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screening criteria are described in Table 1 along with a determination of Project eligibility.
TABLE 1: SCREENING FOR LAND USE POJECTS EXEMPT FROM VMT CALCULATIONS Screening Step Description Result
Step 1: Transit
Priority Area (TPA)
Projects located within a TPA (i.e., within a half mile of an existing major transit stop or an existing stop along a high -quality transit corridor) are presumed to have a less than significant impact on VMT.
Does not meet.
Step 2: Low VMT
Area
Projects located in a low VMT-generating area are presumed to have a less than significant impact on VMT. Does not meet.
Step 3: Project Type
Local-Serving Retail under 50,000 square feet, Local- Serving Essential Services such as parks and day care centers, affordable or supportive housing, senior housing, non-destination small hotels, and small project s generating less than 110 daily vehicle trips are presumed to have a less than significant VMT impact.
Does not meet.
Step 4: Mixed-Use
Projects
To identify if the proposed project requires a VMT analysis, the City of Riverside may evaluate each component of a mixed- use project independently and apply the significance threshold for each project type included (e.g. residential and retail).
Not Applicable.
Step 5:
Redevelopment
Projects
Where a project replaces existing VMT generating land uses, if the replacement leads to a net overall decrease in VMT, the project would lead to less than significant transportation impact. If the project leads to a net overall increase in VMT, then the thresholds described above should apply.
Not Applicable.
Consistent with City Guidelines, projects not eligible for screening are required to prepare a VMT analysis.
VMT ANALYSIS
TRAFFIC MODELING METHODOLOGY
City Guidelines identifies the Riverside County Transportation Model (RIVCOM) as the appropriate tool for conducting VMT analysis for land use projects in the City of Riverside. Western Riverside Council of Governments’ (WRCOG) most recent release of RIVCOM is version 4.0.1, released in January of 2024. RIVCOM is a travel forecasting model that represents a sub -area (Riverside County area) of the Southern California Association of Governments (SCAG) regional traffic model and was designed to provide a greater level of detail and sensitivity in the Riverside County area as compared to the regional SCAG model. RIVCOM is a useful tool to estimate VMT as it considers interaction bet ween different land uses based on socio -economic data such as population, households, and employment. The calculation of VMT for land use projects is based on the total number of trips generated and the average trip length of each vehicle type.
VMT ANALYSIS METHODOLOGY
For the purposes of this analysis, Project-generated VMT has been estimated using the Production/Attraction (PA) method. Consistent with City Guidelines, for residential projects, project-generated VMT is presented as PA Home-Based (HB) VMT per capita.
Louisa Feletto, MLC Holdings, Inc.
June 10, 2025
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PRODUCTION/ATTRACTION METHOD
The PA method for calculating VMT sums all weekday VMT generated by HB trips with at least one trip -end inside the study area (i.e., Project Traffic Analysis Zone or TAZ) by trip purpose to/from their ultimate destination unless that destination is outside of the model boundary area.
Productions are land use types that generate trips (residences), and attractions are land use types that attract trips (employment). The PA method allows Project VMT to be evaluated based on trip purpose, which is consistent with Governor’s Office of Planning and Research’s Technical Advisory on Evaluating Transportation Impacts in CEQA (December 2018).
VMT METRIC AND SIGNIFICANCE THRESHOLD
The City of Riverside has adopted the following thresholds of significance related to VMT for residential land use projects . It is our understanding that the City of Riverside is in process of updating their VMT guidance, of which the revised City threshold will be baseline VMT per capita A project would result in a significant project-generated VMT impact if the following condition is satisfied:
• Baseline or cumulative project-generated VMT per capita below the current jurisdictional baseline VMT per capita.
It is our understanding that the City of Riverside is in the process of updating their VMT guidance, of which the revised City threshold will be baseline VMT per capita. As such the following VMT analysis will evaluate the Project with the anticipated revi sed City thresholds. The City of Riverside’s current VMT per capita and impact threshold has been calculated using the RIVCOM model (see Table 2).
TABLE 2: BASELINE CITYWIDE VMT PER CAPITA
City of Riverside
Population 341,792
VMT 5,547,015
VMT per Capita (City Threshold) 16.2
PROJECT VMT ESTIMATES
To estimate project-generated VMT, land use information such as dwelling units must first be converted into a RIV COM-compatible dataset. The RIVCO M model utilizes socio -economic data (SED) (e.g., population) for the purposes of vehicle trip estimation . Project population estimates were obtained using housing density factors outlined in the C ity of Riverside’s General Plan as shown in Table 3.
Louisa Feletto, MLC Holdings, Inc.
June 10, 2025
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TABLE 3: PROJECT POPULATION ESTIMATE
Land Use Households Population Estimate Factor Population Residential 56 2.93 Person per Household1 164
1City of Riverside General Plan; Appendix H, Page 199
Project-generated VMT and a comparison to the City’s impact threshold is presented in Table 4.
TABLE 4: PROJECT VMT PER CAPITA
Baseline Cumulative
VMT 2,358 2,354
Population 164 164
VMT per Capita 14.4 14.4
City Threshold 16.2 16.2
Exceeds City Threshold? No No
As shown in Table 4, the Project would not exceed the City’s VMT per capita impact threshold for baseline and cumulative conditions.
CONCLUSION
Based on the results of this analysis, the following findings are made:
• The Project was evaluated against screening criteria as outlined in the C ity Guidelines and was not found to meet applicable screening criteria . A project -level VMT analysis was performed.
• The VMT analysis identifies that the Project would generate VMT per capita that would not result in potential transportation impacts.
If you have any questions, please contact me directly at [email protected].
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REFERENCES
1. City of Riverside Public Works Department. Draft Traffic Impact Analysis Guidelines for Vehicle Miles Traveled and Level of Service Assessment. City of Riverside : s.n., July 2020.
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ATTACHMENT A
PROJECT SITE PLAN
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EXHIBIT A-1-1: PROJECT SITE PLAN ALTERNATIVE 1
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EXHIBIT A-1-2: PROJECT SITE PLAN ALTERNATIVE 2