15064.3, the City of Rosemead has
adopted project baselines and thresholds of significance as set forth in Table 1 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 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 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
1) Project Impact: A significant impact would occur if the
50,000 square feet)
VMT rate for the project would exceed 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
A significant impact would occur if the project causes a net
Project
increase in total regional VMT compared to baseline conditions,
opening year no project conditions, or cumulative no project
conditions.
All land use and
A significant impact would occur if the project is inconsistent
transportation
with the RTP/SCS (Regional Transportation Plan/Sustainable
projects
Communities Strategy).
Note: Baseline VMT rate is defined as the rate for SGVCOG, per applicable service
population.
The baseline VMT may be changed pending updates to the SCAG's RTP model.
Attachment B
List of Projects that Can Be Screened Out Based on
Type
List of Projects that Can Be Screened Out
Based on 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 has the effect of reducing vehicle travel. The City of Rosemead 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 (Regional Transportation Plan/Sustainable Communities Strategy)
• Projects generating less than 110 daily vehicle trips. This generally corresponds to
the following "typical" development potentials:
o 11 single family housing units
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 garages and public parking lots
Attachment C
Low VMT Areas including
Transit Priority Areas (3 Maps)
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ADDITIONAL RESOURCES
Exhibit 1: What is VMT?
Please click on the link below to watch a short
video on VMT or copy link to your browser.
hLtps://vout-u.be/UE4TJItVdJ8
ADDITIONAL RESOURCES
Exhibit 2: FAQ —Evaluating Transportation
Impacts in CEQA
FEHRt PEERS
FAQ
Evaluating Transportation Impacts in CEQA
Based on New Guidelines as Directed by SB 743
What was the legislative intent of SB 743 (2013)?
Balance the needs of congestion management with the following statewide goals
a Reduction of greenhouse gas emissions
b Infill development
c Public health through active transportation
Ensure that the environmental impacts of traffic such as noise, air pollution, and safety concerns
continue to be addressed and mitigated through CEQA
What does the new CEQA Section 15064.3 adopted by the state in
December 2018 require?
1 A project's effect on automobile delay (i.e., Level of Service) shall not constitute a significant
environmental impact under CEQA.
2 A lead agency may adopt these provisions immediately, but no later than July 1, 2020.
3 VMT is the "most appropriate" measure of transportation impacts.
4 Other relevant considerations may include effects on transit and non -motorized travel.
5 VMT exceeding an applicable threshold may indicate a significant impact
6 Projects may be presumed to have a less than significant VMT impact if they are located in a transit
priority area (TPA) or would reduce VMT.
7 A lead agency has discretion to choose the most appropriate methodology to evaluate a project's
VMT
8 A lead agency may use models to estimate a project's VMT, and may revise those VMT estimates
based on substantial evidence
9 Any assumptions used to estimate VMT must be documented and explained
What decisions do a local agency need to make to implement these new
guidelines?
1 VMT Metric?
a VMT in absolute terms or
b VMT per capita, VMT per employee, VMT per service population ...
VMT Methodology?
a How to calculate VMT — travel model, spreadsheet tool, other methods
Page 11
FAQ
Evaluating Transportation Impacts in CEQA
Based on New Guidelines as Directed by SB 743
FEHR� PEERS
b Total VMT or partial VMT associated with select vehicle types, land uses, and/or trip
purposes/tours
c Project generated VMT versus project effect on VMT
VMT Impact Significance Threshold?
a Threshold: Level of reduction in VMT below existing conditions?
b Thresholds: (1) Project VMT and (2) Cumulative Impacts (project's effect on VMT)
c Thresholds: (1) Land Use Projects, (2) Land Use Plans, (3) Transportation Projects
d Is the level of VMT reduction compared to regional VMT, citywide VMT, or other baseline?
e For cities and counties, are VMT impacts best addressed at the general plan level given that all
land use decisions only influence land use supply and CEQA Section 15183 provides streamlining
for subsequent projects?
4 VMT Mitigation Options?
a VMT mitigation options for land use projects involve either changing the physical design of
the project (i.e., its density, mix of use, street design, etc.) or requiring trip reduction strategies as
part of a transportation demand management (TDM) program.
i Are cities and counties willing to require stringent TDM programs with annual monitoring and
adjustments if projects do not accomplish required VMT reductions?
ii Should cities and counties instead rely on mitigation programs such as impact fee programs
that are based on a VMT-reduction nexus?
How does the OPR Technical Advisoru recommend implementing CEQA
Section 15o64.3?
If a lead agency uses a travel model as the basis for establishing thresholds, that same model must be
used for subsequent project level VMT analyses.
For land use projects and plans, the Technical Advisory states, "OPR recommends that a per capita or
per employee VMT that is fifteen percent below that of existing development may be a reasonable
threshold" based on substantial evidence related to the state's GHG reduction goals.
a Residential Project Threshold — A proposed project exceeding a level of 15 percent below existing
VMT per capita may indicate a significant transportation impact. Existing VMT per capita may be
measured as regional VMT per capita or dt�/ VMT per capita.
b Office Project Threshold — A proposed project exceeding a level of 15 percent below existing regional
VMT per employee may indicate a significant transportation impact.
c Retail Project Threshold —A net increase in total VMT may indicate a significant transportation
impact.
Page 12
FAQ
Evaluating Transportation Impacts in CEQA
Based on New Guidelines as Directed by SB 743
FEHRt PEERS
d Mixed -Use Projects — Lead agencies can evaluate each component of a mixed-use project
independently and apply the significance threshold for each project type included... Alternatively, a
lead agency may consider only the project's dominant use. In the analysis of each use, a project
should take credit for internal capture.
For transportation projects, the Technical Advisory states:
a Because a roadway expansion project can induce substantial VMT, incorporating quantitative
estimates of induced VMT is critical to calculating both transportation and other impacts of the
projects.
b Transit and active transportation projects generally reduce VMT and therefore are presumed to
cause a less -than -significant impact on transportation.
The Technical Advisory expands Section 15064.3 options for VMT impact screening using the
presumption that certain projects will have less than significant VMT impacts based on location within
a low VMT generating area or by being a locally serving retail project.
Impacts to Transit — lead agencies should consider impacts to transit systems and bicycle and pedestrian
networks. ...a project that blocks access to a transit stop or blocks a transit routes itself may interfere
with transit functions.
Is a lead agency required to follow recommendations in the Technical
Advisory?
The Technical Advisory helps lead agencies think about the variety of implementation questions they
face with respect to shifting to a new VMT metric.
The guidance is not a recipe for SB 743 implementation since lead agencies must still make their own
specific decisions about methodology, thresholds, and mitigation. For cities and counties, these
decisions must be consistent with their general plan, which may not be aligned with state GHG
reduction goals upon which the Technical Advisory is based.
A lead agency has the discretion to choose the most appropriate methodology and thresholds to
evaluate a project's VMT. A lead agency may take into account both its own policy goals and context
in developing a VMT methodology and thresholds.
Page 13
FAQ
Evaluating Transportation Impacts in CEQA
Based on New Guidelines as Directed by SB 743
FEHR/� PEERS
What are the pros and cons of following the Technical Advisory guidance
with respect to CEQA defensibility?
PROS
1 Aligns with state goals for GHG reduction,
infill development, transit, active
transportation, and public health.
2 Requires limited effort to implement.
3 Creates VMT impact screening opportunities
for housing, employment, transit, bicycle,
pedestrian, and minor roadway projects.
4 Includes specific thresholds.
CONS
1 Recommends only reporting partial VMT for
individual land uses, trip purposes/tours, and
vehicle types. This could be interpreted as
presenting an inadequate or incomplete
analysis when compared to the current
practice of reporting total VMT for air quality,
GHG, and energy impact analysis.
2 Includes evidence that a 15 percent reduction
from baseline may not be sufficient to achieve
statewide goals for GHG reduction.
3 Does not consider local general plan role in
setting threshold expectations.
4 Includes inconsistent threshold expectations
based on the same land use and
transportation context.
What other challenges should a lead agency consider?
Direct application of the Technical Advisory results in significant and unavoidable VMT impacts for
projects in jurisdictions with limited transit service and low land use densities even when those
projects are consistent with the local general plan.
Lead agencies have often used transportation demand management (TDM) strategies as mitigation to
reduce VMT. Most TDM strategies are project site and building tenant dependent. Since this
information is typically unknown during the project entitlement and environmental review process, a
lead agency must think about whether it can guarantee TDM mitigation outcomes. This implies that
ongoing monitoring and adjustment of the TDM strategies may be required and that impacts are
likely to remain significant even with mitigation due to the uncertainty associated with building tenant
performance over time.
Caltrans has published a Draft TISG (February 2020) that endorses the OPR Technical Advisory
methodology and thresholds (Page 8). This sets the expectation that local agencies will use the
OPR recommended VMT impact thresholds for all land use plans and projects.
Page 14
ADDITIONAL RESOURCES
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