HomeMy WebLinkAbout05-21-20 Planning Commission AgendaThursday, May 21, 2020
7:00 PM
City of South San Francisco
P.O. Box 711 (City Hall, 400 Grand Avenue)
South San Francisco, CA
TELECONFERENCE MEETING
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Planning Commission
Regular Meeting Agenda
1
May 21, 2020Planning Commission Regular Meeting Agenda
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May 21, 2020Planning Commission Regular Meeting Agenda
Thursday, May 21, 2020, to facilitate inclusion in the meeting record. A maximum of 3 minutes per individual
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May 21, 2020Planning Commission Regular Meeting Agenda
Alan Wong, Chairperson
Michele Evans Vice Chairperson
Norm Faria, Commissioner
JulieAnn Murphy, Commissioner
Alex Tzang, Commissioner
Sam Shihadeh, Commissioner
Robert Bernardo, Commissioner
Sailesh Mehra, Secretary to the Planning Commission
Tony Rozzi, Principal Planner
Billy Gross, Senior Planner
Adena Friedman, Senior Planner
Stephanie Skangos, Associate Planner
Gaspare Annibale, Associate Planner
Michele Clary, Clerk
PLEASE SILENCE CELL PHONES AND PAGERS
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meeting should contact the ADA Coordinator at (650) 877-8505, five working days before the meeting.
In accordance with California Government Code Section 54957.5, any writing or document that is a public
record, relates to an open session agenda item, and is distributed less than 72 hours prior to a regular
meeting will be made available for public inspection in the City Clerk’s Office located at City Hall. If,
however, the document or writing is not distributed until the regular meeting to which it relates, then the
document or writing will be made available to the public at the location of the meeting, as listed on this
agenda. The address of City Hall is 400 Grand Avenue, South San Francisco, California 94080.
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May 21, 2020Planning Commission Regular Meeting Agenda
CALL TO ORDER / PLEDGE OF ALLEGIANCE
ROLL CALL / CHAIR COMMENTS
AGENDA REVIEW
ORAL COMMUNICATIONS
CONSENT CALENDAR
Approval of the regular meeting minutes of April 16, 2020.1.
4-16-2020 - Draft MinutesAttachments:
PUBLIC HEARING
Report regarding a resolution to update the City of South San Francisco’s
transportation impact analysis thresholds, as required by the California Environmental
Quality Act (CEQA), to comply with state-mandated change from level of service
(LOS) to vehicle miles traveled (VMT), pursuant to Senate Bill 743 (2013) and new
2019 CEQA Guidelines. (Chris Espiritu, Senior Planner and Billy Gross, Senior
Planner)
2.
VMT Memo by Fehr & Peers, dated May 11, 2020
CA OPR SB 743 Technical Advisory (December 2018)
Attachments:
Resolution recommending that City Council adopt a resolution to update the City of
South San Francisco’s transportation impact analysis thresholds, as required by the
California Environmental Quality Act (CEQA), to comply with state-mandated change
from level of service (LOS) to vehicle miles traveled (VMT), pursuant to Senate Bill
743 (2013) and new 2019 CEQA Guidelines.
2a.
Exhibit A - SSF VMT ThresholdsAttachments:
ITEMS FROM STAFF
ITEMS FROM THE PUBLIC
ADJOURNMENT
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City of South San Francisco
Legislation Text
P.O. Box 711 (City Hall, 400
Grand Avenue)
South San Francisco, CA
File #:20-333 Agenda Date:5/21/2020
Version:1 Item #:1.
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April 16, 2020 Minutes Page 1 of 5
MINUTES
APRIL 16, 2020
CITY OF SOUTH SAN FRANCISCO
REGULAR PLANNING COMMISSION
CALL TO ORDER / PLEDGE OF ALLEGIANCE TIME: 7:00 P.M.
STAFF PRESENT:
Sailesh Mehra, Planning Manager, Michele Clary, Clerk to the Planning Commission,
Claire Lai, Assistant City Attorney, Tony Rozzi, Principal Planner, Gaspare Annibale,
Associate Planner, and Stephanie Skangos, Associate Planner
AGENDA REVIEW
No changes.
ORAL COMMUNICATIONS
None.
CONSENT CALANDER
1. Approval of the regular meeting minutes of February 20, 2020
2. Approval of the regular meeting minutes of March 5, 2020
MOTION
Commissioner Murphy moved and Commissioner Tzang seconded a motion to approve the Consent
Calendar as amended. The question was called and the motion carried unanimously.
PUBLIC HEARING
3. Report regarding a Conditional Use Permit, Design Review, and Waivers and Modification request
for the Community Civic Campus Park and Recreation Joint Facility design at the northeast corner of
El Camino Real and Chestnut Avenue (APNs 011-326-030, 093-331-070, 093-331-080, 093-330-040,
and 093-312-050) subject to Title 20 of the South San Francisco Municipal Code and determination
that the project is consistent with an adopted Supplemental Environmental Impact Report per
CEQA. (Tony Rozzi, Principal Planner)
ROLL CALL / CHAIR COMMENTS PRESENT: Chair Wong, Vice Chair Evans, Commissioners
Bernardo, Faria, Murphy, Tzang, and Shihadeh
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April 16, 2020 Minutes Page 2 of 5
Chair Wong opened the hearing at 7:09 p.m.
Principal Planner Rozzi presented the staff report.
Ken Litwin and Erin Trompeter, Smith Group, provided a summary of the project; exterior design
including playground concepts, El Camino Real Entrance, and ADA Parking locations; building
renderings; and Council Chambers design.
Commissioner Tzang asked if the wall would be used for seating. Ms. Trompeter discussed the wall
at the front entrance of El Camino Real stating it would not be created for seating. Commissioner
Tzang stated he preferred the option with stairs. Ms. Trompeter stated the stairs were removed in
order to provide one entry for all users for inclusivity. She reminded the Commission that the
parking side would see 90% of the entries and discussed the need for handrails on the ramp.
Commissioner Murphy asked about the façade pattern. Mr. Litwin explained the required
percentage to meet Title 24 energy modeling. Commissioner Murphy asked about parking in the
BART right of way. Principal Planner Rozzi discussed the Code restriction on parking for the
Centennial Trail and indicated the project would not impact the Trail.
Commissioner Shihadeh asked about the atrium between the library and conference center area.
Mr. Litwin discussed efforts to retain an open and transparent look.
Commissioner Faria recalled the lack of funding for the parks. Ms. Trompeter explained the need for
funding and grant applications for the playground.
Chair Wong stated the playground would be built it was just a matter of when funding was
available. Ms. Trompeter explained efforts to determine the desired concept in order to design.
Chair Wong asked the proposed cost. Mr. Litwin discussed efforts to have the park on Day One.
Vice Chair Evans asked if the landscaping was included in the original project. Ms. Trompeter
confirmed that all plantings surrounding the playground were included in the base bid. Vice Chair
Evans asked the distance from the ADA parking in the garage to the Council Chambers. Ms.
Trompeter estimated the distance as 275 feet. Vice Chair Evans asked if the ADA parking on
Antoinette could be increased. Mr. Litwin stated the City had decided on three spaces.
Chair Wong stated he liked the design and asked if the Design Review Board comments had been
incorporated, particularly the green screen. Mr. Litwin discussed the three options of planted wall,
green screen, or metal panel. He stated the City Manager requested the green screen. Chair Wong
agreed with the idea of live plantings.
Chair Wong closed the public hearing at 7:55 p.m.
MOTION
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April 16, 2020 Minutes Page 3 of 5
Commissioner Murphy moved and Commissioner Faria seconded a motion to determine that the
proposed Community Civic Campus Park and Recreation Joint Facility project is consistent with the
adopted 2017 Supplemental Environmental Impact Report under CEQA, and approving a
Conditional Use Permit, Design Review, and Waivers and Modifications request for the project
subject to the Findings of Approval and Conditions of Approval. The question was called and the
motion carried unanimously.
4. Report regarding a request for a Conditional Use Permit to operate a Cannabis Delivery-Only
Operation at 337 Littlefield Avenue in the Mixed industrial (MI) Zoning District in accordance with
Title 20 of the South San Francisco Municipal Code and determination that the project is
categorically exempt from CEQA. (Gaspare Annibale, Associate Planner).
Associate Planner Annibale presented the staff report including history, process, project location,
project proposal, requirements and zoning analysis.
Chair Wong opened the public hearing at 7:58 p.m.
Commissioner Bernardo asked how many employees would be working per shift. Amber Norwood,
applicant, stated there would be 4-6 employees per shift.
Commissioner Murphy thanked the applicant for the thorough information.
Commissioner Shihadeh asked how many cannabis delivery businesses were in and around South
San Francisco. Ms. Norwood discussed the screen grab of unlicensed delivery operations.
Commissioner Shihadeh asked if the businesses were operating illegally. Sgt. Rudis discussed illicit
operators in town and explained the weed maps.
Vice Chair Evans asked if the applicant was a retail operator. Ms. Norwood discussed their
operations throughout California. Vice Chair Evans asked if there was a video recording in addition
to GPS tracker and voice recorder. Sgt. Rudis discussed mandated technologies.
Commissioner Faria asked about State licensing. Christopher Bloom explained the backlog of State
licensing and process.
Chair Wong asked if there would be a six-month review. Planning Manager Mehra discussed the
requirement for an annual permit at which time practices would be reviewed.
Chair Wong closed the hearing at 8:17 p.m.
MOTION
Chair Wong moved and Commissioner Murphy seconded a motion to make findings and determine
the project was exempt under CEQA and to approve the Conditional Use Permit request to operate
a delivery-only cannabis business for a term of five years, expiring in 2025. The question was called
and the motion carried unanimously.
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April 16, 2020 Minutes Page 4 of 5
5. Report regarding a resolution recommending the City Council adopt an ordinance amending Title 20
of the South San Francisco Municipal Code to modify regulations pertaining to Accessory Dwelling
Units and determining that the project is categorically exempt from the California Environmental
Quality Act (CEQA). (Gaspare Annibale, Associate Planner & Stephanie Skangos, Associate Planner)
5a. Resolution recommending that the City Council adopt an ordinance amending Title 20 (Zoning) of
the South San Francisco Municipal Code pertaining to accessory dwelling units.
Chair Wong opened the public hearing at 8:18 p.m.
Commissioner Tzang recused himself and left the meeting.
Associate Planner Skangos presented the staff report including previous South San Francisco Code,
new State Code, and suggested revisions.
Commissioner Murphy asked what the City was proposing beyond the requirements of State
legislation. Associate Planner Skangos explained the City’s proposals based on current State
regulations. Commissioner Murphy asked if ADU applications could be submitted with new
development. Associate Planner Skangos stated they could be submitted together for single family
lots.
Chair Wong closed the hearing at 8:35 p.m.
MOTION
Commissioner Murphy moved and Commissioner Bernardo seconded a motion to adopt a
resolution recommending the City Council adopt an ordinance amending Title 20 of the South San
Francisco Municipal Code to modify regulations pertaining to Accessory Dwelling Units and
determining that the project is categorically exempt from the California Environmental Quality Act
(CEQA). The question was called and the motion carried 6-0, Commission Tzang absent.
Commissioner Tzang returned to the meeting.
ITEMS FROM STAFF
6. Staff to give update on temporary modified hours for Costco on El Camino Real.
Planning Manager Mehra provided an update on Costco’s modified temporary hours and the
condition to notify the residents.
ITEMS FROM THE PUBLIC
None.
ADJOURNMENT
Chair Wong adjourned the Planning Commission meeting at 8:37 p.m.
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April 16, 2020 Minutes Page 5 of 5
Sailesh Mehra Alan Wong, Chairperson
Secretary to the Planning Commission Planning Commission
City of South San Francisco City of South San Francisco
SM/mc
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City of South San Francisco
Legislation Text
P.O. Box 711 (City Hall, 400
Grand Avenue)
South San Francisco, CA
File #:20-311 Agenda Date:5/21/2020
Version:1 Item #:2.
Report regarding a resolution to update the City of South San Francisco’s transportation impact analysis
thresholds,as required by the California Environmental Quality Act (CEQA),to comply with state-mandated
change from level of service (LOS)to vehicle miles traveled (VMT),pursuant to Senate Bill 743 (2013)and
new 2019 CEQA Guidelines.(Chris Espiritu, Senior Planner and Billy Gross, Senior Planner)
RECOMMENDATION
Staff recommends that the Planning Commission adopt a resolution recommending that the City Council
update the City of South San Francisco’s transportation impact analysis thresholds to comply with state-
mandated change from level of service (LOS)to vehicle miles traveled (VMT),pursuant to Senate Bill
743 and new 2019 California Environmental Quality Act (CEQA) Guidelines.
EXECUTIVE SUMMARY
Senate Bill (SB)743 requires changes be made to the method by which agencies analyze transportation impacts
under the California Environmental Quality Act (CEQA).It modifies the environmental review process by
removing automobile delay (as described by Level of Service (LOS))or similar measures of vehicular capacity
or traffic congestion,as a significant impact on the environment pursuant to CEQA.Instead of LOS,SB 743
requires that CEQA assessments completed after July 1,2020 be based on Vehicle Miles Traveled (VMT),a
measure of how much driving is generated by a project,to better align with state greenhouse gas (GHG)
reduction goals.In keeping with SB 743,staff is recommending appropriate VMT thresholds to allow the City
of South San Francisco to transition to the VMT metric to assess environmental impacts.
BACKGROUND
The State of California has adopted several bills over the last decade in an effort to reduce GHG emissions and
the effects of climate change.The transportation sector (including private automobiles)is one of the largest
producers of GHG emissions.Targets for GHG emission reductions have been established and substantial
regulatory efforts are underway to ensure that these reduction targets are met.
Reducing the amount of automobile travel throughout the state is one of the major strategies being put forth to
reduce GHG emissions.In an effort to reduce auto travel,the State is questioning the traditional use of LOS
and congestion-related traffic analysis.Reducing traffic congestion and improving LOS by increasing roadway
capacity promotes or induces additional vehicle trips,thereby increasing the total amount of traffic and
transportation related GHG emissions.Additionally,by prioritizing the movement of automobiles over other
modes of travel through measures such as wider roadways,the use of LOS has also constrained the use of
alternative modes of transportation (e.g.,transit,bicycles,walking)that reduce transportation related GHG
emissions.
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File #:20-311 Agenda Date:5/21/2020
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Adopted in 2013,SB 743 balances the needs of congestion management with statewide goals related to infill
development,promotion of public health through active transportation,and reduction of GHG emissions by
eliminating traffic congestion as a significant impact under CEQA.It requires the Governor’s Office of
Planning and Research (OPR)to amend CEQA Guidelines by developing alternative criteria for determining
the significance of transportation impacts of projects within transit priority areas.These criteria must promote
“the reduction of greenhouse gas emissions,the development of multimodal transportation networks,and a
diversity of land uses”.In particular,the measurements of transportation impacts may include “vehicle miles
traveled,vehicle miles traveled per capita,automobile trip generation rates,or automobile trips generated”.
Once the CEQA Guidelines are amended to include those alternative criteria,auto delay will no longer be
considered a significant impact under CEQA. (Public Resources Code Section 21099(b))
Pursuant to SB 743,OPR adopted new CEQA guidelines in 2018,including the new Guidelines Section
15064.3,specifying that a project’s effect on automobile delay no longer constitutes a metric for determining
significant environmental impact related to transportation,and analysis will now be related to the amount and
distance that a project might cause people to drive,via a new metric,VMT.The metric shift from LOS to VMT
focuses on regional traffic patterns and reducing GHG emissions,rather than vehicle delays on local roadway
networks.Per the revised CEQA Guidelines,all determinations of transportation impacts under CEQA must be
based on VMT analysis after July 1, 2020.
The OPR most recently published a Technical Advisory on Evaluating Transportation Impacts in CEQA in
December 2018 to provide technical guidance and recommendation on assessment of VMT,thresholds of
significance,and mitigation measures.This Technical Advisory provides support for determining the screening
criteria and thresholds of significance based on VMT, and is attached to this report as Attachment 2.
DISCUSSION
Current City Policies related to LOS and CEQA Review of Traffic Impacts
Currently,the City’s General Plan Transportation Element has multiple policies related to LOS and one related
to VMT,but not specifically related to applying VMT as a threshold of significance for purposes of impact
review under CEQA:
Street System
4.2-G-10 Make efficient use of existing transportation facilities and,through the arrangement of
land uses,improved alternate modes,and enhanced integration of various transportation
systems serving South San Francisco, strive to reduce the total vehicle-miles travels.
Traffic Operations and Service Standards
4.2-G-15 Strive to maintain LOS D or better on arterial and collector streets,at all intersections,
and on principal arterials in the CMP during peak hours.
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4.2-G-16 Accept LOS E or F after finding that:
- There is no practical and feasible way to mitigate the lower level of service; and
- The uses resulting in the lower level of service are of clear, overall public benefit.
4.2-G-17 Exempt development within one-quarter mile of a Caltrain or BART station,or a City-
designated ferry terminal, from LOS standards.
Level of Service
4.2-I-17 Design roadway improvements and evaluate development proposals based on LOS
standards.
4.2-I-18 Implement,to the extent feasible,circulation system improvements illustrated in Figures
4-1, 4-2 and 4-3 prior to deterioration in levels of service below the stated standard.
In addition to the Transportation Element,the City’s Climate Action Plan identifies community policies,
programs and projects to reduce GHG emissions and VMT:
Land Use and Transportation Goal LUT1: Reduce Emissions from Transportation
Measure 1.1 Expand active transportation alternatives by providing infrastructure and enhancing
connectivity for bicycle and pedestrian access.
Measure 1.2 Support expansion of public and private transit programs to reduce employee commutes.
Measure 1.3 Integrate higher-density development and mixed-use development near transit facilities
and community facilities,and reduce dependence on autos through smart parking
practices.
While local agencies are required to adopt and utilize a VMT threshold for CEQA transportation analysis by
July 1,2020,they may still retain LOS as a standard for local planning and/or general plan compliance
purposes.LOS analysis could continue to be useful in certain circumstances,such as identifying when an
intersection with stop signs should be replaced with a traffic signal,or to evaluate intersection operations when
access to a site creates a new leg to the intersection.
The City of South San Francisco is currently working on multiple studies/plans that will further coordinate City
policies related to transportation, including the implementation of VMT and LOS requirements.
·2040 General Plan Update, which will set overarching policy goals
·Completed Mobility 20/20 transportation study for East of 101
·Updated East of 101 Specific Plan
·Active SSF Bicycle and Pedestrian Master Plan Update
·Zoning Ordinance Update,including a revised Transportation Demand Management Ordinance,as a
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·Zoning Ordinance Update,including a revised Transportation Demand Management Ordinance,as a
companion to the updated General Plan
·Climate Action Plan Update
·Development of a Citywide Transportation Sub-Area Model
·Revised Citywide Transportation Impact Fee to capture multi-modal projects
At this time,the City cannot eliminate LOS analysis from transportation review unless the General Plan
Transportation Element is amended to remove this analysis requirement,and staff is recommending that any
such changes be incorporated into the larger General Plan Update process.Ultimately,the City will be able to
comprehensively identify and prioritize all types of transportation projects through this larger process.
Therefore,City staff is only recommending that the local impact threshold be amended from LOS to VMT
Screening Thresholds and VMT Thresholds of Significance at this time to comply with the July 1,2020
implementation deadline.Specific mitigations related to VMT impacts will be collected as part of the
aforementioned planning efforts.
As part of the General Plan Update process,the City has contracted with Fehr &Peers as a sub-consultant to
Raimi +Associates to provide transportation analysis.One of the included sub-tasks is to develop a VMT
methodology and thresholds to be applied per new CEQA guidance,which will allow for future preparation of
the General Plan Update EIR documents in accordance with the new VMT requirements.Fehr &Peers has
prepared a “Proposed VMT Threshold and Analysis Methods”memo that is attached to this report (Attachment
1).
The VMT metric measures how many miles South San Francisco residents travel by vehicle (residential VMT),
how many work-based miles employees who work in South San Francisco travel by vehicle (work VMT),or
how many total vehicle miles include an origin and/or destination in South San Francisco (total VMT).As
indicated in “Table 1:Draft Work,Residential and Total VMT,by Location”of the Fehr &Peers Memo,South
San Francisco has a work VMT per employee that is 14 percent higher than the regional average,a residential
VMT per resident that is 27 percent lower that the regional average,and a total VMT per service population
that is 2 percent lower than the regional average.This means that most employment projects attract employees
from the Bay Area region to South San Francisco and will likely have a significant VMT impact.On the other
hand,new residential projects result in fewer miles traveled and will likely have a less than significant impact
for CEQA purposes.
VMT Screening Thresholds
OPR recommends strategies to streamline projects (i.e.,not require further transportation analysis)that are
proposed in locations that have close proximity to transit or in low-VMT areas,or that fit within a size
threshold.If a project meets screening thresholds or falls within the types of transportation projects listed,then
it is presumed VMT impacts would be less than significant for the project and a detailed VMT analysis is not
required. Staff is recommending that the following screening thresholds be set.
Location-Based Screening for VMT
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·Proximity to Transit -Projects within ½mile walkshed of an existing or planned high-quality fixed
route transit corridor (SamTrans ECR or SamTrans 130 routes)or major transit station (SSF BART,San
Bruno BART,SSF Caltrain)should be presumed to have no impact on VMT per CEQA Guidelines
section 15064.3(b)(1).Upcoming changes to the SamTrans bus network and the East of 101 shuttle
services may allow some additional areas to be screened out of VMT analysis in the future.(See Figure
A in Attachment 1)
Ferry terminals only qualify for screening if they are served by high-quality bus service,which is not
the case for the SSF Ferry Terminal under current conditions;however,this could change in the future
with bus service changes.
·Low-VMT Zones.Residential projects located in low-VMT zones (see Figure B in Attachment 1)would
require only a qualitative discussion of VMT to discuss the travel characteristics of the zone that the
project is located within.
VMT Screening on Project Size and Type (per OPR Guidelines)
·Projects attracting fewer than 110 trips per day.
·Local-serving retail at a size less than 50,000 square feet
·100-percent affordable residential developments in infill locations
VMT Impact Thresholds
If a project does not fit within one of the screening thresholds identified above,it would then be required to
provide further VMT analysis to determine if the project will have any impact in relation to transportation.In
its 2018 Guidelines,OPR recommends a reduction in VMT of 15 percent below the regional average.Staff is
recommending that the City of South San Francisco follow OPR’s recommendation at this time,with the ability
to amend this threshold as part of the larger General Plan Update process in the future.Following are
recommended thresholds of significance for specific project types:
·For residential projects,a project would cause substantial additional VMT if it exceeds existing regional
household VMT per capita minus 15 percent.
·For office projects,a project would cause substantial additional VMT if it exceeds the existing regional
VMT per employee minus 15 percent.
·For mixed-use projects,each component of the mixed-use project would be evaluated independently,
per the significance criteria above.
·A land use plan may have a significant impact on VMT if it results in a net increase in total VMT and is
not consistent with the region’s Sustainable Communities Strategy.
·For retail uses,a project may have a significant impact on VMT if it would result in a net increase in
Total VMT.
·For all other land uses,a project may have a significant impact on VMT if it would result in a net
increase in Total VMT.
·For transportation projects,a project would cause substantial additional VMT if the project would result
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·For transportation projects,a project would cause substantial additional VMT if the project would result
in a net increase in VMT.An assessment of total VMT without the project and then with the project
would be made,and the difference in the two assessments is the amount of VMT attributable to the
project.
Practical Impacts of Change to VMT
As discussed,South San Francisco has a work VMT per employee that is higher than the regional average,a
residential VMT per resident that is lower that the regional average,and a total VMT per service population
that is slightly lower than the regional average.This means that most employment projects in South San
Francisco will have a significant VMT impact while many residential projects will likely have a less than
significant impact.The Fehr &Peers memo includes examples of the transportation impact analysis for five
hypothetical projects.
The biggest practical effects and changes to the CEQA process are the ability to screen projects and the type of
mitigation measures that will be required for a proposed project with VMT impacts.Under current CEQA LOS
standards,an employment project that was determined to have a significant impact would be required to
provide typical LOS-related mitigations,such as roadway widening (which is typically infeasible in South San
Francisco), turning lane or traffic queuing improvements, or other roadway infrastructure-related projects.
Under the proposed VMT standards,projects that meet screening criteria would experience a streamlined
transportation analysis.Projects with VMT impacts would be required to consider typical VMT related
mitigations such as offsite bike lanes and trails to improve access to transit stations,pedestrian improvements to
provide a direct path to transit stops/stations,bus and shuttle infrastructure or service improvements,TDM
measures beyond the current requirements,or the provision of on-site housing or amenities such as childcare,
gym equipment and food service to reduce off-site trips.However,full mitigation of VMT impacts for
employment may not be feasible since the City’s VMT per worker is much higher than the regional average.
ENVIRONMENTAL REVIEW
The identification of the proposed VMT regulations is not a “project”pursuant to CEQA as defined in CEQA
Guidelines Section 15378,and is therefore not subject to review pursuant to CEQA Guidelines Section 15060
(c)(3).Separately and independently,the proposal is also exempt pursuant to CEQA Guidelines Section 15061
(b)(3),as it will not result directly or indirectly in significant environmental impacts;and/or Public Resources
Code Section 21080(b)(1),as the proposal is ministerial,because the City is mandated to adopt the proposal.As
such,the new thresholds are categorically exempt pursuant to CEQA Guidelines Section 15308 and none of the
exceptions in Section 15300.2 apply.
CONCLUSION
The mandate for using VMT thresholds for all CEQA analysis beginning July 1,2020 offers the City the ability
to holistically evaluate a project for emissions related impacts.Large employment development that will draw
employees from the entire Bay Area region will be required to include mitigations that support transit use and
on-site amenities;most residential projects will have a less then significant impact under the VMT metric and
cannot be denied for local roadway impacts.Consistent with the report’s discussion and pending adoption
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cannot be denied for local roadway impacts.Consistent with the report’s discussion and pending adoption
timeline, staff recommends that the Planning Commission:
1.Adopt a resolution recommending that the City Council update the City of South San Francisco’s
transportation impact analysis thresholds,as required by the California Environmental Quality Act
(CEQA),to comply with state-mandated change from level of service (LOS)to vehicle miles traveled
(VMT), pursuant to Senate Bill 743 (2013) and new 2019 CEQA Guidelines.
Attachment:
1.VMT Memo by Fehr & Peers, dated May 11, 2020
2.CA OPR SB 743 Technical Advisory (December 2018)
Associated Documents:
1.VMT Resolution (20-312)
a.Exhibit A - City of South San Francisco VMT Thresholds
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Memorandum
Date: May 11, 2020
To: Billy Gross, Tony Rozzi, and Chris Espiritu, City of South San Francisco
From: Taylor McAdam, Daniel Jacobson, and Teresa Whinery, Fehr & Peers
Subject: Proposed VMT Threshold and Analysis Methods
SF19-1040
The following memorandum is meant to summarize the proposed approach for the City of South
San Francisco to assess VMT under CEQA. The contents of the memorandum are as follows:
Table of Contents
SB 743 Essentials .......................................................................................................................................................... 2
What Does SB 743 Change in South San Francisco? ............................................................................ 2
VMT Metric ............................................................................................................................................................ 2
Comparison Geography .................................................................................................................................... 2
VMT Accounting Methodology ..................................................................................................................... 3
VMT Impact Threshold ...................................................................................................................................... 3
Regional VMT Benchmarks ...................................................................................................................................... 4
Part I: Changes to the Development Review Process .................................................................................... 5
Screening ................................................................................................................................................................ 5
Mitigations ............................................................................................................................................................. 7
Part II: Project and Plan Examples ......................................................................................................................... 9
Project 1: 200-Unit Multi-Family Building Downtown .......................................................................... 9
Project 2: 500,000-Square Foot Office Development East of 101 .................................................... 9
Project 3: City-Led Mixed-Use Specific Plan in Lindenville ................................................................. 9
Project 4: New Primary School .................................................................................................................... 10
Project 5: Intersection Expansion on El Camino Real ......................................................................... 10
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SB 743 Essentials
New statewide legislation requires changes to how agencies analyze transportation impacts under
the California Environmental Quality Act (CEQA). Historically, many cities used vehicle Level of
Service (LOS) to analyze the environmental effects of a project on traffic congestion. California
Senate Bill 743 (SB 743) requires CEQA assessment based on vehicle miles traveled, a measure of
how much driving is generated by a project, to better align with state greenhouse gas (GHG)
reduction goals. In short, the new CEQA law changes the focus of transportation impact analysis
in CEQA from measuring impacts to drivers, to measuring the impact of driving.
The California Governor’s Office of Planning and Research (OPR) has issued a Technical Advisory
that includes general guidance for agencies to implement SB 743. Lead agencies have until July 1,
2020 to fully comply. This memorandum outlines the recommendations for VMT impact
thresholds and analysis methods for the City of South San Francisco.
What Does SB 743 Change in South San Francisco?
SB 743 has ramifications for a range of city processes, including but not limited to the General
Plan, CEQA process, the entitlements review process, transportation impact fee programs, and the
TDM Ordinance. VMT thresholds and methods need to be adopted by the City for land use
projects, land use plans, and transportation projects. More detail on changes to the development
review process are outlined below in Part I: Changes to the Development Review Process.
VMT Metric
Different project types will require the use of different VMT metrics, including residential VMT,
work VMT, and total VMT. These metrics measure how many miles South San Francisco residents
travel by vehicle (residential VMT), how many work-based miles employees who work in South
San Francisco travel by vehicle (work VMT), or how many total vehicle miles include an origin
and/or destination in South San Francisco (total VMT). OPR guidance recommends assessing
residential projects using residential VMT and office projects using work VMT. Mixed use or
institutional land use projects are more nuanced and VMT recommendations are outlined below
in Part II: Project & Plan Examples.
In order to compare the plan’s or project’s relative transportation efficiency to the
regional average, OPR recommends presenting VMT as a per capita metric; residential VMT per
resident, work VMT per employee, and total VMT per service population.
Comparison Geography
OPR recommends using a regional geography for office project comparisons and either a regional
or city geography for residential project comparisons. Given South San Francisco’s central location
in the region, we believe that the city geographic area is not robust enough to capture the full
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length of most trips or evaluate the interaction of the project or plan in a regional setting. Fehr &
Peers recommends using the nine-county Bay Area region as the default comparison geography
for VMT assessment. The nine-county Bay Area region will capture the full length of work trips
and would be most consistent with OPR’s guidance. As described in Part II: Project & Plan
Examples, there are a few “local-serving” land uses for which we recommend using San Mateo
County as the comparison geography.
VMT Accounting Methodology
A trip-based model looks at each trip in isolation while tour-based models look at a chain of trips
including multiple stops. Although both can be used to calculate VMT, OPR recommends using a
tour-based VMT accounting method that is based on a chain of trips. The MTC model is the sole
tour-based travel demand model available for South San Francisco. However, the MTC model
lacks the level of local roadway network and land use detail that is necessary for this assessment.
Instead, Fehr & Peers recommends using the C/CAG Regional Model, a trip-based model, plus the
South San Francisco Subarea Model to calculate both regional VMT and local VMT for the plan or
project in question.
VMT Impact Threshold
Different project types require different thresholds. For office, residential, and mixed-use projects,
OPR suggests a reduction in VMT of 15 percent below the regional average. Exceptions to this
recommendation are discussed below in Part II: Project & Plan Examples.
For retail projects and capacity-increasing roadway projects the impact should be based on the
net increase in total VMT. This means that an assessment of total VMT without the project and an
assessment with the project should be made; the difference between the two is the amount of
VMT attributable to the project. Following OPR’s guidance, any transportation project that results
in a net increase in VMT would constitute a significant impact.
VMT Impact Mitigation Options
The available methods of mitigating a VMT impact are to either 1) change the project or 2)
implement physical or programmatic mitigations designed to reduce VMT. South San Francisco’s
current TDM Ordinance does not enforce implementation to the degree necessary for TDM
programs to qualify under the new law. TDM mitigation is described in more detail in Part I:
Changes to the Development Review Process.
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City of South San Francisco May 11, 2020 Page 4 of 12 332 Pine Street | 4th Floor | San Francisco, CA 94104 | (415) 348-0300 | Fax (415) 773-1790 www.fehrandpeers.com Regional VMT Benchmarks Table 1 shows the work, residential, and total VMT for the nine-county Bay Area region and the per capita metric for the respective populations. Equivalent metrics are presented for South San Francisco. As shown, South San Francisco has a work VMT per employee that is 14 percent higher than the regional average, a residential VMT per resident that is 27 percent lower than the regional average, and a total VMT per service population that is two percent lower than the regional average. This means that most employment projects in South San Francisco will have a significant VMT impact while many residential projects will likely have a less than significant impact. Mixed use and other unique land use projects will fall somewhere in between as described below in Part II: Project & Plan Examples. San Mateo County VMT summary statistics are also presented as a point of comparison. South San Francisco exhibits lower work VMT per employee, residential VMT per resident, and total VMT per service population compared with county averages. Table 1: DRAFT Work, Residential and Total VMT, by Location Location Total Work VMT Total Employment Work VMT per Employee Total Residential VMT Total Residential Population Residential VMT per Resident Total VMT Total Population (Emp + Residents) Total VMT per Service Population Bay Area Region 60,757,237 4,285,001 14.2 116,114,466 8,198,636 14.2 345,789,041 12,483,637 27.7 South San Francisco 910,023 56,347 16.2 689,853 67,166 10.3 3,362,564 123513 27.2 Percent Difference +14% -27% -2% San Mateo County 6,860,036 394,228 17.4 9,098,066 742,380 12.3 33,946,470 1,136,608 29.9 Source: C/CAG-VTA Bi-County Transportation Demand Model, 2019; South San Francisco Subarea Model, Fehr & Peers, 2020.22
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Part I: Changes to the Development Review Process
Screening
One of the biggest changes with the implementation of SB 743 is the ability to “screen” or skip
the VMT analysis based on project characteristics associated with lower levels of VMT. Screening
is determined by proximity to transit, existing zone VMT, project size, and project type.
Screening on Project Size and Type
According to OPR, projects attracting fewer than 110 trips per day are presumed to have a less
than significant transportation impact.
The City may also screen “local-serving” uses such as K-12 schools, banks, and parks. The City may
also screen “local-serving” retail at a size less than 50,000 square feet. Because of the unique
nature of local-serving retail and smaller projects, in that they tend to attract trips that would
otherwise go a longer distance, most small projects can be assessed qualitatively and do not
require a quantitative VMT analysis.
Finally, evidence supports a presumption of less than significant impact for a 100 percent
affordable residential development (or the residential component of a mixed-use development) in
infill locations.
Location-Based Screening
Proximity to Transit: CEQA statute explicitly states that projects within ½ mile of an existing or
planned high-quality transit corridor or major transit station should be presumed to have no
impact on VMT. In South San Francisco, major transit stations include the South San Francisco
BART station, South San Francisco Caltrain station, and the San Bruno BART station. The South
San Francisco Ferry Terminal does not qualify due to its lower service levels. High-quality transit
corridor means a corridor with fixed route bus service with service intervals no longer than 15
minutes during peak commute hours. In South San Francisco, this includes existing bus stops
along the SamTrans ECR route (along El Camino Real) and SamTrans 130 route (along parts of
Grand Avenue, Linden Avenue, and Hickey Boulevard).
South San Francisco has a unique circumstance where privately operated transit service may also
meet the screening criteria of a high-quality transit corridor: Genentech’s Glen Park BART shuttle
operates every 12 minutes during peak periods, serving over 1,100 riders per day. The service is
open to the public, and a schedule is posted on the SamTrans website. A key consideration is
whether this shuttle constitutes a “fixed route” service: unlike transit agencies, Genentech does
not publish any planning documents that commit to providing service for a given amount of time;
however, it has operated high service levels on this route for over a decade. One possibility is to
recognize the Glen Park BART shuttle as a high-quality transit route only if 1) a five year
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commitment is made to serving stops at 15 minute or better frequency (similar to a transit
agency’s Short Range Transit Plan); and 2) the service is open to the public with a published map
and schedule.
Upcoming changes to the SamTrans bus network (Reimagine SamTrans) and East of 101 shuttle
services may change the transit screening process. The City should ensure its screening process
reflects the latest service levels.
Fehr & Peers recommends screening based on existing ½-mile walksheds, as shown in Figure A,
unless a project includes new pedestrian connections that would change the walkshed. If a project
qualifies for screening based on existing walksheds, but these walksheds still present a barrier to
pedestrian access, the City may consider adding offsite improvement measures for pedestrian
access during entitlement review.
Low-VMT Zones: OPR’s Technical Advisory presents a method for “map-based” screening, where
projects located in existing low-VMT zones (assessed at the TAZ-level) require only a qualitative
discussion of VMT.
Map-based screening would only apply to residential projects in South San Francisco given that
work VMT is so much higher than the regional average. Attached Figure B shows that residential
low-VMT zones cover all but the most auto-oriented corners of the City.
Infill Best Practice
Location-based screening is only valid if proposed projects comply with planning best practices
for infill development. Disqualifications include a Floor Area Ratio (FAR) of less than 0.75, parking
ratios higher than required by the City, inconsistency with Plan Bay Area, or replacement of
affordable residential units with a smaller number of market-rate units. The City may still consider
requiring physical improvement measures during entitlement review to further support pedestrian
access to transit as described above.
Transportation Project Screening
The City may screen transportation projects based on whether they result in increased or
decreased vehicle capacity on a roadway in the regional Congestion Mitigation Program. Certain
transportation projects may be presumed not to increase vehicle capacity, and therefore not to
contribute to increased VMT. Example projects include installation of bicycle, pedestrian, or transit
facilities, or projects designed to address a local circulation concern. As such, transportation
projects that do not result in an increase in vehicle capacity or are not located on a roadway in the
regional CMP may be discussed qualitatively only.
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Mitigations
Mitigations should exhibit a nexus with the Project’s VMT impact, focusing on physical and
programmatic measures to shift project-related trips to transit and active transportation. The
following types of mitigations may be considered:
• Offsite bike lanes and trails to improve access to transit stations and connect a project
with the City’s existing and planned bike network.
• Offsite sidewalk and crosswalk additions/improvements, bulbouts, median refuges, slip
lane removals, road diets, and other pedestrian improvements to provide a direct path to
transit stops/stations and support mode shift to walking for short trips.
• Offsite bus and shuttle infrastructure or service improvements, such as on-street stops,
transit lanes, queue jumps, transit signal priority, or increased frequency along with access
improvements described above.
• Site plan modifications to improve project connectivity to transit and active
transportation.
• Fully subsidized transit fares and participation in local employer shuttle programs, if not
already included in a project’s TDM program.
• Provision of on-site amenities such as childcare, gym equipment, and food service to
reduce off-site trips.
Recent South San Francisco CEQA studies with VMT impact analyses have approached mitigations
in this manner, emphasizing building out planned citywide improvements that may intersect with
or serve a large share of project-related trips.
Even with such mitigations, it is likely that most VMT impacts for employment projects will be
significant and unavoidable due to the City’s high VMT and lack of available evidence to quantify
reductions below the threshold of significance. Nonetheless, by accepting a significant and
unavoidable impact, it is still incumbent on the City and project sponsor to implement all
reasonable and feasible measure available to partially mitigate the impact.
Citywide Planning Considerations
What about the TDM Ordinance?
The City’s TDM Ordinance functions primarily as a traffic management measure and does not
provide “substantial evidence” to mitigate VMT impacts under CEQA. The TDM Ordinance focuses
on managing drive alone mode share, resulting in performance consistent with countywide
averages.1 VMT is also shaped by vehicle trip generation and vehicle trip lengths, which are not
1In 2017, the TDM Ordinance covered about 19,000 of the City’s 57,000 employees. Drive-alone mode shares
vary by employer, with Genentech having the lowest (59 percent for 12,000 employees) while other
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monitored by the TDM Ordinance. Data collected for the General Plan and recent transportation
impact analyses suggest that South San Francisco employers tend to have average trip generation
rates and above-average vehicle trip lengths, which contribute to above-average VMT. Therefore,
the effects of TDM programs consistent with the TDM Ordinance requirements should already be
reflected in VMT thresholds described in this document.
What about Impact Fees?
SB 743 does not change anything about the Mitigation Fee Act, so there is no inherent legal
contradiction between the City’s existing impact fee programs and the upcoming switchover to
using VMT as a CEQA metric. The City currently has two transportation impact fees funding
general project expenditures – an East of 101 Traffic Impact Fee, which funds projects targeting
intersection LOS, and a Bicycle & Pedestrian Impact Fee, which provides a small funding stream
for pedestrian and bicycle projects.
However, the City may still want to reconsider its approach to impact fees in the context of the
General Plan and citywide planning processes. While projects in the East of 101 Traffic Impact Fee
have acted as a de-facto source for intersection LOS mitigations in EIRs, analysis conducted in the
Mobility 20/20 Study suggests these projects are increasingly ineffective at addressing corridor-
wide transportation issues and often counterproductive in supporting mode shift and VMT goals.
What role does LOS play?
While SB 743 removes vehicle delay from the assessment of environmental concerns, it continues
to allow cities to set standards for local roadways as part of their General Plan and Circulation
Element. Essentially, should the City wish to retain LOS as part of its development review process,
vehicle delay and traffic concerns would be addressed during the entitlements and development
application process rather than as an environmental concern. LOS may also be addressed in an
Impact Fee program as described above.
If the Circulation Element of the General Plan includes an LOS-based standard, the environmental
analysis of the General Plan may find a significant impact to VMT, because such a standard would
likely require roadway capacity improvements that increase total VMT in the City.
A hybrid approach by some cities has been to maintain an LOS policy goal, but to supersede this
goal with a complete streets policy that prioritizes safety and multimodal accessibility over LOS.
The City of South San Francisco’s already has a Complete Streets Policy, but in practice it has
typically been superseded by the LOS policy goal in the past.
office/R&D averaging 73 percent (encompassing 6,00 employees) . The citywide and countywide drive alone
commute mode share is 71 percent, suggesting the TDM Ordinance helps the City match county averages.
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Part II: Project and Plan Examples
This section examines the transportation impact analysis process for five hypothetical projects.
Project 1: 200-Unit Multi-Family Building Downtown
Upon confirming that the proposed project meets infill best practices, the City could use map-
based screening to dismiss VMT impacts. This is because the project would be assessed using
residential VMT per resident and Downtown is in a low residential-VMT zone. VMT would be
discussed qualitatively alongside project impacts on geometric design hazards, emergency vehicle
access, bicycle and pedestrian connectivity, and transit.
Project 2: 500,000-Square Foot Office Development East of 101
Upon confirming that the proposed project falls outside of the high-quality transit screening
buffer, the City would require a quantitative VMT analysis to be performed. The office
development is large enough to necessitate a local model run to assess work VMT per capita. The
model would first be calibrated to existing conditions, at which point the relevant analysis area
would be modified to include the proposed land use. The model would be run for No Project and
Plus Project scenarios, and total VMT for the project site would be divided by the projected
number of employees. If the total is at least 15 percent below the regional average for work-
based VMT per worker, there would be a finding of a less-than-significant impact on VMT;
otherwise, there would be a significant impact to VMT.
Project 3: City-Led Mixed-Use Specific Plan in Lindenville
City-led area plans cannot be screened out of VMT impact analysis. A specific plan would be
analyzed using a local model run to assess total VMT. The difference in VMT would be compared
with and without the project on both a total VMT basis and a per capita VMT basis. Per capita
VMT would be assessed per service population and would be the total VMT for each scenario
divided by the total number of daily employees, residents, and visitors for each scenario.
The specific plan would need to be fully assessed for its effects on VMT. If the plan increases both
total VMT and VMT per service population is more than 15 percent above the regional average, it
would have a significant impact on transportation; otherwise, it will have a less-than-significant
impact on transportation. This plan could also be assessed by looking at each population
separately (i.e., residential VMT per resident, work VMT per employee, other (non-home or work)
VMT per visitor).
If VMT were increased with the specific plan, the sole mitigation would be to change the plan
until the land use changes did not result in a VMT increase. However, once VMT impacts have
been discussed and accepted, future projects within the Plan would be able to proceed without
necessarily requiring an EIR.
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Project 4: New Primary School
OPR guidance states that increasing access to “common goods and services, such as groceries,
schools, and daycare” is a potential measure to reduce VMT. Adding a school or grocery store to
a neighborhood that does not have one, can reduce the trip length for residents in that
neighborhood to access those good and services. OPR only suggests quantitative thresholds for
office, residential, and retail projects; it leaves discretion of these “other” land use types to lead
agencies. The City could choose to identify a list of “local serving” land uses for exemption from
quantitative VMT analysis.
This list should be specific, however, in defining “local serving” for each land use category. Some
grocery stores may serve a more regional purpose (Costco, for example), as may also be the case
for some schools (a private school, for example). The list of local serving uses can be a guide and
evaluated on a project-by-project basis at the City’s discretion. Upon confirming that a project is
local serving, the project can proceed with a qualitative discussion of VMT only. Should there be
concern that a retail, institutional, entertainment, or other use possibly create a regional draw,
VMT should be evaluated quantitatively.
If a project is large enough, its effect on VMT can be evaluated using the South San Francisco
Subarea Model. For smaller projects, VMT per capita can be compared to a County or Regional
average using an off-model comparison. For a private school project, for example, school-based
VMT per student for the project could be compared to the countywide school-based VMT per
student. The intent of this comparison is to prove that the private school is also “local serving”
and that the VMT per student is not any higher than the countywide average. This is different
than the threshold of 15 percent below the regional average because unlike with office trips and
residential trips, local-serving schools or retail are already the best-case scenario. It would be
unreasonable to ask a project to reduce its VMT impact below the best-case scenario.
Project 5: Intersection Expansion on El Camino Real
Transportation projects are assessed using total VMT and not compared on a per capita basis. An
intersection expansion—such as adding a left-turn pocket—would require a qualitative discussion
of VMT, unless it was located on, or would have capacity effects on, a roadway in the CMP (in
South San Francisco this is restricted to El Camino Real or a freeway). Thus a roadway project on
El Camino Real would need to be studied quantitatively by using the South San Francisco Subarea
Model to assess total VMT with and without the additional roadway capacity. If the intersection
expansion resulted in no change in VMT, or a change in VMT less than the margin of error of the
model, there would be no significant impact to transportation. If the change increased VMT, there
would be a significant impact to transportation. If the model shows an increase in VMT, the
primary mitigation would be to change the project.
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ON EVALUATING TRANSPORTATION
IMPACTS IN CEQA
TECHNICAL ADVISORY
December 2018
31
Contents
A. Introduction ...................................................................................................................................... 1
B. Background ....................................................................................................................................... 2
C. Technical Considerations in Assessing Vehicle Miles Traveled ......................................................... 4
1. Recommendations Regarding Methodology ................................................................................ 4
D. General Principles to Guide Consideration of VMT .......................................................................... 7
E. Recommendations Regarding Significance Thresholds .................................................................... 8
1. Screening Thresholds for Land Use Projects ............................................................................... 12
2. Recommended Numeric Thresholds for Residential, Office, and Retail Projects ....................... 15
3. Recommendations Regarding Land Use Plans ............................................................................ 18
4. Other Considerations .................................................................................................................. 19
F. Considering the Effects of Transportation Projects on Vehicle Travel ........................................... 19
1. Recommended Significance Threshold for Transportation Projects .......................................... 22
2. Estimating VMT Impacts from Transportation Projects ............................................................. 23
G. Analyzing Other Impacts Related to Transportation ...................................................................... 25
H. VMT Mitigation and Alternatives .................................................................................................... 26
Appendix 1. Considerations About Which VMT to Count ....................................................................... 29
Appendix 2. Induced Travel: Mechanisms, Research, and Additional Assessment Approaches ............ 32
32
1 | Page
December 2018
A. Introduction
This technical advisory is one in a series of advisories provided by the Governor’s Office of Planning and
Research (OPR) as a service to professional planners, land use officials, and CEQA practitioners. OPR
issues technical assistance on issues that broadly affect the practice of land use planning and the
California Environmental Quality Act (CEQA) (Pub. Resources Code, § 21000 et seq.). (Gov. Code, §
65040, subds. (g), (l), (m).) The purpose of this document is to provide advice and recommendations,
which agencies and other entities may use at their discretion. This document does not alter lead agency
discretion in preparing environmental documents subject to CEQA. This document should not be
construed as legal advice.
Senate Bill 743 (Steinberg, 2013), which was codified in Public Resources Code section 21099, required
changes to the guidelines implementing CEQA (CEQA Guidelines) (Cal. Code Regs., Title 14, Div. 6, Ch. 3,
§ 15000 et seq.) regarding the analysis of transportation impacts. As one appellate court recently
explained: “During the last 10 years, the Legislature has charted a course of long-term sustainability
based on denser infill development, reduced reliance on individual vehicles and improved mass transit,
all with the goal of reducing greenhouse gas emissions. Section 21099 is part of that strategy . . . .”
(Covina Residents for Responsible Development v. City of Covina (2018) 21 Cal.App.5th 712, 729.)
Pursuant to Section 21099, the criteria for determining the significance of transportation impacts must
“promote the reduction of greenhouse gas emissions, the development of multimodal transportation
networks, and a diversity of land uses.” (Id., subd. (b)(1); see generally, adopted CEQA Guidelines, §
15064.3, subd. (b) [Criteria for Analyzing Transportation Impacts].) To that end, in developing the
criteria, OPR has proposed, and the California Natural Resources Agency (Agency) has certified and
adopted, changes to the CEQA Guidelines that identify vehicle miles traveled (VMT) as the most
appropriate metric to evaluate a project’s transportation impacts. With the California Natural Resources
Agency’s certification and adoption of the changes to the CEQA Guidelines, automobile delay, as
measured by “level of service” and other similar metrics, generally no longer constitutes a significant
environmental effect under CEQA. (Pub. Resources Code, § 21099, subd. (b)(3).)
This advisory contains technical recommendations regarding assessment of VMT, thresholds of
significance, and mitigation measures. Again, OPR provides this Technical Advisory as a resource for the
public to use at their discretion. OPR is not enforcing or attempting to enforce any part of the
recommendations contained herein. (Gov. Code, § 65035 [“It is not the intent of the Legislature to vest
in the Office of Planning and Research any direct operating or regulatory powers over land use, public
works, or other state, regional, or local projects or programs.”].)
This December 2018 technical advisory is an update to the advisory it published in April 2018. OPR will
continue to monitor implementation of these new provisions and may update or supplement this
advisory in response to new information and advancements in modeling and methods.
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B. Background
VMT and Greenhouse Gas Emissions Reduction. Senate Bill 32 (Pavley, 2016) requires California to
reduce greenhouse gas (GHG) emissions 40 percent below 1990 levels by 2030, and Executive Order B-
16-12 provides a target of 80 percent below 1990 emissions levels for the transportation sector by 2050.
The transportation sector has three major means of reducing GHG emissions: increasing vehicle
efficiency, reducing fuel carbon content, and reducing the amount of vehicle travel. The California Air
Resources Board (CARB) has provided a path forward for achieving these emissions reductions from the
transportation sector in its 2016 Mobile Source Strategy. CARB determined that it will not be possible to
achieve the State’s 2030 and post-2030 emissions goals without reducing VMT growth. Further, in its
2018 Progress Report on California’s Sustainable Communities and Climate Protection Act, CARB found
that despite the State meeting its 2020 climate goals, “emissions from statewide passenger vehicle
travel per capita [have been] increasing and going in the wrong direction,” and “California cannot meet
its [long-term] climate goals without curbing growth in single-occupancy vehicle activity.”1 CARB also
found that “[w]ith emissions from the transportation sector continuing to rise despite increases in fuel
efficiency and decreases in the carbon content of fuel, California will not achieve the necessary
greenhouse gas emissions reductions to meet mandates for 2030 and beyond without significant
changes to how communities and transportation systems are planned, funded, and built.”2
Thus, to achieve the State’s long-term climate goals, California needs to reduce per capita VMT. This can
occur under CEQA through VMT mitigation. Half of California’s GHG emissions come from the
transportation sector3, therefore, reducing VMT is an effective climate strategy, which can also result in
co-benefits.4 Furthermore, without early VMT mitigation, the state may follow a path that meets GHG
targets in the early years, but finds itself poorly positioned to meet more stringent targets later. For
example, in absence of VMT analysis and mitigation in CEQA, lead agencies might rely upon verifiable
offsets for GHG mitigation, ignoring the longer-term climate change impacts resulting from land use
development and infrastructure investment decisions. As stated in CARB’s 2017 Scoping Plan:
“California’s future climate strategy will require increased focus on integrated land use planning
to support livable, transit-connected communities, and conservation of agricultural and other
lands. Accommodating population and economic growth through travel- and energy-efficient
land use provides GHG-efficient growth, reducing GHGs from both transportation and building
energy use. GHGs can be further reduced at the project level through implementing energy-
efficient construction and travel demand management approaches.”5 (Id. at p. 102.)
1 California Air Resources Board (Nov. 2018) 2018 Progress Report on California’s Sustainable
Communities and Climate Protection Act, pp. 4, 5, available at
https://ww2.arb.ca.gov/sites/default/files/2018-11/Final2018Report_SB150_112618_02_Report.pdf.
2 Id., p. 28.
3 See https://ca50million.ca.gov/transportation/
4 Fang et al. (2017) Cutting Greenhouse Gas Emissions Is Only the Beginning: A Literature Review of the
Co-Benefits of Reducing Vehicle Miles Traveled.
5 California Air Resources Board (Nov. 2017) California’s 2017 Climate Change Scoping Plan, p. 102,
available at https://www.arb.ca.gov/cc/scopingplan/scoping_plan_2017.pdf.
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In light of this, the 2017 Scoping Plan describes and quantifies VMT reductions needed to achieve our
long-term GHG emissions reduction goals, and specifically points to the need for statewide deployment
of the VMT metric in CEQA:
“Employing VMT as the metric of transportation impact statewide will help to ensure GHG
reductions planned under SB 375 will be achieved through on-the-ground development, and will
also play an important role in creating the additional GHG reductions needed beyond SB 375
across the State. Implementation of this change will rely, in part, on local land use decisions to
reduce GHG emissions associated with the transportation sector, both at the project level, and
in long-term plans (including general plans, climate action plans, specific plans, and
transportation plans) and supporting sustainable community strategies developed under SB
375.”6
VMT and Other Impacts to Health and Environment. VMT mitigation also creates substantial benefits
(sometimes characterized as “co-benefits” to GHG reduction) in both in the near-term and the long-
term. Beyond GHG emissions, increases in VMT also impact human health and the natural environment.
Human health is impacted as increases in vehicle travel lead to more vehicle crashes, poorer air quality,
increases in chronic diseases associated with reduced physical activity, and worse mental health.
Increases in vehicle travel also negatively affect other road users, including pedestrians, cyclists, other
motorists, and many transit users. The natural environment is impacted as higher VMT leads to more
collisions with wildlife and fragments habitat. Additionally, development that leads to more vehicle
travel also tends to consume more energy, water, and open space (including farmland and sensitive
habitat). This increase in impermeable surfaces raises the flood risk and pollutant transport into
waterways.7
VMT and Economic Growth. While it was previously believed that VMT growth was a necessary
component of economic growth, data from the past two decades shows that economic growth is
possible without a concomitant increase in VMT. (Figure 1.) Recent research shows that requiring
development projects to mitigate LOS may actually reduce accessibility to destinations and impede
economic growth.8,9
6 Id. at p. 76.
7 Fang et al. (2017) Cutting Greenhouse Gas Emissions Is Only the Beginning: A Literature Review of the
Co-Benefits of Reducing Vehicle Miles Traveled, available at https://ncst.ucdavis.edu/wp-
content/uploads/2017/03/NCST-VMT-Co-Benefits-White-Paper_Fang_March-2017.pdf.
8 Haynes et al. (Sept. 2015) Congested Development: A Study of Traffic Delays, Access, and Economic
Activity in Metropolitan Los Angeles, available at http://www.its.ucla.edu/wp-
content/uploads/sites/6/2015/11/Haynes_Congested-Development_1-Oct-2015_final.pdf.
9 Osman et al. (Mar. 2016) Not So Fast: A Study of Traffic Delays, Access, and Economic Activity in the
San Francisco Bay Area, available at http://www.its.ucla.edu/wp-
content/uploads/sites/6/2016/08/Taylor-Not-so-Fast-04-01-2016_final.pdf.
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Figure 1. Kooshian and Winkelman (2011) VMT and Gross Domestic Product (GDP), 1960-2010.
C. Technical Considerations in Assessing Vehicle Miles Traveled
Many practitioners are familiar with accounting for VMT in connection with long-range planning, or as
part of the CEQA analysis of a project’s greenhouse gas emissions or energy impacts. This document
provides technical information on how to assess VMT as part of a transportation impacts analysis under
CEQA. Appendix 1 provides a description of which VMT to count and options on how to count it.
Appendix 2 provides information on induced travel resulting from roadway capacity projects, including
the mechanisms giving rise to induced travel, the research quantifying it, and information on additional
approaches for assessing it.
1. Recommendations Regarding Methodology
Proposed Section 15064.3 explains that a “lead agency may use models to estimate a project’s vehicle
miles traveled . . . .” CEQA generally defers to lead agencies on the choice of methodology to analyze
impacts. (Santa Monica Baykeeper v. City of Malibu (2011) 193 Cal.App.4th 1538, 1546; see Laurel
Heights Improvement Assn. v. Regents of University of California (1988) 47 Cal.3d 376, 409 [“the issue is
not whether the studies are irrefutable or whether they could have been better” … rather, the “relevant
issue is only whether the studies are sufficiently credible to be considered” as part of the lead agency’s
overall evaluation].) This section provides suggestions to lead agencies regarding methodologies to
analyze VMT associated with a project.
Vehicle Types. Proposed Section 15064.3, subdivision (a), states, “For the purposes of this section,
‘vehicle miles traveled’ refers to the amount and distance of automobile travel attributable to a
project.” Here, the term “automobile” refers to on-road passenger vehicles, specifically cars and light
trucks. Heavy-duty truck VMT could be included for modeling convenience and ease of calculation (for
example, where models or data provide combined auto and heavy truck VMT). For an apples-to-apples
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comparison, vehicle types considered should be consistent across project assessment, significance
thresholds, and mitigation.
Residential and Office Projects. Tour- and trip-based approaches10 offer the best methods for assessing
VMT from residential/office projects and for comparing those assessments to VMT thresholds. These
approaches also offer the most straightforward methods for assessing VMT reductions from mitigation
measures for residential/office projects. When available, tour-based assessment is ideal because it
captures travel behavior more comprehensively. But where tour-based tools or data are not available
for all components of an analysis, a trip-based assessment of VMT serves as a reasonable proxy.
Models and methodologies used to calculate thresholds, estimate project VMT, and estimate VMT
reduction due to mitigation should be comparable. For example:
• A tour-based assessment of project VMT should be compared to a tour-based threshold, or a
trip-based assessment to a trip-based VMT threshold.
• Where a travel demand model is used to determine thresholds, the same model should also be
used to provide trip lengths as part of assessing project VMT.
• Where only trip-based estimates of VMT reduction from mitigation are available, a trip-based
threshold should be used, and project VMT should be assessed in a trip-based manner.
When a trip-based method is used to analyze a residential project, the focus can be on home-based
trips. Similarly, when a trip-based method is used to analyze an office project, the focus can be on
home-based work trips.
When tour-based models are used to analyze an office project, either employee work tour VMT or VMT
from all employee tours may be attributed to the project. This is because workplace location influences
overall travel. For consistency, the significance threshold should be based on the same metric: either
employee work tour VMT or VMT from all employee tours.
For office projects that feature a customer component, such as a government office that serves the
public, a lead agency can analyze the customer VMT component of the project using the methodology
for retail development (see below).
Retail Projects. Generally, lead agencies should analyze the effects of a retail project by assessing the
change in total VMT11 because retail projects typically re-route travel from other retail destinations. A
retail project might lead to increases or decreases in VMT, depending on previously existing retail travel
patterns.
10 See Appendix 1, Considerations About Which VMT to Count, for a description of these approaches.
11 See Appendix 1, Considerations About Which VMT to Count, “Assessing Change in Total VMT” section,
for a description of this approach.
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Considerations for All Projects. Lead agencies should not truncate any VMT analysis because of
jurisdictional or other boundaries, for example, by failing to count the portion of a trip that falls outside
the jurisdiction or by discounting the VMT from a trip that crosses a jurisdictional boundary. CEQA
requires environmental analyses to reflect a “good faith effort at full disclosure.” (CEQA Guidelines, §
15151.) Thus, where methodologies exist that can estimate the full extent of vehicle travel from a
project, the lead agency should apply them to do so. Where those VMT effects will grow over time,
analyses should consider both a project’s short-term and long-term effects on VMT.
Combining land uses for VMT analysis is not recommended. Different land uses generate different
amounts of VMT, so the outcome of such an analysis could depend more on the mix of uses than on
their travel efficiency. As a result, it could be difficult or impossible for a lead agency to connect a
significance threshold with an environmental policy objective (such as a target set by law), inhibiting the
CEQA imperative of identifying a project’s significant impacts and providing mitigation where feasible.
Combining land uses for a VMT analysis could streamline certain mixes of uses in a manner disconnected
from policy objectives or environmental outcomes. Instead, OPR recommends analyzing each use
separately, or simply focusing analysis on the dominant use, and comparing each result to the
appropriate threshold. Recommendations for methods of analysis and thresholds are provided below.
In the analysis of each use, a mixed-use project should take credit for internal capture.
Any project that includes in its geographic bounds a portion of an existing or planned Transit Priority
Area (i.e., the project is within a ½ mile of an existing or planned major transit stop or an existing stop
along a high quality transit corridor) may employ VMT as its primary metric of transportation impact for
the entire project. (See Pub. Resources Code, § 21099, subds. (a)(7), (b)(1).)
Cumulative Impacts. A project’s cumulative impacts are based on an assessment of whether the
“incremental effects of an individual project are considerable when viewed in connection with the
effects of past projects, the effects of other current projects, and the effects of probable future
projects.” (Pub. Resources Code, § 21083, subd. (b)(2); see CEQA Guidelines, § 15064, subd. (h)(1).)
When using an absolute VMT metric, i.e., total VMT (as recommended below for retail and
transportation projects), analyzing the combined impacts for a cumulative impacts analysis may be
appropriate. However, metrics such as VMT per capita or VMT per employee, i.e., metrics framed in
terms of efficiency (as recommended below for use on residential and office projects), cannot be
summed because they employ a denominator. A project that falls below an efficiency-based threshold
that is aligned with long-term environmental goals and relevant plans would have no cumulative impact
distinct from the project impact. Accordingly, a finding of a less-than-significant project impact would
imply a less than significant cumulative impact, and vice versa. This is similar to the analysis typically
conducted for greenhouse gas emissions, air quality impacts, and impacts that utilize plan compliance as
a threshold of significance. (See Center for Biological Diversity v. Department of Fish & Wildlife (2015) 62
Cal.4th 204, 219, 223; CEQA Guidelines, § 15064, subd. (h)(3).)
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D. General Principles to Guide Consideration of VMT
SB 743 directs OPR to establish specific “criteria for determining the significance of transportation
impacts of projects[.]” (Pub. Resources Code, § 21099, subd. (b)(1).) In establishing this criterion, OPR
was guided by the general principles contained within CEQA, the CEQA Guidelines, and applicable case
law.
To assist in the determination of significance, many lead agencies rely on “thresholds of significance.”
The CEQA Guidelines define a “threshold of significance” to mean “an identifiable quantitative,
qualitative12 or performance level of a particular environmental effect, non-compliance 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.” (CEQA Guidelines, §
15064.7, subd. (a) (emphasis added).) Lead agencies have discretion to develop and adopt their own, or
rely on thresholds recommended by other agencies, “provided the decision of the lead agency to adopt
such thresholds is supported by substantial evidence.” (Id. at subd. (c); Save Cuyama Valley v. County of
Santa Barbara (2013) 213 Cal.App.4th 1059, 1068.) Substantial evidence means “enough relevant
information and reasonable inferences from this information that a fair argument can be made to
support a conclusion, even though other conclusions might also be reached.” (Id. at § 15384 (emphasis
added); Protect the Historic Amador Waterways v. Amador Water Agency (2004) 116 Cal.App.4th 1099,
1108-1109.)
Additionally, the analysis leading to the determination of significance need not be perfect. The CEQA
Guidelines describe the standard for adequacy of environmental analyses:
An EIR should be prepared with a sufficient degree of analysis to provide decision makers
with information which enables them to make a decision which intelligently takes
account of environmental consequences. An evaluation of the environmental effects of
a proposed project need not be exhaustive, but the sufficiency of an EIR is to be reviewed
in the light of what is reasonably feasible. Disagreement among experts does not make
an EIR inadequate, but the EIR should summarize the main points of disagreement among
the experts. The courts have looked not for perfection but for adequacy, completeness,
and a good faith effort at full disclosure.
(CEQA Guidelines, § 15151 (emphasis added).)
These general principles guide OPR’s recommendations regarding thresholds of significance for VMT set
forth below.
12 Generally, qualitative analyses should only be conducted when methods do not exist for undertaking a
quantitative analysis.
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E.Recommendations Regarding Significance Thresholds
As noted above, lead agencies have the discretion to set or apply their own thresholds of significance.
(Center for Biological Diversity v. California Dept. of Fish & Wildlife (2015) 62 Cal.4th 204, 218-223 [lead
agency had discretion to use compliance with AB 32’s emissions goals as a significance threshold]; Save
Cuyama Valley v. County of Santa Barbara (2013) 213 Cal.App.4th at p. 1068.) However, Section 21099
of the Public Resources Code states that the criteria for determining the significance of transportation
impacts must promote: (1) reduction of greenhouse gas emissions; (2) development of multimodal
transportation networks; and (3) a diversity of land uses. It further directed OPR to prepare and develop
criteria for determining significance. (Pub. Resources Code, § 21099, subd. (b)(1).) This section provides
OPR’s suggested thresholds, as well as considerations for lead agencies that choose to adopt their own
thresholds.
The VMT metric can support the three statutory goals: “the reduction of greenhouse gas emissions, the
development of multimodal transportation networks, and a diversity of land uses.” (Pub. Resources
Code, § 21099, subd. (b)(1), emphasis added.) However, in order for it to promote and support all three,
lead agencies should select a significance threshold that aligns with state law on all three. State law
concerning the development of multimodal transportation networks and diversity of land uses requires
planning for and prioritizing increases in complete streets and infill development, but does not mandate
a particular depth of implementation that could translate into a particular threshold of significance.
Meanwhile, the State has clear quantitative targets for GHG emissions reduction set forth in law and
based on scientific consensus, and the depth of VMT reduction needed to achieve those targets has
been quantified. Tying VMT thresholds to GHG reduction also supports the two other statutory goals.
Therefore, to ensure adequate analysis of transportation impacts, OPR recommends using quantitative
VMT thresholds linked to GHG reduction targets when methods exist to do so.
Various legislative mandates and state policies establish quantitative greenhouse gas emissions
reduction targets. For example:
•Assembly Bill 32 (2006) requires statewide GHG emissions reductions to 1990 levels by 2020 and
continued reductions beyond 2020.
•Senate Bill 32 (2016) requires at least a 40 percent reduction in GHG emissions from 1990 levels
by 2030.
•Pursuant to Senate Bill 375 (2008), the California Air Resources Board GHG emissions reduction
targets for metropolitan planning organizations (MPOs) to achieve based on land use patterns
and transportation systems specified in Regional Transportation Plans and Sustainable
Community Strategies (RTP/SCS). Current targets for the State’s largest MPOs call for a 19
percent reduction in GHG emissions from cars and light trucks from 2005 emissions levels by
2035.
•Executive Order B-30-15 (2015) sets a GHG emissions reduction target of 40 percent below 1990
levels by 2030.
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• Executive Order S-3-05 (2005) sets a GHG emissions reduction target of 80 percent below 1990
levels by 2050.
• Executive Order B-16-12 (2012) specifies a GHG emissions reduction target of 80 percent below
1990 levels by 2050 specifically for transportation.
• Executive Order B-55-18 (2018) established an additional statewide goal of achieving carbon
neutrality as soon as possible, but no later than 2045, and maintaining net negative emissions
thereafter. It states, “The California Air Resources Board shall work with relevant state agencies
to develop a framework for implementation and accounting that tracks progress toward this
goal.”
• Senate Bill 391 requires the California Transportation Plan to support 80 percent reduction in
GHGs below 1990 levels by 2050.
• The California Air Resources Board Mobile Source Strategy (2016) describes California’s strategy
for containing air pollutant emissions from vehicles, and quantifies VMT growth compatible with
achieving state targets.
• The California Air Resources Board’s 2017 Climate Change Scoping Plan Update: The Strategy for
Achieving California’s 2030 Greenhouse Gas Target describes California’s strategy for containing
GHG emissions from vehicles, and quantifies VMT growth compatible with achieving state
targets.
Considering these various targets, the California Supreme Court observed:
Meeting our statewide reduction goals does not preclude all new development. Rather,
the Scoping Plan … assumes continued growth and depends on increased efficiency and
conservation in land use and transportation from all Californians.
(Center for Biological Diversity v. California Dept. of Fish & Wildlife, supra, 62 Cal.4th at p. 220.) Indeed,
the Court noted that when a lead agency uses consistency with climate goals as a way to determine
significance, particularly for long-term projects, the lead agency must consider the project’s effect on
meeting long-term reduction goals. (Ibid.) And more recently, the Supreme Court stated that “CEQA
requires public agencies . . . to ensure that such analysis stay in step with evolving scientific knowledge
and state regulatory schemes.” (Cleveland National Forest Foundation v. San Diego Assn. of
Governments (2017) 3 Cal.5th 497, 504.)
Meeting the targets described above will require substantial reductions in existing VMT per capita to
curb GHG emissions and other pollutants. But targets for overall GHG emissions reduction do not
translate directly into VMT thresholds for individual projects for many reasons, including:
• Some, but not all, of the emissions reductions needed to achieve those targets could be
accomplished by other measures, including increased vehicle efficiency and decreased fuel
carbon content. The CARB’s First Update to the Climate Change Scoping Plan explains:
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“Achieving California’s long-term criteria pollutant and GHG emissions goals will require four
strategies to be employed: (1) improve vehicle efficiency and develop zero emission
technologies, (2) reduce the carbon content of fuels and provide market support to get these
lower-carbon fuels into the marketplace, (3) plan and build communities to reduce vehicular
GHG emissions and provide more transportation options, and (4) improve the efficiency and
throughput of existing transportation systems.”13 CARB’s 2018 Progress Report on California’s
Sustainable Communities and Climate Protection Act states on page 28 that “California cannot
meet its climate goals without curbing growth in single-occupancy vehicle activity.” In other
words, vehicle efficiency and better fuels are necessary, but insufficient, to address the GHG
emissions from the transportation system. Land use patterns and transportation options also
will need to change to support reductions in vehicle travel/VMT.
• New land use projects alone will not sufficiently reduce per-capita VMT to achieve those targets,
nor are they expected to be the sole source of VMT reduction.
• Interactions between land use projects, and also between land use and transportation projects,
existing and future, together affect VMT.
• Because location within the region is the most important determinant of VMT, in some cases,
streamlining CEQA review of projects in travel efficient locations may be the most effective
means of reducing VMT.
• When assessing climate impacts of some types of land use projects, use of an efficiency metric
(e.g., per capita, per employee) may provide a better measure of impact than an absolute
numeric threshold. (Center for Biological Diversity, supra.)
Public Resources Code section 21099 directs OPR to propose criteria for determining the significance of
transportation impacts. In this Technical Advisory, OPR provides its recommendations to assist lead
agencies in selecting a significance threshold that may be appropriate for their particular projects. While
OPR’s Technical Advisory is not binding on public agencies, CEQA allows lead agencies to “consider
thresholds of significance . . . recommended by other public agencies, provided the decision to adopt
those thresholds is supported by substantial evidence.” (CEQA Guidelines, § 15064.7, subd. (c).) Based
on OPR’s extensive review of the applicable research, and in light of an assessment by the California Air
Resources Board quantifying the need for VMT reduction in order to meet the State’s long-term climate
goals, OPR recommends that a per capita or per employee VMT that is fifteen percent below that of
existing development may be a reasonable threshold.
Fifteen percent reductions in VMT are achievable at the project level in a variety of place types.14
Moreover, a fifteen percent reduction is consistent with SB 743’s direction to OPR to select a threshold
that will help the State achieve its climate goals. As described above, section 21099 states that the
13 California Air Resources Board (May 2014) First Update to the Climate Change Scoping Plan, p. 46
(emphasis added).
14 CAPCOA (2010) Quantifying Greenhouse Gas Mitigation Measures, p. 55, available at
http://www.capcoa.org/wp-content/uploads/2010/11/CAPCOA-Quantification-Report-9-14-Final.pdf.
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criteria for determining significance must “promote the reduction in greenhouse gas emissions.” In its
document California Air Resources Board 2017 Scoping Plan-Identified VMT Reductions and Relationship
to State Climate Goals15, CARB assesses VMT reduction per capita consistent with its evidence-based
modeling scenario that would achieve State climate goals of 40 percent GHG emissions reduction from
1990 levels by 2030 and 80 percent GHG emissions reduction levels from 1990 by 2050. Applying
California Department of Finance population forecasts, CARB finds per-capita light-duty vehicle travel
would need to be approximately 16.8 percent lower than existing, and overall per-capita vehicle travel
would need to be approximately 14.3 percent lower than existing levels under that scenario. Below
these levels, a project could be considered low VMT and would, on that metric, be consistent with 2017
Scoping Plan Update assumptions that achieve climate state climate goals.
CARB finds per capita vehicle travel would need to be kept below what today’s policies and plans would
achieve.
CARB’s assessment is based on data in the 2017 Scoping Plan Update and 2016 Mobile Source Strategy.
In those documents, CARB previously examined the relationship between VMT and the state’s GHG
emissions reduction targets. The Scoping Plan finds:
“While the State can do more to accelerate and incentivize these local decisions, local actions
that reduce VMT are also necessary to meet transportation sector-specific goals and achieve the
2030 target under SB 32. Through developing the Scoping Plan, CARB staff is more convinced
than ever that, in addition to achieving GHG reductions from cleaner fuels and vehicles,
California must also reduce VMT. Stronger SB 375 GHG reduction targets will enable the State to
make significant progress toward needed reductions, but alone will not provide the VMT growth
reductions needed; there is a gap between what SB 375 can provide and what is needed to meet
the State’s 2030 and 2050 goals.”16
Note that, at present, consistency with RTP/SCSs does not necessarily lead to a less-than-significant VMT
impact.17 As the Final 2017 Scoping Plan Update states,
VMT reductions are necessary to achieve the 2030 target and must be part of any strategy
evaluated in this Plan. Stronger SB 375 GHG reduction targets will enable the State to make
significant progress toward this goal, but alone will not provide all of the VMT growth reductions
that will be needed. There is a gap between what SB 375 can provide and what is needed to
meet the State’s 2030 and 2050 goals.”18
15 California Air Resources Board (Jan. 2019) California Air Resources Board 2017 Scoping Plan-Identified
VMT Reductions and Relationship to State Climate Goals, available at
https://ww2.arb.ca.gov/resources/documents/carb-2017-scoping-plan-identified-vmt-reductions-and-
relationship-state-climate.
16 California Air Resources Board (Nov. 2017) California’s 2017 Climate Change Scoping Plan, p. 101.
17 California Air Resources Board (Feb. 2018) Updated Final Staff Report: Proposed Update to the SB 375
Greenhouse Gas Emission Reduction Targets, Figure 3, p. 35, available at
https://www.arb.ca.gov/cc/sb375/sb375_target_update_final_staff_report_feb2018.pdf.
18 California Air Resources Board (Nov. 2017) California’s 2017 Climate Change Scoping Plan, p. 75.
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Also, in order to capture the full effects of induced travel resulting from roadway capacity projects, an
RTP/SCS would need to include an assessment of land use effects of those projects, and the effects of
those land uses on VMT. (See section titled “Estimating VMT Impacts from Transportation Projects”
below.) RTP/SCSs typically model VMT using a collaboratively-developed land use “vision” for the
region’s land use, rather than studying the effects on land use of the proposed transportation
investments.
In summary, achieving 15 percent lower per capita (residential) or per employee (office) VMT than
existing development is both generally achievable and is supported by evidence that connects this level
of reduction to the State’s emissions goals.
1. Screening Thresholds for Land Use Projects
Many agencies use “screening thresholds” to quickly identify when a project should be expected to
cause a less-than-significant impact without conducting a detailed study. (See e.g., CEQA Guidelines, §§
15063(c)(3)(C), 15128, and Appendix G.) As explained below, this technical advisory suggests that lead
agencies may screen out VMT impacts using project size, maps, transit availability, and provision of
affordable housing.
Screening Threshold for Small Projects
Many local agencies have developed screening thresholds to indicate when detailed analysis is needed.
Absent substantial evidence indicating that a project would generate a potentially significant level of
VMT, or inconsistency with a Sustainable Communities Strategy (SCS) or general plan, projects that
generate or attract fewer than 110 trips per day19 generally may be assumed to cause a less-than-
significant transportation impact.
Map-Based Screening for Residential and Office Projects
Residential and office projects that locate in areas with low VMT, and that incorporate similar features
(i.e., density, mix of uses, transit accessibility), will tend to exhibit similarly low VMT. Maps created with
VMT data, for example from a travel survey or a travel demand model, can illustrate areas that are
19 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.
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currently below threshold VMT (see recommendations below). Because new development in such
locations would likely result in a similar level of VMT, such maps can be used to screen out residential
and office projects from needing to prepare a detailed VMT analysis.
Figure 2. Example map of household VMT that could be used to
delineate areas eligible to receive streamlining for VMT analysis.
(Source: City of San José, Department of Transportation, draft output of
City Transportation Model.)
Presumption of Less Than Significant Impact Near Transit Stations
Proposed CEQA Guideline Section 15064.3, subdivision (b)(1), states that lead agencies generally should
presume that certain projects (including residential, retail, and office projects, as well as projects that
are a mix of these uses) proposed within ½ mile of an existing major transit stop20 or an existing stop
20 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.”).
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along a high quality transit corridor21 will have a less-than-significant impact on VMT. This presumption
would not apply, however, if project-specific or location-specific information indicates that the project
will still generate significant levels of VMT. For example, the presumption might not be appropriate if
the project:
● Has a Floor Area Ratio (FAR) of less than 0.75
● Includes more parking for use by residents, customers, or employees of the project than
required by the jurisdiction (if the jurisdiction requires the project to supply parking)
● Is inconsistent with the applicable Sustainable Communities Strategy (as determined by the lead
agency, with input from the Metropolitan Planning Organization)
● Replaces affordable residential units with a smaller number of moderate- or high-income
residential units
A project or plan near transit which replaces affordable residential units22 with a smaller number of
moderate- or high-income residential units may increase overall VMT because the increase in VMT of
displaced residents could overwhelm the improvements in travel efficiency enjoyed by new residents.23
If any of these exceptions to the presumption might apply, the lead agency should conduct a detailed
VMT analysis to determine whether the project would exceed VMT thresholds (see below).
Presumption of Less Than Significant Impact for Affordable Residential Development
Adding affordable housing to infill locations generally improves jobs-housing match, in turn shortening
commutes and reducing VMT.24,25 Further, “… low-wage workers in particular would be more likely to
choose a residential location close to their workplace, if one is available.”26 In areas where existing jobs-
housing match is closer to optimal, low income housing nevertheless generates less VMT than market-
21 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.”).
22 Including naturally-occurring affordable residential units.
23 Chapple et al. (2017) Developing a New Methodology for Analyzing Potential Displacement, Chapter 4,
pp. 159-160, available at https://www.arb.ca.gov/research/apr/past/13-310.pdf.
24 Karner and Benner (2016) The convergence of social equity and environmental sustainability: Jobs-
housing fit and commute distance (“[P]olicies that advance a more equitable distribution of jobs and
housing by linking the affordability of locally available housing with local wage levels are likely to be
associated with reduced commuting distances”).
25 Karner and Benner (2015) Low-wage jobs-housing fit: identifying locations of affordable housing
shortages.
26 Karner and Benner (2015) Low-wage jobs-housing fit: identifying locations of affordable housing
shortages.
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rate housing.27,28 Therefore, a project consisting of a high percentage of affordable housing may be a
basis for the lead agency to find a less-than-significant impact on VMT. Evidence supports a
presumption of less than significant impact for a 100 percent affordable residential development (or the
residential component of a mixed-use development) in infill locations. Lead agencies may develop their
own presumption of less than significant impact for residential projects (or residential portions of mixed
use projects) containing a particular amount of affordable housing, based on local circumstances and
evidence. Furthermore, a project which includes any affordable residential units may factor the effect
of the affordability on VMT into the assessment of VMT generated by those units.
2.Recommended Numeric Thresholds for Residential, Office, and Retail
Projects
Recommended threshold for residential projects: 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 as city VMT per capita. Proposed
development referencing a threshold based on city VMT per capita (rather than regional VMT per
capita) should not cumulatively exceed the number of units specified in the SCS for that city, and
should be consistent with the SCS.
Residential development that would generate vehicle travel that is 15 or more percent below the
existing residential VMT per capita, measured against the region or city, may indicate a less-than-
significant transportation impact. In MPO areas, development measured against city VMT per capita
(rather than regional VMT per capita) should not cumulatively exceed the population or number of units
specified in the SCS for that city because greater-than-planned amounts of development in areas above
the region-based threshold would undermine the VMT containment needed to achieve regional targets
under SB 375.
For residential projects in unincorporated county areas, the local agency can compare a residential
project’s VMT to (1) the region’s VMT per capita, or (2) the aggregate population-weighted VMT per
capita of all cities in the region. In MPO areas, development in unincorporated areas measured against
aggregate city VMT per capita (rather than regional VMT per capita) should not cumulatively exceed the
population or number of units specified in the SCS for that city because greater-than-planned amounts
of development in areas above the regional threshold would undermine achievement of regional targets
under SB 375.
27 Chapple et al. (2017) Developing a New Methodology for Analyzing Potential Displacement, available
at https://www.arb.ca.gov/research/apr/past/13-310.pdf.
28 CAPCOA (2010) Quantifying Greenhouse Gas Mitigation Measures, pp. 176-178, available at
http://www.capcoa.org/wp-content/uploads/2010/11/CAPCOA-Quantification-Report-9-14-Final.pdf.
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These thresholds can be applied to either household (i.e., tour-based) VMT or home-based (i.e., trip-
based) VMT assessments.29 It is critical, however, that the agency be consistent in its VMT measurement
approach throughout the analysis to maintain an “apples-to-apples” comparison. For example, if the
agency uses a home-based VMT for the threshold, it should also be use home-based VMT for calculating
project VMT and VMT reduction due to mitigation measures.
Because new retail development typically redistributes shopping trips rather than creating new trips,30
estimating the total change in VMT (i.e., the difference in total VMT in the area affected with and
without the project) is the best way to analyze a retail project’s transportation impacts.
By adding retail opportunities into the urban fabric and thereby improving retail destination proximity,
local-serving retail development tends to shorten trips and reduce VMT. Thus, lead agencies generally
may presume such development creates a less-than-significant transportation impact. Regional-serving
retail development, on the other hand, which can lead to substitution of longer trips for shorter ones,
may tend to have a significant impact. Where such development decreases VMT, lead agencies should
consider the impact to be less-than-significant.
Many cities and counties define local-serving and regional-serving retail in their zoning codes. Lead
agencies may refer to those local definitions when available, but should also consider any project-
29 See Appendix 1 for a description of these approaches.
30 Lovejoy, et al. (2013) Measuring the impacts of local land-use policies on vehicle miles of travel:
The case of the first big-box store in Davis, California, The Journal of Transport and Land Use.
Recommended threshold for retail projects: A net increase in total VMT may indicate a significant
transportation impact.
Office projects that would generate vehicle travel exceeding 15 percent below existing VMT per
employee for the region may indicate a significant transportation impact. In cases where the region is
substantially larger than the geography over which most workers would be expected to live, it might be
appropriate to refer to a smaller geography, such as the county, that includes the area over which nearly
all workers would be expected to live.
Office VMT screening maps can be developed using tour-based data, considering either total employee
VMT or employee work tour VMT. Similarly, tour-based analysis of office project VMT could consider
either total employee VMT or employee work tour VMT. Where tour-based information is unavailable
for threshold determination, project assessment, or assessment of mitigation, home-based work trip
VMT should be used throughout all steps of the analysis to maintain an “apples-to-apples” comparison.
Recommended threshold for office projects: A proposed project exceeding a level of 15 percent
below existing regional VMT per employee may indicate a significant transportation impact.
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specific information, such as market studies or economic impacts analyses that might bear on
customers’ travel behavior. Because lead agencies will best understand their own communities and the
likely travel behaviors of future project users, they are likely in the best position to decide when a
project will likely be local-serving. Generally, however, retail development including stores larger than
50,000 square feet might be considered regional-serving, and so lead agencies should undertake an
analysis to determine whether the project might increase or decrease VMT.
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 (e.g., residential and retail). 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. Combining different land uses and applying one threshold to those land uses
may result in an inaccurate impact assessment.
Other Project Types
Of land use projects, residential, office, and retail projects tend to have the greatest influence on VMT.
For that reason, OPR recommends the quantified thresholds described above for purposes of analysis
and mitigation. Lead agencies, using more location-specific information, may develop their own more
specific thresholds, which may include other land use types. In developing thresholds for other project
types, or thresholds different from those recommended here, lead agencies should consider the
purposes described in section 21099 of the Public Resources Code and regulations in the CEQA
Guidelines on the development of thresholds of significance (e.g., CEQA Guidelines, § 15064.7).
Strategies and projects that decrease local VMT but increase total VMT should be avoided. Agencies
should consider whether their actions encourage development in a less travel-efficient location by
limiting development in travel-efficient locations.
Redevelopment Projects
Where a project replaces existing VMT-generating land uses, if the replacement leads to a net overall
decrease in VMT, the project would lead to a less-than-significant transportation impact. If the project
leads to a net overall increase in VMT, then the thresholds described above should apply.
As described above, a project or plan near transit which replaces affordable31 residential units with a
smaller number of moderate- or high-income residential units may increase overall VMT, because
31 Including naturally-occurring affordable residential units.
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displaced residents’ VMT may increase.32 A lead agency should analyze VMT for such a project even if it
otherwise would have been presumed less than significant. The assessment should incorporate an
estimate of the aggregate VMT increase experienced by displaced residents. That additional VMT
should be included in the numerator of the VMT per capita assessed for the project.
If a residential or office project leads to a net increase in VMT, then the project’s VMT per capita
(residential) or per employee (office) should be compared to thresholds recommended above. Per
capita and per employee VMT are efficiency metrics, and, as such, apply only to the existing project
without regard to the VMT generated by the previously existing land use.
If the project leads to a net increase in provision of locally-serving retail, transportation impacts from
the retail portion of the development should be presumed to be less than significant. If the project
consists of regionally-serving retail, and increases overall VMT compared to with existing uses, then the
project would lead to a significant transportation impact.
RTP/SCS Consistency (All Land Use Projects)
Section 15125, subdivision (d), of the CEQA Guidelines provides that lead agencies should analyze
impacts resulting from inconsistencies with regional plans, including regional transportation plans. For
this reason, if a project is inconsistent with the Regional Transportation Plan and Sustainable
Communities Strategy (RTP/SCS), the lead agency should evaluate whether that inconsistency indicates
a significant impact on transportation. For example, a development may be inconsistent with an
RTP/SCS if the development is outside the footprint of development or within an area specified as open
space as shown in the SCS.
3. Recommendations Regarding Land Use Plans
As with projects, agencies should analyze VMT outcomes of land use plans across the full area over
which the plan may substantively affect travel patterns, including beyond the boundary of the plan or
jurisdiction’s geography. And as with projects, VMT should be counted in full rather than split between
origin and destination. (Emissions inventories have sometimes spit cross-boundary trips in order to sum
to a regional total, but CEQA requires accounting for the full impact without truncation or discounting).
Analysis of specific plans may employ the same thresholds described above for projects. A general plan,
area plan, or community plan may have a significant impact on transportation if proposed new
residential, office, or retail land uses would in aggregate exceed the respective thresholds
recommended above. Where the lead agency tiers from a general plan EIR pursuant to CEQA Guidelines
sections 15152 and 15166, the lead agency generally focuses on the environmental impacts that are
specific to the later project and were not analyzed as significant impacts in the prior EIR. (Pub. Resources
Code, § 21068.5; Guidelines, § 15152, subd. (a).) Thus, in analyzing the later project, the lead agency
32 Chapple et al. (2017) Developing a New Methodology for Analyzing Potential Displacement, Chapter 4,
pp. 159-160, available at https://www.arb.ca.gov/research/apr/past/13-310.pdf.
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would focus on the VMT impacts that were not adequately addressed in the prior EIR. In the tiered
document, the lead agency should continue to apply the thresholds recommended above.
Thresholds for plans in non-MPO areas may be determined on a case-by-case basis.
4. Other Considerations
Rural Projects Outside of MPOs
In rural areas of non-MPO counties (i.e., areas not near established or incorporated cities or towns),
fewer options may be available for reducing VMT, and significance thresholds may be best determined
on a case-by-case basis. Note, however, that clustered small towns and small town main streets may
have substantial VMT benefits compared to isolated rural development, similar to the transit oriented
development described above.
Impacts to Transit
Because criteria for determining the significance of transportation impacts must promote “the
development of multimodal transportation networks” pursuant to Public Resources Code section 21099,
subd. (b)(1), lead agencies should consider project impacts to transit systems and bicycle and pedestrian
networks. For example, a project that blocks access to a transit stop or blocks a transit route itself may
interfere with transit functions. Lead agencies should consult with transit agencies as early as possible in
the development process, particularly for projects that are located within one half mile of transit stops.
When evaluating impacts to multimodal transportation networks, lead agencies generally should not
treat the addition of new transit users as an adverse impact. An infill development may add riders to
transit systems and the additional boarding and alighting may slow transit vehicles, but it also adds
destinations, improving proximity and accessibility. Such development also improves regional vehicle
flow by adding less vehicle travel onto the regional network.
Increased demand throughout a region may, however, cause a cumulative impact by requiring new or
additional transit infrastructure. Such impacts may be adequately addressed through a fee program that
fairly allocates the cost of improvements not just to projects that happen to locate near transit, but
rather across a region to all projects that impose burdens on the entire transportation system, since
transit can broadly improve the function of the transportation system.
F. Considering the Effects of Transportation Projects on Vehicle Travel
Many transportation projects change travel patterns. A transportation project which leads to additional
vehicle travel on the roadway network, commonly referred to as “induced vehicle travel,” would need to
quantify the amount of additional vehicle travel in order to assess air quality impacts, greenhouse gas
emissions impacts, energy impacts, and noise impacts. Transportation projects also are required to
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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.33
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
33 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.
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• Roadway shoulder enhancements to provide “breakdown space,” dedicated space for use only
by transit vehicles, to provide bicycle access, or to otherwise improve safety, but which will not
be used as automobile vehicle travel lanes
• Addition of an auxiliary lane of less than one mile in length designed to improve roadway safety
• Installation, removal, or reconfiguration of traffic lanes that are not for through traffic, such as
left, right, and U-turn pockets, two-way left turn lanes, or emergency breakdown lanes that are
not utilized as through lanes
• Addition of roadway capacity on local or collector streets provided the project also substantially
improves conditions for pedestrians, cyclists, and, if applicable, transit
• Conversion of existing general purpose lanes (including ramps) to managed lanes or transit
lanes, or changing lane management in a manner that would not substantially increase vehicle
travel
• Addition of a new lane that is permanently restricted to use only by transit vehicles
• Reduction in number of through lanes
• Grade separation to separate vehicles from rail, transit, pedestrians or bicycles, or to replace a
lane in order to separate preferential vehicles (e.g., HOV, HOT, or trucks) from general vehicles
• Installation, removal, or reconfiguration of traffic control devices, including Transit Signal
Priority (TSP) features
• Installation of traffic metering systems, detection systems, cameras, changeable message signs
and other electronics designed to optimize vehicle, bicycle, or pedestrian flow
• Timing of signals to optimize vehicle, bicycle, or pedestrian flow
• Installation of roundabouts or traffic circles
• Installation or reconfiguration of traffic calming devices
• Adoption of or increase in tolls
• Addition of tolled lanes, where tolls are sufficient to mitigate VMT increase
• Initiation of new transit service
• Conversion of streets from one-way to two-way operation with no net increase in number of
traffic lanes
• Removal or relocation of off-street or on-street parking spaces
• Adoption or modification of on-street parking or loading restrictions (including meters, time
limits, accessible spaces, and preferential/reserved parking permit programs)
• Addition of traffic wayfinding signage
• Rehabilitation and maintenance projects that do not add motor vehicle capacity
• Addition of new or enhanced bike or pedestrian facilities on existing streets/highways or within
existing public rights-of-way
• Addition of Class I bike paths, trails, multi-use paths, or other off-road facilities that serve non-
motorized travel
• Installation of publicly available alternative fuel/charging infrastructure
• Addition of passing lanes, truck climbing lanes, or truck brake-check lanes in rural areas that do
not increase overall vehicle capacity along the corridor
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1. Recommended Significance Threshold for Transportation Projects
As noted in Section 15064.3 of the CEQA Guidelines, lead agencies for roadway capacity projects have
discretion, consistent with CEQA and planning requirements, to choose which metric to use to evaluate
transportation impacts. This section recommends considerations for evaluating impacts using vehicle
miles traveled. Lead agencies have discretion to choose a threshold of significance for transportation
projects as they do for other types of projects. As explained above, Public Resources Code section
21099, subdivision (b)(1), provides that criteria for determining the significance of transportation
impacts must promote the reduction of greenhouse gas emissions, the development of multimodal
transportation networks, and a diversity of land uses. (Id.; see generally, adopted CEQA Guidelines, §
15064.3, subd. (b) [Criteria for Analyzing Transportation Impacts].) With those goals in mind, OPR
prepared and the Agency adopted an appropriate transportation metric.
Whether adopting a threshold of significance, or evaluating transportation impacts on a case-by-case
basis, a lead agency should ensure that the analysis addresses:
• Direct, indirect and cumulative effects of the transportation project (CEQA Guidelines, § 15064,
subds. (d), (h))
• Near-term and long-term effects of the transportation project (CEQA Guidelines, §§ 15063,
subd. (a)(1), 15126.2, subd. (a))
• The transportation project’s consistency with state greenhouse gas reduction goals (Pub.
Resources Code, § 21099)34
• The impact of the transportation project on the development of multimodal transportation
networks (Pub. Resources Code, § 21099)
• The impact of the transportation project on the development of a diversity of land uses (Pub.
Resources Code, § 21099)
The CARB Scoping Plan and the CARB Mobile Source Strategy delineate VMT levels required to achieve
legally mandated GHG emissions reduction targets. A lead agency should develop a project-level
threshold based on those VMT levels, and may apply the following approach:
1. Propose a fair-share allocation of those budgets to their jurisdiction (e.g., by population);
34 The California Air Resources Board has ascertained the limits of VMT growth compatible with
California containing greenhouse gas emissions to levels research shows would allow for climate
stabilization. (See The 2017 Climate Change Scoping Plan: The Strategy for Achieving California’s 2030
Greenhouse Gas Target (p. 78, p. 101); Mobile Source Strategy (p. 37).) CARB’s Updated Final Staff
Report on Proposed Update to the SB 375 Greenhouse Gas Emission Reduction Targets illustrates that
the current Regional Transportation Plans and Sustainable Communities Strategies will fall short of
achieving the necessary on-road transportation-related GHG emissions reductions called for in the 2017
Scoping Plan (Figure 3, p. 35). Accordingly, OPR recommends not basing GHG emissions or
transportation impact analysis for a transportation project solely on consistency with an RTP/SCS.
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2. Determine the amount of VMT growth likely to result from background population growth, and
subtract that from their “budget”;
3. Allocate their jurisdiction’s share between their various VMT-increasing transportation projects,
using whatever criteria the lead agency prefers.
2. Estimating VMT Impacts from Transportation Projects
CEQA requires analysis of a project’s potential growth-inducing impacts. (Pub. Resources Code, § 21100,
subd. (b)(5); CEQA Guidelines, § 15126.2, subd. (d).) Many agencies are familiar with the analysis of
growth inducing impacts associated with water, sewer, and other infrastructure. This technical advisory
addresses growth that may be expected from roadway expansion projects.
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 these projects.
Induced travel also has the potential to reduce or eliminate congestion relief benefits. An accurate
estimate of induced travel is needed to accurately weigh costs and benefits of a highway capacity
expansion project.
The effect of a transportation project on vehicle travel should be estimated using the “change in total
VMT” method described in Appendix 1. This means that an assessment of total VMT without the project
and an assessment with the project should be made; the difference between the two is the amount of
VMT attributable to the project. The assessment should cover the full area in which driving patterns are
expected to change. As with other types of projects, the VMT estimation should not be truncated at a
modeling or jurisdictional boundary for convenience of analysis when travel behavior is substantially
affected beyond that boundary.
Transit and Active Transportation Projects
Transit and active transportation projects generally reduce VMT and therefore are presumed to cause a
less-than-significant impact on transportation. This presumption may apply to all passenger rail projects,
bus and bus rapid transit projects, and bicycle and pedestrian infrastructure projects. Streamlining
transit and active transportation projects aligns with each of the three statutory goals contained in SB
743 by reducing GHG emissions, increasing multimodal transportation networks, and facilitating mixed
use development.
Roadway Projects
Reducing roadway capacity (for example, by removing or repurposing motor vehicle travel lanes) will
generally reduce VMT and therefore is presumed to cause a less-than-significant impact on
transportation. Generally, no transportation analysis is needed for such projects.
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Building new roadways, adding roadway capacity in congested areas, or adding roadway capacity to
areas where congestion is expected in the future, typically induces additional vehicle travel. For the
types of projects previously indicated as likely to lead to additional vehicle travel, an estimate should be
made of the change in vehicle travel resulting from the project.
For projects that increase roadway capacity, lead agencies can evaluate induced travel quantitatively by
applying the results of existing studies that examine the magnitude of the increase of VMT resulting
from a given increase in lane miles. These studies estimate the percent change in VMT for every percent
change in miles to the roadway system (i.e., “elasticity”).35 Given that lead agencies have discretion in
choosing their methodology, and the studies on induced travel reveal a range of elasticities, lead
agencies may appropriately apply professional judgment in studying the transportation effects of a
particular project. The most recent major study, estimates an elasticity of 1.0, meaning that every
percent change in lane miles results in a one percent increase in VMT.36
To estimate VMT impacts from roadway expansion projects:
1. Determine the total lane-miles over an area that fully captures travel behavior changes
resulting from the project (generally the region, but for projects affecting interregional travel
look at all affected regions).
2. Determine the percent change in total lane miles that will result from the project.
3. Determine the total existing VMT over that same area.
4. Multiply the percent increase in lane miles by the existing VMT, and then multiply that by the
elasticity from the induced travel literature:
[% increase in lane miles] x [existing VMT] x [elasticity] = [VMT resulting from the project]
A National Center for Sustainable Transportation tool can be used to apply this method:
https://ncst.ucdavis.edu/research/tools
This method would not be suitable for rural (non-MPO) locations in the state which are neither
congested nor projected to become congested. It also may not be suitable for a new road that provides
new connectivity across a barrier (e.g., a bridge across a river) if it would be expected to substantially
35 See U.C. Davis, Institute for Transportation Studies (Oct. 2015) Increasing Highway Capacity Unlikely
to Relieve Traffic Congestion; Boarnet and Handy (Sept. 2014) Impact of Highway Capacity and Induced
Travel on Passenger Vehicle Use and Greenhouse Gas Emissions, California Air Resources Board Policy
Brief, available at https://www.arb.ca.gov/cc/sb375/policies/hwycapacity/highway_capacity_brief.pdf.
36 See Duranton and Turner (2011) The Fundamental Law of Road Congestion: Evidence from US cities,
available at http://www.nber.org/papers/w15376.
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shorten existing trips. If it is likely to be substantial, the trips-shortening effect should be examined
explicitly.
The effects of roadway capacity on vehicle travel can also be applied at a programmatic level. For
example, in a regional planning process the lead agency can use that program-level analysis to
streamline later project-level analysis. (See CEQA Guidelines, § 15168.) A program-level analysis of VMT
should include effects of the program on land use patterns, and the VMT that results from those land
use effects. In order for a program-level document to adequately analyze potential induced demand
from a project or program of roadway capacity expansion, lead agencies cannot assume a fixed land use
pattern (i.e., a land use pattern that does not vary in response to the provision of roadway capacity). A
proper analysis should account for land use investment and development pattern changes that react in a
reasonable manner to changes in accessibility created by transportation infrastructure investments
(whether at the project or program level).
Mitigation and Alternatives
Induced VMT has the potential to reduce or eliminate congestion relief benefits, increase VMT, and
increase other environmental impacts that result from vehicle travel.37 If those effects are significant,
the lead agency will need to consider mitigation or alternatives. In the context of increased travel that is
induced by capacity increases, appropriate mitigation and alternatives that a lead agency might consider
include the following:
• Tolling new lanes to encourage carpools and fund transit improvements
• Converting existing general purpose lanes to HOV or HOT lanes
• Implementing or funding off-site travel demand management
• Implementing Intelligent Transportation Systems (ITS) strategies to improve passenger
throughput on existing lanes
Tolling and other management strategies can have the additional benefit of preventing congestion and
maintaining free-flow conditions, conferring substantial benefits to road users as discussed above.
G. Analyzing Other Impacts Related to Transportation
While requiring a change in the methodology of assessing transportation impacts, Public Resources
Code section 21099 notes that this change “does not relieve a public agency of the requirement to
analyze a project’s potentially significant transportation impacts related to air quality, noise, safety, or
any other impact associated with transportation.” OPR expects that lead agencies will continue to
37 See National Center for Sustainable Transportation (Oct. 2015) Increasing Highway Capacity Unlikely
to Relieve Traffic Congestion, available at
http://www.dot.ca.gov/newtech/researchreports/reports/2015/10-12-2015-
NCST_Brief_InducedTravel_CS6_v3.pdf; see Duranton and Turner (2011) The Fundamental Law of Road
Congestion: Evidence from US cities, available at http://www.nber.org/papers/w15376.
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address mobile source emissions in the air quality and noise sections of an environmental document and
the corresponding studies that support the analysis in those sections. Lead agencies should continue to
address environmental impacts of a proposed project pursuant to CEQA’s requirements, using a format
that is appropriate for their particular project.
Because safety concerns result from many different factors, they are best addressed at a programmatic
level (i.e., in a general plan or regional transportation plan) in cooperation with local governments,
metropolitan planning organizations, and, where the state highway system is involved, the California
Department of Transportation. In most cases, such an analysis would not be appropriate on a project-
by-project basis. Increases in traffic volumes at a particular location resulting from a project typically
cannot be estimated with sufficient accuracy or precision to provide useful information for an analysis of
safety concerns. Moreover, an array of factors affect travel demand (e.g., strength of the local economy,
price of gasoline), causing substantial additional uncertainty. Appendix B of OPR’s General Plan
Guidelines summarizes research which could be used to guide a programmatic analysis under CEQA.
Lead agencies should note that automobile congestion or delay does not constitute a significant
environmental impact (Pub. Resources Code, §21099(b)(2)), and safety should not be used as a proxy for
road capacity.
H. VMT Mitigation and Alternatives
When a lead agency identifies a significant impact, it must identify feasible mitigation measures that
could avoid or substantially reduce that impact. (Pub. Resources Code, § 21002.1, subd. (a).)
Additionally, CEQA requires that an environmental impact report identify feasible alternatives that could
avoid or substantially reduce a project’s significant environmental impacts.
Indeed, the California Court of Appeal recently held that a long-term regional transportation plan was
deficient for failing to discuss an alternative which could significantly reduce total vehicle miles traveled.
In Cleveland National Forest Foundation v. San Diego Association of Governments, et al. (2017) 17
Cal.App.5th 413, the court found that omission “inexplicable” given the lead agency’s “acknowledgment
in its Climate Action Strategy that the state’s efforts to reduce greenhouse gas emissions from on-road
transportation will not succeed if the amount of driving, or vehicle miles traveled, is not significantly
reduced.” (Cleveland National Forest Foundation, supra, 17 Cal.App.5th at p. 436.) Additionally, the
court noted that the project alternatives focused primarily on congestion relief even though “the
[regional] transportation plan is a long-term and congestion relief is not necessarily an effective long-
term strategy.” (Id. at p. 437.) The court concluded its discussion of the alternatives analysis by stating:
“Given the acknowledged long-term drawbacks of congestion relief alternatives, there is not substantial
evidence to support the EIR’s exclusion of an alternative focused primarily on significantly reducing
vehicle trips.” (Ibid.)
Several examples of potential mitigation measures and alternatives to reduce VMT are described below.
However, the selection of particular mitigation measures and alternatives are left to the discretion of
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the lead agency, and mitigation measures may vary, depending on the proposed project and significant
impacts, if any. Further, OPR expects that agencies will continue to innovate and find new ways to
reduce vehicular travel.
Potential measures to reduce vehicle miles traveled include, but are not limited to:
• Improve or increase access to transit.
• Increase access to common goods and services, such as groceries, schools, and daycare.
• Incorporate affordable housing into the project.
• Incorporate neighborhood electric vehicle network.
• Orient the project toward transit, bicycle and pedestrian facilities.
• Improve pedestrian or bicycle networks, or transit service.
• Provide traffic calming.
• Provide bicycle parking.
• Limit or eliminate parking supply.
• Unbundle parking costs.
• Provide parking cash-out programs.
• Implement roadway pricing.
• Implement or provide access to a commute reduction program.
• Provide car-sharing, bike sharing, and ride-sharing programs.
• Provide transit passes.
• Shifting single occupancy vehicle trips to carpooling or vanpooling, for example providing ride-
matching services.
• Providing telework options.
• Providing incentives or subsidies that increase the use of modes other than single-occupancy
vehicle.
• Providing on-site amenities at places of work, such as priority parking for carpools and vanpools,
secure bike parking, and showers and locker rooms.
• Providing employee transportation coordinators at employment sites.
• Providing a guaranteed ride home service to users of non-auto modes.
Notably, because VMT is largely a regional impact, regional VMT-reduction programs may be an
appropriate form of mitigation. In lieu fees have been found to be valid mitigation where there is both a
commitment to pay fees and evidence that mitigation will actually occur. (Save Our Peninsula
Committee v. Monterey County Bd. of Supervisors (2001) 87 Cal.App.4th 99, 140-141; Gentry v. City of
Murrieta (1995) 36 Cal.App.4th 1359; Kings County Farm Bureau v. City of Hanford (1990) 221
Cal.App.3d 692, 727–728.) Fee programs are particularly useful to address cumulative impacts. (CEQA
Guidelines, § 15130, subd. (a)(3) [a “project’s incremental contribution is less than cumulatively
considerable if the project is required to implement or fund its fair share of a mitigation measure or
measures designed to alleviate the cumulative impact”].) The mitigation program must undergo CEQA
evaluation, either on the program as a whole, or the in-lieu fees or other mitigation must be evaluated
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on a project-specific basis. (California Native Plant Society v. County of El Dorado (2009) 170 Cal.App.4th
1026.) That CEQA evaluation could be part of a larger program, such as a regional transportation plan,
analyzed in a Program EIR. (CEQA Guidelines, § 15168.)
Examples of project alternatives that may reduce vehicle miles traveled include, but are not limited to:
• Locate the project in an area of the region that already exhibits low VMT.
• Locate the project near transit.
• Increase project density.
• Increase the mix of uses within the project or within the project’s surroundings.
• Increase connectivity and/or intersection density on the project site.
• Deploy management strategies (e.g., pricing, vehicle occupancy requirements) on roadways or
roadway lanes.
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Appendix 1. Considerations About Which VMT to Count
Consistent with the obligation to make a good faith effort to disclose the environmental consequences
of a project, lead agencies have discretion to choose the most appropriate methodology to evaluate
project impacts.38 A lead agency can evaluate a project’s effect on VMT in numerous ways. The purpose
of this document is to provide technical considerations in determining which methodology may be most
useful for various project types.
Background on Estimating Vehicle Miles Traveled
Before discussing specific methodological recommendations, this section provides a brief overview of
modeling and counting VMT, including some key terminology.
Here is an illustrative example of some methods of estimating vehicle miles traveled. Consider the
following hypothetical travel day (all by automobile):
1. Residence to Coffee Shop
2. Coffee Shop to Work
3. Work to Sandwich Shop
4. Sandwich Shop to Work
5. Work to Residence
6. Residence to Store
7. Store to Residence
Trip-based assessment of a project’s effect on travel behavior counts VMT from individual trips to and
from the project. It is the most basic, and traditionally the most common, method of counting VMT. A
trip-based VMT assessment of the residence in the above example would consider segments 1, 5, 6 and
7. For residential projects, the sum of home-based trips is called home-based VMT.
A tour-based assessment counts the entire home-back-to-home tour that includes the project. A tour-
based VMT assessment of the residence in the above example would consider segments 1, 2, 3, 4, and 5
in one tour, and 6 and 7 in a second tour. A tour-based assessment of the workplace would include
segments 1, 2, 3, 4, and 5. Together, all tours comprise household VMT.
38 The California Supreme Court has explained that when an agency has prepared an environmental
impact report:
[T]he issue is not whether the [lead agency’s] studies are irrefutable or whether they
could have been better. The relevant issue is only whether the studies are sufficiently
credible to be considered as part of the total evidence that supports the [lead agency’s]
finding[.]
(Laurel Heights Improvement Assn. v. Regents of the University of California (1988) 47 Cal.3d 376, 409;
see also Eureka Citizens for Responsible Gov’t v. City of Eureka (2007) 147 Cal.App.4th 357, 372.)
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Both trip- and tour-based assessments can be used as measures of transportation efficiency, using
denominators such as per capita, per employee, or per person-trip.
Trip- and Tour-based Assessment of VMT
As illustrated above, a tour-based assessment of VMT is a more complete characterization of a project’s
effect on VMT. In many cases, a project affects travel behavior beyond the first destination. The location
and characteristics of the home and workplace will often be the main drivers of VMT. For example, a
residential or office development located near high quality transit will likely lead to some commute trips
utilizing transit, affecting mode choice on the rest of the tour.
Characteristics of an office project can also affect an employee’s VMT beyond the work tour. For
example, a workplace located at the urban periphery, far from transit, can require an employee to own
a car, which in turn affects the entirety of an employee’s travel behavior and VMT. For this reason, when
estimating the effect of an office development on VMT, it may be appropriate to consider total
employee VMT if data and tools, such as tour-based models, are available. This is consistent with CEQA’s
requirement to evaluate both direct and indirect effects of a project. (See CEQA Guidelines, § 15064,
subd. (d)(2).)
Assessing Change in Total VMT
A third method, estimating the change in total VMT with and without the project, can evaluate whether
a project is likely to divert existing trips, and what the effect of those diversions will be on total VMT.
This method answers the question, “What is the net effect of the project on area VMT?” As an
illustration, assessing the total change in VMT for a grocery store built in a food desert that diverts trips
from more distant stores could reveal a net VMT reduction. The analysis should address the full area
over which the project affects travel behavior, even if the effect on travel behavior crosses political
boundaries.
Using Models to Estimate VMT
Travel demand models, sketch models, spreadsheet models, research, and data can all be used to
calculate and estimate VMT (see Appendix F of the preliminary discussion draft). To the extent possible,
lead agencies should choose models that have sensitivity to features of the project that affect VMT.
Those tools and resources can also assist in establishing thresholds of significance and estimating VMT
reduction attributable to mitigation measures and project alternatives. When using models and tools for
those various purposes, agencies should use comparable data and methods, in order to set up an
“apples-to-apples” comparison between thresholds, VMT estimates, and VMT mitigation estimates.
Models can work together. For example, agencies can use travel demand models or survey data to
estimate existing trip lengths and input those into sketch models such as CalEEMod to achieve more
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accurate results. Whenever possible, agencies should input localized trip lengths into a sketch model to
tailor the analysis to the project location. However, in doing so, agencies should be careful to avoid
double counting if the sketch model includes other inputs or toggles that are proxies for trip length (e.g.,
distance to city center). Generally, if an agency changes any sketch model defaults, it should record and
report those changes for transparency of analysis. Again, trip length data should come from the same
source as data used to calculate thresholds to be sure of an “apples-to-apples” comparison.
Additional background information regarding travel demand models is available in the California
Transportation Commission’s “2010 Regional Transportation Plan Guidelines,” beginning at page 35.
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Appendix 2. Induced Travel: Mechanisms, Research, and Additional Assessment Approaches
Induced travel occurs where roadway capacity is expanded in an area of present or projected future
congestion. The effect typically manifests over several years. Lower travel times make the modified
facility more attractive to travelers, resulting in the following trip-making changes:
● Longer trips. The ability to travel a long distance in a shorter time increases the attractiveness of
destinations that are farther away, increasing trip length and vehicle travel.
● Changes in mode choice. When transportation investments are devoted to reducing automobile
travel time, travelers tend to shift toward automobile use from other modes, which increases
vehicle travel.
● Route changes. Faster travel times on a route attract more drivers to that route from other
routes, which can increase or decrease vehicle travel depending on whether it shortens or
lengthens trips.
● Newly generated trips. Increasing travel speeds can induce additional trips, which increases
vehicle travel. For example, an individual who previously telecommuted or purchased goods on
the internet might choose to accomplish those tasks via automobile trips as a result of increased
speeds.
● Land Use Changes. Faster travel times along a corridor lead to land development farther along
that corridor; that new development generates and attracts longer trips, which increases vehicle
travel. Over several years, this induced growth component of induced vehicle travel can be
substantial, making it critical to include in analyses.
Each of these effects has implications for the total amount of vehicle travel. These effects operate over
different time scales. For example, changes in mode choice might occur immediately, while land use
changes typically take a few years or longer. CEQA requires lead agencies to analyze both short-term
and long-term effects.
Evidence of Induced Vehicle Travel. A large number of peer reviewed studies39 have demonstrated a
causal link between highway capacity increases and VMT increases. Many provide quantitative
estimates of the magnitude of the induced VMT phenomenon. Collectively, they provide high quality
evidence of the existence and magnitude of the induced travel effect.
39 See, e.g., Boarnet and Handy (Sept. 2014) Impact of Highway Capacity and Induced Travel on
Passenger Vehicle Use and Greenhouse Gas Emissions, California Air Resources Board Policy Brief,
available at https://www.arb.ca.gov/cc/sb375/policies/hwycapacity/highway_capacity_brief.pdf;
National Center for Sustainable Transportation (Oct. 2015) Increasing Highway Capacity Unlikely to
Relieve Traffic Congestion, available at
http://www.dot.ca.gov/research/researchreports/reports/2015/10-12-2015-
NCST_Brief_InducedTravel_CS6_v3.pdf.
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Most of these studies express the amount of induced vehicle travel as an “elasticity,” which is a
multiplier that describes the additional vehicle travel resulting from an additional lane mile of roadway
capacity added. For example, an elasticity of 0.6 would signify an 0.6 percent increase in vehicle travel
for every 1.0 percent increase in lane miles. Many of these studies distinguish “short run elasticity”
(increase in vehicle travel in the first few years) from “long run elasticity” (increase in vehicle travel
beyond the first few years). Long run elasticity is larger than short run elasticity, because as time passes,
more of the components of induced vehicle travel materialize. Generally, short run elasticity can be
thought of as excluding the effects of land use change, while long run elasticity includes them. Most
studies find a long run elasticity between 0.6 and just over 1.0,40 meaning that every increase in lanes
miles of one percent leads to an increase in vehicle travel of 0.6 to 1.0 percent. The most recent major
study finds the elasticity of vehicle travel by lanes miles added to be 1.03; in other words, each percent
increase in lane miles results in a 1.03 percent increase in vehicle travel.41 (An elasticity greater than 1.0
can occur because new lanes induce vehicle travel that spills beyond the project location.) In CEQA
analysis, the long-run elasticity should be used, as it captures the full effect of the project rather than
just the early-stage effect.
Quantifying Induced Vehicle Travel Using Models. Lead agencies can generally achieve the most accurate
assessment of induced vehicle travel resulting from roadway capacity increasing projects by applying
elasticities from the academic literature, because those estimates include vehicle travel resulting from
induced land use. If a lead agency chooses to use a travel demand model, additional analysis would be
needed to account for induced land use. This section describes some approaches to undertaking that
additional analysis.
Proper use of a travel demand model can capture the following components of induced VMT:
• Trip length (generally increases VMT)
• Mode shift (generally shifts from other modes toward automobile use, increasing VMT)
• Route changes (can act to increase or decrease VMT)
• Newly generated trips (generally increases VMT)
o Note that not all travel demand models have sensitivity to this factor, so an off-model
estimate may be necessary if this effect could be substantial.
However, estimating long-run induced VMT also requires an estimate of the project’s effects on land
use. This component of the analysis is important because it has the potential to be a large component of
40 See Boarnet and Handy (Sept. 2014) Impact of Highway Capacity and Induced Travel on Passenger
Vehicle Use and Greenhouse Gas Emissions, California Air Resources Board Policy Brief, p. 2, available at
https://www.arb.ca.gov/cc/sb375/policies/hwycapacity/highway_capacity_brief.pdf.
41 Duranton and Turner (2011) The Fundamental Law of Road Congestion: Evidence from US cities,
available at http://www.nber.org/papers/w15376.
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the overall induced travel effect. Options for estimating and incorporating the VMT effects that are
caused by the subsequent land use changes include:
1. Employ an expert panel. An expert panel could assess changes to land use development that
would likely result from the project. This assessment could then be analyzed by the travel
demand model to assess effects on vehicle travel. Induced vehicle travel assessed via this
approach should be verified using elasticities found in the academic literature.
2. Adjust model results to align with the empirical research. If the travel demand model analysis is
performed without incorporating projected land use changes resulting from the project, the
assessed vehicle travel should be adjusted upward to account for those land use changes. The
assessed VMT after adjustment should fall within the range found in the academic literature.
3. Employ a land use model, running it iteratively with a travel demand model. A land use model
can be used to estimate the land use effects of a roadway capacity increase, and the traffic
patterns that result from the land use change can then be fed back into the travel demand
model. The land use model and travel demand model can be iterated to produce an accurate
result.
A project which provides new connectivity across a barrier, such as a new bridge across a river, may
provide a shortened path between existing origins and destinations, thereby shortening existing trips. In
rare cases, this trip-shortening effect might be substantial enough to reduce the amount of vehicle
travel resulting from the project below the range found in the elasticities in the academic literature, or
even lead a net reduction in vehicle travel overall. In such cases, the trip-shortening effect could be
examined explicitly.
Whenever employing a travel demand model to assess induced vehicle travel, any limitation or known
lack of sensitivity in the analysis that might cause substantial errors in the VMT estimate (for example,
model insensitivity to one of the components of induced VMT described above) should be disclosed and
characterized, and a description should be provided on how it could influence the analysis results. A
discussion of the potential error or bias should be carried into analyses that rely on the VMT analysis,
such as greenhouse gas emissions, air quality, energy, and noise.
66
City of South San Francisco
Legislation Text
P.O. Box 711 (City Hall, 400
Grand Avenue)
South San Francisco, CA
File #:20-312 Agenda Date:5/21/2020
Version:1 Item #:2a.
Resolution recommending that City Council adopt a resolution to update the City of South San
Francisco’s transportation impact analysis thresholds,as required by the California Environmental
Quality Act (CEQA),to comply with state-mandated change from level of service (LOS)to vehicle miles
traveled (VMT), pursuant to Senate Bill 743 (2013) and new 2019 CEQA Guidelines.
WHEREAS,the California Environmental Quality Act (CEQA)was enacted in 1970 to ensure the long-term
protection of the environment and requires public agencies to analyze and disclose the effects of their action on
the environment; and
WHEREAS,Senate Bill 743 (SB 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,SB 743 specifically requires the Governor’s Office of Planning and Research (OPR)to amend
CEQA Guidelines by developing alternative criteria for determining the significance of transportation impacts
of projects within transit priority areas,and which criteria shall promote “the reduction of greenhouse gas
emissions, the development of multimodal transportation networks, and a diversity of land uses”; and
WHEREAS,for such alternative criteria,the measurements of transportation impacts may include “vehicle
miles traveled,vehicle miles traveled per capita,automobile trip generation rates,or automobile trips
generated”; and
WHEREAS,in 2018,OPR proposed,and the California Natural Resources Agency certified and adopted,new
CEQA Guidelines,including 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”(LOS)and other similar metrics,
will no longer be considered a significant impact under CEQA and may no longer serve as a threshold for
analyzing the significance of traffic impacts resulting from a project under CEQA; and
WHEREAS, the requirements of CEQA Guidelines Section 15064.3 will apply state-wide on July 1, 2020; and
WHEREAS,OPR most recently published a Technical Advisory on Evaluating Transportation Impacts in
CEQA in December 2018 to provide technical guidance and recommendation on assessment of VMT,
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File #:20-312 Agenda Date:5/21/2020
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CEQA in December 2018 to provide technical guidance and recommendation on assessment of VMT,
thresholds of significance, and mitigation measures; and
WHEREAS,lead agencies are encouraged to develop standards and procedures necessary to evaluate their
actions and therefore protect environmental quality, including thresholds of significance; and
WHEREAS,thresholds of significance are identifiable quantitative,qualitative or performance level measures
of a particular environmental effect,non-compliance with which means the effect will normally be determined
to be significant,and compliance with which means the effect will normally be determined to be less than
significant; and
WHEREAS,Public Resources Code section 21082 requires all public agencies to adopt by ordinance,
resolution,rule,or regulation,the objectives,criteria,and procedures for the evaluation of projects and the
preparation of environmental impact reports and negative declarations in connection with that evaluation; and
WHEREAS,similarly,in circumstances where public agencies decide to develop their own thresholds of
significance for general use as a part of the public agency’s environmental review process,section 15064.7 of
the CEQA Guidelines require such thresholds of significance be adopted by ordinance,resolution,rule or
regulation, and be developed through a public review process and be supported by substantial evidence; and
WHEREAS,the City of South San Francisco,as a lead agency,implements CEQA pursuant to South San
Francisco Municipal Code Chapter 20.460 Environmental Review,which delegates administration to the Chief
Planner; and
WHEREAS,City staff prepared a proposed Vehicle Miles Traveled Thresholds of Significance,attached hereto
and incorporated herein as Exhibit A, to incorporate the most recent State VMT requirements; and
WHEREAS,the Technical Advisory on Evaluating Transportation Impacts in CEQA (2018)provide substantial
evidence that VMT is an appropriate standard to utilize in analyzing transportation impacts to protect
environmental quality and a better indicator of greenhouse gas,air quality,and energy impacts than LOS,and
that the screening criteria and impact analysis contained therein are appropriate metrics for assessing VMT
impacts and determining thresholds of significance; and
WHEREAS,the identification and adoption of proposed VMT regulations is not a “project”pursuant to CEQA
as defined in CEQA Guidelines Section 15378,and is therefore not subject to review pursuant to CEQA
Guidelines Section 15060(c)(3).Separately and independently,the proposal is also exempt pursuant to CEQA
Guidelines Section 15061(b)(3),as it will not result directly or indirectly in significant environmental impacts;
and/or Public Resources Code Section 21080(b)(1),as the proposal is ministerial,because the City is mandated
to adopt the proposal.As such,the new thresholds are categorically exempt pursuant to CEQA Guidelines
Section 15308 and none of the exceptions in Section 15300.2 apply; and
WHEREAS,the Planning Commission held a lawfully noticed public hearing May 21,2020 to solicit public
comment and consider the proposed the proposed VMT thresholds and take public testimony,at which time all
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File #:20-312 Agenda Date:5/21/2020
Version:1 Item #:2a.
comment and consider the proposed the proposed VMT thresholds and take public testimony,at which time all
persons wishing to testify in connection with the proposed threshold
were heard and the proposed threshold was comprehensively reviewed.
NOW,THEREFORE,BE IT RESOLVED that based on the entirety of the record before it,which includes
without limitation,the California Environmental Quality Act,Public Resources Code §21000,et seq.
(“CEQA”)and the CEQA Guidelines,14 California Code of Regulations §15000,et seq.;the South San
Francisco General Plan and General Plan EIR;the proposed VMT Thresholds of Significance;and all reports,
minutes,and public testimony submitted as part of the Planning Commission’s duly noticed May 21,2020
meeting;and any other evidence (within the meaning of Public Resources Code §21080(e)and §21082.2),the
Planning Commission of the City of South San Francisco hereby finds as follows:
SECTION 1 FINDINGS
A.General Findings
1.The foregoing recitals are true and correct and made a part of this Resolution.
2.The proposed VMT Thresholds of Significance,attached hereto as Exhibit A,is incorporated by
reference and made a part of this Resolution, as if set forth fully herein.
3.The documents and other materials constituting the record for these proceedings are located at the
Planning Division for the City of South San Francisco,315 Maple Avenue,South San Francisco,CA 94080,
and in the custody of the Planning Manager, Sailesh Mehra.
B.CEQA Finding
1.The adoption of proposed VMT Thresholds of Significance is not a “project”pursuant to CEQA as
defined in CEQA Guidelines Section 15378,and is therefore not subject to review pursuant to CEQA
Guidelines Section 15060(c)(3).
2.Separately and independently,the proposal is also exempt pursuant to CEQA Guidelines Section 15061
(b)(3),as it will not result directly or indirectly in significant environmental impacts;and/or Public
Resources Code Section 21080(b)(1),as the proposal is ministerial,because the City is mandated to adopt
the proposal.As such,adoption of proposed new thresholds are categorically exempt pursuant to CEQA
Guidelines Section 15308 and none of the exceptions in Section 15300.2 apply.
C.Adoption of Thresholds of Significance Findings
1.The proposed VMT Thresholds of Significance in Exhibit A is consistent with the adopted General Plan
because they will reinforce the General Plan policies,and is consistent with the City’s overall vision to
reduce greenhouse gas emissions and Climate Action Plan policies to expand active transportation
alternatives,support expansion of public and private transit programs to reduce employee commutes,and
integrate higher-density development and mixed-use development near transit facilities.None of the new or
revised VMT Thresholds of Significance will conflict with or impede any of the goals,policies,or land use
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revised VMT Thresholds of Significance will conflict with or impede any of the goals,policies,or land use
designations established in the General Plan.
2.The proposed VMT Thresholds of Significance have been developed through a public review process
that includes an opportunity for the public to review and comment on the proposed VMT Thresholds of
Significance and a duly noticed public hearing by the South San Francisco Planning Commission to
consider the methodology changes and to consider public comment on those changes.
3.The proposed VMT Thresholds are supported by substantial evidence based on the entirety of the record
before the Planning Commission including all documents, submittals, and public testimony before it.
SECTION 2 RECOMMENDATION
NOW,THEREFORE,BE IT FURTHER RESOLVED that the Planning Commission of the City of South San
Francisco hereby makes the findings contained in this Resolution and recommends that the City Council adopt
the proposed VMT Thresholds of Significance in Exhibit A and update the City of South San Francisco’s
transportation impact analysis thresholds,as required by the California Environmental Quality Act (CEQA),to
comply with state-mandated change from level of service (LOS)to vehicle miles traveled (VMT),pursuant to
Senate Bill 743 (2013) and new 2019 CEQA Guidelines.
BE IT FURTHER RESOLVED that the resolution shall become effective immediately upon its passage and
adoption.
******
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City of South San Francisco Significance Thresholds
for Transportation
Consistent with State CEQA guidelines section 15064.3, the City of South San
Francisco has adopted the thresholds of significance set forth in Table 1 to guide in
determining when a project will have a significant transportation impact.
Table 1
Vehicle Miles Traveled VMT Impact Thresholds
Project Type Threshold (when screening does not apply)
Land Use Plan A significant impact would occur if the plan would
result in a net increase in Total VMT and VMT per
capita1 is more than 15% above the applicable
Baseline VMT2.
Land Use Project
(non-retail)
A significant impact would occur if the VMT1 for
the project would be 15% below the applicable
Baseline VMT2.
Retail Project The project would result in a net increase in Total
VMT.
Transportation Project The project would result in a net increase in Total
VMT.
Note:
1. VMT to be reported as VMT per Service Population, VMT per resident, or VMT per employee.
2. Baseline VMT is defined as the nine-county Bay Area average for total, residential, or
employee VMT.
Certain projects may qualify for VMT screening based on the criteria presented in
Table 2. Projects screened from requiring a VMT analysis would not have an impact
under State CEQA Guidelines section 15064.3 and can be discussed qualitatively.
The following activities generally will not require a TIA that includes VMT. This
presumption is based on the substantial evidence provided in the OPR Technical
Advisory supporting SB 743 implementation or is related to projects that are local
serving which, by definition, would decrease the number of trips or the distance those
trips travel to access the development (and are VMT-reducing projects).
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Table 2
Vehicle Miles Traveled Screening Options
Screening Category Screening Criteria
Project type screening Presumed less than significant impact for:
Local-serving K-12 schools and day care
centers
Local parks
Local-serving banks
Local-serving hotels (e.g. non-destination
hotels)
Local-serving retail projects (defined as less
than 50,000 square feet per OPR’s Technical
Advisory)
100 percent affordable residential
developments
Local serving community colleges that are
consistent with the assumptions noted in the
RTP/SCS
Projects generating less than 110 daily vehicle
trips.1 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 industrial2
63,000 sq. ft. of warehousing2
Low VMT area screening Presumed less than significant VMT impact for
residential and office projects located in low VMT
areas. These areas generate total daily VMT that is
15% less than the Baseline VMT. In South San
Francisco, there are many low VMT residential areas
and no low VMT office areas.
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 use of the site; however, if an alternate threshold is used it is to be memorialized through a use restriction placed on the site through agreement with the project applicant. This number was estimated using rates
from ITE’s Trip Generation Manual.
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High-quality transit area
screening
Presumed less than significant VMT impact for
projects located within ½-mile of high-quality transit
that do not have the following characteristics:
o Floor Area Ratio (FAR) < 0.75
o More parking than required by City
o Inconsistent with the applicable SCAG RTP/SCS
(as determined by the City)
o Replacing affordable housing units with market-
rate units
In South San Francisco, the high-quality transit
definition is currently limited to service provided by
Samtrans routes 130 and ECR.
Transportation projects Transportation projects that promote non-auto
travel, improve safety, or improve traffic operations
at current bottlenecks, such as transit, bicycle and
pedestrian facilities, intersection traffic control
(e.g., traffic signals or roundabouts), or widening
at intersections to provide new turn lanes.
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