08. Apprvl of MOU Gateway Cities COG Technical Assist under SCAG REAP Subregional Partnership 2.0 Grant Prog

Item No. 8.

TO:HONORABLE MAYOR AND MEMBERS OF THE CITY COUNCIL
FROM:OFFICE OF THE CITY MANAGER
BY:IRMA HUITRON, DIRECTOR OF COMMUNITY DEVELOPMENT

MATTHEW BAUMGARDNER, DIRECTOR OF PUBLIC WORKS/CITY ENGINEER DATE:FEBRUARY 10, 2026
SUBJECT:

APPROVAL OF MEMORANDUM OF UNDERSTANDING BETWEEN THE CITY AND

GATEWAY CITIES COUNCIL OF GOVERNMENTS FOR TECHNICAL ASSISTANCE UNDER THE SOUTHERN CALIFORNIA ASSOCIATION OF GOVERNMENTS’ REGIONAL EARLY ACTION PLANNING SUBREGIONAL PARTNERSHIP 2.0 GRANT PROGRAM FOR

DEVELOPMENT OF LOCAL VEHICLE MILES TRAVELED GUIDELINES

EXECUTIVE SUMMARY

The City Council will consider adoption of a Resolution and approval of a Memorandum of Understanding with the Gateway Cities Council of Governments to receive $125,883 in grant-funded technical assistance through the Southern California Association of Governments’ Regional Early Action Planning (REAP) Subregional Partnership

2.0 Grant Program. The funding will support the development of local Vehicle Miles Traveled guidelines consistent with California Senate Bill 743 and the California Environmental Quality Act. The resulting guidelines will improve consistency and efficiency in development review and support housing development in the City. Final draft guidelines are anticipated to be presented to the City Council for adoption in late summer 2026.

RECOMMENDATION

That the City Council:

1. Adopt Resolution No. 26-8334, approving a Memorandum of Understanding by and between the Gateway Cities Council of Governments and the City of Downey for technical assistance under the Southern California Association of Governments’ Regional Early Action Planning Subregional Partnership 2.0 Grant Program; and,

2. Approve a Memorandum of Understanding by and between Gateway Cities Council of Governments and the City of Downey for Technical Assistance under Southern California Association of Governments’ Regional Early Action Planning Subregional Partnership 2.0 Grant Program.

BACKGROUND

On March 4, 2025, the Gateway Cities Council of Governments (GCCOG) entered into a Memorandum of Understanding with the Southern California Association of Governments (SCAG) for a Regional Early Action Planning (REAP) Subregional Partnership 2.0 Grant Program. The grant includes funding for the GCCOG to provide housing element-related technical assistance to its member cities. Subsequently, the GCCOG procured consultants to perform these technical assistance services. Being that Downey is a GCCOG member, the City applied, and has been approved for a technical assistance grant of $125,883 for the analysis, development, and preparation of local Vehicle Miles Traveled (VMT) guidelines consistent with California Senate Bill 743 (SB 743) and the California Environmental Quality Act (CEQA).

When signed into law, SB 743 started a process intended to change transportation impact analysis as part of CEQA compliance. This bill replaced the long-standing Level of Service (LOS) metric, which focused on traffic congestion, with Vehicles Miles Traveled (VMT), a measure of how much and how far people drive, for a project's transportation impact evaluation. This shift aligned CEQA with state goals to reduce greenhouse emissions, and promote infill and mixed-use development.

ANALYSIS
The City of Downey currently complies with Senate Bill 743 by evaluating transportation impacts based on Vehicle Miles Traveled, rather than roadway level of service, in accordance with the State CEQA Guidelines. In the absence of locally adopted VMT thresholds, the City has relied on the Los Angeles County VMT Guidelines when evaluating projects; however, those countywide standards are not always well-suited to Downey’s specific land use patterns, transportation network, and development context. Adoption of locally tailored VMT Guidelines will allow the City to apply SB 743 in a manner that is both compliant with State law and better aligned with local conditions.

To support this effort, the GCCOG has allocated $125,883 in grant-funded technical assistance to the City for development of local VMT guidelines. The project is funded via SCAG’s Subregional Partnership 2.0 Grant Program, and the GCCOG has conducted the solicitation of the consultants that will be assisting the City. The GCCOG will deliver services directly to the City through the consultants team of Raimi + Associates, Fehr & Peers, and Circlepoint, each a qualified professional firm with expertise in urban planning, transportation, and environmental analysis. Development of the VMT Guidelines will be completed collaboratively with the City’s Community Development Department’s Planning Division and Public Works Department to ensure consistency with local land use and transportation policies, as well as development review procedures.

Once complete, the VMT Guidelines will provide greater clarity, consistency, and efficiency in the development review process by establishing standardized screening criteria and evaluation methodologies consistent with State law. The Guidelines are intended to assist staff in efficiently reviewing and screening projects by directing detailed analysis to those proposals where it is most warranted, while preserving the City’s discretion to apply environmental review requirements and policy considerations consistent with CEQA and local regulations.

For applicants and the development community, the Guidelines will improve predictability by clearly outlining expectations, submittal requirements, and evaluation thresholds early in the application process. This clarity supports informed project design and helps reduce unnecessary delays, without altering the City’s authority to review, condition, or deny projects based on applicable policies and standards. Final draft VMT Guidelines are anticipated to be presented to the City Council for consideration and adoption in late summer 2026.

The GCCOG will maintain, monitor, and distribute payment of all grant funds associated with the project. The City will be responsible for monitoring the overall project progress, but will not manage grant funds directly and will have no financial obligation under the proposed MOU.

CITY COUNCIL PRIORITIES

Fiscal Responsibility
Efficiency & Adaptability

Quality of Life, Safety & Infrastructure

FISCAL IMPACT

Approval of the recommended action will result in the receipt of $125,883 in grant-funded in-kind technical assistance provided through the Southern California Association of Governments’ REAP Subregional Partnership

2.0 Grant Program. There is no fiscal impact to the General Fund and no required local match, as all funds are administered and disbursed by the Gateway Cities Council of Governments.

Attachments
Attachment A: Resolution 26-8334
Attachment B: Memorandum of Understanding

Attachment A

RESOLUTION NO. 26-8334
PAGE2
ATTEST:

MARIA ALICIA DUARTE, CMC
City Clerk
APPROVED AS TO FORM:

JaMN M. FUNK
City Attorney
I HEREBY CERTIFY that the foregoing Resolution was adopted by the City Council of the City of Downey at a Regular meeting held on the 10th day of February, 2026, by the following vote, to wit:

AYES:

NOES:

ABSENT:

ABSTAIN:

Council Members:

Council Member:

MARIA ALICIA DUARTE, CMC
City Clerk
Attachment A

RESOLUTION NO. 26-
PAGE 3

EXHIBIT A

MOU BY AND BETWEEN THE GCCOG AND THE CITY OF DOWNEY FOR TECHNICAL ASSISTANCE UNDER SCAG REAP 2.0 PROGAM
Attachment A

Docusign Envelope ID: F16C19DF-564F463E-8E5B-7E24DC6985C6

MEMORANDUM OF UNDERSTANDING

BY AND BETWEEN

GATEWAY CITIES COUNCIL OF GOVERNMENTS

AND THE CITY OF DOWNEY
FOR TECHNICAL ASSISTANCE UNDER SCAG REAP 2.0 PROGRAM
This Memorandum of Understanding (“MOU”) is dated February 10, 2026 (“Effective Date”) and entered into by and between the Gateway Cities Council of Governments (“GCCOG”) and the City of Downey (“City”) (each a Party to this MOU and collectively, the “Parties”).

RECITALS
A. On March 4. 2025. the GCCOG entered into a Memorandum of Understanding (“SCAG MOU”) with the Southern California Association of Governments (“SCAG”) for a Regional Early Action Planning (“REAP”) Subregional Partnership (“SRP”)

2.0 Program Grant. The grant includes funding for the GCCOG to provide housing element technical assistance to its member cities. The GCCOG has engaged consultants to perform these technical assistance services.

B. The City desires technical assistance pursuant to the SCAG MOU and agrees to the terms and conditions set forth herein to receive such services.

NOW, THEREFORE, IT IS MUTUALLY AGREED THAT:
1 Scope of Work and City Responsibilities.

The City requests technical assistance as set forth in the Scope of Work attached hereto as Exhibit “A“ and incorporated herein by this reference. The City agrees to:

A. Provide a point of contact to serve as the City’s Project Manager with name, title, and contact information.

B. Participate in scheduled conference calls and meetings from the anticipated start date to completion date.

C
of Work.

Provide accurate information relevant and necessary to perform the Scope D. Respond to the GCCOG or its consultant’s requests related to the Scope of Work in a timely manner, such as providing information and feedback on draft documents, approaches, and designs.
2 GCCOG Responsibilities.

The GCCOG will engage one of its REAP 2.0 technical assistance consultants to perform the Scope of Work requested by the City and manage the full payment of those services 1 Attachment A

Docusign Envelope ID: F16C19DF-564F-463E-8E5B-7E24DC6985C6 from the grant funding pursuant to the SCAG MOU. The City shall have no financial obligation under this MOU.

3. SCAG MOU
The Parties acknowledge and agree that the performance of the Scope of Work as set forth herein is made possible by the SCAG MOU, and that all work performed under this MOU shall be consistent and in compliance with the terms and provisions of the SCAG MOU.

4. SCAG Requirements.

A. The final deliverables will be presented to the City or its designee for consideration to adopt as required by the REAP 2.0 grant funds or adopt and pursue the recommendations as may be allowable. All uses that include the creation of planning documents, rezoning, and guiding development by updating planning documents, development standards, and zoning ordinances, including general plans, community plans, specific plans, sustainable communities strategies, and local coastal programs must be accompanied by a commitment to adopt by the expenditure deadline.

B. All public-facing communications materials produced under this MOU shall acknowledge and give credit to SCAG, whether with a logo or language. For information, please refer to the SCAG Brand Guidelines.

C. To promote awareness and encourage local support, local elected officials in the project area should be invited to outreach activities.

D. The SCAG MOU (M-022-25) between GCCOG and SCAG effective March 4, 2025 is incorporated into this MOU by reference. In the event of conflict between this MOU and the SCAG MOU, the SCAG MOU prevails.

5. Governing Law.

This MOU shall be governed by the laws of the State of California and venue shall lie in Los Angeles County.

6. Disputes.

Any dispute arising under this MOU which is not resolved by mutual agreement shall be decided through binding arbitration by a neutral arbitrator selected by the Parties. The arbitration proceedings shall be governed by any rules the Parties mutually agree upon in writing. A judgment upon the award rendered by arbitration may be entered into any court having jurisdiction thereof. The arbitrator shall have the authority to grant any remedy or relief that would have been available to the Parties had the matter been heard in a court of law. Following arbitration, the arbitrator shall prepare a written decision containing the essential findings and conclusions on which the award is based. All expenses and fees for the arbitrator and expenses for hearing facilities and other expenses of arbitration shall be borne equally by both Parties unless they agree otherwise 2 Attachment A

Docusign Envelope ID: F16C19DF-564F-463E-8E5B-7E24DC6985C6 in writing or unless the arbitrator in the award assesses such expenses against one of the parties or allocates such expenses other than equally between the Parties. Either Party may bring an action in court to compel arbitration under this MOU or to enforce an arbitration award.

7. No Waiver
A waiver by either Party of any breach of any term, covenant or condition contained in this MOU shall not be deemed to be a waiver of any subsequent breach of the same or any other term, covenant or condition contained in this MOU, whether of the same or different character.
8 . Severability.

If any part of this MOU is held invalid, the remaining terms and conditions shall not be affected unless their enforcement under the circumstances would be unreasonable, inequitable, or otherwise frustrate the purposes of this MOU

8. Independent Contractor.

The Parties are independent entities and are not to be, and shall not be, construed as joint venturers, partners, employer/employee, or agents one of the other, and neither shall have the power to bind or obligate the other except as set forth in this MOU.

9. Construction
The Parties have participated jointly in the negotiation and drafting of this MOU. In the event an ambiguity or question of intent or interpretation arises with respect to this MOU, this MOU shall be construed as if drafted jointly by the Parties and in accordance with its fair meaning. There shall be no presumption or burden of proof favoring or disfavoring any Party by virtue of the authorship of any of the provisions of this MOU.

10. Captions.

The captions herein are for convenience and references only and are not a part of this MOU and do not in any way limit, define or amplify the terms and provisions hereof. 11 . Entire Agreement.

This MOU, including Exhibit A attached hereto, constitutes the entire agreement between the Parties and supersedes any previous oral or written agreements with respect to the subject of this MOU. No amendment or modification to this MOU shall be valid and binding unless in writing and signed by authorized representatives of the Parties.

12. Authority to Execute this MOU.

Each person executing this MOU on behalf of a Party warrants and represents that they have the authority to execute this MOU on behalf of that Party and the authority to bind that Party to the provisions of this MOU.
3 Attachment A

Docusign Envelope ID: F16C19DF-564F-463E-8E5B-7E24DC6985C6

13. Counterparts.

This MOU may be executed in counterparts, each of which shall be deemed an original, and all of such counterparts together shall constitute one and the same instrument.

IN WITNESS WHEREOF, the authorized representatives of the Parties have caused this MOU to be executed as of the date of the last signature below.

CITY GCCOG
Claudia M. Frometa, Mayor H6-6t6iD6 -La Torre, Executive Director Date :Date: 1/27/2026
APPROVED AS TO FORM:APPROVED AS TO FORM:

Signed by:

DRl&t..b
John M. Funk, City Attorney
'S®d by:

I.}qq. al
Ivy -M. T-gai,-General Counsel
ATTEST :

Maria Alicia Duarte, CMC
City Clerk
Attachment A

Docusign Envelope ID: F16C19DF-564F-463E-8E5B-7E24DC6985C6

EXHIBIT A

SCOPE OF WORK
Attachment A

Docusign Envelope ID: F16C19DF-564F-463E-8E5B-7E24DC6985C6 Approach and Work Plan
A. Project Understanding and Background
On September 27, 2013, Governor Jerry Brown signed SB 743 into law and started a process intended to fundamentally change transportation impact analysis as part of CEQA compliance.

The primary change was the elimination of Level of Service (LOS) as a measure of vehicular capacity and traffic congestion as a basis for determining significant transportation impacts under CEQA. The law directed the Governor's OffIce for Land Use and Climate Innovation (LCI), formerly the Governor's OffIce of Planning and Research (OPR), to update the CEQA Guidelines to include new performance criteria for determining the significance of transportation impacts.

In response to SB 743, LCI selected vehicle miles of travel (VMT) as the new transportation impact metric. LCI then submitted updates to the CEQA Guidelines, and these updates were certified by the Natural Resources Agency in December 2018.

To help lead agencies with SB 743 implementation, LCI produced a Technical Advisory1 to help lead agencies think about the variety of implementation questions they face with respect to shifting to a VMT metric. However, lead agencies must still make their own specific decisions about VMT methodology, screening criteria, significance thresholds, and mitigation. These decisions should be consistent with the City of Downey's goals as expressed in its general plan.

Fehr & Peers has helped numerous cities in Southern California develop their own VMT guidelines and thresholds and is very familiar with the State’s guidelines, CEQA requirements, and the decisions that have been made by other jurisdictions.

When communicating with decision makers on VMT thresholds, we have found that it’s helpful to start with why the State adopted new CEQA guidelines. The intent of SB 743 is to better support the following State goals:
+
B
e
Reducing greenhouse gas (GHG) emissions
Encouraging infill development and a diversity of land uses Developing multimodal transportation networks
Improving public health through active transportation
While changes to driving conditions that increase travel times are an important consideration for traffic operations and management, these changes do not fully describe environmental effects associated with fuel consumption, emissions, and public health. VMT-based impact criteria will help to incorporate these environmental effects and move toward achieving the State goals listed above.

B. Project Approach
Most cities in the Gateway Cities Council of Governments apply the Los Angeles County Public Works Transportation Impact Analysis Guidelines, while a few, like Whittier, Pico Rivera, Santa Fe 1 TRtInial AcMsay m EvaluatIng Transpcrtabon Impacts in CEQ/\ LCI, December 2078 6 Attachment A

Docusign Envelope ID: F16C19DF-564F-463E-8E5B-7E24DC6985C6 Springs, and Long Beach, have developed their own guidelines. The guidetines are typically based on SB 743 and the State's corresponding LCI Senate Bill 743 Implementation Guidelines.

Local guidelines that inform vehicle miles traveled help align local policies and approaches for development review with the State's intended goals of SB 743, which include reducing greenhouse gas emissions, promoting infill development over sprawl, and encouraging multimodal transportation networks. Clear and consistent guidance regarding environmental review and analysis requirements assists the City with streamlining development and quickly determining the type and scale of analysis required for development projects within the City of Downey .

Overall project oversight will be led by Raimi + Associates as the prime contractor, who bring ample experience leading sustainability projects and assisting City staff with planning and adoption processes. The tasks described below will be led by Fehr & Peers, who have completed numerous SB 743 guidelines for dozens of agencies and also regularly perform VMT analysis for development projects requiring approval via the California Environmental Quality Act (CEQA). Circlepoint, an environmental consulting specialty firm, will support the team with input and research of published literature regarding distinct CEQA questions on the topics of locally specific screening criteria, impact thresholds, and staff-generated questions. The following section provides the detailed scope of work we propose to provide for the Vehicle Miles Traveled Analysis Guidelines project in Downey based on the RFP.

Attachment A

Docusign Envelope ID: F16C19DF-564F-463E-8E5B-7E24DC6985C6 C. Work Plan
The R+A team has provided a comprehensive Scope of Work that addresses and exceeds the requirements listed in the RFP. The Scope of Work is designed to be flexible and can be tailored to best meet the needs of the City of Downey and GCCOG.

Task 1: Project Initiation & Management
Our team will conduct a project kickoff meeting with City of Downey staff to confirm project objectives, deliverables, schedule, and coordination protocols. The kickoff will focus on aligning expectations for the VMT Analysis Guidelines, confirming available data resources (e.g., roadway network, transit service, land use datasets), and identifying any supplemental data needs.

Circlepoint will provide environmental and CEQA expertise to support the preparatIon of the data needs matrix and the annotated outline for the guidelines and adoption package.

Following the kickoff, Fehr & Peers will lead up to six (6) virtual coordination meetings to review technical progress, discuss interim findings, and obtain City input on methodologies, screening criteria, and thresholds of significance. R+ A and Circlepoint will attend up to four (4) meetings as needed. Additional meetings may be attended on a time-and-materials basis, if requested. All meetings will be documented through summary notes identifying key decisions and next steps.

Task 1 Deliverables and Meetings
• One (1) kick-off meeting with staff – Meeting agenda and summary action notes • Annotated outline for the VMT Guidelines and adoption package • Data needs matrix and project schedule
• Up to sIx (6) coordination meetings – Meeting agenda and summary action notes Task 2: Policy & Legal Framework
Fehr & Peers will summarize the statutory and regulatory framework that governs transportation impact analysis under SB 743, CEQA Guidelines 515084.3, and the LCI 20 /8 TechnIcal AdvIsory as they apply to the City of Downey. The summary will highlight the transition from LOS to Vehicle Miles Traveled (VMT) as the metric for determining transportation impacts under CEQA and outline the implications for the City's current policies, procedures, and development review processes.

Building on this framework, Fehr & Peers will identify feasible threshold options for determining VMT significance consistent with CEQA and LCI guidance, while calibrated to Downey's local context and mobility goals.

Circlepoint will support the preparation of the summary memo by documenting any addItional CEQA considerations and providing recommendations as to how each document applies to the proposed screening thresholds and recommended threshold of significance options.

Task 2 Deliverables
• Technicat memorandum summarizing SB 743, CEQA §15064.3, and LCI 20'18 Technical Advisory applicability to the City of Downey
• Recommended threshold framework for signifIcance determination (for refInement in Task 4,
8 Attachment A

Docusign Envelope ID: F16C19DF-564F-463E-8E5B-7E24DC6985C6 Task 3: Screening Criteria & Tools
Fehr & Peers will develop streamlined screening criteria and supporting tools to help the City determine when proposed development projects are presumed to result in a less-than- significant transportation impact under SB 743 and CEQA 515064.3.

Fehr & Peers will review available modeling and data resources, including the most recent SCAG 2024 RTP/SCS regional travel-demand model and local network land-use, and transit datasets, to ensure screening thresholds reflect Downey's local travel patterns. We will coordinate with City staff to define assumptions and confirm the datasets that will serve the guidelines.

The screening framework will include the following components:
@
•
Project type screening (e.g., 1 00% affordable housing and local serving uses).

Transit proximity of 1/, -mile screening based on the availability and frequency of existing and planned transit service, particularly with the future Southeast Gateway Line station proposed on Garfield Avenue.

Low VMT area screening based on mapping showing the areas of the city that meet the definition of low VMT,
e
e Project size screening based on data-supported daily trip generation/ ADT threshold for the City of Downey for proposed uses.

O While it is common for agencies to request an ADT-based screening threshold, it may not be the best-aligned option with local conditions and CEQA- compliance
()Additional options for local screening include:

Utilizing the City's General Plan and CEOA Section 1 5183 for screening •Screening based on General Plan amendments or updates
•Simplified VMT analysis and screening
•Model sensitivity and testing
Remove this screening option and monitor caselaw and projects C)Options for small project screening will be discussed once we understand the priorities and what makes sense for the City of Downey, Fehr & Peers will provide user-friendly tools, including an Excel/PDF VMT Screening Form, a process flowchart illustrating the screening logic, and applicant instructions to guide consistent application of the criteria.

Circlepoint will support the development of the proposed screening criteria by reviewing CEQA considerations, environmental constraints, and substantial evidence requirements to support the utilization of the draft criteria and small-project ADT threshold.

Task 3 Deliverables
• Memorandum section summarIzing the proposed VMT screening methodology • Flowchart i[lustrating the VMT screening process
+ Excel/PDF Screening Form and applicant instructions
9 Attachment A

Docusign Envelope ID: F16C19DF-564F-463E-8E5B-7E24DC6985C6 Task 4: Thresholds of Significance (Options & Recommendation) Fehr & Peers will develop VMT thresholds of significance for the City of Downey. Using regional model data (e.g., SCAG 2024 RTP/SCS regional model) and locally validated inputs from Task 3, Fehr & Peers will compute and/or confirm Downey VMT levels for the following LCI-consistent metrics
• VMT per service population (population + employment)
• Home-based residential VMT per capita
• Home-based work VMT per employee
These metrics are consistent with LCl’s recommended approach of applying different VMT metrics to different land use types (e.g., residential vs. office) and provide the technical basis for selecting threshotds. Based on this technical foundation, Fehr & Peers will present clear options of developing VMT thresholds of significance, such as:
• Citywide average (no net increase compared to base-year citywide VMT rates); • 15% below existing development (per LCI advisory);
• Alternative thresholds justified by substantial evidence.

To support the City's policy choice, Fehr & Peers, with support from Circlepoint, will compare Downey's options to 3–5 peer jurisdictions in the region, such as Los Angeles County, City of Los Angeles, and other southeast/Gateway-area jurisdictions that have adopted SB 743-compliant transportation guidelines, to illustrate how Downey’s thresholds can remain defensible while not being out of step with nearby agencies. This comparison will note whether a jurisdiction uses a straight 15% reduction, a no-net-increase local baseline, or a tiered/location-based approach.

We will also discuss how the VMT significance thresholds would apply to land use plans and atypical land uses the City anticipates may be developed in the city.

Following City staff input, Fehr & Peers will recommend a preferred threshold framework that:
• identifies which VMT metric applies to which project type; + flags cases where transportation projects may still require VMT analysis (capacity- increasing projects, induced travel, etc.).

Task 4 Deliverables
+ Memorandum section describing Downey’s VMT baseline metrics (resident, worker, service population) and data sources
e Threshold options matrix comparing 3–5 regional/comparable agencies, with CEQA considerations
+ Recommended VMT threshold framework (by land use type and VMT metric), including notes on transportation projects
Task 5: Analysis Method & Data Sources
Fehr & Peers will define the technical methodology and data hierarchy for quantifying Vehicle Miles Traveled within the City of Downey. This task will identify appropriate analytical tools, clarify when each should be used, and specify how to establish baseline and project conditions for VMT evaluation.
10 Attachment A

Docusign Envelope ID: F16C19DF-564F-463E-8E5B-7E24DC6985C6 Fehr & Peers will review and document the capabilities of the SCAG 2024 RTP/SCS regional travel-demand model, the Gateway Cities COG Strategic Transportation Plan (STP) sub-regional model, and other local modeling resources to determine which best reflects Downey's local network and trip patterns. Based on this review, Fehr & Peers will recommend a preferred model or combination of tools for City use.

Project-level VMT estimation methods will include:
• Map-based and spreadsheet tools (e.g., low-VMT area maps, screening calculator) for projects meeting Task 3 criteria;
• Regional or sub-regional model applications for larger or regionally significant projects,' and
•Project-specific models only when warranted by size, complexity, or induced-travel potential.

Fehr & Peers, with support from Circlepoint, will establish bright-line triggers distinguishing when a project can rely on map-based screening versus when full model analysis is required.

These triggers will be based on project type, size, and location relative to screening thresholds developed in Task 3 and Task 4. The City currently has information regarding a General Plan update available on the city's website. Utilizing General Plan analysis, modeling, and land use/socioeconomic forecast offers efficiency for developing thresholds supported by substantial evidence and local consistency.

Finally, Fehr & Peers will define the methodology for determining existing conditions or baseline VMT, consistent with CEQA 915125(a) and LCI guidance. This will include documenting data, model years, and socioeconomic assumptions so that future project analyses remain transparent and reproducible.

Task 5 Deliverables
+ Memorandum detailing ana[ysis methodology and baseline-VMT data sources and assumptions
• Table of recommended analytical tools and appropriate use cases • "Bright-line" screening vs. modeling trigger matrix
Task 6: Mitigation Framework
Fehr & Peers will develop a city-specific mitigation framework to address projects that exceed VMT thresholds. The framework will identify feasible, quantifiable, and CEQA-defensible strategies that reduce vehicle travel by encouraging multimodal transportation, shortening trip lengths, and lowering the share of single-occupant vehicle trips. Measures will include on-site design changes, transportation demand management (TDM) programs, and area-wide or fee- based options where appropriate.

The effectiveness of each mitigation will be based on the California Air Pollution Control Officers Association (CAPCOA) handbooks, Quantifying Greenhouse Gas Mitigation Measures (2010) and its 2021 update, which is supplemented by recent peer-reviewed research and LCl's 2018 Technical Advisory. Fehr & Peers will summarize the applicable measures, provide guidance on combining multiple strategies without double-counting benefits, and outline procedures for determining residual significance when mitigation is infeasible or insufficient. If desired, the Fehr & Peers TDM+ tool will be used to demonstrate the framework's application to representative Downey projects.
11 Attachment A

Docusign Envelope ID: F16C19DF-564F463E-8E5B-7E24DC6985C6 Task 6 Key Deliverables:
• Matrix summarizing VMT-reduction and TDM strategies
• Applicant worksheet/template (Excel/PDF)
• Technica[ memorandum documenting methods and qualification references Task 7: Non-CEQA Traffic Impact Analysis (TIA) & Operational Review Fehr & Peers will prepare a clear framework for conducting non-CEQA traffic impact analyses to evaluate local operational and safety conditions, separate from the VMT-based CEQA review.

The framework will clarify when LOS and other operational metrics may still be used for policy or planning purposes. such as site access design, intersection control. and circulation management, and where such analyses may be requested as part of review.

Fehr & Peers will recommend trip generation thresholds that trigger the need for a TIA based on standard industry practice and tailored to the City of Downey’s street network and development context. for example. 50 to ICX) net new peak-hour trips. The framework will also reference the Los Angeles County Traffic Impact Analysis Guidelines and identify how Downey’s procedures can remain consistent with neighboring jurisdictions.

The resulting guidance will allow City staff to maintain LOS analysis for operational purposes while relying solely on VMT for CEQA determinations, providing a balanced and transparent process for applicants and reviewers.

Task 7 Deliverables
• Technical memorandum documenting data sources and guidance for non-CEQA TIA and operational review
Task 8: Tools, Map & Training
Fehr & Peers will prepare GIS layers and maps identifying low-VMT areas, along with an applicant guide and process flowchart that illustrate screening and review steps. Two staff training sessions will be provided, one for Planning and CEQA staff and one for Public Works and Traffic
Engineering staff. Each session will cover how to apply the screening process, interpret results, and document findings using the VMT tool. These trainings will include examples, reviewer checklists, and a peer-review rubric, and one
session will be recorded for future reference.

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Circlepoint will lead and facilitate the Planning and CEQA staff training session, while Fehr & Peers will lead the session for Public Works and Engineering staff.

Our team proposes that each training session be
conducted as a two-hour virtual session to allow for
maximum staff participation and the recording of the
training and tool demonstrations for future reference.

Sample VMT & TPA Mapping for City
of Santa Fe Springs. Fehr & Peers
Task 8 Deliverables:
• GIS layers and maps of tow-VMT areas
12 Attachment A

Docusign Envelope ID: F16C19DF-564F-463E-8E5B-7E24DC6985C6 • One-page applicant guide and process flowchart
• Training materials and slide decks, and two staff trainIng sessions Task 9: Outreach, Equity, and Transparency
Outreach related to the Vehicle Miles Traveled (VMT) project has been conducted over the past one and a half years as part of the City's General Plan Update. Engagement efforts have included coordination with internal City departments and a town hall meeting with the development community, where participants were asked to identify barriers to housing and mixed-use development, opportunities for streamlining approvals, and tools that could improve predictability in the entitlement process. Through this outreach, the development of clear and standardized VMT screening guidelines was identified as a key strategy to reduce uncertainty, shorten review timelines, and support housing production consistent with State requirements.

Consistent with REAP 2.0 objectives related to transparency, process improvement, and equitable access to information, the City will publish the draft VMT guidelines for public review upon completion. The draft will be posted on the City's website and social media platforms and distributed directly to the development community, including affordable housing developers, and other stakeholders for input. Public and stakeholder feedback will be considered prior to finalizing the guidelines, ensuring the VMT framework is clear, accessible, and responsive to community and market needs. More specifically, Fehr & Peers, will:
+
•
•
Coordinate files/versions for city to post on social media/website; Share draft guidelines with stakeholders,' and
Review, consolidate and incorporate input
Task 9 Deliverables:
• Summary of received comments
Task 10: Adoption Package & Support
Fehr & Peers will assist the City of Downey in preparing materials needed for the formal adoption of the VMT Guidelines and associated thresholds of significance. This will include a draft City Council resolution and findings that document substantial evidence supporting the thresholds, a CEQA compliance pathway memorandum describing the applicability of a Class 8 categorical exemption, and a concise staff report and presentation slide deck for City review.

Fehr & Peers will attend and present at up to two public hearings, including the City Council meeting where adoption is anticipated, to summarize key findings, address questions, and provide technical clarification as needed.

Circlepoint will lead the preparation of a CEQA Compliance Pathway Memo, which summarizes the work produced as part of Tasks 4-6 and details how the recommended screening criteria and thresholds of significance support the CEQA Categorical Exemption 8 criteria (as per CEQA Guidelines 915308). This scope assumes one (1) round of review and comment of the draft Memo by the City before incorporation into the final Memo.

Task 10 Deliverables:
+ Draft Council resolution
+ Findings/substantia[ evidence memo
• Staff report and presentation stides
13 Attachment A

Docusign Envelope ID: F16C19DF-564F-463E-8E5B-7E24DC6985C6 • Participation at up to two public hearings
Task 11: Analysis of SB 743 Compliance in the Gateway Cities COG Subregion Fehr & Peers will evaluate the current status of SB 743 implementation among jurisdictions within the Gateway Cities Council of Governments (COG) subregion to identify consistency, gaps, and opportunities for regionaf alignment. The team will review publicly available Traffic Impact Analysis Guidelines, General Plan policies, and CEQA procedures from each city to determine their degree of compliance with SB 743 requirements and CEQA Guidelines Section 150M.3. A matrix summarizing each jurisdiction's compliance status, including threshold type, screening methodology, and analytical tools used, will be prepared. Based on this review, Fehr & Peers will develop recommendations to support regional consistency and to assist cities that have not yet adopted SB 743-compliant methodologies or thresholds.

Task 11 Deliverables:
• Matrix summarIzing SB 743 compliance status for Gateway Cities COG jurisdictions • Memorandum out[ining recommended next steps for regional coordination and consistency
14 Attachment A

Docusign Envelope ID: F16C19DF-564F463E-8E5B-7E24DC6985C6 Project Timeline
This section provides a proposed schedule to achieve implementation of the city’s VMT guidelines, assuming a start date in February 2026. We are proposing a seven-month schedule, ending with Commission and/or City Council meetings in /summer 2026. We are available to work with the City to modify the schedule for individual tasks to meet the City’s desired completion date and accommodate staff schedules and review times, The schedule assumes that City staff WIll be given two weeks to revIew the submitted deliverables.

Table 1 - Project Timeline
I I 1 2 1 3 1 + 1 s 1 6 1 7 1 8 1 9 1 1 o 1 1 1 1 1 2 1 1 3 1 1 4 1 1 s 116l17l18 jn 1 mIn jn 123 lb 125l26 jn 128 Task 1: Project
Initiation & Work Plan X X X
D

X X X X X X X X X X X
Task 2: Policy & Legal
Framework
Task 3: Screening
Criteria & Tools
F
D F
Task 4: Thresholds of
Significance (Options &
Recommendation)
Task 5: Analysis
Method & Data Sources
D F
Task 6: Mitigation
Franrework
Task 7: Non'CEQA
Traffic Impact Analysis
(TIA) & Operational
Review
Task 8: Tools, Map &
Training
Task 9: Outreach,
Equity, and
TransparencY
Task 10: Adoption
Package & Support
Task 11: Analysis of SB
743 Compliance in the
Gateway Cities COG
Subregion
D F
D F
Task I - Staff coordInation meetings. Bkweekty conference calls (X) Task 2 & Task 10 - Public In-Person meetings (3 Meetings) and Staff TraIning, Exact dates TDB by CIty D = Submittal of Draft Deliverable F = Submittal of Final Deliverable 15 Attachment A

Docusign Envelope ID: F16C19DF-564F-463E-8E5B-7E24DC6985C6 roject Fee ScheduleP
The not-to-exceed project budget ($125,883) for the City of Downey's VMT Analysis / CEQA Guidelines for SB 743 is provided on the fOllOWIng page and is itemized by each task and subtask, Invoices will be submitted monthty for services rendered and are due and payable upon receipt. 16 Attachment A

Docusign Envelope ID. F16C19DF.564F463E-8E5B-7E24DC6985C6 City of Downey, CA
Proposed Fee Schedule i 1 :2lIJlciates
aT
gi
$165
e
]E
:0
Task Description
$315 5190 $300
4 0
4 4
2 $170
8 12
16 28
12 $175 1 1 1 $330 $319 $221 $189 $189 1 $163 1 $142
111
a[Policy & La:miLI
aF==ier linT-ritzIT
TlmT sholds mmFaT=78;iis=
6 3,390
300
300
16 i
4 4
4 4
4 8
1 8
2 57
16 4
12 14
10 16
16 8
2 8
6 112
4 d
4 4
4 48
40 54
46 52
36 15
28 24
$ 11,340
$ 3,430
$ 8,160
4 B–TH S 4,336
$ 6.176
$-M8
T1
m6k
MT i

20.265
10, 587
13, 17019
13 0
0 0
35 0
300
300
300
300
300
300
300
$ 10,580 $ 2,662 936
m6
WG
729
14,478
9,725
9,960

11.309
al rc es
anltlqation Fran
=IFRn -ERa=iSTsT;m&–
$ 6,500
$ 9,020
m2
as
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4 0
2 2
24 8
10 8-
14 156
$ 10,280
$ 8,000
$ 2,995
–s 6.166
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TIm ion Package & Support
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4 T–- r$iQ2 i
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$ 23
$
$ 30,630=aM

TOTAL BY FIRM
F ++817 40
[Em1 1BHl1 1m ImI 1tHEIll
6090 3 +4 4l5 IT133878
FTF4rT;aTT5im8 THQqBnTFD–GiF-li@ S IMliEmIn $ 125,883
!!ro08 1
8,008
It,hlt8 + As\u ufri It'IHrt
WMI Arutnr\ all,I Cl (U t ,u,Nwus Dr \H /4 /
21 ItV III l\iwlhv/LI C (X
Attachment A

Docusign Envelope ID: F16C19DF-564F463E-8E5B-7E24DC6985C6

MEMORANDUM OF UNDERSTANDING

BY AND BETWEEN

GATEWAY CITIES COUNCIL OF GOVERNMENTS

RECITALS
A. On March 4, 2025, the GCCOG entered into a Memorandum of Understanding (“SCAG MOU”) with the Southern California Association of Governments (“SCAG”) for a Regional Early Action Planning (“REAP”) Subregional Partnership (“SRP”)

B. The City desires technical assistance pursuant to the SCAG MOU and agrees to the terms and conditions set forth herein to receive such services.

NOW, THEREFORE, IT IS MUTUALLY AGREED THAT:

1. Scope of Work and City Responsibilities.

The City requests technical assistance as set forth in the Scope of Work attached hereto as Exhibit “A“ and incorporated herein by this reference. The City agrees to:

A. Provide a point of contact to serve as the City’s Project Manager with name, title, and contact information.

B. Participate in scheduled conference calls and meetings from the anticipated start date to completion date.

C
of Work.

Provide accurate information relevant and necessary to perform the Scope D. Respond to the GCCOG or its consultant's requests related to the Scope of Work in a timely manner, such as providing information and feedback on draft documents, approaches, and designs.

2. GCCOG Responsibilities.

The GCCOG will engage one of its REAP 2.0 technical assistance consultants to perform the Scope of Work requested by the City and manage the full payment of those services 1 Attachment B

Docusign Envelope ID: F16C19DF-564F-463E-8E5B-7E24DC6985C6 from the grant funding pursuant to the SCAG MOU. The City shall have no financial obligation under this MOU.

4. SCAG Requirements.

C. To promote awareness and encourage local support, local elected officials in the project area should be invited to outreach activities.

5. Governing Law.

This MOU shall be governed by the laws of the State of California and venue shall lie in Los Angeles County.

6. Disputes.

8. Independent Contractor.

9. Construction
The Parties have participated jointly in the negotiation and drafting of this MOU. In the event an ambiguity or question of intent or interpretation arises with respect to this MOU , this MOU shall be construed as if drafted jointly by the Parties and in accordance with its fair meaning. There shall be no presumption or burden of proof favoring or disfavoring any Party by virtue of the authorship of any of the provisions of this MOU.

10. Captions.

The captions herein are for convenience and references only and are not a part of this MOU and do not in any way limit, define or amplify the terms and provisions hereof. 11 . Entire Aqreement.

12. Authority to Execute this MOU.

Docusign Envelope ID: F16C19DF-564F-463E-8E5B-7E24DC6985C6

13. Counterparts.

This MOU may be executed in counterparts, each of which shall be deemed an original, and all of such counterparts together shall constitute one and the same instrument.

IN WITNESS WHEREOF, the authorized representatives of the Parties have caused this MOU to be executed as of the date of the last signature below.

CITY GCCOG
Claudia M. Frometa, Mayor Hector De La Torre, Executive Director Date :Date. 1/27/2026
APPROVED AS TO FORM:APPROVED AS TO FORM:

L
John M. Funk, City Attorney mI.e
ATTEST
Maria Alicia DuaNe, CMC
City Clerk
Attachment B

Docusign Envelope ID: F16C19DF-564F-463E-8E5B-7E24DC6985C6

EXHIBIT A

SCOPE OF WORK
Attachment B

Docusign Envelope ID: F16C19DF-564F463E-8E5B-7E24DC6985C6 Approach and Work Plan
A. Project Understanding and Background
On September 27, 2013, Governor Jerry Brown signed SB 743 into law and started a process intended to fundamentatly change transportation impact analysis as part of CEQA compliance.

The primary change was the elimination of Level of Service (LOS) as a measure of vehicular capacity and traffic congestion as a basis for determining significant transportation impacts under CEQA. The law directed the Governor's OffIce for Land Use and Climate Innovation (LCI), formerly the Governor's OfRce of Planning and Research (OPFt), to update the CEQA Guidelines to include new performance criteria for determining the significance of transportation impacts.

In response to SB 743. LCI selected vehicle miles of travel (VMT) as the new transportation impact metric. LCI then submitted updates to the CEQA Guidelines, and these updates were certified by the Natural Resources Agency in December 2018.

To help lead agencies with SB 743 implementation, LCI produced a Technical Advisor),t to help lead agencies think about the variety of implementation questions they face with respect to shifting to a VMT metric. However. lead agencies must still make their own specific decisions about VMT methodology, screening criteria, significance thresholds, and mitigation. These decisions should be consistent with the City of Downey's goals as expressed in its general plan.

When communicating with decision makers on VMT thresholds, we have found that it's helpful to start with why the State adopted new CEQA guidelines. The intent of SB 743 is to better support the following State goals:
•
Reducing greenhouse gas (GHG) emissions
Encouraging infill development and a diversity of land uses Developing multimodal transportation networks
Improving public health through active transportation
While changes to driving conditions that increase travel times are an important consideration for traffic operations and management, these changes do not fully describe environmental effects associated with fuel consumption, emissions, and public health. VMT-based impact criteria will help to incorporate these environmental effects and move toward achieving the State goals listed above.

B. Project Approach
Most cities in the Gateway Cities Council of Governments apply the Los Angeles County Public Works Transportation Impact Analysis Guidelines, while a few, like Whittier, Pico Rivera, Santa Fe 1 Tethnica1 A£Mgxy on Evaluating Transpatation Impacts in CECA LCI, tnemtnr 2018 6 Attachment B

Docusign Envelope ID: F16C19DF-564F463E-8E5B-7E24DC6985C6 Springs, and Long Beach, have developed their own guidelines. The guidelines are typically based on SB 743 and the State's corresponding LCI Senate Bill 743 Implementation Guidelines.

Docusign Envelope ID: F16C19DF-564F463E-8E5B-7E24DC6985C6 C. Work Plan
The R+ A team has provided a comprehensive Scope of Work that addresses and exceeds the requirements listed in the RFP. The Scope of Work is designed to be flexible and can be tailored to best meet the needs of the City of Downey and GCCOG.

Circlepoint will provide environmental and CEQA expertise to support the preparation of the data needs matrix and the annotated outline for the guidelines and adoption package.

Following the kickoff, Fehr & Peers will lead up to six (6) virtual coordInation meetings to review technical progress, discuss interim findings, and obtain City input on methodologies, screening criteria, and thresholds of significance. R+ A and Circtepoint will attend up to four (4) meetings as needed. Additional meetings may be attended on a time-and-materials basis, if requested. All meetings will be documented through summary notes identifying key decisions and next steps.

Task 1 Deliverables and Meetings
• One (1) kick-off meeting with staff – Meeting agenda and summary action notes • Annotated outline for the VMT Guidelines and adoption package • Data needs matrix and project schedule
• Up to six (6) coordination meetings – Meeting agenda and summary action notes Task 2: Policy & Legal Framework
Fehr & Peers will summarize the statutory and regulatory framework that governs transportation impact analysis under SB 743, CEQA GuIdeIInes Sl 5064.3, and the LCI 2018 Technical Advisory as they apply to the City of Downey. The summary will highlight the transition from LOS to Vehicle Miles Traveled (VMT) as the metric for determining transportation impacts under CEQA and outline the implications for the City's current policies, procedures, and development review processes.

Building on this Framework, Fehr & Peers will identify feasible threshold options for determining VMT significance consistent with CEQA and LCI guidance, while calibrated to Downey's local context and mobility goals.

Circlepoint will support the preparation of the summary memo by documenting any additional CEQA considerations and providing recommendations as to how each document applies to the proposed screening thresholds and recommended threshold of significance options.

Task 2 Deliverables
• Technical memorandum summarizIng SB 743, CEQA §15064.3, and LCI 2018 Technical Advisory applicability to the City of Downey
• Recommended threshold framework for signifcance determination (for refLnenrent in Task 4'
8 Attachment B

Fehr & Peers will review available modeling and data resources. including the most recent SCAG 2024 RTP/SCS regional travel-demand model and local network. land-use, and transit datasets, to ensure screening thresholds reflect Downey’s local travel patterns. We will coordinate with City staff to define assumptions and confirm the datasets that will serve the guidelines.

The screening framework will include the following components:
•
e
Project type screening (e.g., 100% affordable housing and local serving uses).

Transit proximity of 1/, -mile screening based on the availability and frequency of existing and planned transit service. particularly with the future Southeast Gateway Line station proposed on Garfield Avenue.

Low VMT area screening based on mapping showing the areas of the city that meet the definition of low VMT,
•
e Project size screening based on data-supported daily trip generation/ ADT threshold for the City of Downey for proposed uses.

O While it is common for agencies to request an ADT-based screening threshold. it may not be the best-aligned option with local conditions and CEQA- compliance
()Additional options for local screening include:
• Utilizing the City’s General Plan and CEQA Section 15183 for screening •Screening based on General Plan amendments or updates
Simplified VMT analysis and screening
Model sensitivity and testing
Remove this screening option and monitor caselaw and projects C)Options for small project screening will be discussed once we understand the priorities and what makes sense for the City of Downey.

Fehr & Peers will provide user-friendly tools, including an Excel/PDF VMT Screening Form, a process flowchart illustrating the screening logic, and applicant instructions to guide consistent application of the criteria.

Task 3 Deliverables
• Memorandum section summarizing the proposed VMT screening methodology • Flowchart illustrating the VMT screening process
• Excel/PDF Screening Form and applicant instructions
9 Attachment B

Docusign Envelope ID: F16C19DF-564F463E-8E5B-7E24DC6985C6 Task 4: Thresholds of Significance (Options & Recommendation) Fehr & Peers will develop VMT thresholds of significance for the City of Downey. Using regional model data (e.g., SCAG 2024 RTP/SCS regional model) and locally validated inputs from Task 3, Fehr & Peers will compute and/or confirm Downey VMT levels for the following LCI-consistent metrics
• VMT per service population (population + employment)
• Home–based residential VMT per capita
• Home-based workVMT per employee
These metrics are consistent with LCl's recommended approach of applying different VMT metrics to different land use types (e.g., residential vs. office) and provide the technical basis for selecting thresholds. Based on this technical foundation, Fehr & Peers will present clear options of developing VMT thresholds of significance, such as:
• Citywide average (no net increase compared to base-year citywide VMT rates); • 15% below existing development (per LCI advisory);
• Alternative thresholds justified by substantial evidence.

To support the City's policy choice, Fehr & Peers, with support from Circlepoint. will compare Downey's options to 3–5 peer jurisdictions in the region, such as Los Angeles County, City of Los Angeles, and other southeast/Gateway-area jurisdictions that have adopted SB 743-compliant transportation guidelines, to illustrate how Downey's thresholds can remain defensible while not being out of step with nearby agencies. This comparison will note whether a jurisdiction uses a straight 1 5% reduction, a no-net-increase local baseline. or a tiered/location-based approach.

We will also discuss how the VMT significance thresholds would apply to land use plans and atypical land uses the City anticipates may be developed in the city, Following City staff input, Fehr & Peers will recommend a preferred threshold framework that:
• identifies which VMT metric applies to which project type; • flags cases where transportation projects may still require VMT analysis (capacity- increasing projects, induced travel, etc.).

Task 4 Deliverables
• Memorandum section describing Downey’s VMT base[ine metrics (resident, worker, service population) and data sources
• Threshold options matrix comparing 3–5 regional/comparable agencies, with CEQA considerations
e Recommended VMT threshold framework (by [and use type and VMT metric). including notes on transportation projects
Task 5: Analysis Method & Data Sources
Fehr & Peers will define the technical methodology and data hierarchy for quantifying Vehicle Miles Traveled within the City of Downey. This task will identify appropriate analytical tools, clarify when each should be used, and specify how to establish baseline and project conditions for VMT evaluation.
10 Attachment B

Docusign Envelope ID: F16C19DF-564F-463E-8E5B-7E24DC6985C6 Fehr & Peers will review and document the capabilities of the SCHG 2024 RTP/SCS regIonal travel-demand model the Gateway Cities COG Strategic Transportation Plan (STP) sub-regional model, and other local modeling resources to determine which best reflects Downey's local network and trip patterns. Based on this review, Fehr & Peers will recommend a preferred model or combination of tools for City use.

Project-level VMT estimation methods will include:
• Map-based and spreadsheet tools (e.g., low-VMT area maps, screening calculator) for projects meeting Task 3 criteria;
• Regional or sub-regional model applications for larger or regionally significant projects; and
• Project-specific models only when warranted by size, complexity, or induced-travel potential.

Fehr & Peers, with support from Circlepoint, will establish bright-line triggers distinguishing when a project can rely on map-based screening versus when full model analysis is required.

Task 5 Deliverables
• Memorandum detailing ana[ysis methodology and baseline-VMT data sources and assumptions
• Table of recommended ana[ytical tools and appropriate use cases • "Bright-line" screening vs. modeling trigger matrix
Task 6: Mitigation Framework
Fehr & Peers will develop a city-specific mitigation framework to address projects that exceed VMT thresholds. The framework will identify feasible, quantifiable, and CEQA-defensible strategies that reduce vehicle travel by encouraging multimodal transportation, shortening trip lengths, and lowering the share of single-occupant vehicle trips. Measures will include on-site design changes, transpoltation demand management (TDM) programs, and area-wide or fee- based options where appropriate.

The effectiveness of each mitigation will be based on the CaIIfornIa Air Pollution Control Officers Association (CAPCOA) handbooks. Quantifying Greenhouse Gas Mitigation Measures (20 lO) and its 2021 update, which is supplemented by recent peer-reviewed research and LCl's 2018 Technical Advisory. Fehr & Peers will summarize the applicable measures, provide guidance on combining multiple strategies without double-counting benefits, and outline procedures for determining residual significance when mitigation is infeasible or insufficient. If desired, the Fehr & Peers TDM+ tool will be used to demonstrate the framework's application to representative Downey projects.
11 Attachment B

Docusign Envelope ID: F16C19DF-564F463E-8E5B-7E24DC6985C6 Task 6 Key Deliverables:
e Matrix summarizing VMT-reduction and TDM strategies
• Applicant worksheet/template (Excel/PDF)
• Technica[ mernorandum documenting methods and qualiRcation references Task 7: Non-CEQA Traffic Impact Analysis (TIA) & Operational Review Fehr & Peers will prepare a clear framework for conducting non-CEQA traffic impact analyses to evaluate local operational and safety conditions, separate from the VMT-based CEQA review.

The framework will clarify when LOS and other operational metrics may still be used for policy or planning purposes, such as site access design, intersection control, and circulation management, and where such analyses may be requested as part of review.

Fehr & Peers will recommend trip generation threshotds that trigger the need for a TIA, based on standard industry practice and tailored to the City of Downey's street network and development context, for example, 50 to ICX) net new peak-hour trips. The framework will also reference the Los Angeles County Traffic Impact Analysis Guidelines and identify how Downey's procedures can remain consistent with neighboring jurisdictions.

Task 7 Deliverables
• Technical memorandum documenting data sources and guidance for non-CEQA TIA and operational review
Task 8: Tools, Map & Training
Fehr & Peers will prepare GIS layers and maps identifying low-VMT areas, along with an applicant guide and process flowchart that illustrate screening and review steps. Two staff training sessions will be provided, one for Planning and CEQA staff and one for Public Works and Traffic
Engineering staff. Each session will cover how to apply the screening process, interpret results, and document findings using the VMT tool. These trainings will include examples. reviewer checklists, and a peer-review rubric, and one
session will be recorded for future reference.
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Circlepoint will lead and facilitate the Planning and CEQA staff training session, while Fehr & Peers will lead the session for Public Works and Engineering staff.

Sample VMT & TPA Mapping for City
of Santa Fe Springs, Fehr & Peers
Task 8 Deliverables:
• GIS layers and maps oftow-VMT areas
12 Attachment B

Docusign Envelope ID: F16C19DF-564F-463E-8E5B-7E24DC6985C6 • One-page applicant guide and process flowchart
• Training materials and slide decks, and two staff training sessions Task 9: Outreach, Equity, and Transparency
Outreach related to the Vehicle Miles Traveled (VMT) project has been conducted over the past one and a half years as part of the City's General Plan Update. Engagement efforts have included coordination with internal City departments and a town hall meeting with the development community, where participants were asked to identify barriers to housing and mixed-use development, opportunities for streamlining approvals, and tools that could improve predictability in the entitlement process. Through this outreach, the development of clear and standardized VMT screening guidelines was identified as a key strategy to reduce uncertainty, shorten review timelines, and support housing production consistent with State requirements.

Consistent with REAP 2.0 objectives related to transparency, process improvement, and equitable access to information, the City will publish the draft VMT guidelines for public review upon completion. The draft will be posted on the City's website and social media platforms and distributed directly to the development community, including affordable housing developers, and other stakeholders for input. Public and stakeholder feedback will be considered prior to finalizinq the guidelines, ensuring the VMT framework is clear, accessible, and responsive to community and market needs. More specifically, Fehr & Peers, will:
• Coordinate files/versions for city to post on social media/website; e Share draft quidelines with stakeholders; and
• Review, consolidate and incorporate input
Task 9 Deliverables:
• Summary of received comments
Task 10: Adoption Package & Support
Fehr & Peers will assist the City of Downey in preparing materials needed for the formal adoption of the VMT Guidelines and associated thresholds of significance. This will include a draft City Council resolution and findings that document substantial evidence supporting the thresholds, a CEQA compliance pathway memorandum describing the applicability of a Class 8 categorical exemption, and a concise staff report and presentation slide deck for City review.

Circlepoint will lead the preparation of a CEQA Compliance Pathway Memo, which summarizes the work produced as part of Tasks 4-6 and details how the recommended screening criteria and thresholds of significance support the CEQA Categorical Exemption 8 criteria (as per CEQA Guidelines 615308). This scope assumes one (1) round of review and comment of the draft Memo by the City before incorporation into the final Memo.

Task 10 Deliverables:
+ Draft Council resolution
• Findings/substantial evidence memo
• Staff report and presentation slides
13 Attachment B

Docusign Envelope ID: F16C19DF-564F-463E-8E5B-7E24DC6985C6 • Participation at up to two public hearings
Task 11: Analysis of SB 743 Compliance in the Gateway Cities COG Subregion Fehr & Peers will evaluate the current status of SB 743 implementation among jurisdictions within the Gateway Cities Council of Governments (COG) subregion to identify consistency, gaps, and opportunities for regional alignment. The team will review publicly available Traffic Impact Analysis Guidelines, General Plan policies, and CEQA procedures from each city to determine their degree of compliance with SB 743 requirements and CEQA Guidelines Section 15064.3. A matrix summarizing each jurisdiction’s compliance status, including threshold type, screening methodology, and analytical tools used, will be prepared. Based on this review, Fehr & Peers will develop recommendations to support regional consistency and to assist cities that have not yet adopted SB 743-compliant methodologies or thresholds.

Task 1 1 Deliverables:
• Matrix summarIzing SB 743 compliance status for Gateway Cities COG jurisdictions e Memorandum outlining recommended next steps for regional coordination and consistency
14 Attachment B

Docusign Envelope ID: F16C19DF-564F-463E-8E5B-7E24DC6985C6 roject TimelineP
This section provides a proposed schedule to achieve implementation of the city’s VMT guideIInes, assuming a start date in February 2026. We are proposing a seven-month schedule, ending with CommISsion and/or City Council meetings in /summer 2026. We are available to work with the City to modify the schedule for individual tasks to meet the City's desired completion date and accommodate staff schedules and review times. The schedule assumes that City staff will be given two weeks to review the submitted deliverables.

Table 1 - Project Timeline
Hay
TASKS W,,k l&16
1 1 1 2 1 3 1 + 1 s 1 1:11 1 7 1 8 1 9 1 11E) 1 1 1 1 x11:1 1 HI HI IS jn Weeks 2b28
1 2 1 1 11EII I IIBII 1 24b 1 2 s 1 21:11 1 2 7 1 2 8
Task 1: Project
Initiation & Work Plan
Task 2: Policy & Legal
Framework
X X X
D

X X X X X X X X X X X
F
D FTask 3: Screening
Criteria & Tools
Task 4: Thresholds of
Significance (Options &
Recommendrtion)
Task 5: Analysis
Method & Data Sources
D F
Task 6: Mitigation
Framework
Task 7: Non-CEQA
Traffic Impact Analysis
(TIA) & Operational
Review
Task 8: Tools, Map &
Training
Task 9: Outreach ,
Equity, and
Transparency
Task 10: Adoption
Package & Support
Task 11: Analysis of SB
743 Compliance in the
Gateway Cities COG
Subregion
D F
D F
Task 1 - StaR coordination meetings, BL-weekly conference calls (X) Task ? a Task 10 - Public In-Person meetings (3 Meetings) and Staff Training. Exact dates TDB by City D = Submittal of Draft Deliverable F = Submittal of Final Deliverable 15 Attachment B

Docusign Envelope ID: F16C19DF-564F463E-8E5B-7E24DC6985C6 Project Fee Schedule
The not-to-exceed project budget ($125,883) for the City of Downey’s VMT AnalysIS / CEQA Guidelines for SB 743 is provided on the following page and is itemized by each task and subtask.

Invoices will be submitted monthty for services rendered and are due and payable upon receipt. 16 Attachment B

Docuslgn Envelope ID= F16C19DF-564F-463E-8E5B-7E24DC6985C6 City of Downey, CA
Proposed Fee Schedule bI :!Tilciates
RAIMI + ASSOCIATES n g
Q
&
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6 14
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4 8 $142
ar
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8 1
1 1
1 1
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1 6 3,390
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2 28
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16 28
4 0
4 4
4 8
4 8
0 4
0 40
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40 54
32 46
52 36
15 28
$ 11,340
$ 3,430
$ 8,160
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10.587
13, 170
300
300
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300
300
300
300
14 10
16 16
8 2
8 6
112
$ 10.580 13 is 2,662
0 936 14,478

9.725
9,960
AnajysIS Method & Data Sources
I
Fa=p=ct Analysis (TIA) &
12 16
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10 8
14 156
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$ 8.000
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S
m4
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0 729
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j1 iII–947 1 (
333
11,309
13,151
3,514
14,641
5,083
F a Tr,11111rlc
9 IL
-iCT]mion PackagE, & Support
;]Falysis of SB 743 Compliance in the Gateway
0 35
[17
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0 $ 23 6 m F FIa +6 4b138 78
Bagllnl!=ina]DiEa;E2EanaEBlm]FMna7tIEw$ n6 BFo om2llmlm $ 125,883$ 81,155 24 is 4,750
3 o is
S 30,630

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8,008
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Attachment B

Downey City CouncilFebruary 10, 2026

Downey City Council
February 10, 2026