November 2022
VMT THRESHOLDS AND IMPLEMENTATION
GUIDELINES
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November 2022
VMT THRESHOLDS AND IMPLEMENTATION
GUIDELINES
Prepared for:
Merced County Association of Governments
369 West 18th Street
Merced, California 95340
Prepared by:
LSA Associates, Inc.
1500 Iowa Avenue, Suite 200
Riverside, California 92507
(951) 781‐9310
Project No. MCN2201
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EXECUTIVE SUMMARY
Senate Bill (SB) 743, which became effective July 1, 2020, changes the way transportation impacts are determined in California Environmental Quality Act (CEQA) documents. SB 743 replaces the metric for determining transportation impacts using motor vehicle delay and Level of Service (LOS) to Vehicle Miles Traveled (VMT) in CEQA traffic impact studies. As a result of the SB 743 final rulemaking and the implem
entation deadline of July 1, 2020, the Merced County Association of Governments (MCAG) has prepared this document as a regional guide for the seven member jurisdictions ‐ Merced County and the cities of Atwater, Dos Palos, Gustine, Livingston, Los Banos, and Merced. The member jurisd ictions can adopt the recommendations in the regional guidelines as appropriate based on their individual circumstances, such as growth policies and economic development goals.
This document provides a detailed discussion on implementing the CEQA VMT metric as applicable to the MCAG member jurisdictions. Substantial evidence and explanation on establishing the “Region,” VMT screeni
ng criteria, and VMT analysis thresholds are also described. The following topics establish the steps for preparation of VMT analysis. Each topic is discussed in more detail further in this report. Definition of ‘Region’: Merced County is recommended as the region for VMT analysis purposes. Standardized Screening Methods: Projects within a Transit Priority Area that meet additional requirements, local‐serving retail projects up to 50,000 square feet (sf), residential, office, industrial, or mixed‐use projects within low‐VMT generating areas, projects with 100 percent affordable housing units, and projects that are consistent with the jurisdiction’s General Plan and generate fewer than 1,000 daily tri
ps may be screened out from the need for a VMT analysis.
Additionally, projects that are not consistent with the jurisdiction’s General Plan but generate fewer than 500 daily trips may also be screened out from a VMT analysis. Appropriate VMT Significance Thresholds for Development Projects, Transportation Projects, and Community/General Plans: For all projects (except retail), a significance threshold of 86 percent of the existing regional average of the respective VMT metric is recommended. For retail projects, a significance threshold of no net increase in VMT is recommended. For mixed use projects, the VMT thresholds are based on the respective thresholds for the various land use components. For
transportation projects, net increase in induced VMT is recommended as the significance threshold. Finally, for land use plans, the existing regional average VMT per capita, VMT per employee, and/or VMT per service population is recommended as the threshold of significance.
Feasible Mitigation Strategies: A list of VMT mitigation measures applicable to development projects, transportation projects, and plans in the context of the MCAG member jurisdictions is provided for projects which may not meet the recommended significance thresholds.
Additionally, implementation of a future VMT mitigation bank, VMT mitigation exchange, and/or VMT impact fee are discussed as potential future regional VMT mitigation mechanisms.
MCAG recommends the use of the MCAG Travel Demand Model (TDM) for VMT analysis purposes.
The MCAG TDM is the regional travel demand model applicable to jurisdictions within Merced County for evaluating project VMT. The appropriate use of the MCAG TDM for VMT calculations is further elaborated in
subsequent chapters of this document.
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TABLE OF CONTENTS
EXECUTIVE SUMMARY ............................................................................................................................. I TABLE OF CONTENTS ............................................................................................................................. III FIGURES AND TABLES ............................................................................................................................. V
1.0 INTRODUCTION ................................................................................................... 1
2.0 DEFINITION OF REGION: VEHICLE MILES TRAVELED CONTEXT .............................. 3
3.0 SCREENING CRITERIA ........................................................................................... 5
3.1 DEVELOPMENT PROJECTS .................................................................................................... 5
3.1.1 Average Daily Trips (ADT) Threshold ..................................................................................... 6
3.2 TRANSPORTATION PROJECTS ............................................................................................. 18
4.0 VMT THRESHOLD ANALYSIS FOR DEVELOPMENT PROJECTS ............................... 21
4.1 THRESHOLDS ...................................................................................................................... 21
4.2 IMPACT ASSESSMENT ........................................................................................................ 23
4.2.1 Agency Communication ....................................................................................................... 23
4.2.2 Project Screening ................................................................................................................. 28
4.2.3 VMT Identification ............................................................................................................... 28
4.3 MITIGATION MEASURES .................................................................................................... 29
5.0 VMT THRESHOLD ANALYSIS FOR TRANSPORTATION PROJECTS .......................... 30
6.0 VMT THRESHOLD ANALYSIS FOR LAND USE PLANS ............................................ 35
7.0 MITIGATION STRATEGIES .................................................................................. 37
7.1 DEFINITION OF MITIGATION .............................................................................................. 37
7.2 MITIGATION MEASURES AND PROJECT ALTERNATIVES .................................................... 39
7.2.1 Land Development Projects and Community/General Plans .............................................. 39
7.2.2 Transportation Projects ....................................................................................................... 40
7.3 FUNDING MECHANISMS .................................................................................................... 40
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FIGURES AND TABLES
FIGURES
Figure 1: 2019 GHG Emissions in California by Economic Sector ........................................................... 2 Figure 2: Share of Total Trips Having Origins/Destinations within Individual Jurisdictions, within Entire Merced County, or Outside the County (2015 MCAG TDM) ................................... 4 Figure 3: High‐Quality Transit Area within Merced County ................................................................. 10 Figure 4: VMT per Capita Screening Map for Merced County ............................................................. 12 Figure
5: VMT per Employee Screening Map for Merced County ....................................................... 14 Figure 6: VMT per Service Population Screening Map for Merced County ......................................... 16 Figure 7: SB 375 Regional Plan Climate Targets for California’s 18 MPOs ........................................... 22 Figure 8: VMT Screening Methodology for Development Projects ..................................................... 24 Figure 9‐A: VMT Analysis Methodology for Non‐Scre
ened Residential Projects ................................. 25 Figure 9‐B: VMT Analysis Methodology for Non‐Screened Non‐Residential (Non‐Retail) Projects ........................................................................................................................................ 26 Figure 9‐C: VMT Analysis Methodology for Non‐Screened Non‐Residential (Retail) Projects ............ 27 Figure 10: Induc
ed Travel – VMT Attributable to Project .................................................................... 31 Figure 11: Caltrans Induced Travel Calculator ...................................................................................... 33 Figure 12: Procedural Flow Chart – VMT Bank ..................................................................................... 42 Figure 13: Procedural Flow Chart – VMT Exchange ............................................................................. 43 Figure 14: Procedural Flow Chart – VMT Impact Fee ........................................................................... 44
TABLES
Table A: Representative VMT and GHG Emissions from CalEEMod ....................................................... 7 Table B: CO2e Emission Rates by Land Use Type .................................................................................... 8 Table C: VMT Screening Thresholds for Sample Land Uses ................................................................... 8 Table D: VMT Metrics for Land Use Projects ........................................................................................ 28 Table E: Significance Thresholds for VMT Analysis .............................................................................. 29 Table F: Vehicle Miles Traveled Mitigation Measures for Land Development Projects ...................... 45
APPENDIX
Appendix A: MCAG Travel Demand Modeling Support Services ‐ SB 743 Coordination ..................... 56
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ABBREVIATIONS AND ACRONYMS
ADT Average Daily Trips
CalEEMod California Emissions Estimator Model
Caltrans California Department of Transportation
CAPCOA California Air Pollution Control Officers Association CARB California Air Resources Board
CEQA California Environmental Quality Act
CO2e Carbon Dioxide Equivalent
EIR Environmental Impact Report
EO Executive Order
GHG Greenhouse Gas
GWP Global Warming Potential
HOT High‐Occupancy Toll
HOV High‐Occupancy Vehicle
HQTA High‐Quality Transit Area
ITE Institute of Transportation Engineers
LOS Level of Service
MCAG Merced County Association of Governments
MPO Metropolitan Planning Organization
MT Metric Ton
NCST National Center for Sustainable Transpo
rtation
OPR Governor’s Office of Planning and Research
PRC Public Resources Code
RTP Regional Transportation Plan
SB Senate Bill
SCS Sustainable Communities Strategy
sf Square foot/Feet
SOC Statement of Overriding Considerations
TA Technical Advisory
TDM Travel Demand Model
TPA Transit Priority Area
VMT Vehicle Miles Traveled
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1 1.0 INTRODUCTION
Senate Bill (SB) 743, which became effective July 1, 2020, changes the way transportation impact assessments are conducted in California Environmental Quality Act (CEQA) documents. Most notably, rulemaking in support of SB 743 replaces motor vehicle delay, as measured by Level of Service (LOS), with Vehicle Miles Traveled (VMT) as the metric for use in CEQA tr ansportation impact assessments.
In January 2019, the Natural Resources Agency and the Governor’s Office of Planning and Research (OPR) codified SB 743 into the Public Resources Code (PRC) and the State CEQA Guidelines.
OPR published a Technical Advisory (TA) in December of 2018, as a resource to guide the assessment of the VMT metric, establish thr
esholds of significance, and recommends mitigation measures. The laws and rules governing the CEQA process are contained in the CEQA statute (PRC Section 21000 and following), the State CEQA Guidelines (California Code of Regulations, Title 14, Section 15000 and following), published court decisions interpreting CEQA, and lo cally adopted CEQA procedures. The TA is intended as a reference document; it does not have the weight of law. However, any decision to deviate from the TA recommendations should be supported by substantial evidence.
The State of California is committed to reducing greenhouse gas (GHG) emissions and achieving long‐ term cli
mate change goals. As a means for achieving statewide sustainability and climate goals, California legislation is focused on reducing VMT to achieve statewide climate goals. Over the last 40 years, across the state, VMT has far exceeded that of the state’s population increase during the same period. Transportation is the single larg
est sector contributing to California’s GHG emissions.
Approximately 41 percent of statewide GHG emissions are generated by the transportation sector, primarily passenger cars and light‐duty trucks (see Figure 1, following page). State mandates pertaining to GHG emissions include reducing the number of single‐occupancy vehicle trips and the length
of vehicle trips.
This document provides a guide and substantial evidence for Merced County Association of Governments (MCAG) and its member jurisdictions in setting the thresholds of significance for CEQA transportation studies. The report is organized into the following seven chapters:
Chapter 1 – Introduction: This chapter establishes the purpose and objective of this report. Chapter 2 – Definition of Region: This chapter describes the comparative geographic baseline of a region for analysis purposes.
Chapter 3 –Screening Criteria: OPR acknowledges that certain projects are either low VMT generators, or, by virtue of their location, would have a less than significant impact. This chapter provides the recommended screening criteria to identify potentially exempt projects. Chapter 4 –VMT Threshold Analysis for Development Projects: This chapter identifies the VMT thresholds of significance, which would result in a significant CEQA impact. The actual VMT metric (either an efficiency rate or total VMT) is described. The process of VMT analysis is also described in this chapter.
Chapter 5 – VMT Threshold Analysis for Transportation Projects: This chapter describes the methodology used to evaluate significant CEQA impacts associated with transportation projects.
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2 Many non‐capacity capital projects may be presumed to have a less than significant impact.
Capacity‐enhancing transportation projects may produce significant VMT impacts and would therefore be subject to a comprehensive VMT analysis including an induced travel assessment. Chapter 6 – VMT Threshold An alysis for Land Use Plans: This chapter provides guidance and substantial evidence to support the threshold recommendation for land use plans and CEQA transportation analyses by MCAG member jurisdictions.
Chapter 7 – VMT Mitigation Strategies: The discussion provided in this chapter is intended as a reference and guide for use in the identification of feasible VMT mitigation options that may be used to offset project‐related VMT impacts. It should be noted that this discussion is not intended to represent a full list of VMT mitigation measures available or feasible to th e MCAG member jurisdictions. As in previous CEQA practice, it is generally the lead agency who identifies mitigation measures to offset the specific project‐related impacts identified in an environmental document.
Source: https://ww2.arb.ca.gov/ghg‐inventory‐data
Figure 1: 2019 GHG Emissions in California by Economic Sector ATTACHMENT 2--Page 14
3 2.0 DEFINITION OF REGION: VEHICLE MILES TRAVELED CONTEXT To quantify a project’s impact related to the VMT metric, a geographic context must be established.
In the motor vehicle delay‐based (LOS) analyses, a project study area is the geographic context for measuring a project’s traffic impacts. A project study area is generally determined by the incremental increase in traffic generated by the project and the project’s potential to create travel delays in the area. This generally includes intersections and roadway segments where the project would add a prescribed number of peak‐hour trips. Lead agencies typically limit the LOS‐based project study area boundaries within their jurisdictions.
Unlike delay‐based LOS anal yses, VMT produces a regional impact that is not defined by roadway, intersection, or jurisdictional boundaries. OPR acknowledges this in its TA (page 6), which states:
“Lead agencies should not truncate any VMT analysis because of jurisdictional or other boundaries, for example, by failing to count the portion of a trip that falls outside the jurisdiction or by discou
nting the VMT from a trip that crosses a jurisdictional boundary.” The majority of trips are commute and shopping trips occurring between residential, office, and retail uses. Therefore, pursuant to the OPR TA, the recommendations for VMT thresholds for the three primary land use types (residential, office, and retail) are based on a comparison to a regional average.
OPR does not expl
icitly define the regional average, and instead, recommends:
1. In cases where the region is substantially larger than the geography over which most workers would be expected to live, it might be appropriate to ref er to a smaller geography, such as the county, that includes the area over which nearly all workers would be expected to live. (page 16)
2. For residential projects in unincorporated county areas, the local agency can compare a residential project’s VMT to (1) the region’s VMT per capita, or (2) the aggregate popula
tion weighted VMT per capita of all cities in the region. (page 15) In most of urbanized areas throughout the state, the county boundary is selected as the region for purposes of VMT analysis. The primary attribute considered is that the regional definition includes the majority of th
e trip origins and/or destinations within that region. The denominator of all subsequent land development VMT analyses will include the vast majority of all home‐based trips as the comparative.
The geographic boundary needs to contain the majority of trips that either originate in or are destined to the jurisdiction boundary. To deter mine this boundary, a review of the regional travel demand model data that includes MCAG and its member jurisdictions, was evaluated.
Mobility, as related to vehicle travel, can be studied using a trip‐based approach or a tour‐based approach. A trip‐based approach calculates VMT as individual trips to and from the project. On the other han
d, a tour‐based approach considers a chain of linked trips that includes the project as a trip.
The State supports the trip‐based approach and states “When available, tour‐based assessment is ideal because it captures travel behavior more comprehensively. But whe re tour‐based tools or data ATTACHMENT 2--Page 15
4 are not available for all components of an analysis, a trip‐based assessment of VMT serves as a reasonable proxy.” (OPR TA page 5)
The MCAG Travel Demand Model (TDM) is the regional model for the County. This model is applicable to jurisdictions within Merced County, including the unincorporated county for evaluating project VMT. This model
is also trip‐based and was used to evaluate the typical ‘trip catchment areas’ for the MCAG member jurisdictions. Additionally, consistent with the OPR TA, only trips having origins or destinations or both within the specific jurisdiction were considered for this analysis. External pass‐ through trips were not considered as these are not required for the analysis.
As illustrate
d in Figure 2, based on the analysis using the MCAG TDM, individual MCAG member jurisdictions have a variable percentage of trips contained within themselves, but, for all the jurisdictions, approximately 95 percent or more trips are contained within Merced County. The remaining four to five percen
t trips travel beyond the County boundary. This data was validated by the MCAG travel demand modeling consultant and is included in Appendix A.
Figure 2: Share of Total Trips Having Origins/Destinations within Individual Jurisdictions, within Entire Merced County, or Outside the County (2015 MCAG TDM) Therefore, Merced County is an appropriate ‘region’ for VMT analysis purposes because for all the MCAG member jurisdictions, majority of the trips (approximately 95 percent) are contained within this distinct area.
14.5%
30.6%
37.2%
4.9%
72.5%
54.3%
32.2%
95.1% 95.2% 95.1% 95.2% 95.1% 95.1% 95.3%
4.9% 4.8% 4.9% 4.8% 4.9% 4.9% 4.7%
0%
20%
40%
60%
80%
100%
120%
Atwater Dos Palos Gustine Livingston Los Banos Merced Merced County Within Jurisdiction
Within Entire County
Outside County
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5 3.0 SCREENING CRITERIA
The TA acknowledges that certain activities and projects may result in a reduction of VMT and GHG emissions and may therefore be assumed to produce a less than significant transportation impact.
Due to a presumption of less than significant impact as accepted by OPR, a variety of projects may be screened out of SB 743‐related VMT analysis requirements.
3.1 DEVELOPMENT PROJECTS
For development projects, screening factors may include a project’s size, location, proximity to transit, and trip‐making potential. One or more of the following project attributes may be presumed to produce a less than significant VMT impact:
The project is within 0.5 mile (mi) of a transit priority area or a high‐quality transit area and is consistent with the Regional Transportation Plan (RTP)/Sustainable Communities Strategy (SCS), has a floor area ratio (FAR) equal or greater than 0.75, does not provide an excessive amount of parking, or does not reduce the nu mber of affordable residential units. In accordance with SB 743, “transit priority areas” are defined as “an area within one‐half mile of a major transit stop that is existing or planned, if the planned stop is scheduled to be completed within the planning horizon included in a Transportation Improvement Pro
gram. A Major transit stop means: “a site containing an existing rail transit station, a ferry terminal served by either a bus or rail transit service, or the intersection of two or more major bus routes with a frequency of service of 15 minutes or less during the morning and afte
rnoon peak commute periods.” A high‐quality transit area or corridor is a corridor with fixed route bus service with service intervals no longer than 15 minutes during peak commute hours.
Figure 3 depicts transit priority areas within Merced County, including high‐quality transit areas (within 0.5 mile of a major transit stop) served by The Bus (Merced’s Regional Transit Syste m) with service intervals of 15 minutes or less. Projects proposed in these areas may be presumed to have a less‐than‐significant transportation impact unless the project is inconsistent with the RTP/SCS, has an FAR less than 0.75, provides an excessive amount of parking , or reduces the number of affordable residential units.
The project includes local‐serving retail with a combined area of less than 50,000 square feet (sf). Redevelopment projects that result in an equal or net reduction in VMT may be considered to have less than significant VMT impact. A net reduction in VMT would occur if the land use proposed by the project would generate less VMT than the existing land use. The project includes 100 percent affordable housing units. A project consistent with the jurisdiction’s General Plan may be successfully screened if the project would generate fewer than 1,000 average daily trips (ADT), while a project not consistent with the jurisdiction’s General Plan may be screened if the project would generate fewer than 500 ADT (See section 3.1.1 below.)
Institutional/government and public service uses that support community health, safety and welfare may also be screened from subsequent CEQA VMT analysis. These facilities (e.g., police stations, fire stations, government offices, utilities, public libraries, community centers, and refuse stations) would be a part of the community and, as public services, the VMT would be ATTACHMENT 2--Page 17
6 accounted for within the community. Any other similar use not included in the list can be approved on a case‐by‐case basis by the local jurisdiction as applicable. As such, these uses would result in reduction in total VMT due to the proximity of these services within the community.
Additionally, many of these facili ties would generate fewer than 1,000 ADT and/or use vehicles other than passenger‐cars or light‐duty trucks. These other vehicle fleets are subject to regulation outside of CEQA, such as the California Air Resources Board (CARB) and the San Joaquin Valley Air Pollution Control District.
Local parks, daycare centers, student housing projects on or adjacent to a college campus, local‐ serving gas stations, banks, and K–12 public schools.
Projects located in areas with low VMT may be screened out from further CEQA analysis. The TA acknowledges that residential and office projects located in areas having a low VMT, (which incorporate features such as density, mix of uses, transit accessibility), tend to exhibit similarly low VMT. Also, areas that are mapped as low VMT areas do not need to prepare a detailed VMT analysis. Therefore, residential, office, industrial, or mixed‐use projects that are consistent with the lead agency’s General Plan and located within low VMT areas (using the MCAG VMT Screening Tool1 and applying appropriate thresholds) may be presumed to have similar low VMT profiles and could be screened out from the need for further VMT analysis. It should be noted that if a project constitutes a General Plan Amendment or Zone Change, such projects will be evaluated on a case‐by‐case basis. Figures 4, 5, and 6 illustra te the VMT per capita, VMT per employee, and VMT per service population screening maps for the region. The 2022 State CEQA Guidelines Section 15007 (c) states that “if a document meets the content requirements in effect when the document is sent out for public review, the document shall not need to be revised to conform to any new content requirements in Guideline amendments taking effect before the document is finally approved.” Therefore, if a developmen t/land use plan/ transportation project is already cleared by a certified Environmental Impact Report (EIR) or an adopted Negative Declaration/Mitigated Negative Declaration, then subsequent projects that are consistent with the approved project will not require a new VMT analysis.
3.1.1 Average Daily Trips (ADT) Threshold
Although OPR recommends 110 ADT as an appropriate threshold, this number is not based on any analysis of GHG reduction potential but, rather, on a CEQA categorical exemption. Under Section 15301(e)(2) of the CEQA Guidelines, existing facilities, including additions to existing structures of up to 10,000 sf are exempt from CEQA review if the project is located in an area whe re public infrastructure is available to allow for maximum planned development and the project is not located in an environmentally sensitive area.
Similar adjustments have been successfully implemented in other jurisdictions. The justification for the increase in the proposed screening threshold based on reduction of GHG emissions, is further describe
d below.
1 MCAG VMT Screening Tool: https://gis1.lsa.net/mcagvmt/ ATTACHMENT 2--Page 18
7 According to OPR, projects have a linear increase in trip generation with respect to the building footprint. Specifically, between 110 and 124 daily vehicle trips are anticipated per 10,000 sf. Based on this assumption, OPR recommends 110 ADT as the screening threshold.
The California Emissions Estimator Model (CalEEMod) is a tool provided by CARB and is accepted as the statewide standard
to evaluate air quality and GHG emission impacts for CEQA assessment. As such, CalEEMod was used to characterize the effect of changes in project‐related ADT to the resulting GHG emissions. To account for geographical relevance to project location, LSA calculated trip le ngths from the MCAG TDM. The trip lengths were calculated for various project types and trip purposes.
Table A shows the resulting annual VMT and GHG emissions produced by incremental ADT for single‐ family residential projects.
Table A: Representative VMT and GHG Emissions from CalEEMod Average Daily Trips (ADT)
Annual Vehicle Miles
Traveled (VMT)
Vehicular GHG Emissions
(Metric Tons of CO2e per
year)
Total Project GHG
Emissions
(Metric Tons of CO2e per
year)
200 711,204 306.48 370.20
300 1,083,739 467.02 564.22
400 1,422,408 612.96 740.41
500 1,794,944 773.50 934.43
600 2,167,479 934.04 1,128.27
750 2,675,482 1,152.95 1,392.73
1,000 3,589,887 1,547.00 1,868.68
1,500 5,384,831 2,320.50 2,803.11
Source: CalEEMod version 2020.4.0.
CalEEMod = California Emissions Estimator Model; GHG = Greenhouse Gas; CO2e = carbon dioxide equivalent
A common GHG emissions threshold is 3,000 metric tons (MT) of carbon dioxide equivalent2 (CO2e) per year. As shown in Table A, a project with an ADT lower than 1,500 would generally be expected to have a total project emission of less than 3,000 MT CO2e/year. LSA conducted this exercise for several other land uses to identify appropriate GHG screening thresholds. Table B shows the potential maximum GHG screening thresholds (up to 3,000 MT) for these land uses.
While OPR recommends 110 ADT as the VMT screening threshold, the GHG analysis above concludes that projects with up to 1,500 ADT could be potentially screened out from VMT analysis. As a conservative approach, the MCAG VMT Thre
sholds and Implementation Guidelines document
recommends a daily trip threshold of 1,000 ADT be applied to projects that are consistent with the lead agency’s General Plan. However, for projects that are not consistent with the lead agency’s General Plan, a screening threshold of 500 ADT may be applied. A sample list of size of projects
2 CO2e is a concept developed to provide one metric that includes the effects of numerous GHGs. The global warming potential (GWP) of each GHG characterizes the ability of each GHG to trap heat in the atmosphere relative to another GHG. The GWPs of all GHGs are combined to derive the CO2e.
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8 generating fewer than 1,000 and 500 daily vehicle trips that would be eligible to be exempt from a VMT analysis are included in Table C.
Table B: CO2e Emission Rates by Land Use Type
Land Use Units Total MTCO2e
per year
Annual MTCO2e
per DU or TSF
Single‐Family Residential 170 DU 2,996.95 17.63
Low‐Rise Multifamily Residential 247 DU 2,991.46 12.11 Mid‐Rise Multifamily Residential 349 DU 2,994.91 8.58 Office 240 TSF 2,992.16 12.47
Warehouse 614 TSF 2,998.41 4.88
Light Industrial 361 TSF 2,992.96 8.29
Hotel 309 Rooms 2,998.56 9.70
Medical Office 86 TSF 2,971.57 34.55
Hospital 125 Beds 2,986.23 23.89
Shopping Center 43 TSF 2,946.34 68.52
Strip Mall 83 TSF 2,999.79 36.14
Source: California Emissions Estimator Model (CalEEMod) version 2020.4.0.
DU = Dwelling Units; TSF = Thousand Square Feet; CO2e = carbon dioxide equivalent
Table C: VMT Screening Thresholds for Sample Land Uses
Land Use
Size of Projects
(Requiring a GPA)
Size of Projects
(Not Requiring a GPA)
Single‐Family Residential1 53 DU 106 DU
Low‐Rise Multifamily Residential2 74 DU 148 DU
Mid‐Rise Multifamily Residential3 110 DU 220 DU
Office 46.125 TSF 92.250 TSF
Warehouse 292.397 TSF 584.795 TSF
Light Industrial 102.669 TSF 205.338 TSF
Hotel 62 Rooms 125 Rooms
Medical Office4 13.888 TSF 27.777 TSF
Hospital 22 Beds 44 Beds
Notes: DU = Dwelling Units; TSF = Thousand Square Feet
Project sizes have been determined based on trip generation rates obtained from the ITE Trip Generation Manual (11th Edition). 1 The project sizes have been provided for single‐family detached residential only. 2 The project sizes have been provided for low‐rise multifamily residential (not close to rail transit) only. 3 The project sizes have been provided for mid‐rise multifamily residential (not close to rail transit) only. 4 The project sizes have been provided for stand‐alone medical office buildings only.
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18 3.2 TRANSPORTATION PROJECTS
Transportation projects refer to capital improvement projects that relate to roadway widening, roadway infrastructure improvements, active transportation projects or operational improvements.
The primary attribute to consider with transportation projects is the potential to increase vehicle travel demand, also referred to as ‘induced travel.’ While the lead agency has discretion to continue to use a delay‐based LOS analysis for
CEQA disclosure of transportation projects, changes in vehicle travel must be quantified. To comply with SB 743, the lead agency may solely use VMT analysis for CEQA disclosure of transportation impacts, but may also require a LOS analysis for design, traffic operations, and safety purposes to com ply with the lead agency’s General Plan Circulation Element.
The TA identifies the types of transportation improvement projects that would not likely lead to a substantial or measurable increase in vehicle travel and which would, therefore, not require further VMT analysis. These include the following:
Rehabilitation, maintenance, replacement, safety, and repair projects designed to improve the condition of existing transportation assets (e.g., highways; roadways; bridges; culverts; Transportation Management System field elements such as cameras, message signs, detection, or signals; tunnels; transit systems; and assets that serve bicycle and pedestrian facilities) that do not add additional motor vehicle capacity.
Roadside safety devices or hardware installation such median barriers and guardrails. Roadway shoulder enhancements to provide “breakdown space,” dedicated space for use only by transit vehicles, to provide bicycle access, or to otherwise improve safety, but which will not be used as automobile vehicle travel lanes.
Addition of an auxiliary lane of less than 1 mile in length designed to improve roadway safety. Installation, removal, or reconfiguration of traffic lanes that are not for through traffic, such as left‐turn, right‐turn, and U‐turn pockets, two‐way left‐turn lanes, or emergency breakdown lanes that are not utilized as through lanes.
Addition of roadway capacity on local or collector streets, provided the project also substantially improves conditions for pedestrians, cyclists, and, if applicable, transit. Conversion of existing general‐purpose lanes (including ramps) to managed lanes or transit lanes, or changing lane management in a manner that would not substantially increase vehicle travel. Addition of a new lane that is permanently restricted for use only by transit vehicles. Reduction in the number of through lanes.
Grade separation to separate vehicles from rail, transit, pedestrians, or bicycles, or to replace a lane in order to separate preferential vehicles (e.g., high‐occupancy vehicles [HOV], high‐ occupancy toll [HOT] lane traffic, or trucks) from general vehicles. Installation, removal, or reconfiguration of traffic control devices, including Transit Signal Priority features.
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19 Installation of traffic metering systems, detection systems, cameras, changeable message signs, and other electronics designed to optimize vehicle, bicycle, or pedestrian flow. Timing of signals to optimize vehicle, bicycle, or pedestrian flow. Installation of roundabouts or traffic circles.
Installation or reconfiguration of traffic calming devices. Adoption of or increase in tolls.
Addition of tolled lanes, where tolls are sufficient to mitigate VMT increase. Initiation of a new transit service.
Conversion of streets from one‐way to two‐way operation with no net increase in the number of traffic lanes.
Removal or relocation of off‐street or on‐street parking spaces. Adoption or modification of on‐street parking or loading restrictions (including meters, time limits, accessible spaces, and preferential/reserved parking permit programs). Addition of traffic wayfinding signage.
Rehabilitation and maintenance projects that do not add motor vehicle capacity. Addition of new or enhanced bike or pedestrian facilities on existing streets/highways or within existing public rights‐of‐way.
Addition of Class I bike paths, trails, multi‐use paths, or other off‐road facilities that serve non‐ motorized travel.
Installation of publicly available alternative fuel/charging infrastructure. Addition of passing lanes, truck climbing lanes, or truck brake‐check lanes in rural areas that do not increase overall vehicle capacity along the corridor.
Additionally, transit and active transportation projects generally reduce VMT and, therefore, may be presumed to cause a less than significant impact on transportation. This presumption may apply to all passenger rail projects, bus and bus rapid‐transit pro
jects, and bicycle and pedestrian infrastructure
projects. The lead agency may use this CEQA presumption of less than significant impact to aid in the prioritization of capital improvement projects, as the CEQA process for any of these project types would be more streamline d than other capacity‐enhancing projects.
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21 4.0 VMT THRESHOLD ANALYSIS FOR DEVELOPMENT PROJECTS
4.1 THRESHOLDS
The TA clarifies that SB 743 and all CEQA VMT transportation analyses refer to automobile travel.
Here, the term automobile refers to on‐road passenger vehicles, specifically cars and light‐duty trucks.
Heavy‐duty trucks should be addressed in other CEQA sections (air quality, greenhouse gas, noise, and health risk assessment analysis) and are subject to regula tion in a separate collection of rules under CARB jurisdiction. This approach was amplified by Chris Ganson, former Senior Advisor for Transportation at OPR, in a presentation to the Fresno Council of Governments (October 23, 2019) and by Ellen Greenberg, the California Department of Transportation (Caltrans) Deputy Director for Sustainability, at the San Joaquin
Valley Regional Planning Agencies’ Directors’ Committee meeting (January 9, 2020).
OPR has identified home‐based work trips as the primary type used in the home‐based travel demand modeling. This includes residential uses, office uses, and retail uses. The home‐based work trip type is the primary tri
p type generated during the peak hours of commuter traffic in the morning and evening periods.
The focus of transportation impact assessment has shifted from congestion relief to climate resiliency.
The purpose of the CEQA analysis is to disclose and ultimately reduce GHG emissions by reducing the number and length
of automobile trips. As part of the SB 375 land use/transportation integration process and GHG emissions goal setting, the State and Regional Transportation Planning Agencies have agreed to reduce statewide GHG emissions by an average of approximately 15 percent by 2035 through an approach based on improved integration of land use and transportation plan ning. Figure 7 illustrates SB 375 regional GHG emissions reduction targets for all the 18 Metropolitan Planning Organizations (MPOs) in California that CARB established in 2018. Furthermore, in its 2017 Scoping Plan‐Identified VMT Reductions and Relationship to State Climate Goals, CARB recommends total VMT per capita rates
be reduced to approximately 15 percent below existing conditions. While the current target is 15 percent, CARB periodically revises the target based on changing information and, therefore, the target might be revised in the future. Additionally, for purposes of VMT analysis, the existing setting will follow the base year scenario in the regional travel dema nd model, the MCAG TDM. It is to be noted that the base year scenario in the model is also periodically revised and, as a result, the existing setting will change accordingly.
Specifically, the TA recommends:
A proposed (residential) project exceeding a level of 15 percent below existing regional average VMT per capita may indicate a significant transportation impact. A similar threshold would apply to office projects (15 percent below existing regional average VMT per employee).
VMT generated by retail projects would indicate a significant impact for any net increase in total VMT.
ATTACHMENT 2--Page 33
22 Source: https://ww2.arb.ca.gov/our‐work/programs/sustainable‐communities‐program/regional‐plan‐targets.
Figure 7: SB 375 Regional Plan Climate Targets for California’s 18 MPOs It is noted that the aggregate GHG emission reduction sought after by CARB in the 2017 Scoping Plan is 15 percent statewide. This is one reason OPR believes the 15 percent reduction in VMT is appropriate. The aggregate 15 percent GHG emission reduction applies across all land use and transportation activities and would indicate that the Stat e and its individual MPOs are compliant with the SB 375 goals, the overall State climate change strategy, and Scoping Plan objectives.
CARB establishes GHG targets for each of the 18 MPOs in the State, reviews the SCSs, and makes a determination of whether the SCSs would achieve GHG re duction targets if implemented. In the spring of 2018, CARB adopted new GHG targets for all the 18 MPOs in the State based on the 2017 Scoping Plan and other new data as illustrated in Figure 7. CARB established a 14 percent GHG reduction target for 2035 for the Merced region. The State recognizes that Merced County’s contribution to the aggregate 15 percent statewide GHG emission reduction is 14 percent. Other regions may achieve lower reductions to achieve the aggregate statewide goal.1 As such, reduction in GHG directly corresponds to reduction in VMT. In order to reach the statewide GHG reduction goal of 15 percent, the Merced region must reduce GHG by 14 percent. The method of reducing GHG by 14 percent is to reduce VMT by 14 percent as well.
Therefore, Merced County member juris dictions may establish a threshold for land use developments, specifically residential and office, of 86 percent of the existing regional average as indicative of a significant transportation impact. For retail projects, increase in total regional roadway VMT with the implementation of the project would indicate a significant transportation impact. As such, total
1 The latest GHG targets by region can be found at https://ww2.arb.ca.gov/our‐work/programs/sustainable‐ communities‐program/regional‐plan‐targets.
0%
2%
4%
6%
8%
10%
12%
14%
16%
18%
20%
2020
2035
ATTACHMENT 2--Page 34
23 roadway VMT needs to be calculated using the final roadway assignment outputs from the MCAG TDM.
Other distinct land uses are not identified for threshold development in the OPR TA. For other non‐ residential projects, a significance threshold of 86 percent of existing regional average VMT per employee is recommended. The only exceptions woul d be hotels, hospitals, medical offices, and related projects. These land uses are service oriented facilities which includes both visitors and employees. Therefore, for such projects, VMT per service population (population/users + employment) is recommended as the VMT metric. Any other similar use could be evaluated using the same metric subject to approval of the methodology by th e local jurisdiction on a case‐by‐case basis.
As such, a significance threshold of 86 percent of the existing regional average VMT per service population is recommended for these projects.
Evaluation of mixed‐use projects may be for each land use component of the projec t using the most appropriate VMT metric. Credit for internal trip capture may be made. Internal trip capture may be calculated using the latest edition of the Institute of Transportation Engineers (ITE) Trip Generation Manual, the MCAG TDM, or other applicable sources approved by the lead agency. The appropriate methodology for calculating project’s internal cap
ture would be determined in consultation with the
lead agency’s Traffic Engineer. The significance threshold for these projects would be the respective VMT thresholds for its different land use components.
A lead agency may develop VMT thresholds for other land uses as desired. However, it would require disclosure of substantial e
vidence, including the General Plan findings, and other traffic and air quality forecasting support data. Additionally, if the lead agency wishes to establish some other threshold less stringent than the 86 percent of the existing regional average recommended for residential and office projects, a body of substantial evid ence would be necessary.
4.2 IMPACT ASSESSMENT
Figure 8 illustrates the VMT screening methodology for development entitlement projects.
Additionally, Figures 9‐A through 9‐C illustrate the VMT analysis methodology for non‐screened projects. Every development application is unique and may create alternative or modified steps through the process described in the aforementioned figures. Each step that diverges from this standard process should be accompan
ied with substantial evidence demonstrating compliance with other climate change and GHG emission reduction laws and regulations.
4.2.1 Agency Communication
As part of the site plan review process, the applicant should provide a detailed project description, including potential number of residents added or created by the project, and the applicable VMT analysis methodology. Key elements include a description of the project in sufficient detail to generate trips and the potential catchment area (i.e., trip lengths if no modeling is undertak en), estimated project VMT, project design features that may reduce the VMT from the project development, and the project location and associated existing regional VMT percentages. Further, the applicant or their consultant shall prepare a transportation analysis scope of work for review and approval by the lead agency.
ATTACHMENT 2--Page 35
24 Figure 8: VMT Screening Methodology for Development Projects ATTACHMENT 2--Page 36
25 Figure 9‐A: VMT Analysis Methodology for Non‐Screened Residential Projects ATTACHMENT 2--Page 37
26 Figure 9‐B: VMT Analysis Methodology for Non‐Screened Non‐Residential (Non‐Retail) Projects ATTACHMENT 2--Page 38
27 Figure 9‐C: VMT Analysis Methodology for Non‐Screened Non‐Residential (Retail) Projects ATTACHMENT 2--Page 39
28 Projects that will influence Caltrans facilities may be subject to the Caltrans Local Development‐ Intergovernmental Review program. As part of the program, Caltrans may review the VMT analysis methodology, findings, and mitigation measures to ensure consistency with statewide standards.
4.2.2 Project Screening
Once a development application is filed and determined to be complete for processing purposes, project screening may commence. If the project meets any one of the screening criteria, it may be presumed to have a less than significant transportation impact. No further VMT analysis would then be necessary and a Notice of Exemption may be filed. The CEQA docu ment should enumerate the screening criteria and how the project meets or exceeds that applicable VMT threshold.
If project screening does not apply, a VMT analysis may be required. The extent of this analysis may be a simple algebraic demonstration or a more sophisticated traffic modeling exercise. Th is distinction is addressed later in this report.
4.2.3 VMT Identification
The project land use type will determine the appropriate metric to use (i.e., VMT per capita, VMT per employee, VMT per service population, or total VMT). Appropriate VMT metrics for different land uses are stated in Table D.
Table D: VMT Metrics for Land Use Projects
Land Use VMT Metric
Residential VMT per Capita
Office VMT per Employee
Retail Total VMT
Hotel, Hospital, Medical Office Building, or any similar use with approval from local jurisdiction VMT per Service Population Mixed‐Use, Land Use Plan (General Plan/Specific Plan) Respective VMT metrics for its different land use components
Other Land Uses VMT per Employee
VMT = Vehicle Miles Traveled
For all projects that require a VMT analysis, use of the MCAG TDM is required unless the project includes a special land use that is difficult to analyze using a travel demand model. For the latter, the lead agency may require a qualitative analysis or an analysis using empirical data as applicable to the project.
Next, the project‐
generated VMT (per capita, per employee, per service population, or total) is compared to the appropriate significance threshold provided in Table E. If the project VMT metric is less than the significance threshold, the project is presumed to create a less than significant impact.
No further VMT analysis for CEQA purposes would be requir ed.
Should project VMT metrics exceed the significance threshold, mitigation measures will be required.
It should be noted that the thresholds identified in Table E are based on the current version of the ATTACHMENT 2--Page 40
29 MCAG TDM (provided by MCAG in May 2022). These thresholds are subject to change when a newer version of the MCAG TDM is available.
Table E: Significance Thresholds for VMT Analysis
VMT Metric Threshold
VMT per Capita 10.92
VMT per Employee 8.79
VMT per Service Population 21.47
Source: 2015 MCAG TDM
VMT = Vehicle Miles Traveled
4.3 MITIGATION MEASURES
State law requires the project applicant to identify feasible offsets to mitigate VMT impacts generated by the proposed project. These may come from the mitigation strategies provided in this document (as described in Table F at the end of Chapter 7.0) or selected by the applicant based on their CEQA project experience and expe rtise. The lead agency must approve and accept the final VMT mitigation program ascribed to the project and the related VMT percentage reduction. A detailed discussion about project‐specific mitigations is included in Section 7.2.1.
If it is determined that the selected VMT mitigation measures effectively reduce the project impact to less than the appli
cable threshold, the project is presumed to have an impact mitigated to a less than significant level. No further VMT analysis is required. If the project’s VMT impact cannot be mitigated, the lead agency may (1) request the project be redesigned to reduce the VMT impact, or (2) require the preparation of an EIR with a Sta tement of Overriding Considerations (SOC) for the transportation impacts associated with the project. All feasible mitigation measures must be assigned to and carried out by the project even if an EIR/SOC is prepared.
ATTACHMENT 2--Page 41
30 5.0 VMT THRESHOLD ANALYSIS FOR TRANSPORTATION PROJECTS The 2022 State CEQA Guidelines include Section 15064.3.b.(2) to address transportation projects. It reads:
For roadway capacity projects, agencies have discretion to determine the appropriate measure of transportation impact consistent with CEQA and other applicable requirements.
The lead agency may continue to use motor vehicle delay (LOS) metrics for transportation project design and traffic operation purposes as
long as impacts related to “other applicable requirements” are disclosed. This has generally been interpreted as VMT impacts and other State climate objectives.
These other applicable requirements may be found in other parts of an environmental document (e.g., air quality and GHG), or may be provided in greater deta il in the transportation section.
In addition, projects processed under federal environmental rules have traditionally included a traffic operational analysis to meet the requirements of the National Environmental Policy Act. Federal review is generally required if a project uses federal funding or involves federal lands. Additional safety evaluations may need to be conducted outside the CEQA process since some desirable safety improvements may not be directly related to CEQA safety impacts.
For projects on the State Highway System, Caltrans will require sponsoring agencies to use VMT as the CEQA transportation impact assessment metric, and to evaluate the amount of VMT that is “attributable to the project” (January 9,
2020, conference). Caltrans’ Intergovernmental Review process will review environmental documents for capacity‐enhancing projects for their analysis of VMT impact.
A VMT assessment of a transportation project should disclose the VMT profile without the project and the difference in the VMT profile with the project. Any increase in VMT attributable to the proposed transportation project would result in a significant impact. A significant transportation project impact is presumed when VMT increases with the project as compared to the ‘No Project’ scenario.
Capacity improvement projects have the potential of producing significant transportation impacts because they tend to induce new travel. The OPR TA desc ribes induced travel as the additional motor
vehicle travel that is generated by the newly available capacity on the roadway. Induced travel may include route switching, time‐of‐day change, mode shift to single occupancy vehicle, longer trips, new trips to existing destinations, and additi
onal travel due to new development. Current traffic models have limited abilities to forecast new trips and new developments associated with roadway capacity improvements, as land use or socioeconomic databases are fixed to a specific horizon date. OPR refers to a limited number of published studies that seek to define travel demand elasticities.
The most recent major study (Duranton & Turner 2011,
p. 24) estimates an elasticity of 1.0, meaning
that every one percent change in lane miles results in a one percent increase in VMT.
ATTACHMENT 2--Page 42
31 One method to quantify induced growth is recommended by the OPR TA:
To estimate VMT impacts from roadway expansion projects:
1. Determine the total lane‐miles over an area that fully captures travel behavior changes resulting from the project (generally the region, but for projects affecting interregional travel look at all affected regions).
2. Determine th
e percent change in total lane miles that will result from the project.
3. Determine the total existing VMT over that same area.
4. Multiply the percentage increase in lane miles by the existing VMT, and then multiply that by the elasticity from the induced travel literature:
[% increase in lane miles] × [exi
sting VMT] × [elasticity] = [VMT resulting from the project] OPR assigns this induced growth to project‐induced changes in land use; that is, new land uses that are not included in any approved general or area plan and not accounted for in any traffic‐forecasting tool.
Figure 10 provides a repre
sentative illustration of induced VMT attributable to a project.
Source: Presentation: Caltrans Transportation Analysis under CEQA or TAC: Significance Determinations for Induced Travel Analysis (SHCC Pre‐Release Session 2 Jeremy Ketchum, Division of Environmental Analysis, Caltrans; March 2, 2020)
Figure 10: Induced Travel – VMT Attributable to Project ATTACHMENT 2--Page 43
32 Caltrans has identified a computerized tool to estimate VMT generation from transportation projects.
The tool (https://travelcalculator.ncst.ucdavis.edu) was developed by the National Center for Sustainable Transportation (NCST) at the University of California, Davis, and is based on travel demand elasticities and the relationship of lane mile additions with growth in VMT. It uses Federal Highway Administration definitions of facility typ
e and ascribes VMT increases to each facility. Output data include increases in million miles of VMT per year. Caltrans is investigating the use of this tool for all of its VMT analyses of capital projects on the State Highway System. The NCST tool is available at https://blinktag.com/induced‐
travel‐calculator. Figure 11 provides an illustration of that tool.
Other options to identify induced growth‐ and project‐related VMT provided by the TA include:
1. Employ an expert panel. An expert panel could assess changes to land use development that would likely result from the project. This assessment could then be analyzed by th e travel demand model to assess effects on vehicle travel. Induced vehicle travel assessed via this approach should be verified using elasticities found in the academic literature.
2. Adjust model results to align with the empirical research. If the travel demand model analysis is performed without incorporating projected land use changes resulting from the project, the assessed vehicle travel shou
ld be adjusted upward to account for those land
use changes. The assessed VMT after adjustment should fall within the range found in the academic literature.
3. Employ a land use model, running it iteratively with a travel demand model. A land use model can be used to estimate the land use effects of a roadway capacity increase, an d the traffic patterns that result from the land use change can then be fed back into the travel demand model. The land use model and travel demand model can be iterated to produce an accurate result.
A final advisory from the TA is provided below:
Whenever employing a travel demand model to assess in duced vehicle travel, any limitation or known lack of sensitivity in the analysis that might cause substantial errors in the VMT estimate (for example, model insensitivity to one of the components of induced VMT described above) should be disclosed and characterized, and a description should be provided on how it could influence th
e analysis results. A discussion of the potential error or bias should be carried into analyses that rely on the VMT analysis, such as greenhouse gas emissions, air quality, energy, and noise. (OPR TA page 34)
ATTACHMENT 2--Page 44
33 Source: https://blinktag.com/induced‐travel‐calculator/index.html Figure 11: Caltrans Induced Travel Calculator
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35 6.0 VMT THRESHOLD ANALYSIS FOR LAND USE PLANS
The OPR TA provides guidance on the treatment of CEQA traffic analyses for land use plans (General Plan, Specific Plan) as follows:
Analyze the VMT outcomes over the full area over which the plan may substantively affect travel patterns (the definition of region).
VMT should be counted in full rather than split between origins and destinations (the full impact of the project VMT).
Specifically, OPR states, “A general plan, area plan, or community plan may have a significant impact on transportation if proposed new residential, office or retail land uses would in aggregate exceed the respective thresholds recommended
above.” (OPR TA page 18) This recommendation refers to a threshold of 15 percent lower than the existing regional average for residential and office uses and no net gain for retail land uses.
To assess a land use plan, use of a traffic‐forecasting tool is recommended. The total VMT for the plan may
be identified for all trips and all potential VMT contributors within the plan area. Model runs may be conducted for the existing base year and the horizon year (the future year scenario analyzed in the Circulation Element of the lead agency’s General Plan) with the project (pla n).
SB 375 establishes ambitious and achievable GHG reduction targets for the 18 MPOs in the State.
Achievement of these targets is to be accomplished through the improved integration of regional land use and transportation planning processes; not solely through the imposition of new regulation on passenger cars and light‐duty trucks.
CARB reviews
the SCS that is produced as part of the RTP produced by each of the State’s MPOs. The SCS details the strategies and programs the regional agencies are planning to implement to achieve its designated GHG emission reduction targets. CARB approved the new GHG reduction targets for all 18 MPOs in the State in the spring of 2018. The 2018 targets are applicable to the third SCSs for the MPOs.
Other legislative mandates and State policies are also supportive of GHG reduction targets. A sample of these include:
Assembly Bill 32 (2006) requires statewide GHG emissions reductions to 1990 levels by 2020 and continued reductions beyond 2020.
SB 32 (2016) requires at least a 40 percent reduction in GHG emissions from 1990 levels by 2030. Executive Order (EO) B‐30‐15 (2015) sets a GHG emissions reduction target of 40 percent below 1990 levels by 2030.
EO S‐3‐05 (2005) sets a GHG emissions reduction target of 80 percent below 1990 levels by 2050. EO B‐16‐12 (2012) specifies a GHG emissions reduction target of 80 percent below 1990 levels by 2050 specifically for transportation.
ATTACHMENT 2--Page 47
36 These mandates suggest that a land use plan consistent with the regional RTP/SCS would generally help achieve the target GHG reductions for the region.
California PRC Section 15064.3(b)(4) states (in part) the following:
A lead agency has discretion to choose the most appropriate methodology to evaluate a project’s vehicle miles traveled, including whether to express the change in ab solute terms, per capita, per household, or in any other measure.
Since VMT is the largest contributor to GHG emissions, a land use plan consistent with regional RTP/ SCS GHG reductions target would generally not have a significant VMT impact. Therefore, the recommended methodology for conducting VMT assessments fo r land use plans is to compare the existing VMT per capita, VMT per employee, and/or VMT per service population for the region with the respective expected horizon year VMT metrics for the different land use components (VMT per capita, VMT per employee, and/or VMT per service population) of the land use plan (project) . If there is a net increase in the VMT metric under horizon year conditions, then the project will have a significant impact.
ATTACHMENT 2--Page 48
37 7.0 MITIGATION STRATEGIES
When a lead agency identifies a potentially significant CEQA VMT impact according to the thresholds described in this report, the agency must identify feasible mitigation measures to avoid or substantially reduce that impact. Unlike LOS impacts, which may be mitigated with location‐specific motor vehicle delay improvements, VMT impacts typically require a more regional approach to mitigation, includi
ng the provision of incentives to effect changes in travel behavior. Enforcement of mitigation measures will still be subject to the mitigation monitoring requirements of CEQA, as well as the regular police powers of the agency. VMT mitigation measures may also be incorporated into the design of plans, policies, regulations, or projects.
7.1 DEFINITION OF MITIGATION
Section 15370 of the 2022 State CEQA Guidelines defines mitigations as follows:
“Mitigation” includes:
a. Avoiding the impact altogether by not taking a certain action or parts of an action. b. Minimizing impacts by limiting the degree or magnitude of the action and its implementation.
c. Rectifying the impact by repairing, rehabilitating, or rest oring the impacted environment. d. Reducing or eliminating the impact over time by preservation and maintenance operations during the life of the action.
e. Compensating for the impact by replacing or providing substitute resources or environments, including through permanent protection of such resources in the form of conservation easements.
Section 15097 of the CEQA Guidelines states that, “th e public agency shall adopt a program for
monitoring or reporting on the revisions which it has required in the project and the measures it has imposed to mitigate or avoid significant environmental effects. A public agency may delegate reporting or monitoring responsibilities to another publi c agency or to a private entity which accepts the delegation; however, until mitigation measures have been completed the lead agency remains responsible for ensuring that implementation of the mitigation measures occurs in accordance with the program.”
VMT mitigations may not necessarily be physical improvements. Such improvements are complex in nature and will significan
tly depend on changes in traveler behavior. Therefore, it will be important that lead agencies develop an appropriate monitoring program to ensure the implementation of these mitigation measures throughout the life of a project, in compliance with CEQA. The lead agency must also coordinate with other responsible agencies as part of the mitigation monitoring program to evaluate
the ongoing feasibility and durability of the mitigations.
Historically, mitigation measures for LOS‐based transportation impacts have addressed either trip generation reductions or traffic‐flow‐capacity enhancements. LOS mitigation measures typically ATTACHMENT 2--Page 49
38 include physical infrastructure improvements adding capacity to intersections, roadways, ramps, and freeways. However, transportation demand management activities, active transportation amenities, and other measures designed to reduce the number of new single‐occupancy vehicle trips are also potential LOS mitigation strategies.
VMT mitigation measures are significantly different. Most VMT mitigations may seem feasible from a theoretical perspe
ctive, but practical implementation of these strategies as formal CEQA mitigation measures in perpetuity is yet to be tested. Several of these mitigations are contextual and behavioral in nature. Their success will depend on the size and location of the project as well as expected changes in travel behavior. For example, a project providing a bike share program does not necessarily guarantee a travel mode change among the project’s affected population; the level of improvement may be uncertain and subject to the travel preferences and attitudes of the population affected.
LOS mitigations (such as addition of turn lanes) focus more on rectifying a physical CEQA impact (strategy “c” of State CEQA Guidelines Section
15370). On the contrary, the majority of VMT
mitigations (such as commute trip‐reduction programs) aim at reducing or eliminating an impact over time through preservation and monitoring over the life of the project (strategy “d” of Stat e CEQA Guidelines Section 15370). Additionally, some VMT mitigations (such as those focused on land use/ location‐based policies) aim at minimizing impacts by reducing the number of trips generated by the projects (strategy “b” of State CEQA Guidelines Section 15370).
Furthermore, it may be determined that some VMT impacts are not able to be feasibly mitigated at the project level. Most VMT impacts occur within the context of a regional scale of analysis. The incremental change in VMT associated with a project in its particular locational setting might indicate a greater VMT deficit than individual mitigation strategies can offset. Only a regional solution (e.g., comple
tion of a transit system, purchase of more transit buses, or gap closure of a bicycle lane network) may offer the incremental change necessary to reduce the VMT impact to an appropriate level of significance. Also, VMT, as a proxy for GHG emissions, may not require locational s pecificity.
A project does not necessarily need to diminish the VMT at the project site to provide regional or statewide VMT and GHG reduction benefits. Offsets in an area where the benefit would be greater will have a more effective reduction in VMT and GHG and contribute to achievement of regional and statewide clim
ate goals. This regional perspective provides the basis for cap‐and‐trade style VMT mitigation strategies.
The issues of regional scale, appropriate and timely fair share contributions from projects and/or local jurisdictions (partial versus comprehensive participation), and geographic ambiguity confound the certainty of the lead agency’s identification of an effective VMT mitiga tion strategy. Section 15126.4 of the State CEQA Guidelines states, “Where several measures are available to mitigate an impact, each should be discussed and the basis for selecting a particular measure should be identified.
Formulation of mitigation measures shall no t be deferred until some future time.” [Emphasis added.] Regional VMT mitigation is considered the most effective method for large‐scale VMT reduction, as cost and i
mplementation barriers are often greater than one project may feasibly accommodate. However, regionally scaled VMT mitigation strategies may be provided in the form of mitigation banks, fees, and/or exchanges, with individual projects subject to contribute to these programs consistent with applicable provisions to ensu re compliance and consistency with CEQA and other legal requirements.
ATTACHMENT 2--Page 50
39 Section 21099 (b) (4) of the PRC states, “This subdivision [requiring a new transportation metric under CEQA] does not preclude the application of local general plan policies, zoning codes, conditions of approval, thresholds, or any other planning requirements pursuant to the police power or any other authority.” Hence, although automobile delay will no longer be considered a significant impa ct under CEQA, the lead agency may still require projects to meet the LOS standards designated in its zoning code or general plan. Therefore, a project may still be required to propose LOS improvements for congestion relief in addition to the implementation of any VMT mitigation strategies as required by CEQA.
7.2 MITIGATION MEASURES AND PROJECT ALTERNATIVES
7.2.1 Land Development Projects and Community/General Plans Mitigations and project alternatives for VMT impacts
have been suggested by the OPR. VMT mitigations can
be extremely diverse and can be classified under several categories such as land use/location, road pricing, transit improvements, commute trip reduction
strategies, and parking pricing/policy. However, the issue with VMT mitigations is the quantitative
measurement of the relief provided by the strategies.
How much VMT reduction does a transportation
demand management pr
ogram, a bike share program, a transit route, or one mile of sidewalk provide? Improvements related to VMT reduction strategies have been quantified in sources such as the California Air Pollution Control Officers Association (CAPCOA) report Handbook for Analyzing Greenhouse Gas Emission Reductions, Assessing Climate Vulnerabilities, and Advancing Health and Equity (CAPCOA Manual) Final Draft, December 2021, and by various resources provided by CARB.
This information is generally presented with a wide range of potential VMT reduction percentages.
Table F provides a summary of various VMT mitigation measures and projec t alternatives presented in the CAPCOA Manual (only those strategies directly attributed to transportation) for development projects. For any VMT mitigation measure, the project applicant will be required to provide substantial evidence while identifying a project‐specific value. If that information is not available, the project should apply the low point of provided ranges for VMT reduction. Where a mitigation strategy doe s not have an identified VMT reduction range, the project applicant would be required to provide a reduction estimate supported by evidence.
As for land use plans, the OPR TA does not specifically identify any VMT mitigations. The potentia l VMT mitigation measures for community/general plans are similar to those available for development projects, with certain modifications. Therefore, the mitigation measures provided in Table F can be used as appropriate. Additional measures may also be applied with substantial evidence.
It must be noted that Table F provides only a summary of the VMT mitigations provid ed in the sources indicated above. The reader should refer to the original source for further details and for subsequent updates to the mitigation measures. Also, Table F does not provide an exhaustive list of VMT
Transit in Merced
Source: https://www.mcagov.org/140/Transit‐Joint‐Powers ATTACHMENT 2--Page 51
40 mitigation measures for offsetting CEQA transportation impacts. Other measures may also be accepted by the lead agency based on the provision of substantial evidence.
As additional mitigation measures are evaluated to offset VMT impacts in the future for the State CEQA Guidelines process, linkages between a specific strategy and its quantified incremental VMT reduction effect mu
st be established. This process may be based on the observations and measurements provided by other sources or by the lead agency’s experience in these practices. The key to effective VMT mitigation is to base its efficacy on real and substantial evidence.
7.2.2 Transportation Projects
Although OPR provides detailed guidance on the assessment of induced‐growth impacts associated with transportation improvement projects, it leaves the subject of specific VMT mitigation measures ambiguous. Only four strategies are recommended as potential mitigation options:
Tolling new travel lanes to encourage carpools and fund transit improvements; Converting existing general‐purpose lanes to HOV or HOT lanes; Implementing or funding off‐site transportation demand management programs; and Implementing Intelligent Transportation Systems strategies to improve passenger throughput on existing lanes.
No quantified reduction percentage is allocated to these strategies and currently available data do not offer any substantial evidence that may provide guidance on levels of significance after implementation of these strategies. Review of the four recommended mitigation strategies suggests that OPR is directing strategies aw
ay from general‐purpose mixed‐flow lanes on expressways, freeways, and arterial highways. Additionally, the project description and Purpose and Need may conflict since congestion relief measures will conflict with VMT reduction strategies. The lead agency would be subject to an SOC for the capital project VMT impact.
7.3 FUNDING MECHANISMS
The change in methodology used for the assessment of CEQA transportation impacts from LOS to VMT will lead to a shift in and the scale of mitigation efforts from local and project‐specific, to a more regional approach. OPR acknowledges the regional nature of VMT impacts and states that regional VMT reduction programs and fee programs (in‐ lieu fees and development impact fees) may be appropriate forms of mitigation. Fee programs are particularly useful to address cumulative impacts.
It is very important for the lead agency to coordinate with MCAG to develop such mitigation programs that may be used to fund new transit service or develop applic able active transportation plans or other regionally scaled VMT mitigation activities. These programs are regional in nature and best suited for administration by a regional agency. Projects may be able to pay into the fee program to offset project VMT impact. Regional agencies may also wish to coordinate with appropriate stakeholders, includi
ng participating local jurisdictions, developers, and other interests while conducting nexus studies and checking for rough proportionality and compliance with CEQA.
Most of the VMT mitigations included in Table F are applicable in urban areas. They are less effective in suburban and rural contexts, where traditional transpor tation demand management strategies are less ATTACHMENT 2--Page 52
41 feasible. Thus, site‐specific strategies are more suitable in more densely urbanized areas, whereas program‐level strategies may be more appropriate for some projects located in suburban or rural areas.
In the latter approach, the cumulative VMT mitigation contributions provided in support of individual developments may be used to fund regional VMT reduction strategies that wo uld not be feasible or cost‐effective at the individual project scale. Apart from fee programs, program‐based mitigation strategies may include VMT mitigation exchanges and/or VMT mitigation banks. The VMT mitigation exchange concept requires a developer to select and implement mitigation project(s) from a predetermined list of projects that wo uld serve to reduce the excess new VMT generated by the proposed project. On the other hand, a mitigation banking program would assign monetary values for VMT reductions that would allow developers to purchase the applicable number of VMT reduction credits. These credits would be used to fund larger, regiona lly scaled VMT mitigation projects throughout the affected region.
As previously discussed, VMT impacts are regional in scope. Hence, there may at times be mitigation requirements that extend beyond the control of the lead agency, and without the ability of the lead agency to manage these mitigations, the impacts might remain significant and unaddressed .
Additionally, the identification and management of regionally scaled improvements where developers contribute their fair share to mitigate impacts might prove to be difficult. Therefore, the lead agency may choose to work collaboratively with other jurisdictions within the region to ultimately establish VMT mitigation fee programs, mitigation banks, or exchanges to establish a regional mitigation pathway where developers contribu
te to a regionally administered VMT mitigation funding pool in a manner commensurate to the impact of their individual project. Procedural flow charts for VMT mitigation banks, exchanges, and impact fees are illustrated in Figures 12, 13, and 14, respectively.
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42 Figure 12: Procedural Flow Chart – VMT Bank
Source: VMT Mitigation Through Banks and Exchanges: Understanding New Mitigation Approaches. A White Paper by Fehr & Peers (January 2020).
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43 Figure 13: Procedural Flow Chart – VMT Exchange
Source: VMT Mitigation Through Banks and Exchanges: Understanding New Mitigation Approaches. A White Paper by Fehr & Peers (January 2020).
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44 Figure 14: Procedural Flow Chart – VMT Impact Fee
Source: Understanding New Mitigation Approaches. A White Paper by Fehr & Peers (January 2020).
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56 APPENDIX A:
MCAG TRAVEL DEMAND MODELING SUPPORT SERVICES ‐ SB 743
COORDINATION
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Memorandum
Date: October 21, 2022
To: Natalia Austin, MCAG
From: Mike Wallace, Fehr & Peers
CC: Elizabeth Forte and Blake Dunford, MCAG
Ambarish Mukherjee and Ravi Palakurthy, LSA
Subject: MCAG Travel Demand Modeling Support Services (20220727NA) Task Order 1 – SB 743 Coordination
LA22-3394
This memo summarizes the review performed by Fehr & Peers of the existing travel behavior data and travel model outputs, SB 743 summary data provided by LSA, and recommendations on use of the model for SB 743 application. The review focused on the internalization for Los Banos, the VMT per service population compared to the VMT per person and VMT per employee, and trip distances for trips beyond the model boundary.
Highlights
• Location based services (LBS) data summarized from the StreetLight Data InSight platform were obtained to represent the observed travel patterns in 2019 and 2022. • Los Banos internal capture in the model (72% in the base year and 76% in the futur e years) is consistent with the observed data from StreetLight Data (73% in 2019 and 63% in 2022).
• Based on the model and observed data, no changes to the model for Los Banos are recommended.
• Based on the data available, the travel model representation of external travel, and the project schedule, it is recommended that the CHTS data currently being used for external travel continue to be used for this round of target setting. Updates to the model and the data are recommended for the future.
• With the model land use inputs being used in the SB 743 VMT screening, the VMT per service population does not fully reflect the people generating activity and is not recommended for screening. This is especially true for land uses such as hospitals and hotels where visitor population is not in the service population but they generate a ATTACHMENT 2--Page 69
substantial amount of the vehicle travel. Instead, it is recommended that unique uses perform analysis outside of the travel demand model screening framework.
Observed Travel Behavior Details
This section summarizes the travel model and observed data for daily vehicle trips associated with Los Banos. For consistency with the travel model, daily weekday vehicle trips with at least one trip end within Los Banos were obtained from StreetLight Data InSight platform and were summarized at the Census Block Group (CBG) level for 2019 and 2022 to minimize the impact of COVID -19 on travel. The CBG data outside of Los Banos were aggregated to city and county level, with the focus being on trips within Los Banos, within Merced County excluding Los Banos, and trip outside of Merced County. The travel model data for daily vehicle trips were summarized at the same level of geography.
As shown in Table 1, the trips within Los Banos range between 72% and 76% for the model scenarios and 73% and 63% for the StreetLight Data.
Table 1: Summary of Daily Vehicle Travel for Los Banos Trips between Los
Banos
Model Observed Data
2015 2020 2035 2046 2019 2022
Los Banos 72% 76% 76% 76% 73% 63%
Merced County 17% 19% 19% 20% 18% 26%
Outside Merced County 10% 5% 5% 5% 9% 11%
External Travel
Currently the model calculates the travel external to the county by trip purpose and aggregates the trips for traffic assignment. Similarly, the average travel distance at the gateways that reflects travel beyond the county is an estimated total distance for all trips with one trip within the county.
To reflect the total distance of travel by purpose for use in SB 743 target setting, screening, and project evaluation, LSA is using the California Household Travel Survey (CHTS). Given the model functionality and other data sources being updated next year, this method will be documented and revised in the future as needed.
VMT per Service Population
The model trip generation and travel activity is based on residential units and non -residential area, with a factor that calculates the persons per household and employees per area based on ATTACHMENT 2--Page 70
the MCAG land use allocations used in the RTP/SCS. The exception to this is for schools which are based on total student enrollment and students are used to estimate employees. This does not cause issues when calculating home-based VMT per household population or home-work VMT per employee since the trips generated are related to the population. For special land use types such as hotels or like hospitals, the trips generated are based on both employees and patients/visitors, while the area is used to calculate only employees. As such, the VMT per service population for special uses may be much higher than other uses due to the exclusion of persons generating activity not included in the service population estimate. It is recommended that rather than using VMT per Service Population as a screening criterion, special uses not be screened out of analysis and instead perform analysis to reflect the characteristics of the land use development.
Next Steps
The model will be updated in 2023 to reflect travel behavior, household travel surveys, and land use changes. Fehr & Peers will coordinate with MCAG staff to determine how the interregional travel is reflected, particularly in the trips exiting the model area. Separating trucks from passenger trips, including interregional transit, and other enhancements to the model may also be considered.
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