1 Attachment A
B Street Project Class 32 Categorical Exemption
The California Environmental Quality Act (CEQA) Guideline Section 15332 identifies the Class 32 categorical exemption for projects characterized as in-fill development. This exemption is intended to promote infill development within urbanized areas. The class consists of in-fill projects which are within the city limits and are consistent with applicable local general plan designation and policies and zoning designation and regulations. This class does not apply to projects which would result in any significant traffic, noise, air quality, or water quality effects.
Projects under this exemption must meet Part 1 conditions (a) through (e) described in the analysis below and must not trigger exceptions to the exemption in Part 2.
Infill development is often defined as new development and redevelopment projects located on vacant or underutilized land within existing developed areas. Infill development is one strategy for revitalizing declining city and suburban cores and town centers. It promotes efficient and cost-effective use of existing infrastructure and services (such as streets, transit, and utilities), and expands opportunities for housing, recreation, and economic growth.
Part 1: Qualifications
The B Street Project includes a Use Permit and Design Review to allow redevelopment of an infill site and construction of a 113-room hotel, drive-thru restaurant and retail space on a 4.9- acre site, consistent with the General Plan and Zoning Districts.
The proposed project meets the following thresholds:
(a) The project is consistent with the applicable general plan designation and all applicable general plan policies as well as with applicable zoning designation and regulations.
The subject land has a General Plan Land Use designation of Commercial and Industrial and is zoned C-3 General Commercial and M-1 Light Industrial. The Project includes minor entitlements including a development plan review, Use Permit for a drive-through quick serve restaurant and Design Review Permit for the entire site. Hotels are allowed by right in the C-3 district. Grocery and other indoor retail are permitted by right in both the C-3 and M-1 Districts.
The proposed project complies with the applicable general plan policies. It also complies with the zoning regulations including permissible uses, height, parking/loading, and drive-through standards.
(b) The proposed development occurs within city limits on a project site of no more than five acres substantially surrounded by urban uses.
Land Use
The site is located in an urban area on a site that has been previously developed and is surrounded by existing development. The Project is less than five-acres in size and is located in the downtown area within the City Marysville. The surrounding built-up area is characterized by commercial retail and industrial uses. State Route 70 (SR 70) also known as B Street is a fourlane facility that links the City of Marysville with regional areas to the south and north, located on the west side of the site (B Street). To the east is an elevated portion of the Union Pacific Railroad tracks and residences beyond. West of B Street is Ellis Lake, which is surrounded by 2 urban uses including commercial establishments and residences. On the south side of the project is a Quick Stop self-serve filling station and mini-market with an existing access easement to the parcel on the south via 12th Street. To the north is 14th Street and retail development.
The project Is consistent with the density established by zoning, and is compatible with the plans, policies and regulations associated with properties zoned General Commercial and Industrial.
(c) The project site has no value as habitat for endangered, rare or threatened species.
The site is currently vacant and contains disturbed urban (ruderal) habitat. Impervious surfaces (pavement) covers a majority of the site. The site was previously developed with a bar, a car sales lot, Dairy Queen, single family residences, a motel, and mobile home park in the past.
These uses were previously demolished. The project site does not contain wetlands, riparian habitat, or special status species habitat. There is no value as habitat for endangered, rare or threatened species.
(d) Approval of the project would not result in any significant effects relating to traffic, noise, air quality, or water quality.
As described below, the site will not result in any significant effects relating to traffic, noise, air quality or water quality. Measures are incorporated into the project to ensure that there are no impacts.
(e) The site can be adequately served by all required utilities and public services.
The project site is located in an urban area served by all necessary municipal utilities (i.e. water, wastewater, stormwater, electricity, natural gas and solid waste) as well as public services such as fire and police. Existing water, stormwater, sewer, gas and electricity lines are located both within the project site and adjacent to the site.
Traffic: The project is accessible by existing curb cuts on B Street and 14th Street, and an access easement over the Quick Stop site to 12th Street. The project would not include roadway or transportation system changes. Existing curb cuts for driveways will be maintained. No improvements to B Street are proposed.
Vehicular Access and Circulation. Access would be provided to the site via two driveways on B Street and one driveway on 14th Street. An access easement across the filling station site is provided from 12th Street. The drive-through restaurant has been designed to include two queuing lanes and is substantially set back from B Street so that queuing will not occur on the adjacent street. Pedestrian linkages would be included within the parking areas.
Starting on July 1, 2020, the state of California directed that agencies analyzing the transportation impacts of new projects must now look at a metric known as vehicle miles traveled (VMT) instead of level of service (LOS) to determine CEQA impacts. VMT measures how much actual auto travel (additional miles driven) a proposed project would create on California roads. If the project adds excessive car travel onto roads, the project may cause a significant transportation impact.
A VMT screening criteria assessment was conducted by Flecker Associates, Transportation Engineers, (December 2023) for the site using the state Office of Planning and Research (OPR) 3 screening criteria to determine whether the project would result in any significant effects relating to traffic. OPR allows mixed-use projects to be analyzed separately by use.
The proposed grocery store is 16,000 square feet and the proposed quick serve restaurant is 2,223 square feet. The retail portion of the project, the grocery store and quick service restaurant, totaling 18,500 square feet total can be considered locally serving retail. Local serving retail space of 50,000 square feet or less is presumed to have a less than significant effect.
The proposed hotel was analyzed with map-based screening. This considers whether a project is in a VMT efficient area where regional VMT reduction goals are already satisfied. The project must be consistent in size and land use type (i.e., density, mix of uses, transit accessibility, etc.) as the surrounding built environment.
The Sacramento Area Council of Governments (SACOG) has identified Low VMT generating locations within this region, including Marysville. The project location within the SACOG region was determined. Because Cal Green 2022 identifies hotels as part of residential construction for certain traffic and vehicular purposes, the analysis considered VMT characteristics of residential per capita as identified from the SACOG Residential VMT Hex (screening) maps.
As shown in the table below, the Regional County average residential VMT is 20.82 VMT per day. The hex map location containing the B Street project has a rate of 13.18 VMT per day.
The OPR screening threshold is a 15% reduction from the regional average, or 17.70 VMT per day. Because the B Street project location is more than 15% lower than the regional average (it is 25.5% below the regional average), the VMT for the hotel use is presumed to be less than significant.
The project will provide needed retail services, proximate to existing residents and businesses in the Downtown area that will reduce trips. The project’s location within a VMT efficient area also means that the hotel use is presumed to be less than significant. Therefore, there will be no significant transportation impacts.
Noise: Construction is anticipated to take approximately 18-months. Construction equipment such as tractors, loaders and backhoes will be used. Noise generated during excavation, grading, site preparation and building construction would result in construction noise. However, no residential or noise-sensitive uses are immediately adjacent to the site. The Project will be required to maintain construction noise consistent with the recently adopted Noise Ordinance including the following:
Hours of construction would be restricted to the hours of 7:00 a.m. to 7:00 p.m. weekdays and 8:00 a.m. to 7 p.m. weekends.
Therefore, there would be no significant noise impacts. 4 Air Quality: The project includes hotel and retail use that will not generate new substantial sources of air pollutant emissions. As indicated above, the project will provide needed retail services in an urban infill area, proximate to jobs and housing. It will provide electric vehicle charging stations and infrastructure above what is required by the Calgreen Building Code. The additional charging infrastructure will result in a greenhouse gas (GHG) reduction of 10.1% and will meet the reduction goal (Flecker Associates, VMT Study). Therefore, the impact is less than significant.
Project Subject to Uniformly Applicable Development Policies: The Project is located within the Northern Sacramento Valley Planning Area 2012 Air Quality Attainment Plan In 2010, an update to the 1994 Air Quality Attainment Plan was prepared for the Northern Sacramento Valley Air Basin (NSVAB), which includes Yuba County. The plan proposes rules and regulations that would limit the number of certain emissions, in accordance with the 1994 State Implementation Plan (SIP). The 2010 update summarizes the feasible control measure adoption status of each air district in the NSVAB, including the Feather River Air Quality Management District (FRAQMD). The 2010 update was adopted by the FRAQMD, and the Project would be required to comply with its provisions. In addition, the Project will be required to pay air quality fees to FRAQMD. Therefore, there would be no significant air quality impacts.
Stormwater/Water Quality
Project Subject to Uniformly Applicable Development Policies: The Project involves excavation and movement of soil. Such soil disturbance carries with it the risk of unintended discharges offsite. Such discharges would be prevented, however, through the use of Best Management Practices (BMP). The Project may result in ground disturbance equal to or greater than one acre in size and would then be within the jurisdiction of the Central Valley Regional Water Quality Control Board (RWQCB), which develops and enforces water quality objectives and implementation plans that safeguard the quality of water resources in its region. Prior to construction of a project greater than one acre, the RWQCB requires a project applicant to file for a National Pollution Discharge Elimination System (NPDES) General Permit. The General Permit process requires the project applicant to 1) notify the State, 2) prepare and implement a Storm Water Pollution Prevention Plan (SWPPP), and 3) to monitor the effectiveness of the plan. The project does not conflict with any water quality control plan or sustainable groundwater management plan.
The Project will not affect groundwater recharge, alter the existing drainage pattern including through the alteration of the course of a stream or river, or create substantial additional sources of polluted runoff. Thus, the Project will have no additional impact on groundwater supplies, runoff, or other impacts on water quality.
Flecker Associates
Transportation Engineers
8020 SW Valley View Court • Portland, OR 97225 • (916) 501-7513 January 12, 2024
Ms. Callie Huff
Engstrom Properties, Inc.
837 Jefferson Blvd
West Sacramento, CA 95691
RE: VEHICLE MILES TRAVELED (VMT) ASSESSMENT FOR B STREET HOTEL SITE, MARYSVILLE, CA Dear Ms. Huff:
Flecker Associates (FA) has completed our Vehicle Miles Travelled (VMT) assessment for the proposed B Street Hotel site in Marysville. The site is located along the east side of B Street, between 12th Street and 14th Street (Figure 1). The site is currently vacant; however, the proposed project will include a 113-room hotel, a 2,500 square foot Quick Serve Restaurant (QSR) and a 16,000 square foot grocery store (Figure 2). The QSR is likely to be a Starbucks coffee shop with drive-through lane. The site is zoned C-3, General Commercial.
With the implementation of SB 743 the focus of a transportation impact analysis under CEQA moves from consideration of operating Level of Service (LOS) to evaluation of a project’s effects on regional VMT. The City of Marysville is in the process of updating their General Plan, and with it, adopting guidelines for evaluating VMT impacts under SB 743. Since the City does not have current guidelines, this assessment is using the Technical Advisory on Evaluating Transportation Impacts in CEQA1 (December 2018) prepared by the Governor’s Office of Planning and Research.
Trip Generation. For many types of land use development projects, estimates of the number of vehicle trips generated by a project are developed using trip generation rates from the Institute of Transportation Engineers (ITE) document Trip Generation, 11th Edition. The publication is an industry-standard reference document.
The proposed project includes construction of a 113-room hotel (Land Use Code 310), a 2,500 square foot QSR – coffee shop with drive-through lane (LUC 937) and a 16,000 square foot grocery store (LUC 850).
The trip generation is shown in Table 1 along with descriptions of the various uses.
Trips generated by retail commercial projects fit into two categories. Some trips will be made by patrons who would not otherwise be on the local street system and who go out of their way to reach the site.
These are "new" trips. Other trips will be made by patrons who are already in the roadway network and stop by the site as part of a trip made for another purpose. These “pass-by” trips do not add traffic to the overall system. ITE research has suggested typical "pass-by" percentages for various retail land uses. 1 Technical Advisory on Evaluating Transportation Impacts in CEQA. Governor’s Office of Planning and Research State of California, December 2018.
Ms. Callie Huff
Vehicle Miles Traveled (VMT) Assessment for B Street Hotel Site, Marysville, CA January 12, 2024
FA
TABLE 1
AM / PM PEAK HOUR TRIP GENERATION
Land Use
Unit
Quantity Size
Trips Per Unit
Daily
AM Peak Hour PM Peak Hour
Total In Out Total In Out
Hotel (LUC 310)1 Rooms 113 7.99 0.46 56% 44% 0.59 51% 49% Supermarket (LUC 850)2 KSF 16.00 93.84 2.86 59% 41% 8.95 50% 50% Coffee Donut Shop w/
Drive-Thru (LUC 937)3 KSF 2.50 533.57 85.88 51% 49% 38.99 50% 50% Hotel (LUC 310) 903 52 29 23 67 34 33
Supermarket (LUC 850) 1501 46 27 19 143 72 72
Coffee Donut Shop w/ Drive-Thru (LUC 937) 1174 189 96 93 86 43 43 Sub-Total Trips 3578 287 152 134 296 148 147
Internal Trips
Hotel (LUC 310) 5% (90) (5) (3) (2) (7) (3) (3)
Supermarket (LUC 850) 5% (75) (2) (1) (1) (7) (4) (4)
Coffee Donut Shop w/ Drive-Thru
(LUC 937) 5% (59) (9) (5) (5) (4) (2) (2)
Sub-Total Trips (224) (17) (9) (8) (18) (9) (9)
Pass-By Trips
Supermarket
(23% Daily, 10% AM, 36% PM)4 (328) (4) (3) (2) (49) (24) (24) Coffee Shop with Drive-Through
(49% Daily, 48% AM, 50% PM)4 (558) (135 (69) (66) (41) (20) (20) Total Pass-By Trips (886) (139) (71) (68) (90) (45) (45) Net New Trips 2,468 131 72 59 188 95 93
KSF – thousand square feet 1 ITE Trip Generation, 11th Edition LU 310 - “A hotel is a place of lodging that provides sleeping accommodations and supporting facilities such as a full-service restaurant, cocktail lounge, meeting rooms, banquet room, and convention facilities”. 2 ITE Trip Generation, 11th Edition LU 850 - “A supermarket is a free-standing retail store that sells a complete assortment of food, beverage,food preparation materials, and household products. A supermarket may also provide additional products and services such as a bakery, dry cleaning, floral arrangements, greeting cards, a limited-service bank, and a pharmacy”. 3 ITE Trip Generation, 11th Edition LU 937 – “This land use includes any coffee and donut restaurant that has a drive-through window as well as a walk-in entrance area at which a patron can purchase and consume items. The restaurant sells freshly brewed coffee (along with coffee-related accessories) and a variety of food/drink products such as donuts, bagels, breads, muffins, cakes, sandwiches, wraps, salads, and other hot and cold beverages. 4 ITE Trip Generation Handbook, 3rd Ed (note - used fast food with drive-through rate (LUC 934) for LUC 937) Internally captured trips, those that visit the different uses within the site were assumed to be present between the gas station and car wash. Table 1 presents the “pass-by” trips and internal trips used.
The site is projected to create 3,578 daily trips, 287 a.m. peak hour trips and 296 p.m. peak hour trips.
After considering internal trips, those trips being made to multiple uses by a single vehicle, and pass-by Ms. Callie Huff
Vehicle Miles Traveled (VMT) Assessment for B Street Hotel Site, Marysville, CA January 12, 2024
FA
trips, those vehicles already in the roadway network passing by the site, the net new traffic projected as a result of the project is expected to be 2,468 additional daily trips, 131 new a.m. peak hour trips and 188 additional p.m. peak hour trips.
Transit. The site is located along one Yuba-Sutter Transit bus route. The #4 route is a loop route that operates clockwise (#4A) and counterclockwise (#4B) between Peach Tree Clinic and the intersection of 22nd Street and Hansen Street. The route includes stops at the North Beale Transit Center (Walmart), downtown Marysville, the Yuba County Government Center and Marysville High School. The closest stop is at the Yuba One-Stop at 12th Street and Yuba Street, about ¼ mile from the project location.
The first bus departs in the clockwise loop from Marysville High School at 6:33 a.m. and leaves Peach Tree Clinic at 7:09 a.m. Thereafter, buses run hourly departing Peach Tree Clinic at nine minutes after the hour.
The last bus departs at 6:09 p.m. The first bus departs Peach Tree Clinic in the counterclockwise loop at 6:39 a.m. with buses departing hourly; the last bus departs at 5:39 p.m. The clockwise route takes about an hour while the counterclockwise route takes about 53 minutes to complete the loop.
Vehicle Miles Traveled (VMT) Assessment
Vehicle Miles Traveled. In the City of Marysville, the impact of a project on LOS is an important factor in determining whether a project has a significant impact. However, changes made in 2018 to CEQA have changed how lead agencies use LOS in determining whether a project has a significant impact on transportation. As noted in the California Governor’s Office of Planning and Research (OPR) document Technical Advisory on Evaluating Transportation Impacts in CEQA, “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. . . OPR has proposed, and the California Natural Resources Agency (Agency) has certified and adopted, changes to the CEQA Guidelines that identify vehicle miles traveled (VMT) as the most appropriate metric to evaluate a project’s transportation impacts.
With the California Natural Resources Agency’s certification and adoption of the changes to the CEQA Guidelines, automobile delay, as measured by “level of service” and other similar metrics, generally no longer constitutes a significant environmental effect under CEQA. (Pub. Resources Code, § 21099, subd. (b)(3).)”
To help aid lead agencies with SB 743 implementation, the OPR’s Technical Advisory provides guidance regarding the variety of implementation questions to be faced with respect to shifting to a VMT metric.
Key guidance from this document includes:
• VMT is the most appropriate metric to evaluate a project’s transportation impact. • OPR recommends tour‐ and trip‐based travel models to estimate VMT, but ultimately defers to local agencies to determine the appropriate tools.
• OPR recommends measuring VMT for residential and office projects on a “per capita” and “per employee” basis.
Ms. Callie Huff
Vehicle Miles Traveled (VMT) Assessment for B Street Hotel Site, Marysville, CA January 12, 2024
FA
• OPR recommends that a per capita or per employee VMT that is fifteen percent below that of existing development may be a reasonable significance threshold. For example, an office project that generates VMT per employee that is more than 85 percent of the regional average VMT per employee could result in a significant impact. OPR notes that this threshold is supported by evidence that connects this level of reduction to the State’s emissions goals. • OPR recommends that 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.
• OPR notes that lead agencies generally should presume that certain projects (including residential, retail, and office projects, as well as projects that are a mix of these uses) proposed within ½ mile of an existing major transit stop or an existing stop along a high quality transit corridor will have a less-than-significant impact on VMT. • OPR states that 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.
Generally, OPR suggested that retail development including stores smaller than 50,000 square feet might be considered local serving.
• Lead agencies have the discretion to set or apply their own significance thresholds; as noted, the City of Marysville is in the process of developing significance thresholds.
Certain types of projects as identified in statute, the CEQA Guidelines, or in OPR’s Technical Advisory are presumed to have a less than significant impact on VMT and therefore a less than significant impact on transportation. Generally, the identified projects contribute to efficient land use patterns enabling higher levels of walking, cycling, and transit as well as lower average trip length. These projects include, for example, projects in transit priority areas, projects consisting of residential infill or those located in low VMT areas.
Caltrans references OPR’s December 2018 Technical Advisory, which identifies projects and areas presumed to have a less than significant transportation impact. Those include:
1. An area pre-screened by an agency as having low residential or office VMT:
a. An area where existing residential projects exhibit VMT per capita 15 percent or more below city or regional average.
b. An area where existing office projects exhibit VMT per capita 15 percent or more below regional average.
2. Residential projects composed of 100 percent or near-100 percent affordable housing located in any infill location. Additionally, per OPR’s Technical Advisory, “Lead agencies may develop their own presumption of less than significant impact for residential projects (or residential portions of mixed-use projects) containing a particular amount of affordable housing, based on local circumstances and evidence. Furthermore, a project which includes any affordable residential units may factor the effect of the affordability on VMT into the assessment of VMT generated by those units.”
Ms. Callie Huff
Vehicle Miles Traveled (VMT) Assessment for B Street Hotel Site, Marysville, CA January 12, 2024
FA
3. A locally-serving retail project (such a project typically reduces vehicle travel by providing a more proximate shopping destination, i.e., better accessibility).
4. Mixed-use projects composed entirely of low-VMT project types. 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.
5. In any area of the state, 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.
6. Residential, office, or retail projects within a Transit Priority Area, where a project is within a ½ mile of an existing or planned major transit stop or an existing stop along a high-quality transit corridor.
a. A major transit stop is defined as 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 (Pub. Resources Code, § 21064.3). b. A high-quality transit corridor is defined as a corridor with fixed route bus service with service intervals no longer than 15 minutes during peak commute hours (Pub. Resources Code, § 21155).
However, a land use project near transit may have a significant impact on VMT if it:
1. Has a floor area ratio less than 0.75.
2. Includes more parking than required by the local permitting agency.
3. Is inconsistent with the region’s Sustainable Communities Strategy (i.e., development is outside region’s development footprint, or in area specified as open space).
4. Replaces affordable residential units with a smaller number of moderate- or high-income residential units.
The City of Marysville has yet to adopt local VMT guidelines; therefore, the above OPR guidelines were used in this analysis.
Screening Criteria. Screening criteria can be used to quickly identify whether sufficient evidence exists to presume a project will have a less than significant VMT impact without conducting a detailed study.
However, each project should be evaluated against the evidence supporting that screening criteria to determine if it applies. Projects meeting at least one of the criteria below can be presumed to have a less than significant VMT impact, absent substantial evidence that the project will lead to a significant impact.
Ms. Callie Huff
Vehicle Miles Traveled (VMT) Assessment for B Street Hotel Site, Marysville, CA January 12, 2024
FA
The following screening criteria have been reviewed. The extent to which the proposed project qualifies under each criterion is also noted.
Small Projects: Defined as a project that generates 110 or fewer average daily vehicle trips or less than 880 VMT on a typical day.
Assessment. The proposed project is estimated to generate 2,468 new vehicle trips per day. As this value exceeds the 110 daily trip threshold, the B Street Hotel site does not qualify under this metric.
Conclusion. This criterion does not apply to the project. Affordable Housing: Defined as a project consisting of deed-restricted affordable housing.
Conclusion. The proposed project is not of deed restricted affordable housing. This screening criteria does not apply.
Proximity to High Quality Transit: The directive notes that employment and residential development located within ½ mile of a high-quality transit corridor offering 15-minute headways can be presumed to have a less than significant impact. A high-quality transit stop is defined as a site containing an existing rail transit station or the intersection of at least two bus routes with a frequency of service of at least 15 minutes during the morning and evening commute periods.
The City maintains a map showing the parcels that fit this criterion.
Assessment. The proposed project is along the #4 route serviced by Yuba-Sutter Transit. The #4 route operates in clockwise and counterclockwise directions. The closest current stop is about
0.20 miles from the site and both routes operate at 60-minute headways; therefore, the current service does not meet the High Quality Transit requirements.
Conclusion. The proposed project is not in an area served by high quality transit. Local Serving Retail: Defined as retail uses of 50,000 square feet or less can be presumed to have a less than significant impact. Increasing retail opportunities closer to homes and workplaces may decrease VMT by substituting shorter trips for longer ones. Projects that fit this criterion for an individual retail site are used to distinguish local serving retail from more regional type businesses that draw customers from greater distances.
Assessment. The project is a combination of retail uses, i.e. supermarket and QSR, and hotel use.
CalGreen 2022, the statewide Green Buildings Standards Code, identifies hotels as part of residential construction when determining electric vehicle requirements. The retail portion of the project, the supermarket and QSR, total 18,500 square feet.
Conclusion. Since the retail portion of the project is 50,000 square feet or less the project’s VMT impacts can be presumed to be less than significant with no additional assessment necessary.
Ms. Callie Huff
Vehicle Miles Traveled (VMT) Assessment for B Street Hotel Site, Marysville, CA January 12, 2024
FA
• Map-Based Screening for Residential and Office Projects Projects in Low VMT-Generating Area.
This evaluation criteria is defined as a residential or office project that is in a VMT efficient area where regional VMT reduction goals are already satisfied. The project must be consistent in size and land use type (i.e., density, mix of uses, transit accessibility, etc.) as the surrounding built environment.
The Sacramento Area Council of Governments (SACOG) has identified Low VMT generating locations within this region, including Marysville. The project location within the SACOG region was determined. As previously stated, Cal Green 2022 identifies hotels as part of residential construction when determining electric vehicle requirements. Therefore, the VMT characteristics of residential per capita is identified from the SACOG Residential VMT Hex (screening) maps. The per capita VMT is shown in Table 2 and the Hex map is attached.
TABLE 2
VMT ANALYSIS RESULTS
Land Use
Per Capita VMT B Street Hotel
Reduction from
Average
Jurisdiction
Goal Met? Regional
Average
15% Reduction
Goal B St Hotel
Hotel
(Residential) 20.82 17.70 13.18 -25.5% Yes
The Regional County average residential VMT is 20.82 vehicles miles traveled per day. The hex map location containing the B Street project has a rate of 13.18. The OPR recommended goal would be a 15% reduction from the regional average, or 17.70; therefore, the VMT for the hotel use is presumed to be less than significant.
Electric Vehicle Charging Infrastructure. The project intends to provide electric vehicle charging infrastructure beyond what is required as identified CalGreen 2022. Table 3 presents the EV requirements for the site.
The net impact of the additional charging infrastructure was determined using CAPCOA2 Guidelines.
The project would have two additional charger spaces beyond what is required on the project site.
Measure T-14 “Provide Electric Vehicle Charging Infrastructure” calculates the greenhouse gas reduction (GHG) for additional charging stations and will result in a GHG reduction of 2.9%. 2 Handbook for Analyzing Greenhouse Gas Emission Reductions, Assessing Climate Vulnerabilities, and Advancing Health and Equity, California Air Pollution Control Officers Association, December 2021 Ms. Callie Huff
Vehicle Miles Traveled (VMT) Assessment for B Street Hotel Site, Marysville, CA January 12, 2024
FA
TABLE 3
EV CHARGING REQUIREMENTS
Required EV
Infrastructure
Provided
EV Infrastructure
Net Over / (Under)
Hotel (160 spaces)
EV Capable (10% total parking spaces) 16 16 0
EV Ready (25% total parking spaces) 40 40 0
EV Supply Equipment
(5% total parking spaces)
8 8 0
Net Over / (Under) 0
Retail (99 total spaces)
EV Charger Spaces1 4 6 2
EV Capable Spaces1 13 13 0
Net Over / (Under) 2 1 Table 5.106.5.3.1, CalGreen 2022 Evaluation / Findings
Engstrom Properties intends to develop the vacant land in Marysville located along the east side of B Street between 12th Street and 14th Street; a gas station in the northeast quadrant of B Street and 12th Street will remain with the project constructed to the north and adjacent to the gas station. The proposed project will include a 113-room hotel, a 2,500 square foot Quick Serve Restaurant (QSR) and a 16,000 square foot grocery store. The QSR is likely to be a Starbucks coffee shop with drive-through lane.
To meet CEQA guidelines a VMT analysis needs to be completed. The City of Marysville is currently updating their General Plan, and with it, development of their own VMT guidelines. Since City guidelines are currently unavailable, OPR guidelines were used following their 2018 publication Technical Advisory on Evaluating Transportation Impacts in CEQA.
The project is projected to create 3,578 daily trips, 287 a.m. peak hour trips and 296 p.m. peak hour trips.
After accounting for internally captured trips and pass-by trips, the project is expected to generate 2,468 new daily trips, 131 new a.m. peak hour trips and 188 new p.m. peak hour trips.
A VMT screening criteria assessment was conducted for the site using the OPR screening criteria to determine if the project can be considered to have less than significant transportation impacts. OPR allows mixed-use projects to be analyzed separately by use.
The retail portion of the project, the grocery store and quick service restaurant, totaling 18,500 square feet can be considered locally serving retail. Local serving retail space of 50,000 square feet or less can be presumed to have a less than significant effect.
Map Based screening using the SACOG Hex Maps was used to analyze the hotel portion of the project; Ms. Callie Huff
Vehicle Miles Traveled (VMT) Assessment for B Street Hotel Site, Marysville, CA January 12, 2024
FA
hotels, while not defined as to a type of use in the OPR guidelines, are considered residential for analyzing EV charging criteria in the CalGreen 2022 standards. The Map Based screening shows that the hotel land use is 25.5% lower than the 15% reduction goal of 17.70 per capita VMT. The project can be presumed to have a less than significant effect.
The project intends to exceed the minimum requirement of EV charging infrastructure by adding two additional charger spaces. The CAPCOA handbook was used to identify greenhouse gas reductions, and the additional charging spaces beyond the requirements is projected to result in a net 2.9% GHG reduction.
Should you have any questions please free to contact me at (916) 501-7513 or you may reach me via email at [email protected].
Flecker Associates.
Jonathan D. Flecker, P.E., T.E.
President
Attachments
B St Hotel VMT
FLECKER ASSOCIATES VICINTY MAP FIGURE 1
3500-04
N
PROJECT
E12THST
14THST
B
S
T
FLECKER ASSOCIATES B STREET HOTEL SITE PLAN FIGURE 2
N
3500-04
TRANSPORTATION | 116
T-14. Provide Electric Vehicle Charging Infrastructure
GHG Mitigation Potential
Up to 11.9% of GHG
emissions from vehicles
accessing the commercial or
multifamily housing building
Co-Benefits (icon key on pg. 34)
Climate Resilience
Providing electric vehicle charging
infrastructure increases fuel redundancy
for electric vehicles even if an extreme
weather event disrupts other fuel sources.
Electric vehicles could also provide benefits
to buildings and the grid, such as
emergency backup, energy reserves, and
demand response.
Health and Equity Considerations
Differential costs of PHEVs compared to
conventional vehicles are decreasing over
time, but at present are more expensive,
which means this measure could
disproportionately benefit those of greater
economic means. As costs come into parity
over time, this will be less of an issue.
Employer, electricity provider, and state
incentives for PHEV purchase could help
address near-term disparities.
Measure Description
Install onsite electric vehicle chargers in an amount beyond what is required by the 2019 California Green Building Standards (CALGreen) at buildings with designated parking areas (e.g., commercial, educational, retail, multifamily). This will enable drivers of PHEVs to drive a larger share of miles in electric mode (eVMT), as opposed to gasoline-powered mode, thereby displacing GHG emissions from gasoline consumption with a lesser amount of indirect emissions from electricity. Most PHEVs owners charge their vehicles at home overnight. When making trips during the day, the vehicle will switch to gasoline mode if/when it reaches its maximum all-electric range.
Subsector
Parking or Road Pricing/Management
Locational Context
Urban, suburban, rural
Scale of Application
Project/Site
Implementation Requirements
Parking at the chargers must be limited to electric vehicles.
Cost Considerations
The primary costs associated with electric vehicle charging infrastructure include the capital costs of purchasing and installing charging stations, electricity costs from use of stations, and maintenance costs of keeping the charging stations in working order. Costs initially fall to the station owners, either municipalities or private owners, but can be passed along to station users with usage fees. Depending on station placement and charging times required for PHEVs, businesses near charging stations can derive benefits from patronage of station users.
Expanded Mitigation Options
In addition to increasing the percentage of electric miles for PHEVs, the increased availability of chargers from implementation and increase the adoption and use of battery electric vehicles (BEVs), but this potential effect is not included in the calculations as a conservative assumption. Expanded mitigation could include quantification of the effect of this measure on BEV use.
11.9%
T-14. Provide Electric Vehicle Charging Infrastructure TRANSPORTATION | 117 GHG Reduction Formula
GHG Calculation Variables
ID Variable Value Unit Source
Output
A Percent reduction in GHG emissions from
vehicles accessing the office building or
housing
0 11.9 % calculated
User Inputs
B Number of chargers installed at site [ ] integer user input C Total vehicles accessing the site per day [ ] integer user input Constants, Assumptions, and Available Defaults
D Average number of PHEVs served per day
per charger installed
2 integer CARB 2019
E Percent of PHEV miles in electric mode
without measure
46 % CARB
2020a
F Percent of PHEV miles in electric mode with
measure
80 % CARB 2017
G Average emission factor of PHEV in gasoline
mode
205.1 g CO2e per
mile
CARB
2020a; U.S.
DOE 2021
H Energy efficiency of PHEV in electric mode 0.327 kilowatt hours (kWh)
per mile
CARB
2020b; U.S.
DOE 2021
I Carbon intensity of local electricity provider Tables E-4.3 and E-4.4
lb CO2e per
megawatt
hour (MWh)
CA Utilities
2021
J Average emission factor of non-electric
vehicles accessing the site
307.5 g CO2e per
mile
CARB
2020a
K conversion from lb to g 454 g per lb conversion
L Conversion from kWh to MWh 0.001 MWh per
kWh
conversion
Further explanation of key variables:
(D) The average number of PHEVs served per day per charger installed is 2 vehicles (CARB 2019). If the user can provide a project-specific value, they should replace the default in the GHG reduction formula.
(E) - Based on the EMFAC2017 model (v1.0.3), 46 percent of miles traveled by PHEVs in California are eVMT, and 54 percent are in gasoline mode (CARB 2020a).
T-14. Provide Electric Vehicle Charging Infrastructure TRANSPORTATION | 118 (F) Advanced Clean
Cars Mid-Term Report suggest that PHEV owners can reach 80 percent eVMT with access to adequate supportive charging infrastructure (CARB 2017). (G) As described for (J), the average GHG emission factor for gasoline vehicles is 307.5 grams of CO2e per mile.
The fuel efficiency of a PHEV in gasoline mode is calculated as 66.7 percent of the fuel consumption rate of a gasoline vehicle, based on the assumption that a gasoline hybrid vehicle has 50 percent higher fuel economy (miles per gal [mpg]) than a comparable gasoline vehicle, based on a comparison of the gasoline and hybrid Toyota Camry and Corolla models (U.S. DOE 2021). This percentage is applied to the average GHG emission factor for gasoline vehicles to determine the average emission factor for PHEVs in gasoline mode as (66.7%×307.5 g CO2e per mile). If the user can provide a projectspecific value by running EMFAC based on the future year of a project, they should replace the default in the GHG reduction formula.
(H) Scaled from a light-duty automobile gasoline equivalent fuel economy 30.3 mpg (CARB 2020a), an energy efficiency ratio (EER) of 2.5 (CARB 2020b), and an assumption of 33.7 kWh electricity per gallon of gasoline (U.S. DOE 2021). (I) GHG intensity factors for major California electricity providers are provided in Tables E-4.3 and E-4.4 in Appendix C. If the project study area is not serviced by a listed electricity provider, or the user is able to provide a project-specific value (i.e., for the future year not referenced in Appendix C), the user should replace the default in the GHG calculation formula. If the electricity provider is not known, the user may elect to use the statewide grid average carbon intensity.
(J) The average GHG emission factor for non-electric vehicles accessing the site was calculated in terms of CO2e per mile using EMFAC2017 (v1.0.3). The model was run for a 2020 statewide average of LDA, LDT1, and LDT2 vehicles using diesel and gasoline fuel. The running emission factors for CO2, CH4, and N2O (CARB 2020a) were multiplied by the corresponding 100-
Assessment Report (IPCC 2007). If the user can provide a project-specific value (i.e., for a future year and project location), the user should run EMFAC to replace the default in the GHG reduction formula.
GHG Calculation Caps or Maximums
Measure Maximum
(Amax) The percent reduction in GHG emissions (A) is capped at 11.9 percent, which is based on the following assumptions used to generate a maximum scenario:
(B) number of chargers installed = 20. CALGreen provides a non-residential voluntary Tier 2 measure that requires projects with 201 or more parking spaces to allocate 10 spaces)
(CBSC 2019). Note that EV Capable parking spaces do not actually have EV chargers installed, though they do have electrical panel capacity, a dedicated branch circuit, and a raceway to the EV parking spot to support future installation of charging stations.
Therefore, using the number of EV Capable parking spaces as a proxy for EV chargers as a high-end estimate is conservative.
T-14. Provide Electric Vehicle Charging Infrastructure TRANSPORTATION | 119 (C) total vehicles accessing the site = 200. Per the CALGreen voluntary measure, the numb
is 201.
(D) PHEVs served per day per charger installed = 7. This value is the max (Dmax). This assumes that all PHEV drivers would coordinate sharing of the limited number of chargers at the site. Value is based on data from the National Renewable Energy Laboratory (CARB 2019).
(I) carbon intensity of local electricity provider = 0 lb CO2e per MWh. This assumes that the local electricity provider is powered 100 percent by renewables and thus has a carbon intensity of zero.
Subsector Maximum
This measure is in the Parking or Road Pricing/Management subsector. This subcategory includes Measures T-14 through T-16. The VMT reduction from the combined implementation of all measures within this subsector is capped at 35 percent.
Example GHG Reduction Quantification
The user will install electric vehicle chargers at their proposed office or multifamily housing development, which will enable employees or residents with PHEVs to drive a larger share of miles in electric mode, as opposed to gasoline-powered mode, thereby displacing GHG emissions from gasoline consumption with a lesser amount of indirect emissions from indirect electricity. In this example, 20 chargers (B) will be installed at a workplace with 200 daily employee vehicles accessing the site (C). The electricity provider for the project area is the Sacramento Municipal Utility District (SMUD) and the analysis year is 2022. The carbon intensity of electricity is therefore 344 lb CO2e per MWh (I). The GHG impact is calculated as a 3.4 percent reduction from the total emissions from vehicles accessing the site.
Quantified Co-Benefits
While the measure will achieve fuel savings, it will also increase electricity consumption.
This section defines the methods for quantifying Improved Local Air Quality and fuel savings, as well as increased electricity consumption.
Improved Local Air Quality
Local criteria pollutants will be reduced by the reduction in fossil fuel combustion.
The percent reduction in criteria pollutants can be calculated using the GHG reduction formula. Electricity supplied by statewide fossil-fueled or bioenergy power plants will generate criteria pollutants. However, because these power plants are located throughout the state, electricity consumption from vehicles charging will not generate localized criteria pollutant emissions. Consequently, for the quantification T-14. Provide Electric Vehicle Charging Infrastructure TRANSPORTATION | 120 of criteria pollutant emission reductions, either the electricity portion of the equation can be removed, or the electricity intensity (I) can be set to zero.
Fuel Savings (Increased Electricity)
The percent reduction in vehicle fuel consumption would be the same as the percent reduction in criteria pollutant emissions. The percent increase in electricity use (M) from this measure can be calculated as follows.
Electricity Use Increase Formula
Electricity Use Increase Calculation Variables
ID Variable Value Unit Source
Output
M Increase in electricity from PHEVs [ ] % calculated
User Inputs
N Existing electricity consumption
of project/site
[ ] kWh per year user input
O Days per year with vehicles
accessing the site
260 365 days per year user input
P Average annual VMT of vehicles
accessing the site
[ ] miles per day
per vehicle
user input
Constants, Assumptions, and Available Defaults
None
Further explanation of key variables:
(N) The user should take care to properly quantify building electricity using accepted methodologies (such as CalEEMod).
(O) If the proposed development is a workplace in which employees access the site an average of 5 days per week, the user should input 260 workdays. If the development is multifamily dwelling, the user should input 365 days.
Please refer to the GHG Calculation Variables table above for definitions of variables that have been previously defined.
Sources
California Air Resources Board (CARB). 2017. Advanced Clean Cars Mid-Term Report, Appendix G:
Plug-in Electric Vehicle In-Use and Charging Data Analysis. Available:
https://ww2.arb.ca.gov/resources/documents/2017-midterm-review-report. Accessed: January 2021.
California Air Resources Board (CARB). 2019. Final Sustainable Communities Strategy Program and Evaluation Guidelines Appendices. November. Available:
https://ww2.arb.ca.gov/sites/default/files/2019-
11/Final%20SCS%20Program%20and%20Evaluation%20Guidelines%20Appendices.pdf. Accessed:
January 2021.
T-14. Provide Electric Vehicle Charging Infrastructure TRANSPORTATION | 121 California Air Resources Board (CARB). 2020a. EMFAC2017 v1.0.3. August. Available:
https://arb.ca.gov/emfac/emissions-inventory. Accessed: January 2021.
California Air Resources Board (CARB). 2020b. Unofficial electronic version of the Low Carbon Fuel Standard Regulation. Available: https://ww2.arb.ca.gov/sites/default/files/2020- 07/2020_lcfs_fro_oal-approved_unofficial_06302020.pdf
California Air Resources Board (CARB). 2021. OFFROAD2017 ORION. Available:
https://arb.ca.gov/emfac/emissions-inventory. Database queried by Ramboll and provided electronically to ICF. March 2021.
California Utilities. 2021. Excel database of GHG emission factors for delivered electricity, provided to the Sacramento Metropolitan Air Quality Management District and ICF. January through March 2021.
California Building Standards Commission (CBSC). 2019. Green Building Standards Code, Title 24, Part 11. Appendix A5 Nonresidential Voluntary Measures. Table A5.601 Nonresidential Buildings:
Green Building Standards Code Proposed Performance Approach. July. Available:
https://codes.iccsafe.org/content/CAGBSC2019/appendix-a5-nonresidential-voluntary-measures.
Accessed: May 2021.
Intergovernmental Panel on Climate Change (IPCC). 2007. Climate Change 2007: The Physical Science Basis. Contribution of Working Group I to the Fourth Assessment Report of the Intergovernmental Panel on Climate Change [Solomon, S., D. Qin, M. Manning, Z. Chen, M. Marquis, K. B. Averyt, M. Tignor and H.L. Miller (eds.)]. Cambridge University Press, Cambridge, United Kingdom and New York, NY, USA, 996 pp. Available: https://www.ipcc.ch/report/ar4/wg1/.
Accessed: January 2021.
U.S. Department of Energy (U.S. DOE). 2021. Download Fuel Economy Data. January. Available:
https://www.fueleconomy.gov/feg/download.shtml. Accessed: January 2021.
T-14
A= B x D x (F - E) x (G - (H x I x K x L))/ -C x J
A
B Number of chargers installed at site 2 beyond required by CalGreen 2022 C Total vehicles accessing the site per day 2675
D Average number of PHEVs served per day per charger installed 2 E Percent of PHEV miles in electric mode without measure 46 F Percent of PHEV miles in electric mode with measure 80 G Average emission factor of PHEV in gasoline mode 205.1 H Energy efficiency of PHEV in electric mode 0.327
I Carbon intensity of local electricity provider 206
J Average emission factor of non-electric vehicles accessing the site 307.5 K conversion from lb to g 454
L Conversion from kWh to MWh 0.001
-2.89%
PROVIDE ELECTRIC VEHICLE CHARGING INFRASTRUCTURE
A=
CAPCOA CALCULATIONS
Percent reduction in GHG emissions from vehicles accessing