HomeMy WebLinkAboutStaff Report 4.B 12/17/2018• •
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DATE: December 17, 2018
TO: Honorable Mayor and Members of the City Council through City Manager
FROM: Heather Hines, Planning Manager
SUBJECT: Resolution Authorizing the City Manager to Execute a Professional Services
Agreement with Fehr & Peers for Transportation Consulting Services to Develop
Thresholds, Implementation Criteria, and Guidelines for Vehicle Miles Traveled
Consistent with SB 743 and to Update the General Plan
RECOMMENDATION
It is recommended that the City Council adopt the attached resolution authorizing the City
Manager to execute a Professional Services Agreement with Fehr & Peers for transportation
consulting services to develop thresholds, implementation criteria, and guidelines for Vehicle
Miles Traveled consistent with SB 743 and to update the General Plan.
BACKGROUND
In 2006, the California Legislature passed Assembly Bill 32, California Global Warming Solutions
Act, which created a comprehensive, multi-year program to reduce greenhouse gas (GHG)
emissions. AB 32 required the California Air Resources Board (CARB) to develop a Scoping Plan
that describes the approach to reduce GHG emissions to 1990 levels by 2020. CARB developed
the first Scoping Plan in 2008 and updated it in May 2014. Another update is currently underway
to reflect implementation progress and the revised target of reducing GHG emissions to 40% below
1990 levels by 2030 as required by Executive Order B-30-15 and codified by SB 32 (2016).
Senate Bill 743, Level of Service Standards, was signed into law in September 2013 to implement
AB 32 targets by reducing GHG emissions associated with the transportation sector. SB 743
initiated a process to update how transportation impacts are evaluated under the California
Environmental Quality Act (CEQA). The bill eliminates level of service (LOS) and other similar
measures as a basis for determining whether projects result in significant traffic impacts under
CEQA because these metrics were found to encourage development patterns and travel activity
associated with relatively higher transportation -related GHG emissions. SB 743 required the
Governor's Office of Planning and Research (OPR) to update the CEQA Guidelines to define
"criteria for determining the significance of transportation impacts of projects within transit
priority areas... [to] promote the reduction of greenhouse gas emissions, the development of
multimodal transportation networks, and a diversity of land uses." In 2013, OPR explored options
for an LOS alternative that would achieve these goals.
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In 2014, after analyzing LOS alternatives, OPR found that Vehicle Miles Travelled (VMT) would
achieve SB 743 goals and AB 32 targets for the transportation sector by, among other benefits,
reducing the traffic impact mitigation burden on infill projects; reducing roadway expansion as a
mitigation measure; and lowering air pollution, GHG emissions, and energy demand by reducing
vehicular trip lengths. Thus, OPR published a revised CEQA Guidelines §15064.3 to establish
VMT as the preferred metric for traffic impact analysis. Following statewide review and input,
OPR further refined the CEQA Guidelines and published two Technical Advisory documents (in
November 2017 and April 2018) to assist with local implementation of VMT as the traffic impact
criterion for CEQA. Upon the completion of the "rulemaking" process to update the CEQA
Guidelines, SB 743 will go into effect, however local agencies have an opt -in period until July 1,
2020 to evaluate OPR CEQA guidance on SB 743 and to potentially implement local guidelines.
DISCUSSION
LOS measures how a proposed project affects the delay that drivers experience through
intersections or roadway segments connected to a project. VMT, in contrast, measures the total
amount of driving resulting from a project. LOS is measured on an alphabetic ranking scale where
LOS "A" represents free flow and LOS "F" represents congested conditions with excessive delays.
Petaluma's General Plan 2025 Mobility Element, Policy 5-P-10 establishes the acceptable LOS
level for projects:
Maintain an intersection level of service (LOS) standard for motor vehicle
circulation that ensures efficient traffic flow and supports multi -modal mobility
goals. LOS should be maintained at Level D or better for motor vehicles due to
traffic from any development project.
The transition to a VMT evaluation metric through SB 743 is focused on the project's CEQA
review. Currently, a project that caused LOS to degrade below level D would create an impact
with respect to General Plan 2025 Policy 5-P-10 and would be found to generate a significant
traffic impact under CEQA. With SB 743 implementation, the same project would create an impact
with respect to the General Plan 2025, but it would be found to generate a significant traffic impact
under CEQA only if the VMT generated by the project exceeded acceptable thresholds.
Analyzing VMT relies on using a travel demand model that considers baseline VMT conditions
for the model area, VMT generation rates based on development type (e.g. the proposed land uses
or transportation improvements), and other factors that influence travel behavior (e.g. density of
activity in an area, infrastructure, economic activity, etc.). Projects are assessed on whether they
generate VMT beyond identified thresholds relative to baseline conditions. In the updated CEQA
Guidelines OPR has provided recommendations on the threshold levels to be applied statewide
based on a broad survey of VMT conditions and what is necessary to achieve AB 32 goals for
GHG reduction. However, travel behavior, baseline conditions, and VMT implications are highly
context specific. The proposed Project seeks to calibrate the OPR recommendations on VMT
implementation to ensure that projects are appropriately evaluated pursuant to CEQA within the
Petaluma context.
On July 9, 2018 City staff and the transportation consulting firm Fele & Peers facilitated a joint
workshop with the Petaluma City Council and Planning Commission on SB 743 implementation
in anticipation of the proposed Project. This presentation provided background on SB 743 and the
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development of OPR's CEQA Guidelines update to incorporate VMT as the metric for traffic
impact analysis.I
Senate Bill 1 (Beall, 2017) created a funding plan for various transportation programs across the
State. More than 80 percent of the funding under SB -1 is reserved for programs that solely fund
projects that will be analyzed using VMT, and which would be streamlined under CEQA because
they would not increase VMT. The proposed project to calibrate VMT implementation under
CEQA to the Petaluma context will help ensure that CEQA streamlining is available to appropriate
projects in the City and make local projects more competitive for SB -1 funding.
Anticipating the implementation of SB 743, the Petaluma City Council adopted as part of its Goals
and Priorities for 2017 and 2018, Goal III to Establish/Revise Local Legislation, which sets as
Priority #1: Review, and Amend the Elements of the General Plan 2025 to Reflect Changes Since
its Adoption in 2008. Task "e" under this priority is to "update acceptable traffic CEQA thresholds
to transition from LOS to VMT, in keeping ivith anticipated state CEQA guidelines."
Pursuant to California Government Code Section 65358, the City of Petaluma can only amend a
mandatory Element of the General Plan up to four times per calendar year. Subject to that
limitation, an amendment may be made at any time, as determined by the local legislative body.
Separate amendments may be combined and evaluated together as one amendment action.
However, the effectiveness of the General Plan lies in its consistency and integrity in maintaining
the public interest over the long term. Therefore, the General Plan should not be changed without
careful consideration. The proposed project is expected to result in policy changes within the
Mobility Element of the Petaluma General Plan 2025 to reflect the transition to a VMT-basis for
CEQA analysis, at a minimum. The project is expected to be completed in 2020 and will constitute
one of the four permitted General Plan amendments in that year. At this time, no other General
Plan amendments are anticipated in 2020 at this time.
On July 1, 2020, VMT will replace LOS as the CEQA metric for traffic impact analysis across
California: Following a comprehensive review of published data to identify feasible and necessary
VMT reductions that would meet AB 32 GHG reduction targets statewide, OPR established
thresholds of significance for project -generated VMT that would determine whether the project
created a significant traffic impact (Attachment 2). OPR also provided VMT implementation
criteria to support these thresholds. OPR-recommended thresholds of significance are provided in
Attachment 3. After July 2020, it is recommended that local agencies utilize OPR's thresholds and
VMT-based criteria unless local guidelines and thresholds are adopted.
OPR's recommended thresholds of significance and implementation criteria do not account for
local conditions that affect transportation behavior and transportation -related GHG emissions.
Alternatively—and more appropriate—thresholds and implementation criteria may be established
1 The presentation and accompanying staff report are available for review at
http://petaluma.granicus.com/GeneratedAgendaViewer.php?view id=31&clip_id=2541
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by local agencies so long as substantial evidence is provided to demonstrate how the revised
thresholds and criteria achieve the three core objectives of SB 743: reducing transportation -related
GHG emissions, encouraging infill, and promoting active transportation. The proposed Project
will establish thresholds and VMT implementation criteria calibrated to the Petaluma context. The
Project will address the following key questions:
What are the parameters for setting local VMT criteria?
The Project will assess OPR's recommended implementation criteria to develop an
understanding of the requirements for establishing a transportation impact metric to replace
LOS and the associated thresholds of significance in the Petaluma context.
What is the baseline condition and when do projects create significant impacts?
The Project will evaluate baseline conditions in Petaluma and establish defensible local
thresholds of significance. Baseline VMT conditions are needed to ensure that local VMT
thresholds are supported by substantial evidence as required by CEQA Guidelines §15064.7;
and that local thresholds address the three core objectives of SB 743.
When projects create traffic impacts by generating excessive VMT, which options are available
for mitigating those impacts?
After defining baseline conditions and proposing local VMT thresholds of significance, the
Project will identify VMT reduction strategies and their efficacy in the Petaluma context that
may be used when projects exceed local VMT thresholds of significance.
What role will LOS have in the community when VMT is used for CEQA review?
The Project will identify when LOS -based criteria continued to be appropriate for transportation
analyses in Petaluma outside of CEQA's traffic impact analysis and will provide
recommendations on how to revise existing LOS -based General Plan policies to ensure the
appropriate review criteria are applied to all projects.
The Project scope was developed in consultation with Fehr & Peers and the Sonoma County
Transportation Authority (SCTA) to ensure it is comprehensive, appropriate to the purpose, and
achievable within the timeframe and budget identified. Due to their involvement in preparing the
OPR guidance on VMT implementation, Fehr & Peers is uniquely experienced to advise on the
scope for the project.
A detailed scope of work for the project is provided in Attachment 1, Exhibit A. The project is
expected to be completed in time for the July 2020 implementation of SB 743. The anticipated
budget for the scope of work is $108,500 with optional tasks totaling an additional $27,000. It is
anticipated that Fehr & Peers will be contracted to conduct the scope of work for the Project
(Attachment 1, Exhibit B) and the project would commence as soon as the contract is executed.
The scope of work for the Project includes optional Task 5, General Plan Update Support, for the
transportation consultant to assist staff with incorporating the results of the Project into the
Petaluma General Plan and processing the General Plan Amendment. Updates may include
updated figures, tables and map exhibits along with updated or new narratives, goals, policies, and
programs to reflect the outcomes of the Project. Work completed for Tasks 1-4 will inform whether
the consultant is needed and in what capacity to assist with the completion of Task 5, which will
be led by staff.
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The Project has been reviewed under the provisions of the California. Environmental Quality Act
(CEQA) Guidelines. The scope of work of entails a study to determine alternative VMT thresholds
and implementation criteria for the City. Authorizing funding for a study will not in and of itself
institute a material change in the environment; therefore, pursuant to §15061(b)(3) (Review for
Exemption, General Rule) of the CEQA Guidelines, there is no possibility that the study may have
a significant effect on the environment. Furthermore, the study is Categorically Exempt pursuant
to CEQA Guidelines §15306, Information Collection, in that the Project constitutes information
gathering as part of a study leading to an action which a public agency has not yet approved or
adopted.
The environmental impacts of any alternative VMT thresholds and implementation criteria will be
considered once the Project deliverables are completed and alternative CEQA Guidelines are
provided to the City for review and adoption.
FINANCIAL IMPACTS
The Project budget totals $108,500, with a contingency of $27,000 to cover optional Task 5. This
allocation is not identified in the FY 18/19 budget. A budget adjustment will be brought forward
in conjunction with all other mid -year budget adjustments. The Project has been identified in the
City Council Goals and Priorities for 2017/18 and constitutes a General Plan 2025 update. The
City collects a portion of development impact fees into a General Plan Update Fund to finance
necessary General Plan 2025 updates; the implementation of updated standards for evaluating
traffic impacts in Petaluma would constitute a General Plan Update, -and such a study would
typically be conducted within the scope of a comprehensive General Plan Update. The General
Plan Update Reserve Fund is an appropriate funding source for the Project. The current fund
balance available at June 30, 2018 and reserved for this purpose is approximately $1.3 million.
ATTACHMENTS
Attachment 1. Resolution authorizing the City Manager to enter into a contract with Fehr
& Peers
Exhibit A. Project Scope
Attachment 2. CEQA Guideline Implementing SB 743 (§15064.3).
Attachment 3. OPR Technical Advisory on Evaluating Transportation Impacts in CEQA.
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ATTACHMENT 1
RESOLUTION OF THE CITY COUNCIL AUTHORIZING THE CITY MANAGER TO
EXECUTE A PROFESSIONAL SERVICES AGREEMENT WITH FEHR & PEERS FOR
TRANSPORTATION CONSULTING SERVICES TO DEVELOP THRESHOLDS,
IMPLEMENTATION CRITERIA, AND GUIDELINES FOR VEHICLE MILES
TRAVELED CONSISTENT WITH SB 743 AND TO UPDATE THE GENERAL PLAN
WHEREAS, the Petaluma City Council passed Resolution 2008-084 N.C.S on May 19,
2008 adopting the General Plan 2025, a comprehensive and integrated statement of development
policies and principles that guide future growth and development within Petaluma; and
WHEREAS, on September 27, 2006, the California Legislature passed Assembly Bill 32,
California Global Warming Solutions Act, which created a comprehensive, multi-year program to
reduce greenhouse gas (GHG) emissions; and
WHEREAS, Assembly Bill 32 required the California Air Resources Board (CARB) to
develop a Scoping Plan that describes the approach to reduce GHG emissions in California to
targeted levels as revised and updated from time to time to reflect climate science and
implementation feasibility; and
WHEREAS, pursuant to the CARB Scoping Plan, Senate Bill 743, Level of Service
Standards, was signed into law on September 27, 2013 to reduce GHG emissions associated with
the transportation sector by eliminating level of service (LOS) and other similar measures as a
basis for determining whether projects result in significant traffic impacts under the California
Environmental Quality Act (CEQA) because such metrics were found to encourage development
patterns and travel activity with relatively higher transportation -related GHG emissions; and
WHEREAS, SB 743 required the Governor's Office of Planning and Research (OPR) to
update the CEQA Guidelines to define "criteria for determining the significance of transportation
impacts of projects within transit priority areas... [to] promote the reduction of greenhouse gas
emissions, the development of multimodal transportation networks, and a diversity of land uses;"
and
WHEREAS, on December 30, 2013 OPR concluded and published a study, Preliminary
Evaluation of Alternative Methods of Transportation Analysis, and determined that Vehicle Miles
Travelled (VMT) is a preferred metric to replace LOS to evaluate traffic impacts pursuant to
CEQA and in accordance with SB 743; and
WHEREAS, on August 6, 2014 OPR published a preliminary discussion draft of updated
CEQA Guidelines §15064.3 to adopt VMT as the preferred metric to evaluate traffic impacts in
accordance with SB 743, and then published an updated CEQA Guidelines following public input
on January 20, 2016; and
WHEREAS, upon the completion of the "rulemaking" process to adopt the updated CEQA
Guidelines § 15 064.3, SB 743 goes into effect throughout California and agencies will have an opt -
in period until July 1, 2020 to evaluate and prepare to implement the updated CEQA Guidelines
or to implement local guidelines consistent with SB 743; and
WHEREAS, in the updated CEQA Guidelines §15064.3 implementing SB 743, OPR
recommends thresholds of significance and implementation criteria for local jurisdictions to
evaluate traffic impacts using VMT; however, travel behavior, baseline conditions, and VMT
implications are highly context specific and OPR guidance is not calibrated to the Petaluma
context; and
WHEREAS, the City of Petaluma General Plan 2025 Mobility Element Policy 5-P-10
establishes a Level -of -Service standard for determining whether projects may have a significant
impact on the environment; and
WHEREAS, the Petaluma City Council adopted as its Goals and Priorities for 2017 and
2018, Goal III, to EstablishlRevise Local Legislation, which sets as Priority #1: Revie}a, and Amend
the Elements of the General Plan 2025 to Reflect Changes Since its Adoption in 2008. Task "e"
under this priority is to "update acceptable traffic CEQA thresholds to transition ftom LOS to
VMT; in keeping with anticipated state CEQA guidelines"; and
WHEREAS, on July 9, 2018 the Petaluma City Council and Planning Commission held a
joint workshop to hear a presentation from City staff and transportation consultants at Fehr & Peers
on SB 743 and the implications of adopting local VMT thresholds and implementation criteria, at
which time the City Council and Planning Commission advised staff to pursue a scope of work to
develop and adopt local thresholds and criteria; and
WHEREAS, staff developed a scope of work (the "Project") to prepare local VMT
thresholds of significance and implementation criteria in consultation with transportation
consultants Fehr & Peers, and the Sonoma County Transportation Authority to be completed for
$108,500 with optional tasks totaling $27,000; and
WHEREAS, the Project constitutes a study and is exempt from further environmental
review under CEQA pursuant to CEQA Guidelines §15061(b)(3) ("General Rule"), as it can be
seen with certainty that there is no possibility that the study may have a significant effect on the
environment, and CEQA Guidelines §15306 ("Information Collection"), in that the Project
constitutes information gathering as part of a study leading to an action which a public agency has
not yet approved or adopted; and
WHEREAS, on December 17, 2018 at a duly noticed meeting the City Council considered
the staff report dated December 17, 2018 describing and analyzing the Project, including the
CEQA determination included therein; and
NOW, THEREFORE, BE IT RESOLVED, that the City Council of the City of Petaluma hereby
authorizes the City Manager to execute an agreement to fund the City of Petaluma SB 743
Implementation and General Plan Update Project, as presented in Exhibit A, in an amount up to
$135,500, subject to approval by the City Manager of the final agreement terms, as set forth in a
Professional Services Agreement, and confirmed by the City Attorney that the agreement terms
appropriately address the needs of the project and the City's interests.
ATTACHMENT 1– EXHIBIT A
All, �Wl] 1111111111:2:10
SB743 IMPLEMENTATION AND GENERAL
PLAN UPDATE
JOHN BROWN, CITY MANAGER MILAN NEVAJDA, SENIOR PLANNER
JBROWN@CI.PETALUMA.CA.US MNEVAJDA@M-GROUP.US
707-778-4345 707-540-0723 x 204
11 ENGLISH STREET 499 HUMBOLDT STREET
PETALUMA, CA 94952 SANTA ROSA, CA 95404
PROJECT PURPOSE
Senate Bill 743 – Level of Service Standards was signed into law September 2013 to implement AB 32—the California
Global Warming Solutions Act of 2006—which initiated a process to update how transportation impacts will be
evaluated in accordance with the California Environmental Quality Act (CEQA). SB 743 eliminates auto delay, level
of service (LOS), and other similar measures of vehicular capacity or traffic congestion as a basis for determining
ATTACHMENT 1— EXHIBIT A
whether projects result in significant impacts under CEQA. SB 743 requires the Governor's Office of Planning and
Research (OPR) to update the CEQA Guidelines to define "criteria for determining the significance of transportation
impacts of projects within transit priority areas... [to] promote the reduction of greenhouse gas emissions, the
development of multimodal transportation networks, and a diversity of land uses."
OPR issued options for setting metrics to achieve the intent of SB 743 in 2013. OPR has recommended Vehicle Miles
Travelled (VMT) as the criteria for evaluating transportation impacts and issued the first draft of the CEQA Guidelines
update in 2014 to this effect. Following Statewide review and input on the draft Guidelines update, OPR issued a
revised draft update to the CEQA Guidelines together with a Technical Advisory on implementing VMT as the
transportation impact criterion for CEQA purposes. In November 2017, a second Technical Advisory was issued by
OPR on evaluating VMT-based transportation impacts under the proposed CEQA Guidelines.
Until SB 743, transportation impacts were measured by assessing how projects affected the level of delay that drivers
experience through relevant intersections or roadway segments. LOS is measured on an alphabetic ranking scale;
LOS "A" represents the most favorable conditions (free flow) and LOS "F" represents the least favorable conditions
(congested with excessive delays). The Petaluma General Plan Mobility Element, Policy 5-P-10 establishes acceptable
LOS standards throughout the city:
Petaluma General Plan 2025: Mobility Element, Policy 5-P-10:
Maintain an intersection level of service (LOS) standard for motor vehicle circulation that ensures
efficient traffic flow and supports multi -modal mobility goals. LOS should be maintained at Level D
or better for motor vehicles due to traffic from any development project.
Projects that cause LOS to degrade below acceptable levels are found to generate a significant transportation impact
pursuant to CEQA, unless otherwise dictated by the Petaluma General Plan. With SB 743, LOS will cease to be an
appropriate metric for evaluating transportation (traffic) impacts for CEQA purposes.
4 —
ATTACHMENT 1— EXHIBIT A
The purpose of the SB 743 Compliance General Plan Update project described herein is to:
1. Evaluate OPR guidance on VMT implementation as the transportation impact metric for CEQA purposes.
SB 743 establishes the criteria that will be used to evaluate transportation impacts for CEQA purposes:
reduce greenhouse gas (GHG) emissions, encourage infill development, and promote active transportation.
OPR recommends VMT as the best approach to achieve these criteria. The first step in this project is to
assess the criteria and develop a sound understanding of the requirements for establishing transportation
impact metrics and associated thresholds of significance for impact assessment in the Petaluma context.
2. Establish an accurate VMT baseline condition for Petaluma and appropriate VIVIT thresholds
SB 743 recommends VMT as the preferred transportation impact metric, and provides a VMT-based
threshold, beyond which, projects would be found to have "significant impacts" pursuant to CEQA
Guidelines and would require mitigations or other measures. The City of Petaluma may accept the
recommended VMT-based thresholds of significance per OPR guidance, however these thresholds do not
account for unique, local conditions that affect transportation patterns and behavior in the Petaluma area,
such as environmental conditions, the built environment, alternative transportation systems, and local
roadway conditions. Evaluating baseline conditions in Petaluma is critical for establishing local and
appropriate thresholds. Baseline VMT conditions are needed to ensure that local VMT thresholds are
supported by substantial evidence as required by CEQA Guidelines Section 15064.7, and that local
thresholds address the three core objectives of SB 743: reducing GHG emissions, encouraging infill, and
promoting active transportation.
3. Identify mitigation measures that can be utilized by projects in Petaluma to reduce VMT.
After defining baseline conditions and proposing local VMT thresholds of significance, this project will
determine the availability and efficacy of VMT reduction strategies that could be utilized by local project
proponents (such as housing and other forms of development) to mitigate VMT-based transportation
impacts when they are associated with a project.
4. Define the appropriate and desirable applications of LOS and VMT metrics in Petaluma.
SB 743 and the transition to a VMT-based approach to evaluating transportation impacts directly affects
CEQA review for projects. Local jurisdictions may choose to continue evaluating projects on an alternative
basis, such as the prevailing LOS -basis, for non-CEQA project review. This project will explore which
applications of the prevailing LOS criteria may continue to be appropriate for Petaluma.
ATTACHMENT 1— EXHIBIT A
Task 1.1. Kick -Off Meeting
The City will hold a kick-off meeting with the Consultant staff to discuss the project scope, expectations, and
administration including invoicing, reporting, and all other relevant project information. A meeting summary will be
prepared by staff. The kick-off meeting will establish key project milestones and refine the outreach strategy to
gather technical and public input. The kick-off meeting agenda will include:
• Introductions.
• Review of project schedule and'milestones.
• Facilitated discussion of project objectives.
• Definition of action items throughout the project.
• Agreement on project schedule and regular meetings.
• Coordination on outreach activities.
• Discussion of the desired format for all deliverables.
Task 1.2 Ongoing Project Management
Throughout the project the City will convene bi-weekly in-person or conference meetings with the Consultants to
ensure good communication on upcoming tasks and to make sure the project remains on time and within budget.
Meeting summaries will be prepared by staff and documented. Upon project initiation, the Consultant will work with
City staff to finalize the workscope and budget. The Consultant will prepare and maintain a project schedule
throughout the life of the project, oversee the budget expenditures of the Consultant team, including
subcontractors, and invoice on the project monthly with a status report identifying potential delays and proposed
corrective actions.
VMT baseline, VMT calculation methodology, and VMT threshold setting tasks involve a degree of coordination
between the tasks. As such, Tasks 2 and 3 are anticipated to occur concurrently. The proposed project schedule for
the scope of the work shows the coordination between these tasks.
Task 2.1 Planning Documents and Travel Demand Model Review
The Consultant shall collect, review, and incorporate relevant data from current and previous planning documents,
including current transportation planning documents, State guidance on SB 743 implementation, and the City of
Petaluma General Plan and the Downtown Specific Plan.
The Consultant shall review the existing SCTA Travel Demand Model, City of Petaluma Travel Demand Model, and
MTC Travel Demand Model. This information will be used in the analysis to determine how to best establish VMT
baselines, identify options for VMT baseline methodology, define necessary model modifications/calibrations, and
inform threshold setting.
Task 2.2 Baseline VMT Data
Based on the review of the travel demand models and data collected the Consultant will estimate and summarize
the baseline VMT by major trip types for review by the TAC (see Task 2.3 below). The summary shall clearly identify
the model assumptions and highlight potential areas of dispute in the data, if any. Based on this summary, Consultant
will recommend one candidate travel demand model for further use in the setting of VMT calculation methodology,
VMT accounting methodology, and VMT thresholds.
1q ` "1
ATTACHMENT 1— EXHIBIT A
Task 2.3 TAC Review of Baseline VMT Data
The Consultant shall present the baseline VMT data and model calibration considerations to a Technical Advisory
Committee (TAC) for review and comment. Feedback regarding the recommended candidate travel demand model
will be solicited. The TAC will be formed by Petaluma staff, committee members and decision makers, at project
commencement. The TAC is intended to include:
• One (1) liaison from:
o Petaluma Pedestrian and Bicycle Advisory Committee
o Petaluma Transit Advisory Committee
o Planning Commission
o City Council
• City of Petaluma staff
• Sonoma County Transportation Authority (SCTA) staff
• Caltrans staff
• Sonoma County staff (where applicable).
Task 2.4 Planning Commission and City Council Review of Baseline VMT Data
The Consultant shall present the baseline VMT data, VMT calculation methodology, and model calibration
considerations to the Planning Commission and City Council at a joint workshop for review and comment.
Task 2.5 Finalize Baseline VMT Data
After reviewing the draft baseline VMT and VMT calculation methodology with the TAC and making necessary
updates to the data, the Consultant will document the baseline VMT data and VMT calculation methodology in a
Technical Memorandum.
Task 2.6 Analysis of VMT Reduction Strategies
The Consultant shall review applicable VMT Mitigation Measures, with a focus on those most applicable to the City
of Petaluma, and identify at least seven (7) strategies, ranked in order of priority based on their potential to result
in VMT reduction, for project prototypes appropriate to Petaluma. The prototypes will be identified by staff in
consultation with the Consultant.
The Consultant will identify methodologies to quantify VMT reductions associated with the five (5) highest priority
reduction strategies.
VMT baseline, VMT calculation methodology, and VMT threshold setting tasks involve a degree of coordination
between the tasks. As such, Tasks 2 and 3 are anticipated to occur concurrently. The proposed project schedule for
the scope of the work shows the coordination between these tasks.
Task 3.1 Review Potential VMT Metrics
The Consultant will review the recommended OPR guidance on the implementation of VMT metrics and thresholds
and the information collected in Task 2. The Consultant will analyze and determine the most appropriate VMT
metrics (i.e. per capita, per employee, etc.) for establishing VMT thresholds for Petaluma. The Consultant will also
consider the amount of VMT reduction that is achievable when recommending appropriate thresholds.
The analysis and recommendations made on VMT thresholds will be applicable to development projects,
transportation projects, and land use and transportation planning documents, e.g. the General Plan 2025 and EIR.
ATTACHMENT 1— EXHIBIT A
Task 3.2 Stakeholder Meetings
The potential thresholds will be presented by the consultant with support from City staff at up to four (4)
stakeholders meeting, inclusive of at least one (1) TAC meeting, one (1) Planning Commission meeting, and one (1)
joint meeting of the Pedestrian and Bike Advisory Committee and Transit Advisory Committee. The Consultant will
solicit input on possible thresholds that are appropriate for a range of project types in the Petaluma context. The
presentation will identify the applicability and considerations of each potential threshold on varying project
typologies.
Task 3.3 Develop VMT Accounting Methodology and VMT Thresholds
Based on the stakeholder meetings and results from Task 3.1, the Consultant will identify up to three (3) potential
VMT accounting methodologies for use by the City of Petaluma. These accounting methodologies will consider
projects of varying size and scale. Consultant will review and test the accounting methodologies to verify their
appropriateness for use in the City of Petaluma. Consultant will develop guidelines and other materials to document
VMT accounting approaches that can be used by the City of Petaluma.
Based on the stakeholder meetings in Task 2 and Task 3.2, the Consultant will prepare a recommendation of up to
three (3) potential VMT CEQA thresholds that could be used for projects of varying sizes, types of uses, and other
considerations. The thresholds will include potential screening criteria that could limit the need for detailed analysis
for projects likely to have a limited effect on VMT. Each of the three (3) threshold options will be verified to ensure
they can be applied in the City of Petaluma context and that do not create unintended consequences. The Petaluma
context shall consider potential projects within the City's Sphere of Influence.
Task 3.4 Presentation of Thresholds
The recommended methodology and thresholds shall be presented to the TAC by City staff for final review and
comment.
it-; .1 .• .► * . .ori.
Task 4.1 Draft Report Development and Presentation to TAC
The Consultant will prepare an Administrative Draft Report. The report shall incorporate an overview of adjustments
to the Petaluma General Plan to incorporate the VMT recommendations on baseline conditions, thresholds, and
implementation for projects in the City. The Consultant shall present the draft report for review and comment by
the TAC; comments received from the TAC will be incorporated into a revised Final Draft Report.
Task 4.2Draft Report Presentation to Planning Commission and City Council
The Final Draft Report will be presented by the Consultant to the Petaluma Planning Commission and City Council at
separate meetings.
Task 4.3 Final Report
The Consultant will consider and incorporate the comments received on the Final Draft Report into the Final Report,
as appropriate, and present it at a second meeting of the City Council if requested.
—�
ATTACHMENT 1- EXHIBIT A
Task 4.4 VMT Adoption Support
The Consultant will assist City staff in the process to adopt VMT as the CEQA transportation metric for projects
throughout the City. The Consultant will assist City staff in the preparation of the staff report for the adoption process
and attend up to three Planning Commission or City Council meetings.
Task 4.5 VMT Transportation Impact Analysis Guidelines
The Consultant will prepare VMT Transportation Impact Analysis (TIA) guidelines for the City. The guidelines will be
based on the data and analysis prepared as part of the Final Report (Task 4.3). This task assumes that the guidelines
will be limited to general VMT methodology, VMT thresholds of significance and VMT reduction strategies only;
guidelines related to the qualitative or quantitative analysis of the bicycle, pedestrian and transit modes will not be
provided. The guidelines will take the form of a brief (five to ten page) technical memorandum.
This scope task has been developed with the understanding that further scoping will be required prior to
authorization to proceed on the task. Depending on the assumptions and expectations for this task, a scope or
budget amendment may be required to provide the level of effort requested from the City.
As an optional task, the Consultant will assist City staff with incorporating the results of the tasks above into the
Petaluma General Plan. Updates will include updated figures, tables and map exhibits along with updated and new
narrative, goals, policies, and programs to address the outcomes of the above tasks. The following tasks have been
developed with the understanding that the work in Tasks 1-4 will be used to inform the full scope of the following
tasks. A scope amendment will be prepared to further define the tasks below prior to authorization for work on
these tasks.
Task 5.1 Administrative Draft General Plan Amendment
The Consultant will prepare an administrative draft General Plan update for staff review.
Task 5.2 General Plan Amendment: Planning Commission
Staff shall prepare the staff report for a meeting of the Planning Commission to review the General Plan Amendment
to incorporate VMT language and policy. The Consultant shall attend one (1) Planning Commission and present the
General Plan Amendment with staff to the Petaluma Planning Commission for review.
Task 5.3 General Plan Amendment: City Council
Comments received from Planning Commission will be incorporated into a revised General Plan Amendment. Staff
shall prepare the staff report for a meeting of the City Council to review the General Plan Amendment to incorporate
VMT language and policy. The Consultant shall attend one (1) City Council meeting and present the General Plan
Amendment with staff to the Petaluma City Council for review.
4--7
ATTACHMENT 1— EXHIBIT A
TASK
DELIVERABLES
OUTREACH/MEETINGS
1
Contact list, project schedule, data needs memo
Kick-off meeting
Bi -Weekly in-person
meetings or conference
calls
2
Technical Memo: Baseline VMT Data and VMT Calculation Methodology
TAC (1)
Planning Commission/City
Technical Memo: VMT Mitigation Measures
Council Joint Workshop (1)
3
Stakeholder meetings (up to
VMT Threshold Guidance Document
4 meetings)
VMT Accounting Methodologies
VMT Traffic Study Guidelines
VMT Forecasting Tool and User Manual
4
Draft VMT Report
TAC (1)
Final VMT Report
Planning Commission and
VMT Transportation Impact Analysis Guidelines
City Council (up to 3)
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ATTACHMENT 2
Analyzing Transportation Impacts
Text of the Proposed New Section 15064.3, Determining the Significance
of Transportation Impacts
(a) Purpose.
This section describes specific considerations for evaluating a project's transportation impacts.
Generally, vehicle miles traveled is the most appropriate measure of transportation impacts. For the
purposes of this section, "vehicle miles traveled" refers to the amount and distance of automobile travel
attributable to a project. Other relevant considerations may include the effects of the project on transit
and non -motorized travel. Except as provided in subdivision (b)(2) below (regarding highway capacity),
a project's effect on automobile delay does not constitute a significant environmental impact.
(b) Criteria for Analyzing Transportation Impacts.
(1) Land Use Projects. Vehicle miles traveled exceeding an applicable threshold of significance may
indicate a significant impact. Generally, projects within one-half mile of either an existing major transit
stop or a stop along an existing high quality transit corridor should be presumed to cause a less than
significant transportation impact. Projects that decrease vehicle miles traveled in the project area
compared to existing conditions should be considered to have a less than significant transportation
impact.
(2) Transportation Projects. Transportation projects that reduce, or have no impact on, vehicle miles
traveled should be presumed to cause a less than significant transportation impact. For roadway
capacity projects, agencies have discretion to determine the appropriate measure of transportation
impact consistent with CEQA and other applicable requirements. To the extent that such impacts have
already been adequately addressed at a programmatic level, a lead agency may tier from that analysis as
provided in Section 15152.
(3) Qualitative Analysis. If existing models or methods are not available to estimate the vehicle miles
traveled for the particular project being considered, a lead agency may analyze the project's vehicle
miles traveled qualitatively. Such a qualitative analysis would evaluate factors such as the availability of
transit, proximity to other destinations, etc. For many projects, a qualitative analysis of construction
traffic may be appropriate.
(4) Methodology. A lead agency has discretion to choose the most appropriate methodology to
evaluate a project's vehicle miles traveled, including whether to express the change in absolute terms,
per capita, per household or in any other measure. A lead agency may use models to estimate a
project's vehicle miles traveled, and may revise those estimates to reflect professional judgment based
on substantial evidence. Any assumptions used to estimate vehicle miles traveled and any revisions to
Page 1 1
November 2017
model outputs should be documented and explained in the environmental document prepared for the
project. The standard of adequacy in Section 15151 shall apply to the analysis described in this section.
(c) Applicability.
The provisions of this section shall apply prospectively as described in section 15007. A lead agency may
elect to be governed by the provisions of this section immediately. Beginning on January 1, 2020, the
provisions of this section shall apply statewide.
Page 1 2
November 2017
ATTACHMENT 3
TECHNICAL ADVISORY
ON EVALUATING TRAIRSPORTATIM11
IMPACTS IN CEQA
OF PLANN/
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A. Introduction......................................................................................................................................1
B. Background........................................................................................................................................1
C. Technical Considerations in Assessing Vehicle Miles Traveled......................................................... 3
1. Recommendations Regarding Methodology................................................................................3
D. General Principles to Guide Consideration of VMT..........................................................................5
E. Recommendations Regarding Significance Thresholds.................................................................... 6
1. Screening Thresholds for Land Use Projects...............................................................................10
2. Recommended Numeric Thresholds for Residential, Office, and Retail Projects.......................12
3. Recommendations Regarding Land Use Plans............................................................................15
4. Other Considerations..................................................................................................................15
F. Considering the Effects of Transportation Projects on Vehicle Travel...........................................16
1. Recommended Significance Threshold for Transportation Projects...........................................18
2. Estimating VMT Impacts from Transportation Projects.............................................................19
G. Analyzing Other Impacts Related to Transportation......................................................................21
H. VMT Mitigation and Alternatives....................................................................................................22
Appendix 1. Considerations About Which VMT to Count.......................................................................25
Appendix 2. Induced Travel: Mechanisms, Research, and Additional Assessment Approaches .....:......28
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), (1), (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 (Feb. 28, 2018, B279590)
_Cal.App.5th_, ordered pub. Mar. 22, 2018.) 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).)
To that end, OPR has proposed changes to the CEQA Guidelines that identify vehicle miles traveled
(VMT) as the most appropriate metric to evaluate a project's transportation impacts. Once the California
Natural Resources Agency adopts these changes to the CEQA Guidelines, automobile delay, as measured
by "level of service" and other similar metrics, generally will no longer constitute a significant
environmental effect under CEQA.
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 April 2018 technical advisory is an update to the advisory it published in November 2017. 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.
B. Background
VMT and Greenhouse Gas Emissions Reduction. Senate Bill 32 (Pavley, 2016) requires California to
reduce greenhouse gas emissions 40 percent below 1990 levels by 2030, and Executive Order B-16-12
11 Page
April 2018 — j
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 greenhouse gas emissions: increasing vehicle
efficiency, reducing fuel carbon content, and reducing the amount of vehicle travel. The California Air
Resources Board (CARE) 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.
VMT and Other Impacts to Health and Environment. Beyond greenhouse gas emissions, increases in
VMT also impact human health and the natural environment. Human health is impacted as increases in
vehicle travel leads 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
affects 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 which 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. (Fang et al., 2017.)
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.','
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Figure 1. VMT and Gross Domestic Product (GDP); 1960-2010 (Kooshian and Winkelman 201
1 Haynes et al., Congested Development: A Study of Traffic Delays, Access, and Economic Activity in
Metropolitan Los Angeles, Sept. 2015,
2 Osman et al., Not So Fast: A Study of Traffic Delays, Access, and Economic Activity in the San Francisco
Bay Area, March 2016.
21 Page
April 2018 �Lt
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
comparison, vehicle types considered should be consistent across project assessment, significance
thresholds, and mitigation.
Residential and Office Projects. Tour- and trip -based approaches' 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:
' See Appendix 1, Considerations About Which VMT to Count, for a description of these approaches.
3 1 P a g e
April 2018
• 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 VMT' 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.
Considerations for All Projects. Lead agencies should not truncate any VMT analysis because of
jurisdictional or other boundaries. 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. Analyses should
also consider a project's both short- and long-term effects on VMT.
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''/= 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).)
' See Appendix 1, Considerations About Which VMT to Count, "Assessing Change in Total VMT" section,
for a description of this approach.
41 Page
April 2018
3—
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,
qualitative' 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." (ld. 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 HistoricAmador 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.
s Because the amount of a project's VMT is needed (and is currently being used in practice) to assess the
environmental impacts on a variety of resources (such as air quality, greenhouse gases, energy, and
noise), qualitative analysis should only be applied when models or methods do not exist for undertaking
a quantitative analysis.
51 Page
April 2018
3d7
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.
Various legislative mandates and state policies establish quantitative greenhouse gas emissions
reduction targets. For example:
® AssemblV Bill 32 (2006) requires statewide greenhouse gas reductions to 1990 levels by 2020
and continued reductions beyond 2020.
• Senate Bill 32 (2016) requires at least a 40 percent reduction in greenhouse gas emissions by
2030.
• Pursuant to Senate Bill 375 (2008), the California Air Resources Board establishes greenhouse
gas 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. Current targets for the largest metropolitan planning
organizations range from 13% to 16% reductions by 2035.
• Executive Order B-30-15 (2015) sets a GHG emissions reduction target of 40 percent below 1990
levels by 2030.
• Executive Order 5-3-05 (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.
• 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
61 Page
April 2018
—3__
greenhouse gas 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 greenhouse gases and other pollutants. But those targets 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:
"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." (CARB, First Update to the Climate Change
Scoping Plan, May 2014, p. 46 (emphasis added).) In other words, vehicle efficiency and better
fuels are necessary, but insufficient, to address the greenhouse gas 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.
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April 2018
3-9
• When assessing climate impacts 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 literature on this topic, OPR finds that in most
instances a per capita or per employee VMT that is fifteen percent below that of existing development
may be a reasonable threshold.
First, as described above, Section 21099 states that the criteria for determining significance must
"promote the reduction in greenhouse gas emissions." SB 743 also states the Legislature's intent that
the analysis of transportation in CEQA better promotes the State's goals of reducing greenhouse gas
emissions. It cites in particular the reduction goals in the Global Warming Solutions Act (AB 32) and the
Sustainable Communities and Climate Protection Act (SB 375), both of which call for substantial
reductions. As indicated above, CARB established long-term reduction targets for the largest regions in
the state that ranged from 13 to 16 percent.
Second, Caltrans has developed a statewide VMT reduction target in its Strategic Management Plan.
Specifically, it calls for a 15 percent reduction in per capita VMT, compared to 2010 levels, by 2020.
Third, fifteen percent reductions in VMT are achievable at the project level in a variety of place types.
(Quantifying Greenhouse Gas Measures, p. 55 CAPCOA, 2010).
Fourth, in CARB's most recent update to the Climate Change Scoping Plan, a 15 percent reduction in
light-duty VMT beyond what existing plan and policies achieve is recommended to achieve the State's
2030 and 2050 targets. (CARB, The 2017 Climate Change Scoping Plan: The Strategy for Achieving
California's 2030 Greenhouse Gas Target, October 2017, pp. 116, 150; see generally, CARB, Climate
Change Scoping Plan: A Framework for Chanqe, December 2008, p. 27; CARB, First Update to the Climate
Change Scoping Plan, May 2014, p. 113; CARB, The 2017 Climate Change Scoping Plan: The Strategy for
Achieving California's 2030 Greenhouse Gas Target, October 2017, p. 149.)
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." (CARB, California's 2017 Climate Change Scoping Plan,
November 2017, p. 75.)
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April 2018
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Furthermore,
At the State level, a number of important policies are being developed. Governor Brown signed
Senate Bill 743 (Steinberg, 2013), which called for an update to the metric of transportation
impact in CEQA. That update to the CEQA Guidelines is currently underway. 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. (Id. at p.
76.)
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.
The State can provide guidance and tools to assist local governments in achieving those
objectives. (Id. at p. 76.)
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. Further, the State's
understanding of transportation impacts continues to evolve. The CEQA Guidelines are being
updated to focus the analysis of transportation impacts on VMT. CPR's Technical Advisory
includes methods of analysis of transportation impacts, approaches to setting significance
thresholds, and includes examples of VMT mitigation under CEQA. (Id. at p. 102.)
Also, the Scoping Plan includes the following item as a "Recommended Action": "forthcoming statewide
implementation of SB 743[.]" (Id. at p. 103.)
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. The following pages describe a series of screening thresholds
below which a detailed analysis may not be required. Next, this advisory describes numeric thresholds
recommended for various project types. Finally, this advisory describes the analysis for certain unique
circumstances.
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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, and transit availability.
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 day' 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
data from a travel survey or travel demand model can illustrate areas that are 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.
' 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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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 Jose, 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 % mile of an existing major transit stop or an existing stop
along a high quality transit corridor' 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
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.").
8 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.").
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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)
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).
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 city 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.
These thresholds can be applied to either household (i.e., tour -based) VMT or home-based (i.e., trip -
based) VMT assessments.' It is critical, however, that the agency be consistent in its VMT measurement
' See Appendix 1 for a description of these approaches.
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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. .
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.
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 retail projects: A net increase in total VMT may indicate a significant
transportation impact.
Because new retail development typically redistributes shopping trips rather than creating new trips,"
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 -
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
90 Lovejoy, et al., 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, 2013.
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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.
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.
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3.16
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.
Recommendations Regarding Land Use Plans
As with projects, agencies should analyze VMT outcomes of land use plans over the full area over which
the plan may substantively affect travel patterns, including beyond the boundary of the plan or
jurisdiction's geography. 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
it is not consistent with the relevant RTP -SCS.
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
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3—I
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.
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
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. (See, e.g.,
California Department of Transportation, Guidance for Preparers of Growth -related, Indirect Impact
Analyses (2006).)
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:
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• 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 and repair projects designed to improve the
condition of existing transportation assets (e.g., highways, roadways, bridges, culverts, tunnels,
transit systems, and assets that serve bicycle and pedestrian facilities) and that do not add
additional motor vehicle capacity
• 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, 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
• Traffic metering systems
• 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
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• 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 in rural areas that do not increase overall vehicle capacity along the
corridor
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.
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)11
• The impact of the transportation project on the development of multimodal transportation
networks (Pub. Resources Code, § 21099)
11 The Air Resources Board has ascertained, in The 2017 Climate Change Scoping Plan: The StrotegV for
Achieving California's 2030 Greenhouse Gas Target (p. 116) and Mobile Source Strotegtr (p. 37), the
limits of VMT growth compatible with California containing greenhouse gas emissions to levels research
shows would allow for climate stabilization. The Staff Report on Proposed Update to the SB 375
Greenhouse. Gas Emission Reduction Targets (Figure 1, p. 10, and Figure 2, p. 23), illustrates that
Regional Transportation Plans and Sustainable Communities Strategies will fall short of achieving GHG
reductions research says is needed to achieve climate stabilization, so OPR recommends not basing
transportation project thresholds on those documents.
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• The impact of the transportation project on the development of a diversity of land uses (Pub.
Resources Code, § 21099)
The recommendations in this technical advisory may be updated over time
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"). (See U.C. Davis, Institute for Transportation
Studies, Increasing Highwov CaoacitV Unlikely to Relieve Traffic Congestion, (October 2015); Boarnet and
Handy, Impact of Highway Capacity and Induced Travel on Passenger Vehicle Use and Greenhouse Gas
Emissions, California Air Resources Board Policy Brief, September 30, 2014.) 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 (Duranton and Turner, 2011), estimates an
elasticity of 1.0, meaning that every percent change in lane miles results in a one percent increase in
VMT.
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]
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
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
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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.12 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
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,
"See Increasing Highway Capacity Unlikely to Relieve Traffic Congestion, National Center for
Sustainable Transportation, October 2015, available at
http://www,dot.ca.Rov/newtech/research reports/reports/2015/10-12-2015-
NCST Brief InducedTravel CS6 v3.pdf; see Duranton and Turner, The Fundamental Law of Road
Congestion: Evidence from US cities, 2011, available at http:%/www.nber.org/papers/wl5376.
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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 the 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.Sth 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.Sth 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 vehicle miles traveled are
described below. However, the selection of particular mitigation measures and alternatives are left to
the discretion of 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.
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• 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 or roadway pricing or cash -out programs.
• 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
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.
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• 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.13 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.
"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 CaIEEMod 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 studies14 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.
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
14 See, for example, Impact of HighwaV Capacity and Induced Travel on Passenger Vehicle Use and
Greenhouse Gas Emissions: Policy Brief (CARB, Sept. 30, 2014) and Increasing HighwoV Capacity Unlikely
to Relieve Traffic Congestion (National Center for Sustainable Transportation, Oct. 2015).
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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 (See Impact of Highwoy Capacity and
Induced Travel on Passenger Vehicle Use and Greenhouse Gas Emissions: Policy Brief, p. 2.), 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 (Duranton and Turner, The Fundamental Law of Road Congestion:
Evidence from US Cities, 2011) 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. (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
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
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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
some 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.
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