Memorandum
Date: April 20, 2026
To: Ms. Melanie Griswold, Trace Estates, LLC
From: Gary Black, AICP
Daniel Choi
Miles Henninger
Subject: VMT Screening Analysis and Design Review for a Residential Development at 4103 Old Trace Road in Palo Alto, California
Hexagon Transportation Consultants, Inc. has completed Vehicle Miles Traveled (VMT) screening analysis and a traffic design analysis for the proposed residential development located at 4103 Old Trace Road in Palo Alto, California. The project site location is shown on Figure 1. The project site plan is shown on Figure 2. The project proposes to construct 9 single-family homes (5 detached and 4 attached) on a vacant lot. Seven of the single-family homes would contain a junior accessory dwelling unit (JADU).
Project Trip Generation
Through empirical research, data have been collected that indicate the amount of traffic that can be expected to be generated by common land uses. Project trip generation was estimated by applying to the size and uses of the development the appropriate trip generation rates. The average trip generation rates for Single-Family Detached Housing (Land Use 210), Single-Family Attached Housing (Land Use 215), and Multifamily Housing (Low-Rise) (Land Use 220) as published in the Institute of Transportation Engineers (ITE) Trip Generation Manual, 12th Edition (2025) were applied to the proposed project. The JADUs are not expected to generate any trips on their own.
They are part of the main house and are typically used by family members or guests instead of long-term tenants.
Table 1
Trip Generation
Land Use Rate Trips Rate In Out Total Rate In Out Total Proposed Project
#210 - Single-Family Detached Housing 5 Dwelling Units 9.09 45 0.70 1 3 4 0.93 3 2 5 #215 - Single-Family Attached Housing 4 Dwelling Units 6.57 26 0.47 1 1 2 0.51 1 1 2 Total Project Trips 71 2 4 6 4 3 7
Source: ITE Trip Generation Manual (12th Edition, 2025) Trip generation rate for the proposed residential uses are based on average rates found in the ITE's Trip Generation Manual, 12th Edition rates for Land Use 210 "Single-Family Detatched Housing - General Urban/Suburban" and for Land Use 215 "Single-Family Attached Housing - General Urban/Suburban".
PM Peak HourAM Peak Hour
Size
Trips TripsDaily
Palo
Alto
Arastradero RdArastradero Rd
Foothill ExpyFoothill Expy
Miranda AveMiranda Ave
Foothill ExpyFoothill Expy
Miranda AveMiranda Ave
Hillview AveHillview Ave
Old Trace RdOld Trace Rd
Old Adobe RdOld Adobe Rd
Arastradero Rd
Foothill Expy
Miranda Ave
Foothill Expy
Miranda Ave
Hillview Ave
Old Trace Rd
Old Adobe Rd
= Site Location
LEGEND4
103 Old Trace Road VMT Screening and Design Review
Figure 1
Site Location
4 103 Old Trace Road VMT Screening and Design Review
Figure 2
Project Site Plan
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Based on the trip generation rates, it is estimated that the project would generate 71 daily trips, with 6 trips in the AM peak hour and 7 trips in the PM peak hour. The City’s Local Transportation Analysis (LTA) Policy requires an LTA for projects that generate more than 50 peak hour trips.
Since the project would generate fewer than 50 peak-hour trips, an LTA analysis is not required.
Vehicles Miles Traveled
The City of Palo Alto provides screening criteria to determine whether a development project would be required to conduct a VMT analysis. Projects that meet the screening criteria would be presumed to have a less than significant impact on VMT and would not be required to conduct a detailed VMT analysis. The city has the following screening criteria for development projects:
• Small Developments (projects that generate fewer than 110 trips per day) • Projects in Low-VMT Areas (projects located in low-VMT areas that have similar features to existing developments)
• Projects in Proximity to Major Transit Stops (projects located within ½ mile of an existing or planned high quality transit corridor or major transit stop) • Affordable Housing (100% affordable housing projects in infill locations) • Local-Serving Retail (retail projects of 10,000 s.f. or less) • Transportation Projects (roadway, transit, bicycle, and pedestrian projects that do not lead to a measurable increase in vehicle travel)
Since the project is anticipated to generate 71 daily trips, the project would meet the small development screening criterion and can be presumed to have a less than significant impact on VMT.
Palo Alto Comprehensive Plan and Housing Element Update The project site is included in the City’s 2030 Comprehensive Plan. The 2030 Comprehensive Plan included 13 additional housing units within the project’s zone. The City adopted their new Housing Element in May 2023, for which an environmental impact report (EIR) was prepared. The Housing Element was approved as an addendum to the Comprehensive Plan. Therefore, projects that are consistent with the Comprehensive Plan are presumed to have their transportation impacts included in the analysis conducted for the Housing Element Update.
The proposed project’s 9 single-family residences is within number of units included in the Comprehensive Plan and would not change the conclusions of the findings of the EIR prepared for the Housing Element Update.
Roadway Width Analysis
The development’s 9 lots would be served by a private roadway with a 30.5-foot-wide right-of-way and a 20-foot curb-to-curb width. No parking would be allowed along the entire length of the roadway. Section 21.20.240 of the Palo Alto Municipal Code requires a minimum right-of-way width of 32 feet for private roadways serving five or more lots, or a minimum of 22 feet for private roadways serving fewer than five lots.
Appendix D of the California Fire Code stipulates that fire apparatus access roads must be a minimum of 20 feet wide. Fire apparatus turning templates (shown in Figure 3) indicate that fire trucks could adequately navigate the proposed roadway. As such, the proposed road would not pose issues for fire truck access. Furthermore, the 2018 edition of the American Association of 4103 Old Trace Road VMT Screening and Design Review April 20, 2026 P a g e | 5
State Highway and Transportation Officials’ A Policy on Geometric Design of Highways and Streets stipulates that the minimum lane width for residential streets in developed areas should be 9-10 feet. Due to the small scale of the development and associated low traffic volume, the 20-foot width of the roadway would be suitable for vehicular circulation throughout the site.
Figure 3
Fire Apparatus Turning Templates
4 103 Old Trace Road VMT Screening and Design Review