TO: Mayor and City Council
FROM: Philippe Eskandar, City Manager
BY: Amber Shah, Parks & Public Works Director
DATE: June 12, 2024
SUBJECT: APPROVAL OF RESOLUTION NO. R-24-21, ADOPTING
UPDATED VEHICLES MILES TRAVELED (VMT)
THRESHOLDS AND FINDING THE ACTION EXEMPT FROM
THE CALIFORNIA ENVIRONMENTAL QUALITY ACT (CEQA)
STRATEGIC PLAN CRITICAL SUCCESS FACTORS
Efficient, Responsive, and Effective City Services
BACKGROUND
At its July 8, 2020, meeting, the City Council, with guidance provided by the San Gabriel Valley Council of Governments (SGVCOG), adopted Resolution R20-18 new California Environmental Quality Act (CEQA) thresholds of significance for transportation impacts due to changes in State law pursuant to Senate Bill 743 (SB 743). The City is one of 26 SGVCOG member cities that opted into the SGVCOG SB 743 Implementation process to share the cost of a contract with Fehr & Peers to perform the requisite land use and transportation modeling, and prepare project thresholds, evaluation criteria and toolboxes. These changes modified how the City evaluates projects for transportation impacts for the purposes of CEQA. Specifically, the City is required to use Vehicle Miles Traveled (VMT) instead of Level of Service (LOS) as the metric to evaluate transportation impacts in CEQA documents.
The current SGVCOG VMT Evaluation Tool is based on VMT outputs from the 2016 Southern California Association of Governments (SCAG) Regional Transportation Plan/Sustainable Communities Strategy (RTP/SCS) trip-based model (TBM) and needs to be updated to be consistent with the 2020 RTP/SCS activity-based model (ABM). As with every RTP update, the regional travel Steven W. Huang, DDS, Mayor
Gretchen Shepherd Romey, Vice Mayor
Tony Chou, Council Member
Calvin Lo, Council Member
Steve Talt, Council Member
demand model is updated to reflect the latest population, employment, and traffic count information (socioeconomic data). In 2023, the City once again opted to join with SGVCOG member cities to share the cost for this required update.
The SGVCOG participating cities were aware that the model would be changing from TBM to ABM after the regulatory deadline of July 1, 2020 for implementing SB 743, and had anticipated that the change may prompt them to change the adopted baseline for their VMT significance thresholds. However, the cities did not anticipate that the updated data would result in more significant changes to low VMT areas than the conversion to an activity-based model. The recommendation herein recognizes the following:
1) every four years the SCAG RTP/SCS will be updated prompting an update to the regional travel demand model, 2) the City’s low VMT areas are based on the SCAG model, 3) low VMT areas under each of the three geographic baselines are likely to change when the SCAG model is updated, and 4) the City intends to use the baselines that maximize the number of “low VMT” screening areas and to set the most achievable bar for reaching a given threshold.
This report describes the changes in VMT, more specifically, the change in the number of low VMT areas that meet the low VMT screening criterion, discusses the SGVCOG recommendations, and includes a draft Resolution to adopt CEQA transportation thresholds that comply with State guidance and align with the City’s policies, goals, and objectives.
DISCUSSION
The SCAG 2016 RTP/SCS is based on traffic counts collected in 2012, the 2012 roadway network, 2012 transit network and ridership information, land use information, and other socio-economic inputs. The 2020 RTP/SCS is based on the same datapoints collected in 2016. This is the first update to the RTP since the SGVCOG participating cities adopted VMT thresholds of significance. The changes in the underlying data significantly altered the low, moderate, and high VMT-generating areas throughout the SGVCOG region for each of the three baseline alternatives (City, Northwest Subarea, and SGVCOG Region).
In some cities under their adopted baseline, an area considered a low VMT area using the 2016 RTP model became a high VMT area using the 2020 RTP model. And under different baselines, the reverse occurred. This is important because the selection of baselines for determining VMT significance may impact a city’s ability to approve projects. For example, if a developer selected a location for a housing project based on the city’s low VMT areas for residential uses and compatibility with the city’s general plan but before they had submitted the development application the SCAG model was updated and the area became a high VMT area for housing, then the project would likely require the City to certify an environmental impact report (EIR) and adopt a statement of overriding considerations to move forward. Not only would this scenario delay project approval by up to two years, but it would delay construction of housing in an area designated for housing and result in higher priced housing units.
The City of San Marino is located in the Northwest Subarea of the SGVCOG region. According to the City of San Marino Transportation Study Guidelines for Vehicle Miles Traveled and Level of Service Assessment (September 2020), the City adopted the SGVCOG baseline VMT as the benchmark to determine CEQA transportation impacts for all project types (residential, employment, and mixed-use/regional retail). Under the 2016 SCAG RTP/SCS model, the SGVCOG baseline represented the most stringent VMT baseline only for the employment metric. This baseline was adopted for all three VMT metrics:
home-based, work-based, and total miles traveled per total residents and employees.
Pursuant to the Governor’s Office of Planning and Research (OPR) Guidance, cities can adopt different baselines based on project types but states that employment based VMT thresholds should use subregional or regional baselines, which for San Marino would be the SGVCOG or Northwest Subarea.
Under the currently available 2020 RTP/SCS, SGVCOG is no longer the most stringent VMT baseline for any of the three VMT metrics. The changes in low VMT areas between the 2016 and 2020 RTP/SCS models was not foreseen or anticipated, and similar changes could occur every four years when SCAG updates the RTP/SCS. For this reason, the City has two options to consider:
1) continue to utilize the SGVCOG baseline for all metrics, or 2) adopt a resolution setting the thresholds of significance for VMT impacts as the lowest available baseline in favor of being the most stringent. The SGVCOG VMT Tool will be updated every four years to reflect either option selected.
For comparison, the table below reflects the VMT baselines for both 2016 and 2020 RTP/SCS models.
For this update, if option 2 is selected, the lowest threshold available for the three metrics are as follows:
1. Employment generated VMT (VMT/employee): Northwest Subarea as the threshold
2. Residential generated VMT (VMT/capita): City as the threshold
3. Total citywide VMT (VMT/(capita+employee): City as the threshold Adopting this change will allow the City to approve projects that align with the City’s policies goals and objectives, are consistent with the City’s General Plan, and meet CEQA requirements.
There will be little impact to the processing of developments in San Marino as a result of adopting these new thresholds. San Marino is almost entirely built out, and the City primarily receives applications for single family home remodeling/renovation projects, which are consistent with the General Plan and will comply with the new thresholds.
FISCAL IMPACT & PROCUREMENT REVIEW
The adoption of new local CEQA thresholds of significance for transportation impacts and adoption of new Local Transportation Assessment Guidelines will not have a fiscal impact. 26 cities joined the San Gabriel Valley Council of Government to share the total cost of the update to the SGVCOG VMT Assessment Tool and continue regular maintenance of the Tool for a period of 5 years. The one time shared cost for the entirety of the 5-year contract was $14,000 per City, which was significantly less than if the City hired its own consultant. There were sufficient funds in the Department’s FY 23-24 budget for Contract Engineering for this expense therefore, no additional budget appropriation was necessary.
LEGAL REVIEW
This Resolution has been assessed in accordance with the authority and criteria contained in the California Environmental Quality Act (CEQA), the State CEQA Guidelines, and the environmental regulations of the City. The adoption of new local CEQA thresholds of significance for transportation impacts and the adoption of new Local Transportation Assessment Guidelines will not have a significant environmental impact and are exempt from the CEQA pursuant to Section 15308 of Title 14 of the California Code of Regulations because the two actions are undertaken by the City for the protection of the environment. The revised CEQA thresholds will be compliant with a State mandate (SB 743) and will be used in a regulatory process (CEQA process) that involves procedures for the protection of the environment. Accordingly, the City Council will consider the recommendation to find the Resolution exempt from the environmental review requirements of CEQA pursuant to Section 15308 of Title 14 of the California Code of Regulations.
RECOMMENDATION
Staff recommends the City Council approve Resolution No. R-24-21, adopting the proposed thresholds of significance and finding the action exempt from the California Environmental Quality Act (CEQA).
“I move to approve Resolution No. R-24-21 updating the VMT thresholds of significance, and find the action exempt from the California Environmental Quality Act (CEQA).
ATTACHMENTS
1. Draft Resolution No. R-24-21