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
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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
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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
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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
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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
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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.