Appendix H
Vehicle Miles Traveled Analysis Memorandum
kimley-horn.com 660 S. Figueroa Street, Suite 2050, Los Angeles, CA 90017 213-261-4040
MEMORANDUM
To: Steve Quintanilla, Moreno Valley City Attorney
CC: Angelica Frausto-Lupo, City of Moreno Valley Community Development Director From: Mehul Champaneri, PTP, RSP
Rachel Krusenoski
Kimley-Horn and Associates, Inc.
Date: September 2, 2026
Subject: Vehicle Miles Traveled Analysis Memorandum
Public Safety Campus Project
This memorandum documents Senate Bill (SB) 743-compliant analysis completed as part of the Community Plan Exemption Checklist (Checklist) for the Public Safety Campus Project (Project), prepared pursuant to California Environmental Quality Act (CEQA) Guidelines Section 15183. The Checklist evaluates whether the potential environmental impacts of the Project are addressed in the 2024 Revised Final Program Environmental Impact Report (RFEIR) for the City of Moreno Valley 2040 General Plan Update (GPU), Municipal Code and Zoning Amendments, and Climate Action Plan (“MoVal 2040 Project”) (State Clearinghouse [SCH] No. 2020039022).
With the passage of SB 743, Vehicle Miles Traveled (VMT) has become an important indicator for determining whether new development would result in a “significant transportation impact” under CEQA. This memorandum summarizes the VMT analysis and findings for the proposed land use development as part of the Project.
BACKGROUND
The MoVal 2040 General Plan Update (MoVal 2040 GPU) was adopted, and the 2024 RFEIR was certified by the City of Moreno Valley (City) in 2026. The MoVal 2040 GPU serves as the guide for the future growth and development of the City through 2040, including implementation of five new General Plan land use designations: Business-Flex, Corridor Mixed Use, Center Mixed Use, Downtown Center, and Highway Office/Commercial.
Public Services
The 2024 RFEIR reported that buildout of the MoVal 2040 Project would generate approximately 43,882 new residents within the Planning Area by 2040, which would necessitate construction of additional fire stations and police facilities. The 2024 RFEIR notes that the Moreno Valley Fire Department (MVFD) has identified potential locations for new or expanded fire stations in the MVFD Strategic Plan. Similarly, for police services, the 2024 RFEIR also notes that the City is planning an expansion of the Civic Center complex that would include a remodeled Public Safety Building capable Kimley»Horn
kimley-horn.com 660 S. Figueroa Street, Suite 2050, Los Angeles, CA 90017 213-261-4040 of accommodating roughly 600 total personnel, as well as a satellite police substation in the southeastern part of the City to serve the anticipated demand from new development.
Vehicle Miles Traveled
The 2024 RFEIR evaluated VMT consistent with the City of Moreno Valley Traffic Impact Preparation Guide (June 2020) and was supported by the Vehicle Miles Traveled Assessment for the MoVal 2040 Revised Draft Program Environmental Impact Report (VMT Assessment), dated April 8, 2025, by Kimley-Horn and Associates, Inc. (Kimley-Horn). The VMT Assessment compared VMT generated by the Proposed General Plan (2040) to VMT generated by the Existing Baseline (2024) at a total and per capita level. Specifically, the VMT Assessment analyzed both Total VMT, which represents all VMT generated in the City, and VMT per Service Population, Resident, or Employee, which is an efficiency metric representing VMT generated on a typical day per person who lives and/or works in the City. VMT per person can be measured as VMT per Resident for residential-only projects, VMT per Employee for employment-only projects, and VMT per Service Population for projects and land use plans that include both residential and employment uses. Given the programmatic nature of the MoVal 2040 Project, VMT per Service Population is the most applicable metric to the implementation of a general plan. The VMT Assessment used three different methodologies to analyze VMT and established that any increase in the VMT per Service Population, Resident, or Employee compared to the Existing Baseline would be considered a significant impact.
The 2024 RFEIR determined that impacts would be significant and unavoidable because implementation of the MoVal 2040 GPU would exceed thresholds of significance related to VMT, resulting in an increase in total VMT and VMT per Service Population. As a result of some metrics that exceeded the significance criteria based on certain analysis methodologies, impacts would be significant. The MoVal 2040 GPU includes transportation demand management (TDM) goals, policies, and actions that would support VMT reductions; however, anticipated VMT reductions associated with proposed TDM measures would not be large enough to ensure that significant impacts could be fully mitigated. Therefore, projected VMT generated under buildout of the MoVal 2040 GPU would be inconsistent with CEQA Guidelines Section 15064.3, subdivision (b), and impacts would be significant and unavoidable.
PROJECT LOCATION & DESCRIPTION
Project Components
The Project comprises of three components: (1) development of a Public Safety Campus (PSC); (2) construction of a Corporate Yard Fueling Station (CYFS); and (3) tenant improvements at existing civic center facilities throughout the City. The Project also includes improvements to a drainage culvert and roadway improvements on nearby streets. These improvements would accommodate a range of civic uses identified in the City’s Capital Improvement Plan (CIP) and are intended to enhance emergency response capabilities, improve operational efficiency, and support the City’s growing public safety and municipal service needs. The Project would encompass approximately 60.37 acres at various locations throughout the City (Project Site).
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kimley-horn.com 660 S. Figueroa Street, Suite 2050, Los Angeles, CA 90017 213-261-4040 Public Safety Campus
The PSC would be located on City-owned vacant land located at the southwest corner of Redlands Boulevard and Brodiaea Avenue (PSC Site). The PSC Site is traversed by Redlands Boulevard and is bordered by Brodiaea Avenue and residential development to the north, Cactus Avenue and residential uses to the south, Wilmot Street, residential uses, and vacant land to the west. The PSC would be developed on 17 City-owned parcels (Assessor Parcel Numbers [APNs] 478-110-001, -002, -003, 004, 005, 006, -007; 478-120-001, -002, -005, -006, -007, -008, -017, -018, -025, and -027), encompassing approximately 56.8 acres. Of those parcels, 43.2 acres are located west of Redlands Boulevard and
13.6 are located east of Redlands Boulevard.
The PSC would establish a centralized public safety hub, consisting of a new joint-use fire and police station, Emergency Operations Center (EOC), and a regional animal shelter. The PSC would improve interdepartmental coordination, increase operational efficiency, strengthen emergency preparedness, and provide enhanced public safety services for the City and surrounding region.
Corporate Yard Fueling Station
The CYFS would be constructed on the northern portion of the City’s existing Corporate Yard (APNs 478-170-018, -019, -020, -026, -028, -029, -030, -031, and -032) at 25180 Santiago Drive (CYFS Station Site). The CYFS would be approximately 0.22 acres of the City’s Corporate Yard. Access to the CYFS is provided via two driveways off Santiago Drive.
The CYFS would consist of a new aboveground fueling facility that would support the City’s growing municipal fleet demands and ensure reliable emergency fueling capabilities for critical operations. It would include a 4,000-gallon UL 2085 aboveground unleaded gasoline storage tank equipped with four tank-mounted dispensing pumps and a 1,000-gallon UL 2085 aboveground diesel storage tank equipped with two tank-mounted dispensing pumps.
Civic Center Tenant Improvements
The Project would include upgrades to the following existing civic center uses, totaling approximately
3.35 acres and consisting of retrofits to existing infrastructure and buildings. Specifically, these tenant improvements would be implemented at the following locations:
Fire Station Nos. 2, 6, 48, 58, 65, 91, and 99, located throughout the City (APNs: 481-322-044, 291-650-017, 260-460-009, 488-330-001, 485-042-029, 308-030-018, and 487-370-018), would be renovated and expanded to accommodate increased staffing, improve emergency response operations, and address deferred maintenance needs. Improvements include new living quarters, expanded operational space, modernized interiors and kitchens, upgraded equipment and furnishings, and enhanced vehicle exhaust extraction systems to improve firefighter safety and station functionality;
The Moreno Valley Animal Shelter, located at 14041 Elsworth Street (APNs: 297-210-009 and 297-210-010) would be upgraded to improve disaster readiness, modernize animal care facilities, and accommodate both large and small livestock during emergencies. Improvements include new livestock housing and support infrastructure, enhanced site security, and a Kimley»Horn
kimley-horn.com 660 S. Figueroa Street, Suite 2050, Los Angeles, CA 90017 213-261-4040 redesigned shared entrance and veterinary service area to improve safety, functionality, and customer access.
The Public Safety Building, located at 22850 Calle San Juan De Los Lagos (APN: 297-14-020), and the Emergency Operation Center, located at 22870 Calle San Juan De Los Lagos (APN:
297-14-020), would be renovated to enhance working space efficiency and public services.
Trip Generation
The anticipated trip generation for the Project was estimated using standard rates published by the Institute of Transportation Engineers (ITE) in Trip Generation Manual, 12th Edition, 2025. The PSC and the CYFS components of the Project are anticipated to generate new vehicle trips during operation.
Table 1: Project Trip Generation Summary shows the estimated trip generation for daily trips as well as AM peak-hour and PM peak-hour by proposed use.
Table 1: Project Trip Generation Summary
Unit
Daily
Trips
AM Peak-hour PM Peak-Hour
Land Use/ Project
Component Quantity In Out Total In Out Total
Fire and Rescue Station
(PSC – Fire)1 50 KSF 240 - - - 7 17 24
Government Office Building
(PSC – Police) 90 KSF 2,033 225 75 300 39 115 154
Government Office Building
(PSC –EOC) 30 KSF 678 75 25 100 13 38 51
Animal Hospital/Veterinary
Clinic (PSC – Animal
Shelter)
65 KSF 1,398 159 78 237 92 138 230
Gasoline/Service Station
(CYFS) 4 Fueling Position 688 21 21 42 28 28 56
Total Project Trips 5,037 480 199 679 179 336 515
Source: ITE Manual, 12th Edition.
Notes:
KSF = thousand square feet
1 The daily trip rate for the Fire Station at the PSC was assumed to be ten times the PM peak house based on industry standard practices.
APPROACH
As set forth in California Public Resources Code (PRC) Section 21083.3 and CEQA Guidelines Section 15183, projects that are “consistent with the development density established by the existing zoning, community plan, or general plan policies for which an EIR was certified shall not require additional environmental review, except as might be necessary to examine whether there are project-specific significant effects which are peculiar to the project or its site” (CEQA Guidelines Section 15183(a) and PRC Section 21083.3(b)). The CEQA Guidelines further state that “[i]f an impact is not peculiar to the parcel or to the project, has been addressed as a significant effect in the prior EIR, or can be Kimley»Horn
kimley-horn.com 660 S. Figueroa Street, Suite 2050, Los Angeles, CA 90017 213-261-4040 substantially mitigated by the imposition of uniformly applied development policies or standards […] then an additional EIR need not be prepared for the project solely on the basis of that impact” (CEQA Guidelines Section 15183(c)).
Therefore, this analysis considers whether the potential VMT impacts of the Project are adequately addressed in the 2024 RFEIR by considering whether the Project would result in any new or more severe environmental impacts requiring additional environmental review. The analysis focuses on identifying project-specific effects, peculiar site conditions, changed circumstances, or new information that were not addressed in the prior environmental document.
Significance Criteria
Pursuant to CEQA Guidelines Section 15064.3 and the City of Moreno Valley Traffic Impact Preparation Guide, a transportation impact may be significant if a project would cause a substantial increase in VMT. Under CEQA Guidelines Section 15183, additional environmental review is not required unless the project would result in project-specific significant effects that are peculiar to the project or site, or impacts that are more severe than those analyzed in the 2024 RFEIR. Therefore, additional environmental review would be required if the Project would result in a significant transportation impact related to VMT beyond what was evaluated in the 2024 RFEIR.
IMPACT ANALYSIS
Project Consistency with the 2024 RFEIR
Consistency with Public Service Facilities Anticipated by the General Plan As previously discussed under Background, the 2024 RFEIR established that expansion of public services was anticipated to meet the population growth that would occur as a result of the MoVal 2040 Project. Specifically, it anticipated additional or expanded fire stations as well as the development of the public safety campus, which would be funded by development impact fees as the MoVal 2040 Project is built out. The Project consists of public service and municipal support facilities that implement these planned public infrastructure improvements.
The PSC would establish a centralized public safety hub consisting of police, fire, emergency operations, and animal shelter functions. The CYFS would support municipal fleet operations, while the tenant improvements would modernize and expand existing public facilities. These uses are governmental and public service functions that support growth anticipated under the MoVal 2040 GPU and contemplated by the MoVal 2040 Project rather than introducing new population- or employmentgenerating land uses beyond those evaluated in the 2024 RFEIR.
Consistency with the 2024 RFEIR Program-Level VMT Analysis The 2024 RFEIR evaluated VMT impacts associated with full buildout of the MoVal 2040 GPU, including population growth, employment growth, and the public infrastructure necessary to serve that growth.
The Project represents implementation of public facilities specifically contemplated by the General Plan and does not alter the land use assumptions, population forecasts, employment forecasts, or development intensity evaluated in the VMT Assessment. The Project would not induce additional growth beyond that already assumed under the MoVal 2040 GPU. Rather, the Project would provide Kimley»Horn
kimley-horn.com 660 S. Figueroa Street, Suite 2050, Los Angeles, CA 90017 213-261-4040 public safety and municipal services necessary to accommodate growth already analyzed in the 2024 RFEIR. Accordingly, operation of the Project would occur within the growth forecasts, service population assumptions, and transportation modeling framework used in the program-level VMT analysis.
Peculiar Effects
The Project would not result in a transportation impact peculiar to the site or Project. The PSC, CYFS, and civic center improvements would primarily accommodate existing and planned municipal operations. While employees, emergency responders, and visitors would travel to and from the Project sites, these trips are associated with public facilities anticipated as part of implementation of the MoVal 2040 GPU and do not represent a unique transportation condition that was not considered in the 2024 RFEIR. Emergency response trips generated by police and fire operations are inherent components of public safety services and do not constitute a new land use type or transportation characteristic that would create a peculiar VMT impact beyond those associated with planned municipal growth and service provision.
Changed Circumstances or New Information
No substantial changes have occurred with respect to the Project, the surrounding area, or applicable transportation regulations that would require new VMT analysis beyond that contained in the 2024 RFEIR. The Project remains consistent with the land use framework evaluated in the MoVal 2040 GPU, and no new information demonstrates that the Project would result in transportation impacts that are substantially more severe than those disclosed in the 2024 RFEIR.
Severity of Impact
The 2024 RFEIR concluded that buildout of the MoVal 2040 GPU would result in significant and unavoidable VMT impacts. As previously discussed, the Project would not increase the severity of that previously identified impact because the Project was anticipated as part of the public facility expansion necessary to serve forecasted growth. It does not increase residential or employment growth beyond that evaluated in the 2024 RFEIR or modify the land use assumptions used in the program-level VMT analysis. Therefore, the Project would not create a new significant VMT impact or substantially increase the severity of the significant and unavoidable VMT impact previously identified in the 2024 RFEIR.
CONCLUSION
The Project would not result in transportation impacts related to VMT that are peculiar to the Project or Project Site, nor would it result in impacts that are substantially more severe than those identified in the 2024 RFEIR. The Project implements public safety and municipal service facilities anticipated under the MoVal 2040 GPU and falls within the scope of the program-level VMT analysis previously evaluated. Accordingly, no new or more severe VMT impacts would occur.
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