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HomeMy WebLinkAboutItem 07c - Vehicle Miles Traveled DATE: June 16, 2020 TO: Honorable Mayor and City Council FROM: Jason Kruckeberg, Assistant City Manager/Development Services Director Philip A. Wray, Deputy Director of Development Services/City Engineer SUBJECT: RESOLUTION NO. 7312 CONCERNING “VEHICLE MILES TRAVELED” THRESHOLDS OF SIGNIFICANCE FOR PURPOSES OF ANALYZING TRANSPORTATION IMPACTS UNDER THE CALIFORNIA ENVIRONMENTAL QUALITY ACT (“CEQA”); AND FINDING THAT THIS ACTION IS CONSISTENT WITH THE CITY OF ARCADIA GENERAL PLAN Recommendation: Adopt SUMMARY On September 27, 2013, Governor Jerry Brown signed SB 743 into law, which is intended to fundamentally change how transportation impact analysis is conducted as part of project review under the California Environmental Quality Act (“CEQA”). The State of California Office of Planning and Research (“OPR”) has developed the framework for implementation of SB 743, which eliminates Level of Service (“LOS”) as the basis for determining transportation impacts under CEQA and requires the use of Vehicle Miles Traveled (“VMT”) instead. Cities must begin using VMT analysis on July 1, 2020, and in order to do so, must adopt thresholds of significances from which to analyze VMT. To assist the San Gabriel Valley cities in making the transition to VMT based transportation analysis, the San Gabriel Valley Council of Governments (“SGV COG”) coordinated a VMT study for the region. The study provided guidance for cities to select their own specific thresholds and criteria for VMT Analysis. This report includes a brief discussion of the critical thresholds and criteria, identifies the City of Arcadia’s recommendations, addresses General Plan consistency, and includes a resolution to adopt the new thresholds of significance. Resolution 7312 – Vehicle Miles Traveled June 16, 2020 Page 2 of 6 It is recommended that the City Council adopt Resolution No. 7312 concerning “Vehicle Miles Traveled” Thresholds of Significance for purposes of analyzing transportation impacts under CEQA; and find that this action is consistent with the City of Arcadia General Plan. BACKGROUND For many years, transportation impact analysis of new development projects for CEQA purposes has been based on travel delay using LOS as the measure of impact on streets and intersections. LOS is essentially a method of “grading” the impact of traffic on a City’s street system based on the amount of wait time found at an individual intersection. An intersection might be given a LOS of “A” for a very short wait time or little impact, to a LOS “F” for very long wait times and significant impacts. The General Plan Circulation Element sets a minimum acceptable standard of LOS “D” for all streets and intersections in the City, with certain exceptions. State law under SB 743 requires cities to use VMT instead of LOS as the measure of impact on development for CEQA purposes, and to adopt new thresholds of significance for analysis. VMT is the measure of the amount and distance of automobile travel attributable to a project. The State’s goal in changing to VMT is to encourage land use and transportation decisions that reduce greenhouse gas emissions, encourage infill development, and improve public health through active transportation. Therefore, while the previously used LOS criteria evaluated impacts very specific to a City, the VMT methodology focuses on regional impacts. SB 743 requires that cities have the basic thresholds and criteria for their analysis in place by July 1, 2020 to begin transportation analysis using VMT. In late 2019, the City of Arcadia joined 25 other cities in the San Gabriel Valley to share in the cost of a study to assist the cities with establishing their thresholds and criteria. The study was conducted by Fehr and Peers (“F&P”) and was coordinated by the SGV COG. DISCUSSION The F&P study identifies the specific thresholds and criteria that must be adopted by local jurisdictions in order to evaluate VMT on projects for CEQA purposes. The three primary thresholds and criteria are project screening criteria, baseline VMT thresholds, and VMT significant impact thresholds. Making these decisions now will establish the type of projects that will need to be reviewed through environmental analysis, and the scope of when and how to review them. The following is a brief discussion of each of these decision points, and the recommendation for each. Resolution 7312 – Vehicle Miles Traveled June 16, 2020 Page 3 of 6 Project Screening Criteria OPR recognizes that certain projects have an inherent local benefit and there is no need for VMT analysis. In other words, these types of projects do not have a regional impact and it is unnecessary to spend time and resources evaluating them. There are four (4) recommended categories of projects that can be “screened out”, or removed from the VMT review process, as follows: Project Type Screening – OPR recognizes that certain project types provide mostly local benefits and thus the VMT per vehicle trip are very low. Because of this, OPR recommends that certain local-benefiting projects be screened out from VMT analysis for CEQA purposes, as follows: • Local benefiting retail projects up to 50,000 square feet in floor area • Projects generating less than 110 daily trips (equivalent of eight (8) single-family residences) • K–12 public schools • Pre-K child care/daycare • Affordable housing • Student housing • Public facilities (Libraries, Community Centers, City Halls, etc.) • Local serving churches • Assisted living Low VMT Area Screening – Southern California Association of Governments (“SCAG”) has created a regional VMT model that divides the SCAG region into many small Traffic Analysis Zones (“TAZ”). Each TAZ has an assigned average VMT based on the uses in that zone. Arcadia is divided into 37 TAZs. Project VMT analysis will be based on the current VMT for the TAZ where the project is located. OPR recommends screening out residential and office projects located in low VMT TAZs. Low VMT is defined as 15% below the City’s Baseline VMT. Transit Priority Area (“TPA”) Screening – OPR defines Transit Priority Areas as locations within ½ mile of a transit stop/station with a minimum of 15-minute headways during peak commute hours. OPR recommends screening out projects within a TPA. Arcadia has several TPAs along its major transit corridors and at the Gold Line Station. Affordable Housing Screening – OPR recommends screening out affordable housing developments or affordable housing units within mixed-use developments. The City of Arcadia’s recommendation is to adopt all of the recommended Screening Criteria as stated above, and “screen out” projects that meet these criteria from further VMT review. Resolution 7312 – Vehicle Miles Traveled June 16, 2020 Page 4 of 6 Baseline VMT Threshold SB 743 requires each city to adopt a Baseline VMT threshold from which to evaluate new projects. The San Gabriel Valley COG study identified four (4) thresholds for the cities to choose from, or a city can choose its own baseline through its own analyses. Cities are cautioned to select a baseline that is reasonably justified and supportable. For Arcadia, the study identifies four (4) choices for a VMT Baseline per service area population as follows: • The overall SCAG area average – 36.09 • The San Gabriel Valley Council of Governments (“SGV COG”) Region average – 36.12 • The SGV COG Northwest sub-region average (which includes Arcadia) – 37.02 • The City of Arcadia average – 36.42 These numbers represent the average VMT per person per day, averaged over the service population (all residents and visitors) for that particular region. These numbers are derived from a study conducted by SCAG in 2016. It should be noted that the City’s selection is only for the region-type, and is not the actual number that will be used for studies over time. The VMT numbers will change from year to year as population and employment change within the sub-region selected. The City of Arcadia’s recommendation is to adopt the SGV COG Northwest sub-regional Baseline to be consistent with neighboring cities in the sub-region, and to allow the most flexibility for evaluating projects. VMT Significant Impact Threshold An important component of CEQA work is to determine at what point a “significant impact” takes place. For evaluating a new project for VMT impacts, OPR recognizes four (4) categories of CEQA analysis, and recommends the following significant impact thresholds for each: • Land Use Plans (such as a Specific Plan): Significant impacts would occur if the VMT per service population for the land use plan exceeds 15% below the Baseline VMT. So, for example, if the VMT for a Land Use Plan exceeds 31.47 (15% below 37.02), a significant impact would occur. • Land Use Projects: Significant impacts would occur if a project generates VMT exceeding 15% below the Baseline VMT. • Retail Projects: Significant impacts would occur if a project generates VMT exceeding 15% below the baseline VMT. • Transportation Projects: Significant impacts would occur if the projects result in a net increase in VMT. Resolution 7312 – Vehicle Miles Traveled June 16, 2020 Page 5 of 6 The City of Arcadia’s recommendation is to adopt all the recommended Significant Impact Thresholds as stated above. By adopting the recommended project screening criteria, baseline VMT threshold, and VMT significant impact thresholds listed above, the City will be establishing a realistic and fair set of criteria for review of transportation and traffic impacts. For most environmental studies in Arcadia, traffic and transportation are the primary concern, and the most significant impact evaluated. These criteria will standardize the review of these impacts for future projects and will modernize Arcadia’s approach to this review in compliance with State law. The recommended criteria can all be approved by adopting Resolution No. 7312, and the associated Exhibit “A”. It is important to note that outside of the CEQA process, the LOS criteria will still be used to evaluate project impacts on the City’s streets and intersections, and conditions of approval will be applied where necessary as part of the project review process. GENERAL PLAN CONSISTENCY SB 743 tasked OPR with selecting alternative criteria for evaluating transportation impacts that “promote the reduction of greenhouse gas emissions, the development of multimodal transportation networks, and a diversity of land uses.” The update to the Transportation Section of the CEQA threshold is in substantial conformance with the purpose, intent, and provisions of the Arcadia’s General Plan Land Use and Community Design and Circulation and Infrastructure Elements, and it will not amend any portion of the City’s General Plan. As such, the changes are in conformance with the goals, objectives, and policies of the City’s General Plan. ENVIRONMENTAL ANALYSIS The adoption of the proposed update to the Transportation Section of the California Environmental Quality Act (CEQA) is not a “project” pursuant to CEQA as defined in the CEQA Guidelines Section 15378, and is therefore not subject to the CEQA Guidelines per section 15061(c)(3). As such, the new thresholds are categorically exempt pursuant to CEQA Guidelines Section 15308. FISCAL IMPACT There is no fiscal impact to the City as a result of this action. RECOMMENDATION It is recommended that the City Council find that the proposed Update to the Transportation section of CEQA will not have a significant environmental impact and is exempt from CEQA pursuant to Section 15308, adopt Resolution No. 7312 adopting “Vehicle Miles Traveled” thresholds of significance for purposes of analyzing Resolution 7312 – Vehicle Miles Traveled June 16, 2020 Page 6 of 6 transportation impacts under the California Environmental Quality Act (“CEQA”); and find that this action is consistent with the City of Arcadia General Plan. Attachment: Resolution No. 7312 City of Arcadia Significance Thresholds for Transportation Consistent with State CEQA guidelines section 15064.3, the City of Arcadia 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 Thresholds Land Use Plan 1) Project Impact: A significant impact would occur if the VMT rate for the plan would exceed a level of 15% below the applicable baseline VMT rate. 2) Project Effect: A significant impact would occur if the project increases total regional VMT compared to cumulative no project conditions. Land Use Project 1) Project Impact: A significant impact would occur if the VMT rate for the project would exceed a level of 15% below the applicable baseline VMT rate. 2) Project Effect: A significant impact would occur if the project increases total regional VMT compared to baseline conditions. Retail Project 1) Project Impact: A significant impact would occur if the VMT rate for the project would exceed a level of 15% below the applicable baseline VMT. 2) Project Effect: A significant impact would occur if the project increases total VMT in the study area compared to baseline conditions. Transportation Project A significant impact would occur if the project causes a net increase in total regional VMT compared to baseline conditions, opening year no project conditions, or cumulative no project conditions. All land use and transportation projects A significant impact would occur if the project is inconsistent with the RTP/SCS. Note: 1. VMT to be reported as VMT per Service Population, VMT per capita, or VMT per employee. 2. The Baseline VMT rate is defined as the San Gabriel Valley Council of Governments Northwest Sub-Region per applicable service population.