Agenda packet, first session — Watsonville City Council, March 14, 2023 (part 6 of 7)

307 Roemer Way, Suite 300, Santa Maria, CA 93454
TEL: (805) 922-4772
www.oecusa.com FAX: (805) 925-3376

Page 1053 of 1256 ends

Project:

Project Number:

Project Manager:

Reported:

Wade Allmon
1309 Morrison Ave. Watsonville
Wade Allmon
Santa Barbara County Litigation Project
Santa Barbara CA, 93103 02-Jun-10 17:03
Oilfield Environmental and Compliance, INC.

Analyte Result
Limit Reporting Prepared Analyzed Method Notes Units Dilution Batch DRAFT: Y1-C6
1001778-02 (Solid)
DRAFT: Wet Chemistry by EPA or APHA Standard Methods
pH 6.37 0.100 pH Units 1 A005394 22-May-10 22-May-10 9045 HoldX DRAFT: Total Metals by EPA 6000/7000 Series Methods
Antimony 4.8 ND mg/kg 5 A005439 31-May-10 01-Jun-10 EPA 6020 Arsenic 5.1 0.97 " " "" " "
Barium 72 0.48 " " "" " "
Beryllium 2.4 ND " " " "" "
Cadmium 0.97 ND " " " "" "
Chromium 41 0.97 " " "" " "
Cobalt 10 0.97 " " "" " "
Copper 35 0.97 " " "" " "
Lead 130 0.97 " " "" " " N-02, N-03
Mercury 0.31 0.098 " 1 A006002 01-Jun-10 01-Jun-10 EPA 7471A Molybdenum 0.97 ND " 5 A005439 31-May-10 01-Jun-10 EPA 6020 Nickel 40 0.97 " " "" " "
Selenium 4.8 ND " " " "" "
Silver 0.97 ND " " " "" "
Thallium 4.8 ND " " " "" "
Titanium 210 39 mg/L 20 " " 02-Jun-10 "
Vanadium 32 4.8 mg/kg 5 " " 01-Jun-10 "
Zinc 270 9.7 " 20 " " 02-Jun-10 "
DRAFT REPORT The results in this report apply to the samples analyzed in accordance with the chain of custody document. This analytical report must be reproduced in its entirety.

Page 4 of 24 ends

307 Roemer Way, Suite 300, Santa Maria, CA 93454
TEL: (805) 922-4772
www.oecusa.com FAX: (805) 925-3376

Page 1054 of 1256 ends

Project:

Project Number:

Project Manager:

Reported:

Wade Allmon
1309 Morrison Ave. Watsonville
Wade Allmon
Santa Barbara County Litigation Project
Santa Barbara CA, 93103 02-Jun-10 17:03
Oilfield Environmental and Compliance, INC.

Analyte Result
Limit Reporting Prepared Analyzed Method Notes Units Dilution Batch DRAFT: Y2-C2
1001778-03 (Solid)
DRAFT: Wet Chemistry by EPA or APHA Standard Methods
pH 8.57 0.100 pH Units 1 A005394 22-May-10 22-May-10 9045 HoldX DRAFT: Total Metals by EPA 6000/7000 Series Methods
Antimony 4.7 ND mg/kg 5 A005439 31-May-10 01-Jun-10 EPA 6020 Arsenic 4.1 0.94 " " "" " "
Barium 37 0.47 " " "" " "
Beryllium 2.3 ND " " " "" "
Cadmium 0.94 ND " " " "" "
Chromium 36 0.94 " " "" " "
Cobalt 8.5 0.94 " " "" " "
Copper 24 0.94 " " "" " "
Lead 270 3.8 " 20 " " 02-Jun-10 " N-02, N-03
Mercury 0.096 ND " 1 A006002 01-Jun-10 01-Jun-10 EPA 7471A Molybdenum 0.94 ND " 5 A005439 31-May-10 01-Jun-10 EPA 6020 Nickel 28 0.94 " " "" " "
Selenium 4.7 ND " " " "" "
Silver 0.94 ND " " " "" "
Thallium 4.7 ND " " " "" "
Titanium 290 38 mg/L 20 " " 02-Jun-10 "
Vanadium 34 4.7 mg/kg 5 " " 01-Jun-10 "
Zinc 190 9.4 " 20 " " 02-Jun-10 "
DRAFT REPORT The results in this report apply to the samples analyzed in accordance with the chain of custody document. This analytical report must be reproduced in its entirety.

Page 5 of 24 ends

307 Roemer Way, Suite 300, Santa Maria, CA 93454
TEL: (805) 922-4772
www.oecusa.com FAX: (805) 925-3376

Page 1055 of 1256 ends

Project:

Project Number:

Project Manager:

Reported:

Wade Allmon
1309 Morrison Ave. Watsonville
Wade Allmon
Santa Barbara County Litigation Project
Santa Barbara CA, 93103 02-Jun-10 17:03
Oilfield Environmental and Compliance, INC.

Analyte Result
Limit Reporting Prepared Analyzed Method Notes Units Dilution Batch DRAFT: Y2-D2
1001778-04 (Solid)
DRAFT: Wet Chemistry by EPA or APHA Standard Methods
pH 7.24 0.100 pH Units 1 A005394 22-May-10 22-May-10 9045 HoldX DRAFT: Total Metals by EPA 6000/7000 Series Methods
Antimony 4.8 ND mg/kg 5 A005439 31-May-10 01-Jun-10 EPA 6020 Arsenic 7.1 0.95 " " "" " "
Barium 49 0.48 " " "" " "
Beryllium 2.4 ND " " " "" "
Cadmium 1.5 0.95 " " "" " "
Chromium 48 0.95 " " "" " "
Cobalt 11 0.95 " " "" " "
Copper 46 0.95 " " " " 02-Jun-10 "
Lead 730 9.5 " 50 " " 01-Jun-10 " N-02, N-03
Mercury 0.10 0.098 " 1 A006002 01-Jun-10 01-Jun-10 EPA 7471A Molybdenum 0.95 ND " 5 A005439 31-May-10 01-Jun-10 EPA 6020 Nickel 38 0.95 " " "" " "
Selenium 4.8 ND " " " "" "
Silver 0.95 ND " " " "" "
Thallium 4.8 ND " " " "" "
Titanium 370 95 mg/L 50 " " 02-Jun-10 "
Vanadium 38 4.8 mg/kg 5 " " 01-Jun-10 "
Zinc 390 24 " 50 " " 02-Jun-10 "
DRAFT REPORT The results in this report apply to the samples analyzed in accordance with the chain of custody document. This analytical report must be reproduced in its entirety.

Page 6 of 24 ends

307 Roemer Way, Suite 300, Santa Maria, CA 93454
TEL: (805) 922-4772
www.oecusa.com FAX: (805) 925-3376

Page 1056 of 1256 ends

Project:

Project Number:

Project Manager:

Reported:

Wade Allmon
1309 Morrison Ave. Watsonville
Wade Allmon
Santa Barbara County Litigation Project
Santa Barbara CA, 93103 02-Jun-10 17:03
Oilfield Environmental and Compliance, INC.

Analyte Result
Limit Reporting Prepared Analyzed Method Notes Units Dilution Batch DRAFT: Y3-G2
1001778-05 (Solid)
DRAFT: Wet Chemistry by EPA or APHA Standard Methods
pH 7.41 0.100 pH Units 1 A005394 22-May-10 22-May-10 9045 HoldX DRAFT: Total Metals by EPA 6000/7000 Series Methods
Antimony 4.6 ND mg/kg 5 A005439 31-May-10 01-Jun-10 EPA 6020 Arsenic 5.5 0.93 " " "" " "
Barium 62 0.46 " " "" " "
Beryllium 2.3 ND " " " "" "
Cadmium 0.93 ND " " " "" "
Chromium 29 0.93 " " "" " "
Cobalt 12 0.93 " " "" " "
Copper 72 0.93 " " "" " "
Lead 370 3.7 " 20 " " 02-Jun-10 " N-02, N-03
Mercury 0.15 0.097 " 1 A006002 01-Jun-10 01-Jun-10 EPA 7471A Molybdenum 1.2 0.93 " 5 A005439 31-May-10 01-Jun-10 EPA 6020 Nickel 29 0.93 " " "" " "
Selenium 4.6 ND " " " "" "
Silver 0.93 ND " " " "" "
Thallium 4.6 ND " " " "" "
Titanium 1300 190 mg/L 100 " " 02-Jun-10 "
Vanadium 56 4.6 mg/kg 5 " " 01-Jun-10 "
Zinc 300 9.3 " 20 " " 02-Jun-10 "
DRAFT REPORT The results in this report apply to the samples analyzed in accordance with the chain of custody document. This analytical report must be reproduced in its entirety.

Page 7 of 24 ends

307 Roemer Way, Suite 300, Santa Maria, CA 93454
TEL: (805) 922-4772
www.oecusa.com FAX: (805) 925-3376

Page 1057 of 1256 ends

Project:

Project Number:

Project Manager:

Reported:

Wade Allmon
1309 Morrison Ave. Watsonville
Wade Allmon
Santa Barbara County Litigation Project
Santa Barbara CA, 93103 02-Jun-10 17:03
Oilfield Environmental and Compliance, INC.

Analyte Result
Limit Reporting Prepared Analyzed Method Notes Units Dilution Batch DRAFT: Y3 -H4
1001778-06 (Solid)
DRAFT: Wet Chemistry by EPA or APHA Standard Methods
pH 8.30 0.100 pH Units 1 A005394 22-May-10 22-May-10 9045 HoldX DRAFT: Total Metals by EPA 6000/7000 Series Methods
Antimony 4.8 ND mg/kg 5 A005439 31-May-10 01-Jun-10 EPA 6020 Arsenic 5.7 0.96 " " "" " "
Barium 55 0.48 " " "" " "
Beryllium 2.4 ND " " " "" "
Cadmium 0.96 ND " " " "" "
Chromium 42 0.96 " " "" " "
Cobalt 10 0.96 " " "" " "
Copper 35 0.96 " " "" " "
Lead 570 9.6 " 50 " " 02-Jun-10 " N-02, N-03
Mercury 0.19 0.095 " 1 A006002 01-Jun-10 01-Jun-10 EPA 7471A Molybdenum 0.96 ND " 5 A005439 31-May-10 01-Jun-10 EPA 6020 Nickel 51 0.96 " " "" " "
Selenium 4.8 ND " " " "" "
Silver 0.96 ND " " " "" "
Thallium 4.8 ND " " " "" "
Titanium 250 38 mg/L 20 " " 02-Jun-10 "
Vanadium 34 4.8 mg/kg 5 " " 01-Jun-10 "
Zinc 320 9.6 " 20 " " 02-Jun-10 "
DRAFT REPORT The results in this report apply to the samples analyzed in accordance with the chain of custody document. This analytical report must be reproduced in its entirety.

Page 8 of 24 ends

307 Roemer Way, Suite 300, Santa Maria, CA 93454
TEL: (805) 922-4772
www.oecusa.com FAX: (805) 925-3376

Page 1058 of 1256 ends

Project:

Project Number:

Project Manager:

Reported:

Wade Allmon
1309 Morrison Ave. Watsonville
Wade Allmon
Santa Barbara County Litigation Project
Santa Barbara CA, 93103 02-Jun-10 17:03
Oilfield Environmental and Compliance, INC.

Analyte Result
Limit Reporting Prepared Analyzed Method Notes Units Dilution Batch DRAFT: Y4-B2
1001778-07 (Solid)
DRAFT: Wet Chemistry by EPA or APHA Standard Methods
pH 8.70 0.100 pH Units 1 A005394 22-May-10 22-May-10 9045 HoldX DRAFT: Total Metals by EPA 6000/7000 Series Methods
Antimony 4.6 ND mg/kg 5 A005439 31-May-10 01-Jun-10 EPA 6020 Arsenic 2.9 0.92 " " "" " "
Barium 59 0.46 " " "" " "
Beryllium 2.3 ND " " " "" "
Cadmium 0.92 ND " " " "" "
Chromium 29 0.92 " " "" " "
Cobalt 14 0.92 " " "" " "
Copper 64 0.92 " " "" " "
Lead 100 0.92 " " "" " " N-02, N-03
Mercury 0.099 0.091 " 1 A006002 01-Jun-10 01-Jun-10 EPA 7471A Molybdenum 0.99 0.92 " 5 A005439 31-May-10 01-Jun-10 EPA 6020 Nickel 43 0.92 " " "" " "
Selenium 4.6 ND " " " "" "
Silver 0.92 ND " " " "" "
Thallium 4.6 ND " " " "" "
Titanium 890 92 mg/L 50 " " 02-Jun-10 "
Vanadium 58 4.6 mg/kg 5 " " 01-Jun-10 "
Zinc 280 9.2 " 20 " " 02-Jun-10 "
DRAFT REPORT The results in this report apply to the samples analyzed in accordance with the chain of custody document. This analytical report must be reproduced in its entirety.

Page 9 of 24 ends

307 Roemer Way, Suite 300, Santa Maria, CA 93454
TEL: (805) 922-4772
www.oecusa.com FAX: (805) 925-3376

Page 1059 of 1256 ends

Project:

Project Number:

Project Manager:

Reported:

Wade Allmon
1309 Morrison Ave. Watsonville
Wade Allmon
Santa Barbara County Litigation Project
Santa Barbara CA, 93103 02-Jun-10 17:03
Oilfield Environmental and Compliance, INC.

Analyte Result
Limit Reporting Prepared Analyzed Method Notes Units Dilution Batch DRAFT: Y4 -C4
1001778-08 (Solid)
DRAFT: Wet Chemistry by EPA or APHA Standard Methods
pH 8.17 0.100 pH Units 1 A005394 22-May-10 22-May-10 9045 HoldX DRAFT: Total Metals by EPA 6000/7000 Series Methods
Antimony 4.7 ND mg/kg 5 A005439 31-May-10 01-Jun-10 EPA 6020 Arsenic 8.6 0.94 " " "" " "
Barium 50 0.47 " " "" " "
Beryllium 2.3 ND " " " "" "
Cadmium 8.5 0.94 " " "" " "
Chromium 39 0.94 " " "" " "
Cobalt 15 0.94 " " "" " "
Copper 150 3.8 " 20 " " 02-Jun-10 "
Lead 850 9.4 " 50 " " 02-Jun-10 " N-02, N-03
Mercury 0.099 ND " 1 A006002 01-Jun-10 01-Jun-10 EPA 7471A Molybdenum 3.7 0.94 " 5 A005439 31-May-10 01-Jun-10 EPA 6020 Nickel 45 0.94 " " "" " "
Selenium 4.7 ND " " " "" "
Silver 0.94 ND " " " "" "
Thallium 4.7 ND " " " "" "
Titanium 390 38 mg/L 20 " " 02-Jun-10 "
Vanadium 49 4.7 mg/kg 5 " " 01-Jun-10 "
Zinc 650 23 " 50 " " 02-Jun-10 "
DRAFT REPORT The results in this report apply to the samples analyzed in accordance with the chain of custody document. This analytical report must be reproduced in its entirety.

Page 10 of 24 ends

307 Roemer Way, Suite 300, Santa Maria, CA 93454
TEL: (805) 922-4772
www.oecusa.com FAX: (805) 925-3376

Page 1060 of 1256 ends

Project:

Project Number:

Project Manager:

Reported:

Wade Allmon
1309 Morrison Ave. Watsonville
Wade Allmon
Santa Barbara County Litigation Project
Santa Barbara CA, 93103 02-Jun-10 17:03
Oilfield Environmental and Compliance, INC.

Analyte Result
Limit Reporting Prepared Analyzed Method Notes Units Dilution Batch DRAFT: Y5-D2
1001778-09 (Solid)
DRAFT: Wet Chemistry by EPA or APHA Standard Methods
pH 8.44 0.100 pH Units 1 A005394 22-May-10 22-May-10 9045 HoldX DRAFT: Total Metals by EPA 6000/7000 Series Methods
Antimony 5.0 ND mg/kg 5 A005439 31-May-10 01-Jun-10 EPA 6020 Arsenic 5.8 1.0 " " "" " "
Barium 63 0.50 " " "" " "
Beryllium 2.5 ND " " " "" "
Cadmium 1.3 1.0 " " "" " "
Chromium 40 1.0 " " "" " "
Cobalt 10 1.0 " " "" " "
Copper 57 1.0 " " "" " "
Lead 250 4.0 " 20 " " 02-Jun-10 " N-02, N-03
Mercury 0.26 0.093 " 1 A006002 01-Jun-10 01-Jun-10 EPA 7471A Molybdenum 1.0 ND " 5 A005439 31-May-10 01-Jun-10 EPA 6020 Nickel 44 1.0 " " "" " "
Selenium 5.0 ND " " " "" "
Silver 1.0 ND " " " "" "
Thallium 5.0 ND " " " "" "
Titanium 300 40 mg/L 20 " " 02-Jun-10 "
Vanadium 36 5.0 mg/kg 5 " " 01-Jun-10 "
Zinc 380 10 " 20 " " 02-Jun-10 "
DRAFT REPORT The results in this report apply to the samples analyzed in accordance with the chain of custody document. This analytical report must be reproduced in its entirety.

Page 11 of 24 ends

307 Roemer Way, Suite 300, Santa Maria, CA 93454
TEL: (805) 922-4772
www.oecusa.com FAX: (805) 925-3376

Page 1061 of 1256 ends

Project:

Project Number:

Project Manager:

Reported:

Wade Allmon
1309 Morrison Ave. Watsonville
Wade Allmon
Santa Barbara County Litigation Project
Santa Barbara CA, 93103 02-Jun-10 17:03
Oilfield Environmental and Compliance, INC.

Analyte Result
Limit Reporting Prepared Analyzed Method Notes Units Dilution Batch DRAFT: Y5-E2
1001778-10 (Solid)
DRAFT: Wet Chemistry by EPA or APHA Standard Methods
pH 8.35 0.100 pH Units 1 A005394 22-May-10 22-May-10 9045 HoldX DRAFT: Total Metals by EPA 6000/7000 Series Methods
Antimony 4.6 ND mg/kg 5 A005439 31-May-10 01-Jun-10 EPA 6020 Arsenic 4.7 0.91 " " "" " "
Barium 75 0.46 " " "" " "
Beryllium 2.3 ND " " " "" "
Cadmium 10 0.91 " " "" " " N-02
Chromium 38 0.91 " " "" " "
Cobalt 13 0.91 " " "" " "
Copper 73 0.91 " " "" " "
Lead 340 3.6 " 20 " " 02-Jun-10 " N-02, N-03
Mercury 0.47 0.084 " 1 A006002 01-Jun-10 01-Jun-10 EPA 7471A Molybdenum 0.91 ND " 5 A005439 31-May-10 01-Jun-10 EPA 6020 Nickel 45 0.91 " " "" " "
Selenium 4.6 ND " " " "" "
Silver 0.91 ND " " " "" "
Thallium 4.6 ND " " " "" "
Titanium 300 36 mg/L 20 " " 02-Jun-10 "
Vanadium 58 4.6 mg/kg 5 " " 01-Jun-10 "
Zinc 460 9.1 " 20 " " 02-Jun-10 "
DRAFT REPORT The results in this report apply to the samples analyzed in accordance with the chain of custody document. This analytical report must be reproduced in its entirety.

Page 12 of 24 ends

307 Roemer Way, Suite 300, Santa Maria, CA 93454
TEL: (805) 922-4772
www.oecusa.com FAX: (805) 925-3376

Page 1062 of 1256 ends

Project:

Project Number:

Project Manager:

Reported:

Wade Allmon
1309 Morrison Ave. Watsonville
Wade Allmon
Santa Barbara County Litigation Project
Santa Barbara CA, 93103 02-Jun-10 17:03
Oilfield Environmental and Compliance, INC.

Analyte Result
Limit Reporting Prepared Analyzed Method Notes Units Dilution Batch DRAFT: Y6-C2
1001778-11 (Solid)
DRAFT: Wet Chemistry by EPA or APHA Standard Methods
pH 8.35 0.100 pH Units 1 A005394 22-May-10 22-May-10 9045 HoldX DRAFT: Total Metals by EPA 6000/7000 Series Methods
Antimony 5.0 ND mg/kg 5 A005439 31-May-10 01-Jun-10 EPA 6020 Arsenic 6.2 1.0 " " "" " "
Barium 52 0.50 " " "" " "
Beryllium 2.5 ND " " " "" "
Cadmium 1.0 ND " " " "" "
Chromium 22 1.0 " " "" " "
Cobalt 12 1.0 " " "" " "
Copper 80 1.0 " " "" " "
Lead 170 4.0 " 20 " " 02-Jun-10 " N-02
Mercury 1.2 0.099 " 1 A006002 01-Jun-10 01-Jun-10 EPA 7471A Molybdenum 1.0 ND " 5 A005439 31-May-10 01-Jun-10 EPA 6020 Nickel 18 1.0 " " "" " "
Selenium 5.0 ND " " " "" "
Silver 1.0 ND " " " "" "
Thallium 5.0 ND " " " "" "
Titanium 400 40 mg/L 20 " " 02-Jun-10 "
Vanadium 63 5.0 mg/kg 5 " " 01-Jun-10 "
Zinc 360 10 " 20 " " 02-Jun-10 "
DRAFT REPORT The results in this report apply to the samples analyzed in accordance with the chain of custody document. This analytical report must be reproduced in its entirety.

Page 13 of 24 ends

307 Roemer Way, Suite 300, Santa Maria, CA 93454
TEL: (805) 922-4772
www.oecusa.com FAX: (805) 925-3376

Page 1063 of 1256 ends

Project:

Project Number:

Project Manager:

Reported:

Wade Allmon
1309 Morrison Ave. Watsonville
Wade Allmon
Santa Barbara County Litigation Project
Santa Barbara CA, 93103 02-Jun-10 17:03
Oilfield Environmental and Compliance, INC.

Analyte Result
Limit Reporting Prepared Analyzed Method Notes Units Dilution Batch DRAFT: Y7-B2
1001778-12 (Solid)
DRAFT: Wet Chemistry by EPA or APHA Standard Methods
pH 7.12 0.100 pH Units 1 A005394 22-May-10 22-May-10 9045 HoldX DRAFT: Total Metals by EPA 6000/7000 Series Methods
Antimony 4.7 ND mg/kg 5 A005439 31-May-10 01-Jun-10 EPA 6020 Arsenic 5.7 0.93 " " "" " "
Barium 74 0.47 " " "" " "
Beryllium 2.3 ND " " " "" "
Cadmium 0.93 ND " " " "" "
Chromium 49 0.93 " " "" " "
Cobalt 9.9 0.93 " " "" " "
Copper 23 0.93 " " "" " "
Lead 86 0.93 " " "" " " N-02, N-03
Mercury 0.093 ND " 1 A006002 01-Jun-10 01-Jun-10 EPA 7471A Molybdenum 0.93 ND " 5 A005439 31-May-10 01-Jun-10 EPA 6020 Nickel 40 0.93 " " "" " "
Selenium 4.7 ND " " " "" "
Silver 0.93 ND " " " "" "
Thallium 4.7 ND " " " "" "
Titanium 370 37 mg/L 20 " " 02-Jun-10 "
Vanadium 37 4.7 mg/kg 5 " " 01-Jun-10 "
Zinc 140 9.3 " 20 " " 02-Jun-10 "
DRAFT REPORT The results in this report apply to the samples analyzed in accordance with the chain of custody document. This analytical report must be reproduced in its entirety.

Page 14 of 24 ends

307 Roemer Way, Suite 300, Santa Maria, CA 93454
TEL: (805) 922-4772
www.oecusa.com FAX: (805) 925-3376

Page 1064 of 1256 ends

Project:

Project Number:

Project Manager:

Reported:

Wade Allmon
1309 Morrison Ave. Watsonville
Wade Allmon
Santa Barbara County Litigation Project
Santa Barbara CA, 93103 02-Jun-10 17:03
Oilfield Environmental and Compliance, INC.

Analyte Result
Limit Reporting Prepared Analyzed Method Notes Units Dilution Batch DRAFT: Y8-B2
1001778-13 (Solid)
DRAFT: Wet Chemistry by EPA or APHA Standard Methods
pH 7.38 0.100 pH Units 1 A005394 22-May-10 22-May-10 9045 HoldX DRAFT: Total Metals by EPA 6000/7000 Series Methods
Antimony 5.0 ND mg/kg 5 A005439 31-May-10 01-Jun-10 EPA 6020 Arsenic 7.0 1.0 " " "" " "
Barium 69 0.50 " " "" " "
Beryllium 2.5 ND " " " "" "
Cadmium 1.0 ND " " " "" "
Chromium 31 1.0 " " "" " "
Cobalt 8.0 1.0 " " "" " "
Copper 110 1.0 " " "" " "
Lead 170 4.0 " 20 " " 02-Jun-10 " N-02, N-03
Mercury 0.098 ND " 1 A006002 01-Jun-10 01-Jun-10 EPA 7471A Molybdenum 1.0 ND " 5 A005439 31-May-10 01-Jun-10 EPA 6020 Nickel 28 1.0 " " "" " "
Selenium 5.0 ND " " " "" "
Silver 1.0 ND " " " "" "
Thallium 5.0 ND " " " "" "
Titanium 290 40 mg/L 20 " " 02-Jun-10 "
Vanadium 34 5.0 mg/kg 5 " " 01-Jun-10 "
Zinc 320 10 " 20 " " 02-Jun-10 "
DRAFT REPORT The results in this report apply to the samples analyzed in accordance with the chain of custody document. This analytical report must be reproduced in its entirety.

Page 15 of 24 ends

307 Roemer Way, Suite 300, Santa Maria, CA 93454
TEL: (805) 922-4772
www.oecusa.com FAX: (805) 925-3376

Page 1065 of 1256 ends

Project:

Project Number:

Project Manager:

Reported:

Wade Allmon
1309 Morrison Ave. Watsonville
Wade Allmon
Santa Barbara County Litigation Project
Santa Barbara CA, 93103 02-Jun-10 17:03
Oilfield Environmental and Compliance, INC.

Analyte Result
Limit Reporting Prepared Analyzed Method Notes Units Dilution Batch DRAFT: Y9-C6
1001778-14 (Solid)
DRAFT: Wet Chemistry by EPA or APHA Standard Methods
pH 8.45 0.100 pH Units 1 A005394 22-May-10 22-May-10 9045 HoldX DRAFT: Total Metals by EPA 6000/7000 Series Methods
Antimony 4.5 ND mg/kg 5 A005439 31-May-10 01-Jun-10 EPA 6020 Arsenic 8.7 0.89 " " "" " "
Barium 93 0.45 " " "" " "
Beryllium 2.2 ND " " " "" "
Cadmium 1.2 0.89 " " "" " "
Chromium 46 0.89 " " "" " "
Cobalt 12 0.89 " " "" " "
Copper 42 0.89 " " "" " "
Lead 310 3.6 " 20 " " 02-Jun-10 " N-02, N-03
Mercury 0.24 0.075 " 1 A006002 01-Jun-10 01-Jun-10 EPA 7471A Molybdenum 0.89 ND " 5 A005439 31-May-10 01-Jun-10 EPA 6020 Nickel 61 0.89 " " "" " "
Selenium 4.5 ND " " " "" "
Silver 0.89 ND " " " "" "
Thallium 4.5 ND " " " "" "
Titanium 180 36 mg/L 20 " " 02-Jun-10 "
Vanadium 33 4.5 mg/kg 5 " " 01-Jun-10 "
Zinc 340 8.9 " 20 " " 02-Jun-10 "
DRAFT REPORT The results in this report apply to the samples analyzed in accordance with the chain of custody document. This analytical report must be reproduced in its entirety.

Page 16 of 24 ends

307 Roemer Way, Suite 300, Santa Maria, CA 93454
TEL: (805) 922-4772
www.oecusa.com FAX: (805) 925-3376

Page 1066 of 1256 ends

Project:

Project Number:

Project Manager:

Reported:

Wade Allmon
1309 Morrison Ave. Watsonville
Wade Allmon
Santa Barbara County Litigation Project
Santa Barbara CA, 93103 02-Jun-10 17:03
Oilfield Environmental and Compliance, INC.

Analyte Result
Limit Reporting Prepared Analyzed Method Notes Units Dilution Batch DRAFT: Y10-B4
1001778-15 (Solid)
DRAFT: Wet Chemistry by EPA or APHA Standard Methods
pH 9.00 0.100 pH Units 1 A005394 22-May-10 22-May-10 9045 DRAFT: Total Metals by EPA 6000/7000 Series Methods
Antimony 4.7 ND mg/kg 5 A005439 31-May-10 01-Jun-10 EPA 6020 Arsenic 5.1 0.94 " " "" " "
Barium 53 0.47 " " "" " "
Beryllium 2.4 ND " " " "" "
Cadmium 0.94 ND " " " "" "
Chromium 36 0.94 " " "" " "
Cobalt 9.8 0.94 " " "" " "
Copper 41 0.94 " " " " 02-Jun-10 "
Lead 140 1.9 " 10 " " 01-Jun-10 " N-02, N-03
Mercury 0.22 0.078 " 1 A006002 01-Jun-10 01-Jun-10 EPA 7471A Molybdenum 0.94 ND " 5 A005439 31-May-10 01-Jun-10 EPA 6020 Nickel 32 0.94 " " "" " "
Selenium 4.7 ND " " " "" "
Silver 0.94 ND " " " "" "
Thallium 4.7 ND " " " "" "
Titanium 190 19 mg/L 10 " " 02-Jun-10 "
Vanadium 41 4.7 mg/kg 5 " " 01-Jun-10 "
Zinc 150 4.7 " 10 " " 02-Jun-10 "
DRAFT REPORT The results in this report apply to the samples analyzed in accordance with the chain of custody document. This analytical report must be reproduced in its entirety.

Page 17 of 24 ends

307 Roemer Way, Suite 300, Santa Maria, CA 93454
TEL: (805) 922-4772
www.oecusa.com FAX: (805) 925-3376

Page 1067 of 1256 ends

Project:

Project Number:

Project Manager:

Reported:

Wade Allmon
1309 Morrison Ave. Watsonville
Wade Allmon
Santa Barbara County Litigation Project
Santa Barbara CA, 93103 02-Jun-10 17:03
Oilfield Environmental and Compliance, INC.

Analyte Result
Limit Reporting Prepared Analyzed Method Notes Units Dilution Batch DRAFT: Y11-B2
1001778-16 (Solid)
DRAFT: Wet Chemistry by EPA or APHA Standard Methods
pH 9.16 0.100 pH Units 1 A005394 22-May-10 22-May-10 9045 DRAFT: Total Metals by EPA 6000/7000 Series Methods
Antimony 4.5 ND mg/kg 5 A005439 31-May-10 01-Jun-10 EPA 6020 Arsenic 3.1 0.89 " " "" " "
Barium 45 0.45 " " "" " "
Beryllium 2.2 ND " " " "" "
Cadmium 0.89 ND " " " "" "
Chromium 34 0.89 " " "" " "
Cobalt 9.7 0.89 " " "" " "
Copper 29 0.89 " " "" " "
Lead 410 3.6 " 20 " " 02-Jun-10 " N-02, N-03
Mercury 0.59 0.087 " 1 A006002 01-Jun-10 01-Jun-10 EPA 7471A Molybdenum 0.89 ND " 5 A005439 31-May-10 01-Jun-10 EPA 6020 Nickel 35 0.89 " " "" " "
Selenium 4.5 ND " " " "" "
Silver 0.89 ND " " " "" "
Thallium 4.5 ND " " " "" "
Titanium 290 36 mg/L 20 " " 02-Jun-10 "
Vanadium 38 4.5 mg/kg 5 " " 01-Jun-10 "
Zinc 110 2.2 " " "" " "
DRAFT REPORT The results in this report apply to the samples analyzed in accordance with the chain of custody document. This analytical report must be reproduced in its entirety.

Page 18 of 24 ends

307 Roemer Way, Suite 300, Santa Maria, CA 93454
TEL: (805) 922-4772
www.oecusa.com FAX: (805) 925-3376

Page 1068 of 1256 ends

Project:

Project Number:

Project Manager:

Reported:

Wade Allmon
1309 Morrison Ave. Watsonville
Wade Allmon
Santa Barbara County Litigation Project
Santa Barbara CA, 93103 02-Jun-10 17:03
Oilfield Environmental and Compliance, INC.

Result Limit
Reporting
Units Level
Spike
Result
Source
%REC
%REC
Limits RPD
RPD
Analyte Limit Notes
DRAFT: Wet Chemistry by EPA or APHA Standard Methods - Quality Control Batch A005394 - EPA 9045 pH Prep
LCS (A005394-BS1) Prepared & Analyzed: 22-May-10
pH pH Units 4.00 0.100 4.00 10 100 90-110
LCS (A005394-BS2) Prepared & Analyzed: 22-May-10
pH pH Units 7.02 0.100 7.00 10 100 90-110
LCS (A005394-BS3) Prepared & Analyzed: 22-May-10
pH pH Units 9.98 0.100 10.0 10 99.8 90-110
Duplicate (A005394-DUP1) Source: 1001770-01 Prepared & Analyzed: 22-May-10 pH pH Units 8.00 0.100 8.09 10 1.12
DRAFT REPORT The results in this report apply to the samples analyzed in accordance with the chain of custody document. This analytical report must be reproduced in its entirety.

Page 19 of 24 ends

307 Roemer Way, Suite 300, Santa Maria, CA 93454
TEL: (805) 922-4772
www.oecusa.com FAX: (805) 925-3376

Page 1069 of 1256 ends

Project:

Project Number:

Project Manager:

Reported:

Wade Allmon
1309 Morrison Ave. Watsonville
Wade Allmon
Santa Barbara County Litigation Project
Santa Barbara CA, 93103 02-Jun-10 17:03
Oilfield Environmental and Compliance, INC.

Result Limit
Reporting
Units Level
Spike
Result
Source
%REC
%REC
Limits RPD
RPD
Analyte Limit Notes
DRAFT: Total Metals by EPA 6000/7000 Series Methods - Quality Control Batch A005439 - EPA 3050B
Blank (A005439-BLK1) Prepared: 31-May-10 Analyzed: 01-Jun-10 Titanium mg/L ND 2.0
Antimony mg/kg ND 1.0
Arsenic " ND 0.20
Barium " ND 0.10
Beryllium " ND 0.50
Cadmium " ND 0.20
Chromium " ND 0.20
Cobalt " ND 0.20
Copper " ND 0.20
Lead ND 0.20 "
Molybdenum " ND 0.20
Nickel " ND 0.20
Selenium " ND 1.0
Silver " ND 0.20
Thallium " ND 1.0
Vanadium " ND 1.0
Zinc ND 0.50 "
LCS (A005439-BS1) Prepared: 31-May-10 Analyzed: 01-Jun-10 Titanium mg/L 14.4 2.0 15.0 20 95.9 85-115
Antimony mg/kg 15.1 1.0 15.0 20 101 85-115
Arsenic " 15.4 0.20 15.0 20 103 85-115
Barium " 14.9 0.10 15.0 20 99.0 85-115
Beryllium " 15.5 0.50 15.0 20 103 85-115
Cadmium " 15.2 0.20 15.0 20 101 85-115
Chromium " 15.1 0.20 15.0 20 101 85-115
Cobalt " 15.4 0.20 15.0 20 103 85-115
Copper " 15.4 0.20 15.0 20 103 85-115
Lead 14.9 0.20 15.0 20 " 99.3 85-115
Molybdenum " 14.6 0.20 15.0 20 97.5 85-115
Nickel " 15.3 0.20 15.0 20 102 85-115
Selenium " 15.3 1.0 15.0 20 102 85-115
Silver " 15.6 0.20 15.0 20 104 85-115
Thallium " 14.3 1.0 15.0 20 95.1 85-115
Vanadium " 15.2 1.0 15.0 20 101 85-115
Zinc 15.0 0.50 15.0 20 " 100 85-115
DRAFT REPORT The results in this report apply to the samples analyzed in accordance with the chain of custody document. This analytical report must be reproduced in its entirety.

Page 20 of 24 ends

307 Roemer Way, Suite 300, Santa Maria, CA 93454
TEL: (805) 922-4772
www.oecusa.com FAX: (805) 925-3376

Page 1070 of 1256 ends

Project:

Project Number:

Project Manager:

Reported:

Wade Allmon
1309 Morrison Ave. Watsonville
Wade Allmon
Santa Barbara County Litigation Project
Santa Barbara CA, 93103 02-Jun-10 17:03
Oilfield Environmental and Compliance, INC.

Result Limit
Reporting
Units Level
Spike
Result
Source
%REC
%REC
Limits RPD
RPD
Analyte Limit Notes
DRAFT: Total Metals by EPA 6000/7000 Series Methods - Quality Control Batch A005439 - EPA 3050B
LCS Dup (A005439-BSD1) Prepared: 31-May-10 Analyzed: 01-Jun-10 Titanium mg/L 14.2 2.0 15.0 20 94.6 1.39 85-115
Antimony mg/kg 15.4 1.0 15.0 20 103 1.64 85-115
Arsenic " 15.9 0.20 15.0 20 106 2.99 85-115
Barium " 15.2 0.10 15.0 20 101 2.41 85-115
Beryllium " 15.0 0.50 15.0 20 100 2.91 85-115
Cadmium " 15.4 0.20 15.0 20 103 1.64 85-115
Chromium " 15.2 0.20 15.0 20 101 0.617 85-115
Cobalt " 15.4 0.20 15.0 20 103 0.403 85-115
Copper " 15.4 0.20 15.0 20 103 0.340 85-115
Lead 15.2 0.20 15.0 20 " 101 1.88 85-115
Molybdenum " 15.0 0.20 15.0 20 99.8 2.31 85-115
Nickel " 15.4 0.20 15.0 20 103 0.795 85-115
Selenium " 15.8 1.0 15.0 20 105 3.08 85-115
Silver " 15.9 0.20 15.0 20 106 1.99 85-115
Thallium " 14.9 1.0 15.0 20 99.4 4.40 85-115
Vanadium " 15.2 1.0 15.0 20 101 0.0672 85-115
Zinc 15.3 0.50 15.0 20 " 102 1.67 85-115
Duplicate (A005439-DUP1) Source: 1001778-01 Prepared: 31-May-10 Analyzed: 02-Jun-10 Titanium mg/L 260 38 275 20 5.78
Antimony mg/kg ND 4.7 ND 20
Arsenic " 16.9 0.94 17.8 20 5.51
Barium " 174 1.9 182 20 4.70
Beryllium " ND 2.3 ND 20
Cadmium " 1.51 0.94 1.64 20 8.63
Chromium " 52.1 0.94 61.9 20 17.2
Cobalt " 12.4 0.94 13.0 20 4.48
Copper " 89.4 0.94 93.8 20 4.80
Lead 722 9.4 748 20 " 3.56
Molybdenum " ND 0.94 0.515 20
Nickel " 56.8 0.94 59.6 20 4.97
Selenium " ND 4.7 ND 20
Silver " 0.885 0.94 0.954 20 7.51
Thallium " ND 4.7 ND 20
Vanadium " 36.6 19 36.5 20 0.437
Zinc 643 23 702 20 " 8.83
DRAFT REPORT The results in this report apply to the samples analyzed in accordance with the chain of custody document. This analytical report must be reproduced in its entirety.

Page 21 of 24 ends

307 Roemer Way, Suite 300, Santa Maria, CA 93454
TEL: (805) 922-4772
www.oecusa.com FAX: (805) 925-3376

Page 1071 of 1256 ends

Project:

Project Number:

Project Manager:

Reported:

Wade Allmon
1309 Morrison Ave. Watsonville
Wade Allmon
Santa Barbara County Litigation Project
Santa Barbara CA, 93103 02-Jun-10 17:03
Oilfield Environmental and Compliance, INC.

Result Limit
Reporting
Units Level
Spike
Result
Source
%REC
%REC
Limits RPD
RPD
Analyte Limit Notes
DRAFT: Total Metals by EPA 6000/7000 Series Methods - Quality Control Batch A005439 - EPA 3050B
Matrix Spike (A005439-MS1) Source: 1001778-01 Prepared: 31-May-10 Analyzed: 02-Jun-10 Titanium mg/L 583 95 284 275 20 108 75-125
Antimony mg/kg 19.0 19 284 ND 20 6.67 0-88
Arsenic " 293 3.8 284 17.8 20 96.8 73-124
Barium " 246 1.9 284 182 20 22.5 18-166
Beryllium " 296 9.5 284 ND 20 104 76-132
Cadmium " 288 3.8 284 1.64 20 101 82-118
Chromium " 357 3.8 284 61.9 20 104 58-139
Cobalt " 311 3.8 284 13.0 20 105 85-114
Copper " 394 3.8 284 93.8 20 106 64-138
Lead 959 9.5 284 748 20 " 74.4 61-138
Molybdenum " 271 3.8 284 0.515 20 95.2 67-112
Nickel " 355 3.8 284 59.6 20 104 68-132
Selenium " 273 19 284 ND 20 96.2 66-132
Silver " 287 3.8 284 0.954 20 101 18-153
Thallium " 272 19 284 ND 20 95.9 78-114
Vanadium " 333 19 284 36.5 20 104 80-119
Zinc 986 24 284 702 20 " 99.9 40-153
Matrix Spike Dup (A005439-MSD1) Source: 1001778-01 Prepared: 31-May-10 Analyzed: 01-Jun-10 Titanium mg/L 487 37 275 275 20 QR-02 77.0 33.8 75-125
Antimony mg/kg 17.2 18 275 ND 20 QR-02 6.23 6.83 0-88
Arsenic " 290 3.7 275 17.8 20 98.8 1.99 73-124
Barium " 232 1.8 275 182 20 QM-08 18.1 22.0 18-166
Beryllium " 262 9.2 275 ND 20 95.3 8.93 76-132
Cadmium " 283 3.7 275 1.64 20 102 1.39 82-118
Chromium " 333 3.7 275 61.9 20 98.5 5.23 58-139
Cobalt " 292 3.7 275 13.0 20 101 3.55 85-114
Copper " 358 3.7 275 93.8 20 95.9 9.55 64-138
Lead 917 9.2 275 748 20 " 61.5 19.0 61-138
Molybdenum " 267 3.7 275 0.515 20 96.8 1.63 67-112
Nickel " 340 3.7 275 59.6 20 102 2.18 68-132
Selenium " 256 18 275 ND 20 93.0 3.41 66-132
Silver " 252 3.7 275 0.954 20 91.0 10.0 18-153
Thallium " 267 18 275 ND 20 97.2 1.33 78-114
Vanadium " 304 18 275 36.5 20 97.4 7.08 80-119
Zinc 919 23 275 702 20 QR-02 " 78.7 23.7 40-153
DRAFT REPORT The results in this report apply to the samples analyzed in accordance with the chain of custody document. This analytical report must be reproduced in its entirety.

Page 22 of 24 ends

307 Roemer Way, Suite 300, Santa Maria, CA 93454
TEL: (805) 922-4772
www.oecusa.com FAX: (805) 925-3376

Page 1072 of 1256 ends

Project:

Project Number:

Project Manager:

Reported:

Wade Allmon
1309 Morrison Ave. Watsonville
Wade Allmon
Santa Barbara County Litigation Project
Santa Barbara CA, 93103 02-Jun-10 17:03
Oilfield Environmental and Compliance, INC.

Result Limit
Reporting
Units Level
Spike
Result
Source
%REC
%REC
Limits RPD
RPD
Analyte Limit Notes
DRAFT: Total Metals by EPA 6000/7000 Series Methods - Quality Control Batch A006002 - EPA 7471A Prep
Blank (A006002-BLK1) Prepared & Analyzed: 01-Jun-10
Mercury mg/kg ND 0.10
LCS (A006002-BS1) Prepared & Analyzed: 01-Jun-10
Mercury mg/kg 1.73 0.10 1.67 20 104 85-115
LCS Dup (A006002-BSD1) Prepared & Analyzed: 01-Jun-10
Mercury mg/kg 1.75 0.10 1.67 20 105 0.899 85-115
Duplicate (A006002-DUP1) Source: 1001778-01 Prepared & Analyzed: 01-Jun-10 Mercury mg/kg 0.228 0.092 0.240 20 5.46
Matrix Spike (A006002-MS1) Source: 1001778-01 Prepared & Analyzed: 01-Jun-10 Mercury mg/kg 1.78 0.091 1.52 0.240 20 102 75-125
Matrix Spike Dup (A006002-MSD1) Source: 1001778-01 Prepared & Analyzed: 01-Jun-10 Mercury mg/kg 1.77 0.088 1.47 0.240 20 103 1.88 75-125
DRAFT REPORT The results in this report apply to the samples analyzed in accordance with the chain of custody document. This analytical report must be reproduced in its entirety.

Page 23 of 24 ends

307 Roemer Way, Suite 300, Santa Maria, CA 93454
TEL: (805) 922-4772
www.oecusa.com FAX: (805) 925-3376

Page 1073 of 1256 ends

Project:

Project Number:

Project Manager:

Reported:

Wade Allmon
1309 Morrison Ave. Watsonville
Wade Allmon
Santa Barbara County Litigation Project
Santa Barbara CA, 93103 02-Jun-10 17:03
Oilfield Environmental and Compliance, INC.

Notes and Definitions
QR-02 The RPD result exceeded the QC control limits; however, both percent recoveries were acceptable. Sample results for the QC batch were accepted based on percent recoveries and completeness of QC data.

QM-08 The spike recovery was outside acceptance limits for the MS and/or MSD. The QC Batch was accepted based on LCS/LCSD percent recoveries and RPD values.

N-03 Analyte concentration above 20 X TCLP.

N-02 Analyte concentration below TTLC but above 10 X STLC.

HoldX Sample holding time expired.

Sample results reported on a dry weight basis
RPD Relative Percent Difference
dry
NR Not Reported
ND Analyte NOT DETECTED at or above the reporting limit DET Analyte DETECTED
DRAFT REPORT The results in this report apply to the samples analyzed in accordance with the chain of custody document. This analytical report must be reproduced in its entirety.

Page 24 of 24 ends

307 Roemer Way, Suite 300, Santa Maria, CA 93454
TEL: (805) 922-4772
www.oecusa.com FAX: (805) 925-3376

Page 1074 of 1256 ends

Oilfield Environmental and Compliance
307 Roemer Way Suite 300, Santa Maria CA 93454
phone: (805) 922-4772 fax: (805) 925-3376 www.oecusa.com Highway 33, McKittrick CA
phone: (661) 762-9143
Company:~~ Project Name/#:

Analysis Requested
E-mail:

Received By:
f!.!~!'5!.~L!~~-~.Y.:----------------------------------------------------------1?~!~: ________________ !!'!!!~--------------- Received By: Date: Time:
!!!~!'.<1.~L~~~~-~.x;:----------------------------------------------------------1?~!~: ________________ !!'!!!~--------------- Received By: Date: Time:

CHAIN OF CUSTODY
Page ' of
Special Instructions:

Page 1075 of 1256 ends

Received By:

Oilfield Environmental and Compliance
307 Roemer Way Suite 300, Santa Maria CA 93454
phone: (805} 922·4772 fax: (805) 925-3376 www.oecusa.com Highway 33, McKittrick CA
phone: (661) 762-9143
Project Name/#:

Analysis Requested
E-mall:
48 hr- O 24 hr- D ASAP- 0 C

CHAIN OF CUSTODY

Page 2 ends

Special Instructions:

Sampl:: Matrix ~~. Client Sample ID a __ ,....__ ....... __ _...., ...... -.-_______________ --1---1-----1---1----1--..J.----1---1----l--.tm•••"•••••••••••"'"•"'"""'''''"'"'"'""""""""""'''''''''"" 'f/TJ.jaA l4co 'L l 8° - ~ 'Z. -t------t---t---t----.t,___..:;._ ________ -+--+--t--+-+--1--t--+----l--+---l--+---l----I······ ................................................................ . -1-----"---t--ll---t---l----''----=---------+--+---l---l--l--l--l---+----l--+---l---l----l----I·"'''"'""""'""'"'"""'""""""""""""""""'"'''"'''"'''"'"""""''''""' '"''~ l 'I '-C.b 1 'f1o-S4
+-----t--lf---t---t----'---'--=---------+-f--t--l-+---il-+--l---l----l----l--l---1----1····· ................................................................. .

I YL\-~Z.
------+---l---+--------------+---1---1----4--1---1---1-----1---1----1---I····· ................................................................. . ------t----t---+--------------+---+--t----t--+---l--+----+--+---1---1······"''"""""""""'"···· .......................................... . ------+---+---+--------------+---+---l----t--1---1---1----4--1---1-----I········· ............................................................. . ------t---l---+--------------+---+---1----+--1---1---1-----1---1---1---1 ..................................................................... .. ------+----+----+--------------1---+--+---+--l---+---l-----l--l---l---I· .. ···· ............................................................... . ------+----+----+--------------+---+--t---+--+---+---1-----1--1---1---1·· .................................................................... . ------+----+----+--------------1---+--+---+--+---+---l----t--+---l---I•"""""""'""""'"""""'"""'""''""""'''""'"'''"''""•""'" ~l!~!'.9.~~~~!!:'_~.x:----------------------------------------------------------~~!!: ________________ !!'!!..~~--------------- Received By: Date: Time:
~l!~!'.9.~~~~~!:'-~.X:----------------------------------------------------------~~!!: ________________ !!'!!..~~--------------- Received By: Date: Page 1076 of 1256 Time:
(• l#(;JsAMPLE RECEIPT CLIENT: (Jt!lde ,4 //n,ari
-...:::::::: ;;;;;J' Rev IH/15110

COC RECEIVED
DATE/TIME: I 7 CJC>
RECEIPT LOGIN . .

DATE/TIME: 5 ·-J "I- ( D
SAMPLE TRANSPORT, RECEIPT, CONDITION & PRESERVATION: Yes D OEC Courier/Sampler COC document(s) received with samples )S.Delivery(Other than OEC Courier) Correct containers for analysis requested ~ ,;g{ Samples Received on Ice Container(s) intact and in good condition D } Samples Received Outside Temp. Range* Container label(s) consistent with COC D Samples Direct from field (Outside Temp) OEC preservative added (**note std ID) D** D After.Hours Outside Drop·off [Brought Inside] Proper preservation on sample label(s) D (Initials/Date/Time): VOA containers free ofheadspace D Tedlar Bags free of condensation D
OECID#:~/_o_0_/_7_7_8'~ Temp: --~~· ___ ° C
Acceptable Range: 0°C to 6°C
REFRIGERATOR(s): ___ _
No NIA (*)PROBLEM CHAIN FO~D
D* D Custody Seals (circle): Present Absent
D* D Samples I Coolers
D* D Intact! Broken*
D* D Method of Shipment & Tracking #(lfapphcable)
D ~
D 15' (**) OEC Preservative ID:

D* 1: Dissolved Metals Filtration (Datc/lnit/Prcserve ID) D*
CONTAINERS, COC CHANGES AND/OR CORRECTIONS CHANGES AUTHORIZED BY:

OECID Client ID ***If blank, refertoCoC Container Description Preservative Res Cl Matrix Dateffime Comments I Remarks I /pH Sampled*** Condition Notes, Etc.
1-11.:.A t- Jtci. cf(!L.fr &.P- - - fd~/:l
J,2/(l,. ~B i J .J, J . ------- --------
-------
RECEIPT LOGIN BY: IJ.\ --+-7- RECEIPT REVIEWED BY: ---""At?1--""'-''-'------ Page ' of I

Page 1077 of 1256 ends

Oilfield Environmental and Compliance, INC.

Dear Client:

Enclosed is an analytical report for the above referenced project. The samples included in this report were received on 22-May-10 17:00 and analyzed in accordance with the attached chain-of-custody.

Unless otherwise noted, all analytical testing was accomplished in accordance with the guidelines established in our Quality Assurance Manual, applicable standard operating procedures, and other related documentation. The results in this analytical report are limited to the samples tested and any reproduction thereof must be made in its entirety.

If you have any questions regarding this report, please do not hesitate to contact the undersigned.

Sincerely,
Work Order: 1001779
02 June 2010
Laboratory Manager
Lisa Race
Wade Allmon
1309 Morrison Ave.

Santa Barbara, CA 93103
RE: Santa Barbara County Litigation Project
Wade Allmon
307 Roemer Way, Suite 300, Santa Maria, CA 93454
TEL: (805) 922-4772
www.oecusa.com FAX: (805) 925-3376

Page 1078 of 1256 ends

Project:

Project Number:

Project Manager:

Reported:

Wade Allmon
1309 Morrison Ave. Santa Barbara County Litigation Project Wade Allmon
Santa Barbara County Litigation Project
Santa Barbara CA, 93103 02-Jun-10 08:40
Oilfield Environmental and Compliance, INC.

Sample ID Laboratory ID Matrix Date Sampled

ANALYTICAL REPORT FOR SAMPLES
Date Received
X1 1001779-01 19-May-10 11:20 22-May-10 17:00 Solid
X2 1001779-02 19-May-10 12:10 22-May-10 17:00 Solid
X3 1001779-03 19-May-10 12:25 22-May-10 17:00 Solid
X4 1001779-04 19-May-10 12:45 22-May-10 17:00 Solid
X5 1001779-05 19-May-10 13:00 22-May-10 17:00 Solid
X6 1001779-06 19-May-10 13:40 22-May-10 17:00 Solid
X7 1001779-07 19-May-10 14:30 22-May-10 17:00 Solid
X8 1001779-08 19-May-10 14:50 22-May-10 17:00 Solid
X9 1001779-09 19-May-10 15:40 22-May-10 17:00 Solid
X10 1001779-10 19-May-10 15:55 22-May-10 17:00 Solid
X11 1001779-11 19-May-10 16:10 22-May-10 17:00 Solid
X12 1001779-12 19-May-10 16:20 22-May-10 17:00 Solid
X13 1001779-13 19-May-10 16:40 22-May-10 17:00 Solid
X14 1001779-14 19-May-10 17:20 22-May-10 17:00 Solid
X15 1001779-15 19-May-10 17:40 22-May-10 17:00 Solid
X16 1001779-16 19-May-10 18:10 22-May-10 17:00 Solid
Oilfield Environmental and Compliance The results in this report apply to the samples analyzed in accordance with the chain of custody document. This analytical report must be reproduced in its entirety.

Page 2 of 11 ends

307 Roemer Way, Suite 300, Santa Maria, CA 93454
TEL: (805) 922-4772
www.oecusa.com FAX: (805) 925-3376

Page 1079 of 1256 ends

Project:

Project Number:

Project Manager:

Reported:

Analyte Result
Limit Reporting Prepared Analyzed Method Notes Units Dilution Batch X1
1001779-01 (Solid)
Wet Chemistry by EPA or APHA Standard Methods
pH 7.09 0.100 pH Units 1 A006008 23-May-10 23-May-10 9045 HoldX Total Metals by EPA 6000/7000 Series Methods
Arsenic 3.6 0.99 mg/kg 5 A005440 31-May-10 01-Jun-10 EPA 6020 Lead 19 0.99 " " "" " "
Analyte Result
Limit Reporting Prepared Analyzed Method Notes Units Dilution Batch X2
1001779-02 (Solid)
Wet Chemistry by EPA or APHA Standard Methods
pH 5.54 0.100 pH Units 1 A006008 23-May-10 23-May-10 9045 HoldX Total Metals by EPA 6000/7000 Series Methods
Arsenic 3.7 0.90 mg/kg 5 A005440 31-May-10 01-Jun-10 EPA 6020 Lead 99 0.90 " " "" " " N-02
Analyte Result
Limit Reporting Prepared Analyzed Method Notes Units Dilution Batch X3
1001779-03 (Solid)
Wet Chemistry by EPA or APHA Standard Methods
pH 6.45 0.100 pH Units 1 A006008 23-May-10 23-May-10 9045 HoldX Total Metals by EPA 6000/7000 Series Methods
Arsenic 2.6 0.97 mg/kg 5 A005440 31-May-10 01-Jun-10 EPA 6020 Lead 29 0.97 " " "" " "
Oilfield Environmental and Compliance The results in this report apply to the samples analyzed in accordance with the chain of custody document. This analytical report must be reproduced in its entirety.

Page 3 of 11 ends

307 Roemer Way, Suite 300, Santa Maria, CA 93454
TEL: (805) 922-4772
www.oecusa.com FAX: (805) 925-3376

Page 1080 of 1256 ends

Project:

Project Number:

Project Manager:

Reported:

Analyte Result
Limit Reporting Prepared Analyzed Method Notes Units Dilution Batch X4
1001779-04 (Solid)
Wet Chemistry by EPA or APHA Standard Methods
pH 5.90 0.100 pH Units 1 A006008 23-May-10 23-May-10 9045 HoldX Total Metals by EPA 6000/7000 Series Methods
Arsenic 2.3 0.91 mg/kg 5 A005440 31-May-10 01-Jun-10 EPA 6020 Lead 26 0.91 " " "" " "
Analyte Result
Limit Reporting Prepared Analyzed Method Notes Units Dilution Batch X5
1001779-05 (Solid)
Wet Chemistry by EPA or APHA Standard Methods
pH 6.17 0.100 pH Units 1 A006008 23-May-10 23-May-10 9045 HoldX Total Metals by EPA 6000/7000 Series Methods
Arsenic 2.5 0.93 mg/kg 5 A005440 31-May-10 01-Jun-10 EPA 6020 Lead 7.0 0.93 " " "" " "
Analyte Result
Limit Reporting Prepared Analyzed Method Notes Units Dilution Batch X6
1001779-06 (Solid)
Wet Chemistry by EPA or APHA Standard Methods
pH 5.54 0.100 pH Units 1 A006008 23-May-10 23-May-10 9045 HoldX Total Metals by EPA 6000/7000 Series Methods
Arsenic 4.3 0.98 mg/kg 5 A005440 31-May-10 01-Jun-10 EPA 6020 Lead 45 0.98 " " "" " "
Oilfield Environmental and Compliance The results in this report apply to the samples analyzed in accordance with the chain of custody document. This analytical report must be reproduced in its entirety.

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307 Roemer Way, Suite 300, Santa Maria, CA 93454
TEL: (805) 922-4772
www.oecusa.com FAX: (805) 925-3376

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Project:

Project Number:

Project Manager:

Reported:

Analyte Result
Limit Reporting Prepared Analyzed Method Notes Units Dilution Batch X7
1001779-07 (Solid)
Wet Chemistry by EPA or APHA Standard Methods
pH 6.95 0.100 pH Units 1 A006008 23-May-10 23-May-10 9045 HoldX Total Metals by EPA 6000/7000 Series Methods
Arsenic 23 0.95 mg/kg 5 A005440 31-May-10 01-Jun-10 EPA 6020 Lead 85 0.95 " " "" " " N-02
Analyte Result
Limit Reporting Prepared Analyzed Method Notes Units Dilution Batch X8
1001779-08 (Solid)
Wet Chemistry by EPA or APHA Standard Methods
pH 7.15 0.100 pH Units 1 A006008 23-May-10 23-May-10 9045 HoldX Total Metals by EPA 6000/7000 Series Methods
Arsenic 3.2 0.96 mg/kg 5 A005440 31-May-10 01-Jun-10 EPA 6020 Lead 28 0.96 " " "" " "
Analyte Result
Limit Reporting Prepared Analyzed Method Notes Units Dilution Batch X9
1001779-09 (Solid)
Wet Chemistry by EPA or APHA Standard Methods
pH 6.18 0.100 pH Units 1 A006008 23-May-10 23-May-10 9045 HoldX Total Metals by EPA 6000/7000 Series Methods
Arsenic 3.2 0.97 mg/kg 5 A005440 31-May-10 01-Jun-10 EPA 6020 Lead 16 0.97 " " "" " "
Oilfield Environmental and Compliance The results in this report apply to the samples analyzed in accordance with the chain of custody document. This analytical report must be reproduced in its entirety.

Page 5 of 11 ends

307 Roemer Way, Suite 300, Santa Maria, CA 93454
TEL: (805) 922-4772
www.oecusa.com FAX: (805) 925-3376

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Project:

Project Number:

Project Manager:

Reported:

Analyte Result
Limit Reporting Prepared Analyzed Method Notes Units Dilution Batch X10
1001779-10 (Solid)
Wet Chemistry by EPA or APHA Standard Methods
pH 7.23 0.100 pH Units 1 A006008 23-May-10 23-May-10 9045 HoldX Total Metals by EPA 6000/7000 Series Methods
Arsenic 17 0.85 mg/kg 5 A005440 31-May-10 01-Jun-10 EPA 6020 Lead 63 0.85 " " "" " " N-02
Analyte Result
Limit Reporting Prepared Analyzed Method Notes Units Dilution Batch X11
1001779-11 (Solid)
Wet Chemistry by EPA or APHA Standard Methods
pH 7.69 0.100 pH Units 1 A006008 23-May-10 23-May-10 9045 HoldX Total Metals by EPA 6000/7000 Series Methods
Arsenic 4.4 1.0 mg/kg 5 A005440 31-May-10 01-Jun-10 EPA 6020 Lead 11 1.0 " " "" " "
Analyte Result
Limit Reporting Prepared Analyzed Method Notes Units Dilution Batch X12
1001779-12 (Solid)
Wet Chemistry by EPA or APHA Standard Methods
pH 7.60 0.100 pH Units 1 A006008 23-May-10 23-May-10 9045 HoldX Total Metals by EPA 6000/7000 Series Methods
Arsenic 7.4 0.94 mg/kg 5 A005440 31-May-10 01-Jun-10 EPA 6020 Lead 14 0.94 " " "" " "
Oilfield Environmental and Compliance The results in this report apply to the samples analyzed in accordance with the chain of custody document. This analytical report must be reproduced in its entirety.

Page 6 of 11 ends

307 Roemer Way, Suite 300, Santa Maria, CA 93454
TEL: (805) 922-4772
www.oecusa.com FAX: (805) 925-3376

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Project:

Project Number:

Project Manager:

Reported:

Analyte Result
Limit Reporting Prepared Analyzed Method Notes Units Dilution Batch X13
1001779-13 (Solid)
Wet Chemistry by EPA or APHA Standard Methods
pH 7.63 0.100 pH Units 1 A006008 23-May-10 23-May-10 9045 HoldX Total Metals by EPA 6000/7000 Series Methods
Arsenic 12 0.90 mg/kg 5 A005440 31-May-10 01-Jun-10 EPA 6020 Lead 51 0.90 " " "" " " N-02
Analyte Result
Limit Reporting Prepared Analyzed Method Notes Units Dilution Batch X14
1001779-14 (Solid)
Wet Chemistry by EPA or APHA Standard Methods
pH 5.57 0.100 pH Units 1 A006008 23-May-10 23-May-10 9045 HoldX Total Metals by EPA 6000/7000 Series Methods
Arsenic 1.9 0.90 mg/kg 5 A005440 31-May-10 01-Jun-10 EPA 6020 Lead 9.5 0.90 " " "" " "
Analyte Result
Limit Reporting Prepared Analyzed Method Notes Units Dilution Batch X15
1001779-15 (Solid)
Wet Chemistry by EPA or APHA Standard Methods
pH 8.38 0.100 pH Units 1 A006008 23-May-10 23-May-10 9045 HoldX Total Metals by EPA 6000/7000 Series Methods
Arsenic 5.0 0.97 mg/kg 5 A005440 31-May-10 01-Jun-10 EPA 6020 Lead 9.5 0.97 " " "" " "
Oilfield Environmental and Compliance The results in this report apply to the samples analyzed in accordance with the chain of custody document. This analytical report must be reproduced in its entirety.

Page 7 of 11 ends

307 Roemer Way, Suite 300, Santa Maria, CA 93454
TEL: (805) 922-4772
www.oecusa.com FAX: (805) 925-3376

Page 1084 of 1256 ends

Project:

Project Number:

Project Manager:

Reported:

Analyte Result
Limit Reporting Prepared Analyzed Method Notes Units Dilution Batch X16
1001779-16 (Solid)
Wet Chemistry by EPA or APHA Standard Methods
pH 6.76 0.100 pH Units 1 A006008 23-May-10 23-May-10 9045 HoldX Total Metals by EPA 6000/7000 Series Methods
Arsenic 4.6 0.96 mg/kg 5 A005440 31-May-10 01-Jun-10 EPA 6020 Lead 8.2 0.96 " " "" " "
Oilfield Environmental and Compliance The results in this report apply to the samples analyzed in accordance with the chain of custody document. This analytical report must be reproduced in its entirety.

Page 8 of 11 ends

307 Roemer Way, Suite 300, Santa Maria, CA 93454
TEL: (805) 922-4772
www.oecusa.com FAX: (805) 925-3376

Page 1085 of 1256 ends

Project:

Project Number:

Project Manager:

Reported:

Result Limit
Reporting
Units Level
Spike
Result
Source
%REC
%REC
Limits RPD
RPD
Analyte Limit Notes
Wet Chemistry by EPA or APHA Standard Methods - Quality Control Batch A006008 - EPA 9045 pH Prep
LCS (A006008-BS1) Prepared & Analyzed: 23-May-10
pH pH Units 4.06 0.100 4.00 10 102 90-110
LCS (A006008-BS2) Prepared & Analyzed: 23-May-10
pH pH Units 7.08 0.100 7.00 10 101 90-110
LCS (A006008-BS3) Prepared & Analyzed: 23-May-10
pH pH Units 9.98 0.100 10.0 10 99.8 90-110
Duplicate (A006008-DUP1) Source: 1001779-01 Prepared & Analyzed: 23-May-10 pH pH Units 7.12 0.100 7.09 10 0.422
Oilfield Environmental and Compliance The results in this report apply to the samples analyzed in accordance with the chain of custody document. This analytical report must be reproduced in its entirety.

Page 9 of 11 ends

307 Roemer Way, Suite 300, Santa Maria, CA 93454
TEL: (805) 922-4772
www.oecusa.com FAX: (805) 925-3376

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Project:

Project Number:

Project Manager:

Reported:

Result Limit
Reporting
Units Level
Spike
Result
Source
%REC
%REC
Limits RPD
RPD
Analyte Limit Notes
Total Metals by EPA 6000/7000 Series Methods - Quality Control Batch A005440 - EPA 3050B
Blank (A005440-BLK1) Prepared: 31-May-10 Analyzed: 01-Jun-10 Arsenic mg/kg ND 0.20
Lead ND 0.20 "
LCS (A005440-BS1) Prepared: 31-May-10 Analyzed: 01-Jun-10 Arsenic mg/kg 16.3 0.20 15.0 20 108 85-115
Lead 15.6 0.20 15.0 20 " 104 85-115
LCS Dup (A005440-BSD1) Prepared: 31-May-10 Analyzed: 01-Jun-10 Arsenic mg/kg 16.4 0.20 15.0 20 109 0.904 85-115
Lead 15.4 0.20 15.0 20 " 102 1.25 85-115
Duplicate (A005440-DUP1) Source: 1001779-01 Prepared: 31-May-10 Analyzed: 01-Jun-10 Arsenic mg/kg 3.89 0.95 3.59 20 8.11
Lead 18.8 0.95 18.9 20 " 0.233
Matrix Spike (A005440-MS1) Source: 1001779-01 Prepared: 31-May-10 Analyzed: 01-Jun-10 Arsenic mg/kg 256 3.5 262 3.59 20 96.2 73-124
Lead 279 3.5 262 18.9 20 " 99.4 61-138
Matrix Spike Dup (A005440-MSD1) Source: 1001779-01 Prepared: 31-May-10 Analyzed: 01-Jun-10 Arsenic mg/kg 272 3.7 280 3.59 20 96.0 0.263 73-124
Lead 295 3.7 280 18.9 20 " 98.6 0.746 61-138
Oilfield Environmental and Compliance The results in this report apply to the samples analyzed in accordance with the chain of custody document. This analytical report must be reproduced in its entirety.

Page 10 of 11 ends

307 Roemer Way, Suite 300, Santa Maria, CA 93454
TEL: (805) 922-4772
www.oecusa.com FAX: (805) 925-3376

Page 1087 of 1256 ends

Project:

Project Number:

Project Manager:

Reported:

Notes and Definitions
N-02 Analyte concentration below TTLC but above 10 X STLC.

HoldX Sample holding time expired.

Sample results reported on a dry weight basis
RPD Relative Percent Difference
dry
NR Not Reported
ND Analyte NOT DETECTED at or above the reporting limit DET Analyte DETECTED
Oilfield Environmental and Compliance The results in this report apply to the samples analyzed in accordance with the chain of custody document. This analytical report must be reproduced in its entirety.

Page 11 of 11 ends

307 Roemer Way, Suite 300, Santa Maria, CA 93454
TEL: (805) 922-4772
www.oecusa.com FAX: (805) 925-3376

Page 1088 of 1256 ends

CHAIN OF CUSTODY
Page l of z_
City/State/ZIP: .,~ ~~ CA '13£.c::.3 Analysis Requested Special Instructions:
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E-mail:

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CHAIN OF CUSTODY
Page~ of .. %.

Special Instructions:
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(. ISltlsAMPLE RECEIPT -.;;;;::;;;; Rev 01/IS/10
CLIENT: tJad€,/;/l/rl()n OEC ID#: _/~o~o_r_r_7 _1.7_ Temp: ---=-q;-· __ ° C Acceptable Range: 0°C to 6°C
COC RECEIVED ~Jg.:;.//() RECEIPT LOGIN
DATE/TIME: 17()0 DATE/TIME: sh.<1/Jo /Jtit/ .;J- REFRIGERA TOR(s): l , , I , SAMPLE TRANSPORT, RECEIPT, CONDITION & PRESERVATION: Yes No N/A (*)PROBLEM CHAIN FORM N1e11nvD ~EC Courier/Sampler COC document(s) received with samples rn' D* D Custody Seals (circle): Pres6bs~ ~elivery(Other than OEC Courier) Correct containers for analysis requested ~ D* D Samples I Coolers
Samples Received on Ice Container(s) intact and in good condition D* 0 Intact i Broken* 0 Samples Received Outside Temp. Range* Container label(s) consistent with COC ~ D* ~ Method of Shipment & Tracking #(if apphcablel
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CONTAINERS, COC CHANGES AND/OR CORRECTIONS CHANGES AUTHORIZED BY:

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Page 1 of 6 ends

ASSISTANT PUBLIC WORKS & UTILITIES DIRECTOR FONTES
THROUGH: CITY MANAGER MENDEZ
SUBJECT: RESOLUTION APPROVING AN IN-LIEU FEE TO REDUCE

VEHICLE MILES TRAVELED (VMT) ASSOCIATED WITH
DEVELOPMENT PROJECTS AND FINDING THAT THE VMT INLIEU FEE IS NOT CONSIDERED A PROJECT OR IF A PROJECT,

IS EXEMPT UNDER CEQA
RECOMMENDED ACTION:

Staff recommends that City Council adopt a Resolution:

1. Finding the approval of a VMT In-Lieu fee and the establishment of a fund is not a project under CEQA, or if a project is exempt under CEQA; and

2. Approving the adoption of a VMT In-Lieu fee.

DISCUSSION:

Background
The Vehicle Miles Traveled (VMT) Policy adopted by Council Resolution No. 205-22 on September 27, 2022, describes how the City (as the agency responsible for the approval of land use, construction, and transportation projects) is required to assess the anticipated environmental impacts of development projects.

In 2013, Senate Bill (SB) 743 (Steinberg) changed how transportation impacts of a project are analyzed. The Bill determined that the most appropriate way to measure a project's transportation impacts is by using a VMT analysis as opposed to the prior methodology, Level of Service (LOS). The VMT Policy staff report is included as Attachment 1.

The intent of SB 743 is to bring California Environmental Quality Act (CEQA) transportation analyses into closer alignment with other statewide policies regarding greenhouse gas emissions, complete streets, and smart growth. As of July 1, 2020, automobile delay and LOS may no longer be used as the performance measure to determine the transportation impacts of land development projects under CEQA. Using VMT as a performance measure instead of LOS is intended to discourage urban sprawl, reduce greenhouse gas emissions, and encourage the development of smart growth, complete streets, and multimodal transportation networks.

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If a project is not screened out based on the criteria for identifying the types of projects that can be presumed to have a less than significant impact (e.g., small projects with less than 110 trips per day) and the project’s transportation-related impacts are likely to be above the Thresholds of Significance in the VMT Policy (e.g., above 15% below the county-wide average VMT per capita), then it is subject to a detailed VMT analysis and application of mitigation measures to reduce the project’s VMT. As discussed in the September 27, 2022 staff report on page 5, since the menu of Transportation Demand Management (TDM) strategies to reduce a project’s VMT, such as promoting rideshare programs or allowing telecommuting, is limited to up to 15 percent, there is a need for additional options, such as the payment of in-lieu fee.

Monetary Value of VMT
The VMT Policy established a VMT Mitigation Banking Program to provide an additional VMT mitigation option for project developers. In order to implement the banking program, a value for VMT reduction was determined. The analysis determined the monetary value of VMT by considering the following:
 Appropriate projects that are not listed in the City's Capital Improvement Program  The cost to construct the projects
 The anticipated reduction in VMT associated with the complete projects Through the analysis, the cost per VMT, was found to be $1,524.21. The VMT Program has identified the following trail improvements that the VMT In-Lieu fee will fund:

Table 1: VMT Banking Projects List
How the Fee Would be Used

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Note that there is a flat fee for every single vehicle mile travel reduction. For example, if a project is unable to reduce the VMT impact of the project by 1 VMT, the developer may elect to pay an in-lieu fee of $1,524.21 for a single VMT reduction. The fee will be placed in the VMT fund where the funds will be used on projects that have an anticipated reduction of VMT. The $1,524.21 in this example will be used to construct projects that will result in a corresponding VMT reduction, such as through the creation of new trails that allow residents to commute to work or run errands by foot or bike.

Fee Details (Compliance with the Mitigation Fee Act - Assembly Bill 1600) The Mitigation Fee Act (Assembly Bill 1600) sets forth the procedures for adopting fees and exactions that apply to development projects. Since the VMT in-lieu fee is not imposed on development projects, but rather paid by developers on a voluntary basis, the Mitigation Fee Act’s requirements most likely to not apply to the adoption of the VMT in-lieu fee. However, in an abundance of caution, the City commissioned Kimley Horn to provide a nexus evaluation in compliance with the Mitigation Fee Act to determine the appropriate purpose, use, relationship to development, and relationship between development and cost of improvements. The Kimley Horn nexus evaluation is included in the VMT policy set forth in Attachment 2.

The requirements of the Mitigation Fee Act are summarized below:
 Identify the purpose of the VMT In-Lieu fee
The purpose of the fee is to reduce and/or mitigate project-generated VMT in compliance with SB 743 and CEQA regulations. This also aligns with the goals and objectives of the City’s Climate Action and Adaptation Plan (CAAP).  Identify the use to which the fee is to be put
Projects included in the City’s VMT Mitigation Banking Program will fund the construction of facilities that support active transportation (cycling and walking) to mitigate VMT impacts from new development by moving trips from automobiles to bike or pedestrian facilities. The identified projects are outlined in Table 1.  Determine a reasonable relationship between the fee’s use and the type of development project on which the fee is imposed
As pedestrian and bicycle improvements cannot be sufficiently analyzed using the Travel Demand Model (TDM) given limitations within the model related to the representation of bike and pedestrian facilities, the projects were analyzed using offmodel techniques. Bike improvements were evaluated using NCHRP 552 Guidelines for Analysis of Investments in Bicycle Facilities, and focused on commute riders, rather than bicyclists riding for exercise only. These bike ridership estimates are listed in Exhibit 8 to the VMT Policy.

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3/10/2023 12:16:21 PM3/10/2023 8:58:58 AM3/9/2023 5:22:26 PM C:\Program Files\eSCRIBE\TEMP\12153976516\12153976516,,,RECOMMENDATION ON AN IN LIEU FEE TO REDUCE VEHICLE MILES TRAVELED (VMT) AND ESTABLISHING AN IMPACT FEE FUND.docxP:\FORMS\Agenda Report Template.doc Based on the study, the bicycle improvement projects listed in Table 1 could add almost 7,350 riders per day throughout the City through 2032, which could double the existing bicycle ridership.
 Determine how there is a reasonable relationship between the need for public facility and type of development
Based on research conducted by California Air Pollution Control Officers Association, the maximum reduction in VMT that can be feasibly attained using exclusively sitespecific mitigation measures in a suburban context is 15%. Site-specific solutions most often rely on TDM measures, although project land use modifications can also be utilized to mitigate impacts. The projects that exceed the VMT significant impact thresholds by more than 15% must rely on non-site-specific approaches if full mitigation is to be achieved.

Based on this, if a project exceeds the City’s VMT threshold by more than 15%, it will require a combination of site-specific measures and non-site-specific measures, including the VMT Mitigation Bank, in order to achieve mitigation. This could mean using only site-specific mitigation measures to reach the 15% threshold, using only the VMT Mitigation Bank to reach the 15% threshold, or using both to reach the 15% threshold, such as using TDM measures to reduce VMT by 6%, and then using the VMT Mitigation Bank to reduce VMT by the remaining 9%.
 Determine a reasonable relationship between the amount of the fee and the cost of the facility attributable to development
The Nexus Study followed the following 4 steps to identify the VMT Banking projects and calculate the VMT Banking credit rate:

1. Identify appropriate mitigation projects;

2. Determine the cost of construction of the mitigation projects;

3. Determine the total VMT that can be mitigated by the projects; and

4. Calculate the maximum mitigation credit rate per VMT by dividing the total cost of the mitigation projects by the total VMT mitigated by the projects to determine the rate per unit of VMT.

To determine the maximum overall credit rate, the total project costs of $44,799,000 was divided by total VMT reduction of 29,392 daily VMT. This calculation resulted in a maximum cost per VMT reduction of $1524.21. The full analysis is included in the adopted VMT Policy, included as Attachment.

Fee Account Rules and Specific Information for Public Review The collected fees will be held in a VMT In-Lieu fee account and expended on projects identified in the VMT Policy. The City Engineer will monitor the fund to ensure purchased VMT credits are used for constructing appropriate projects as identified in the VMT Policy to achieve the intended VMT reduction. As part of the annual Capital Improvement Program (CIP) reporting to Planning Commission and City Council, the City Engineer shall include a progress report on any funds accumulated in the VMT Mitigation Banking Program and expenditures on constructing or improving active transportation facilities providing additional VMT-reducing investments that would not have occurred if bank funding were not available. The City Engineer

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Supplemental Funding
The VMT In-Lieu fee is intended to fund identified facilities, or portions thereof, needed to mitigate, in whole or in part, VMT impacts created by future development in the City. Direct impact project mitigation measures and other revenue sources may also be used to augment funding of these facilities. Sources of additional revenue may include, but are not limited to:
 General and special taxes (including property taxes, Measure D Funds, Gas Tax, and other sales/use taxes)
 State and federal grant monies
 General fund
The existence and availability of additional funding sources may help the City leverage other infrastructure dollars. For example, grant programs often require a high level of difficult-to find matching funds. Having a VMT In-Lieu fee demonstrates a committed plan of action for facility improvements and the revenues can provide a ready source for Program Implementation matching funds.

At this point, the City has not secured any supplemental funding from other sources. In the event that the City does secure supplemental funding to increase revenues available for VMT reduction projects, the City will reevaluate the VMT In-Lieu fee to account for the additional funding streams.

Environmental Review
The adoption of the VMT In Lieu fee is not subject to the California Environmental Quality Act (“CEQA”). This action is not a project within the meaning of the CEQA Guidelines Section 15378 and 15061(b)(3) as it has no potential for physical effects on the environment because it involves an adoption of certain rates and/or charges imposed by the City and does not select or approve any specific project, and said rates and/or charges will be used to fund future projects and/or activities, each of which future projects and/or activities will be fully evaluated in compliance with CEQA when sufficient physical details regarding said projects and/or activities are available to permit meaningful CEQA review (see CEQA Guidelines, Section 15004(b)(1)). Pursuant to CEQA Guidelines section 15378(b)(4), the creation of government funding mechanisms which do not involve the selection or approval of any specific project which may cause significant effect on the environment, is not defined as a “project” under CEQA.

Therefore, approval of the rates and/or charges is not a “project” for purposes of CEQA, pursuant to CEQA Guidelines, Section 15378(b)(4); and, even if considered a “project” under CEQA, is exempt from CEQA review pursuant to CEQA Guidelines Section 15061(b)(3) because it can be seen with certainty that there is no possibility that approval of the rates and/or charges may have a significant effect on the environment.

STRATEGIC PLAN:

This project is consistent with the following Strategic Plan Priorities:
1-Housing
3-Infrastructure & Environment

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ALTERNATIVE ACTION:

The City Council may choose to not approve the proposed VMT In-Lieu fee. However, Council has approved the VMT Policy without the fee the City will not provide an additional option for projects needing to reduce VMT impacts below applicable thresholds. This would cause significant hardship to development projects that cannot reduce their VMT impacts with TDM measures, and increase the cost and time required to comply with CEQA.

ATTACHMENTS AND/OR REFERENCES:

Attachment 1: September 27, 2022 VMT Policy Council Staff Report Attachment 2: Adopted VMT Policy

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PUBLIC WORKS & UTILITIES DIRECTOR DI RENZO

JUSTIN MEEK, AICP, PRINCIPAL PLANNER
MARIA ESTHER RODRIGUEZ, P.E., ASSIST. PW&U DIRECTOR
THROUGH: CITY MANAGER MENDEZ
SUBJECT: RESOLUTION APPROVING VEHICLE MILES TRAVELED POLICY

STATEMENT OF ISSUES
On September 6, 2022, the Planning Commission of the City of Watsonville adopted Resolution No. 14-22 (PC), recommending the City Council adopt a Vehicle Miles Traveled (VMT) Policy establishing VMT as the appropriate metric for evaluating transportationrelated impacts under the California Environmental Quality Act (CEQA).

RECOMMENDED ACTION
Staff recommends that the City Council adopt a Resolution:
1) Approving a VMT Policy inclusive of establishing VMT as the appropriate metric for evaluating transportation-related impacts under CEQA, establishing VMT thresholds of significance, establishing screening criteria, establishing Transportation Demand Management (TDM) strategies, and establishing a VMT Mitigation Banking Program; and
2) Authorizing the Community Development Director to update the VMT thresholds of significance for land use projects and plans; and
3) Finding the approval of a VMT Policy, including the VMT Mitigation Banking Program is not a “project” under CEQA, or if a “project,” exempt under the “common sense” exception (14 Cal. Code Regs. § 15061(b)(3)).

BACKGROUND
The California Environmental Quality Act requires public agencies responsible for approval of land use projects and construction of transportation projects to assess their anticipated environmental impacts and to select project alternatives or implement mitigation measures that lessen those impacts where feasible.1 Known as a “lead agency” under CEQA, a public agency with the discretionary authority to approve or deny a project (or to carry it out 1 Cal. Pub. Res. Code § 21100 et seq. See 14 Cal. Code Regs. §§ 15000 et seq. (CEQA Guidelines).

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directly) generally must analyze the proposed project’s impacts to the physical environment, identify alternatives and mitigation measures, and approve a project alternative and/or mitigation measures that substantially reduce significant impacts, unless those measures are infeasible due to economic, social, or other conditions.2 In 2013, state law was changed with the passage Senate Bill (SB) 743 (Steinberg) to update the way transportation impacts are analyzed under CEQA for new land use and transportation projects. Previously, transportation analyses had been based on automobile delay, typically measured as “level of service,” or LOS. SB 743 also required the Governor’s Office of Planning and Research (OPR) to develop a new metric for evaluating transportation impacts other than LOS to more appropriately balance the needs of congestion management with statewide goals related to infill development, promotion of public health through active transportation, and reduction of greenhouse gas emissions.

In 2018, after five years and over 200 public meetings and other outreach events, OPR released updates to the state’s CEQA Guidelines to implement SB 743 by replacing LOS with VMT as the most appropriate measure of a project’s transportation impacts; this update was formally certified and adopted by the California Natural Resources Agency and codified as section 15064.3 of the CEQA Guidelines (Attachment 1). Simultaneously, OPR released a Technical Advisory on Evaluating Transportation Impacts in CEQA (Attachment 2). The Technical Advisory includes recommendations for thresholds of significance for evaluating impacts of office, residential and retail developments, and provides screening criteria for identifying the types of projects that can be presumed to have a less than significant impact.

In order to comply with SB 743, the City of Watsonville joined the Cities of Capitola, Santa Cruz, and Scotts Valley and the County of Santa Cruz to collectively approach this new paradigm of measuring transportation impacts for the purposes of conducting environmental review. The Cities and County hired Kimley Horn & Associates, a transportation consulting firm, to assist with the necessary work, including updating baseline traffic conditions, updating and running the county-wide Travel Demand Model, creating screening maps, and producing thresholds of significance for the Santa Cruz region. This work forms the foundation of the City’s proposed VMT Policy, and was used by other jurisdictions within our region that have adopted VMT thresholds of significance and SB 743 guidelines in conformance of with section 15064.3 of the CEQA Guidelines and OPR’s Technical Advisory.

In preparation for adopting a VMT Policy, staff gave an informational presentation to the Planning Commission in March 2020 (presentation slides, minutes) and maintains a website on the topic (link). On September 6, 2022, staff introduced the proposed VMT Policy for consideration by the Planning Commission. At the conclusion of the public hearing, the Planning Commission adopted Resolution No. 14-22 (PC), recommending the City Council adopt a VMT Policy inclusive of establishing VMT as the appropriate metric for evaluating transportation-related impacts under CEQA, establishing VMT thresholds of significance, establishing screening criteria, establishing TDM strategies, and establishing a VMT Mitigation Banking Program.

2 Cal. Pub. Res. Code §§ 21100 (state agencies), 21151 (local agencies); Cal. Pub. Res. Code § 21002.1 (project selection and feasibility).

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DISCUSSION
SB 743 Intent
The intent of SB 743 is to bring CEQA transportation analyses into closer alignment with other statewide policies regarding greenhouse gases, complete streets, and smart growth.

As of July 1, 2020, automobile delay and LOS may no longer be used as the performance measure to determine the transportation impacts of land development projects under CEQA. Using VMT as a performance measure instead of LOS is intended to discourage suburban sprawl, reduce greenhouse gas emissions, and encourage the development of smart growth, complete streets, and multimodal transportation networks. Previously, when using LOS, the environmental impact analysis process could impede infill and other beneficial projects.

In changing the way that transportation impacts are measured under CEQA, SB 743 is removing a hurdle to building new development in a way that allows Californians more options to drive less. This change should help achieve the state’s climate commitments, discourage greenfield development, preserve more of the environment, improve health and safety, and boost local economies by prioritizing co-located jobs, services, and housing.

On average, it should also reduce the time spent driving to get places and foster more choices for how people travel, which would help to promote business, provide access to opportunity, and improve quality of life in one’s community and across the state.

LOS and VMT
“Level of service,” or LOS, is a measure of delay or congestion. It is based on a road’s volume-to-capacity and measures a driver’s perception of convenience. As shown in Table 1, a road that has free-flowing traffic—i.e., no delay—is given a LOS of “A”; whereas, a road where drivers experience a delay of 80 second or more is graded LOS “F.” Previously, a project’s contribution to a roadway’s LOS was treated as an environmental impact. And if a project was determined to generate a large number of new trips, that say reduced the LOS of an intersection from “C” to “D,” it would often have to mitigate this impact by increasing the capacity of the intersection or nearby roadway segments. Increasing a roadway’s capacity, however, has the unintended effect of often inducing further driving without reducing congestion because of pent up desire for travel known as latent demand.
3,4

3 “Induced travel” refers to an increase in total vehicle mileage due to roadway improvements that increase vehicle trip frequency and distance, but exclude travel shifted from other times and routes. For more information, see Generated Traffic: Implications for Transport Planning by Todd Litman. 4 “Latent demand” refers to additional trips that would be made if travel conditions improve (i.e., less congested roads, higher design speeds, lower vehicle costs or tolls). For more information, see Generated Traffic: Implications for Transport Planning by Todd Litman Attachment 1

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TABLE 1 LOS Criteria for Signalized Intersections1
LOS Control Delay
(seconds/vehicle)
Travel Speed at %
Free-Flow Speed
A ≤ 10 > 85
B > 10 and ≤ 20 > 67 and ≤ 85
C > 20 and ≤ 35 > 50 and ≤ 67
D > 35 and ≤ 55 > 40 and ≤ 50
E > 55 and ≤ 80 > 30 and ≤ 40
F > 80 > 30
Notes:

1. Adapted from the 2000 and 2010 Highway Capacity Manual for urban streets. “Vehicle Miles Traveled,” or VMT, is a measure of the amount and distance people travel by car. Therefore, switching from LOS to VMT changes the transportation impact analysis from people’s perception of convenience to an evaluation of the amount and distance that a project might cause people to drive and the associated greenhouse gas emissions released into the environment.

VMT Policy
Now that the primary consideration in transportation environmental analysis under CEQA must be the amount and distance that the project might cause people to drive, any Environmental Impact Report (EIR) and Negative Declaration circulated for public review are required to consider VMT when determining whether a project may cause a significant impact. Staff has proposed a VMT Policy document setting forth guidelines for how the City shall implement SB 743 in compliance with the updated CEQA Guidelines (Attachment 3).

A description of key provisions are summarized below.

Thresholds of Significance
Lead agencies under CEQA may establish thresholds of significance for the purpose of determining whether a project may cause a significant effect.5 When adopting or using thresholds of significance, a lead agency may consider recommendations by other public agencies or experts, provided that they are supported by substantial evidence. For land use projects, the Technical Advisory states, “OPR recommends that a per capita or per employee VMT that is fifteen percent below that of existing development may be a reasonable threshold” based on substantial evidence related to the state’s greenhouse gas reduction goals.6,7 The proposed VMT Policy includes establishing the following thresholds of significance based on OPR’s recommendations:

5 14 Cal. Code Regs. 14 §§ 15064(b)(2), 15064.7(b). 6 OPR (2018), OPR Technical Advisory on Evaluating Transportation Impacts in CEQA, p. 10. For additional information, refer to pages 10-12 in Attachment 2. 7 In its document California Air Resources Board 2017 Scoping Plan-Identified VMT Reductions and Relationship to State Climate Goals (2019), CARB assessed VMT reduction per capita consistent with its evidence-based modeling scenario that would achieve State climate goals of 40 percent GHG emissions reduction from 1990 levels by 2030 and 80 percent GHG emissions reduction levels from 1990 by 2050. CARB found that overall per-capita vehicle travel would need to be approximately 14.3 percent Attachment 1

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• Residential projects: 15% below existing county-wide average VMT per capita8 • Office projects: 15% below existing county-wide average Work VMT per employee9 • Retail projects: No net increase (based on county-wide VMT)10 • Other customers: No net increase (based on county-wide VMT for similar land uses)
• Other employment: 15% below existing county-wide average Work VMT per employee for similar uses
As shown in Table 2, currently the per employee average VMT for work-related commute trips to office land uses is 7.4 miles. The per capita average VMT for residents is a little greater at 8.9 miles. While VMT thresholds will remain the same, the VMT averages will be updated periodically based on additional available travel data, improved VMT modeling, and changes in driving behavior (e.g., shifting modes from driving far distances or alone to shorter distances or using an alternative mode of transportation, such as walking, bicycling and taking transit).

TABLE 2 VMT for Residential and Office Land Uses
Land Use VMT Basis
Residential 8.9 VMT/capita11 15% below existing county-wide average VMT per capita Office 7.4 Work VMT/employee12 15% below existing county-wide average Work VMT per employee If a project is not screened out with the criteria outlined, as further described below, then it is subject to a detailed VMT analysis. Should a project exceed the threshold of significance, a menu of accepted Transportation Demand Management (TDM) strategies are available to reduce the project’s VMT to an acceptable level, which are described in detail in Appendix C of Attachment 3. Since TDM measures may feasibly reduce VMT up to 15 percent, there will be times when a project will need additional options for mitigating its VMT impacts. Therefore, the VMT Policy also includes a VMT Mitigation Banking Program to help address the need for additional VMT mitigation.

Screening Criteria
The proposed VMT Policy includes screening criteria for determining whether certain types of projects may be presumed to not result in a significant impact. Projects that meet one or more of these criteria would be “screened out” from having to conduct further detailed VMT

lower than existing levels. Therefore, below this level, a project could be considered low VMT and would, on that metric, be consistent with 2017 Scoping Plan Update assumptions that achieve state climate goals. 8 OPR recommends using a 15 percent below existing VMT per capita as a threshold of significance, because a residential project measured in this way should not cumulatively exceed the population or number of units specified for Watsonville in the MTP/SCS. Conversely, projects that result in greater-than-planned development above the county-wide threshold would undermine the VMT containment needed to achieve regional targets under SB 375. For additional information, refer to VMT Thresholds of Significance on page 8 in Attachment 3 and Recommended Numeric Thresholds for Residential, Office, and Retail Projects on page 15 in Attachment 2. 9 Similarly, OPR recommends using a 15 percent below existing VMT per employee as a threshold of significance, because office projects that would generate vehicle travel above this threshold would likely indicate a significant transportation impact. For additional information, refer to VMT Thresholds of Significance on page 8 in Attachment 3 and Recommended Numeric Thresholds for Residential, Office, and Retail Projects on page 16 in Attachment 2. 10 Because new retail development typically redistributes shopping trips rather than create new trips, basing a threshold of significance on the total change in VMT—i.e., the difference in total VMT in area affected with and without the project—is recommended by OPR as the way to analyze a retail project’s transportation impacts. For additional information, refer to Recommended Numeric Thresholds for Residential, Office, and Retail Projects on page 16 in Attachment 2. 11 Residential VMT specifically applies to all home-based trips as represented in the Travel Demand Model. Refer to Appendix A in Attachment 3 for additional information. 12 Work VMT specifically applies to commute trips as represented in the Travel Demand Model. Refer to Appendix A in Attachment 3 for additional information.

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analysis. The following is a summary of the screening criteria based on project size, maps, transit availability, local-serving retail, and provision of affordable housing. These criteria were developed in accordance with OPR’s Technical Advisory on evaluating transportation impacts in CEQA.
• Small Projects. If a project generates or attracts less than 110 trips per day, and is consistent with the General Plan and Metropolitan Transportation Plan/Sustainable Communities Strategy (MTP/SCS), that project may be presumed to cause a lessthan-significant transportation impact. • Proximity to Transit Stations. Lead agencies generally should presume that certain projects (including residential, retail, and office projects, as well as projects that are a mix of these uses) proposed within ½ mile of an existing major transit stop13 or an existing stop along a high-quality transit corridor14 will have a less-thansignificant impact on VMT. This presumption would not apply, however, if projectspecific or location-specific information indicates that the project will still generate significant levels of VMT, as might be the case if the project has a floor area ratio (FAR)15 of less than 0.75, includes parking in excess of requirements, is inconsistent with local and regional plans (i.e., the General Plan and MTP/SCS), or replaces affordable units with a smaller number of market rate units. • Local-Serving Retail. If a project includes a retail component with a floor area16 up to 50,000 square feet and is considered local serving, the project would result in a net decrease in VMT and may be presumed to cause a less-than-significant transportation impact. New retail development typically redistributes shopping trips rather than create new trips. Because of this fact, adding retail opportunities will often shorten the distance people drive to shop and, thereby, reduce VMT.

Generally, however, retail development consisting of stores larger than 50,000 square feet are considered regional-serving. Unlike local-serving retail development, regional-serving retail development often leads to the substitution of shorter trips for longer ones, resulting in a net increase in VMT.
• Affordable Residential Development. Adding affordable housing to infill locations generally improves jobs-housing match, in turn shortening commutes and reducing VMT. Projects that are 100% affordable residential development, or the residential component of a mixed-use development, in infill locations are presumed to have a less than significant impact on transportation under CEQA. Furthermore, a project which includes any affordable residential units may factor the effect of the affordability on VMT into the assessment of VMT generated by those units. 13 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 interval of 15 minutes or less during the morning and afternoon peak commute periods (Cal. Pub. Res. Code § 21064.3). 14 A “high-quality transit corridor” means a corridor with fixed route bus service with service intervals no longer than 15 minutes during peak commute hours (Cal. Pub. Res.

Code § 21155). 15 “Floor area ratio,” or FAR, means the total area of a building on a lot divided by the total area of the lot (Watsonville 2005 General Plan Glossary, p. 210; WMC § 14-

18.362). 16 “Floor area” is defined as the total gross footage of a building or structure, but not including any area within the building used for required off-street parking (Watsonville 2005 General Plan Glossary, p. 210; WMC § 14-18.358).

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• Local Essential Service. Similar to local-serving retail, the addition of necessary local in-person services will reduce VMT given that trips to these locations will be made irrespective of distance given their inelastic, non-discretionary nature. The following types of projects are presumed to cause a less-than-significant transportation impact: day care centers, public K-12 schools, police or fire facilities, medical/dental offices, assisted living/memory care facilities, and government offices.
• Map-Based Screening (Development in Low-VMT Areas). Maps showing existing VMT values within a city are referred to as heat maps. These maps display colors representing the level of variation from a local or regional VMT reference average for a jurisdiction. The purpose of these heat maps is to determine if a project could be located in an area with low existing VMT.

OPR’s Technical Advisory indicates that residential and office projects in areas of low VMT, which are compatible with surrounding development in terms of density, mix of uses, and transit accessibility, will exhibit similarly low VMT. Therefore, these projects are presumed to have a less-than-significant VMT impact. OPR’s Technical Advisory also recommends using regional as opposed to citywide geographies for reviewing office development, as employees often commute from outside the city boundary to their jobs. Under the recommended approach for map-based screening, projects located in low-VMT areas (zones with VMT that is at least 15% below the regional average VMT) would be presumed to have a less-than-significant transportation impact under CEQA.

The OPR Technical Advisory includes further detailed discussion on each of these screening criteria that are presumed to have a less-than-significant transportation impact (Attachment 2).

VMT Mitigation Banking Program
The proposed VMT Policy includes a VMT Mitigation Banking Program to provide an additional VMT mitigation option. A mitigation bank creates a monetary value for VMT reduction such that a developer could purchase VMT reduction credits, which would allow a project’s transportation impacts to be reduced below applicable VMT thresholds. The underlying VMT Banking Projects identified in the proposed Policy may be either regionally or locally beneficial to the area in which the project is located. This option is needed because TDM measures often have limited effectiveness in suburban settings like Watsonville, which has fairly low-density development patterns and limited transit service.

The City will set up a separate account for the purpose of tracking the collection of payments into the VMT Mitigation Banking Program. This account will be monitored by the City Engineer to ensure purchased VMT credits are used for constructing appropriate projects to achieve the intended VMT reduction. As part of the annual Capital Improvement Program (CIP) reporting to Planning Commission and City Council, the City Engineer shall include a progress report on any funds accumulated in the VMT Mitigation Banking Program and expenditures on constructing or improving active transportation facilities providing additional VMT-reducing investments that would not have occurred if this funding Attachment 1

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Planning Commission Comments
During the September 6th Planning Commission meeting, the Commissioners all reviewed the proposed VMT Policy and provided comments. Of particular note where comments from Commissioner Rojas and Kammer.

Commissioner Rojas inquired about the VMT Mitigation Banking Program and posed a hypothetical example to understand whether a developer would be charged a fee if the transportation impact analysis for a new project was determined to be above the relevant VMT threshold. In response, staff clarified that the VMT Mitigation Banking Program provided another option for mitigating transportation-related impacts. A developer may choose to purchase VMT reduction credits for mitigating the project’s VMT impact, which in turn would serve as a new funding source for building new trails identified in the City’s Trails & Bicycle Master Plan (2012).

In responding to Commissioner Rojas’ follow-up question about whether or not a developer agrees to pay a fee for mitigating transportation-related impacts, staff noted that not doing so and going the EIR route would be more expensive, take more time, and may have other CEQA related implications (e.g., having to make findings of significant and unavoidable impact).

Commissioner Kammer recommended that Planning Commissioners and City Council members review the proposed trails and bicycle network map in the Trails & Bicycle Master Plan.
17 Commissioner Kammer further noted that she supports the establishment of a VMT Mitigation Banking Program that could fund trail projects, which would both provide a better connected trail network and help meet the City’s climate goals.

Public Comments
No public comments were received at the Planning Commission hearing relating to the proposed VMT Policy.

Subsequent Updates
The City may update the VMT thresholds and methodology on an as needed basis to reflect changes in CEQA requirements, new methodological refinements, or other process improvements moving forward. As such, the City should periodically review these SB 743 implementation guidelines and project developers and transportation consultants should contact the City to ensure that they are applying current City requirements for evaluating VMT impacts under CEQA.

Environmental Review
The proposed VMT Policy, including the VMT Mitigation Banking Program, is consistent with state law, in that it would allow the City to implement SB 743 in accordance with OPR’s

17 See Figure 3-1: Greater Watsonville Trail Master Plan on page 39 of the City’s Trails & Bicycle Master Plan for the Watsonville Scenic Trail Network (2012), which is available on the City’s website at: https://www.cityofwatsonville.org/774/Urban-Greening-Plan.

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technical guidelines on evaluating transportation impacts in CEQA. The adoption of a VMT Policy is not a “project” as defined in section 15378 of the CEQA Guidelines and Public Resources Code section 21065, as this is not a “project” that may cause a direct, or reasonably foreseeable indirect, physical change in the environment. The VMT Policy is an administrative activity of the City, providing guidance to property owners, project developers, applicants and proponents for determining the significance of transportation impacts of land use projects. The VMT Policy would not approve any specific development and would therefore not lead to any particular physical change to the environment.

Moreover, even if found to be a “project,” the VMT Policy is exempt under the “common sense” exception (14 Cal. Code Regs. § 15061(b)(3)) because it can be seen with certainty that there is no possibility that the action of adopting the Policy would have a significant effect on the environment.

CONCLUSION
SB 743 changed the way that transportation impacts are evaluated under CEQA. The Planning Commission adopted Resolution No. 15-22 (PC) recommending the City Council adopt the proposed VMT Policy for analyzing VMT in accordance with SB 743 and CEQA.

The proposed VMT Policy provides guidelines for how a land use or transportation project would be evaluated in accordance with this state law and OPR’s Technical Advisory on evaluating transportation impacts. The proposed VMT Policy removes automobile delay as a significant impact on the environment and replaces it with a VMT threshold for all CEQA environmental determinations.

STRATEGIC PLAN
The purpose of the City of Watsonville’s 2021-2023 Strategic Plan is to help the City prioritize its efforts, allocating both fiscal and human resources to achieve a shared vision and goal. The 2021-23 Strategic Plan identifies seven goals, concerning housing, fiscal health, infrastructure and environment, economic development, community engagement and well-being, public safety, and efficient and well-performing government.

Approval of the VMT Policy is consistent with the City Council’s goal for housing, infrastructure and environment, and economic development, in that the VMT Policy would remove barriers to affordable housing development and encourage infill development to increase the number of jobs, services, and housing in close proximity to one another.

FINANCIAL IMPACT
The VMT Policy would have no direct fiscal impact on the City. Indirect costs associated with staff time in coordinating the environmental review for land use projects would be covered under a reimbursement agreement with the developer. Indirect costs with administering the VMT Mitigation Banking Program would be borne by the Public Works and Utilities Department, as with any efforts involving infrastructure investments, such as trail improvement projects and other active transportation projects.

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ALTERNATIVES
The City Council may choose to not adopt the proposed VMT Policy. However, SB 743 would still obligate the City to evaluate transportation-related impacts under CEQA using VMT as the appropriate metric instead of LOS. The City would also not have established a VMT Mitigation Banking Program to provide an additional option for projects needing to reduce VMT impacts below applicable thresholds.

ATTACHMENTS

1. Section 15064.3 of the CEQA Guidelines

2. Technical Advisory on Evaluating Transportation Impacts in CEQA (OPR, December 2018)

3. Analyzing VMT for CEQA Compliance: SB 743 Implementation Guidelines for the City of Watsonville (City of Watsonville, September 27, 2022)

4. Resolution No. 14-22 (PC)
An electronic copy of the VMT Policy will be available on the City’s website at:
https://www.cityofwatsonville.org/DocumentCenter/Index/157

REFERENCES
California Air Pollution Control Officers Association (CAPCOA). 2010. Quantifying Greenhouse Gas Mitigation Measures: A Resource for Local Government to Assess Emission Reductions from Greenhouse Gas Mitigation Measures. Prepared by CAPCOA in association with Northeast States for Coordinated Air Use Management, National Association of Clean Air Agencies, Environ, and Fehr & Peers. Retrieved from http://www.capcoa.org/wp-content/uploads/2010/11/CAPCOA-Quantification-Report-9-14- Final.pdf.

CAPCOA. 2021. Handbook for Analyzing Greenhouse Gas Emission Reductions, Assessing Climate Vulnerabilities, and Advancing Health and Equity: Designed for Local Governments, Communities, and Project Developers. Prepared by CAPCOA in association with Caltrans, Sacramento Metropolitan Air Quality Management District, ICF, STi Sonoma Technology and Fehr & Peers. Retrieved from
https://www.airquality.org/ClimateChange/Documents/
Handbook%20Public%20Draft_2021-Aug.pdf.

California Air Resources Board (CARB). 2017. California’s 2017 Climate Change Scoping Plan: The Strategy for Achieving California’s 2030 Greenhouse Gas Target. Retrieved from
https://ww2.arb.ca.gov/sites/default/files/classic/cc/scopingplan/scoping_plan_2017.pdf.

CARB. 2019. California Air Resources Board 2017 Scoping Plan-Identified VMT Reductions and Relationship to State Climate Goals. Retrieved from https://ww2.arb.ca.gov/resources/ documents/carb-2017-scoping-plan-identified-vmtreductions-and-relationship-state-climate.

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City of Watsonville. 2012. Trails & Bicycle Master Plan for the Watsonville Scenic Trails Network. Retrieved from https://www.cityofwatsonville.org/774/Urban-Greening-Plan.

Elkin, Ethan N., Ted Lamm, and Eric Prather. 2018. Implementing SB 743: An Analysis of Vehicle Miles Traveled Banking and Exchange Frameworks. Berkeley: UC Berkeley Law.

Retrieved from https://www.law.berkeley.edu/wp-content/uploads/2018/09/ImplementingSB-743-October-2018.pdf.

Elkin, Ethan N., Ted Lamm, and Katie Segal. 2022. Implementing SB 743: Design Considerations for VMT Mitigation Bank and Exchange Programs. Berkeley: UC Berkeley Law. Retrieved from https://www.law.berkeley.edu/wpcontent/uploads/2022/08/Implementing-SB-743-August-2022.pdf.

Handy, Susan and Marlon G. Boarnet. 2014. Impact of Highway Capacity and Induced Travel on Passenger Vehicle Use and Greenhouse Gas Emissions. California Air Resources Board Policy Brief. Retrieved from
https://ww2.arb.ca.gov/sites/default/files/2020-06/
Impact_of_Highway_Capacity_and_Induced_Travel_on_Passenger_Vehicle_Use_and_G reenhouse_Gas_Emissions_Policy_Brief.pdf.

Litman, Todd. 2022. Understanding Transport Demands and Elasticities: How Prices and Other Factors Affect Travel Behavior. Victoria Transport Policy Institute. Retrieved from https://www.vtpi.org/elasticities.pdf.

Litman, Todd. 2022. Generated Traffic and Induced Travel: Implications for Transport Planning. Victoria Transport Policy Institute. Retrieved from https://www.vtpi.org/gentraf.pdf.

Lovejoy, Kristin, et al. 2013. Measuring the impacts of local land-use policies on vehicle miles of travel: The case of the first big-box store in Davis, California. The Journal of Transport and Land Use. Retrieved from
https://www.jtlu.org/index.php/jtlu/article/view/336.

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Association of Environmental Professionals 2020 CEQA Guidelines 154
Note: Authority cited: Sections 21083, 21083.05, Public Resources Code. Reference: Sections 21003, 21065, 21068, 21080, 21082, 21082.1, 21082.2, 21083, 21083.05, and 21100, Public Resources Code; No Oil, Inc. v. City of Los Angeles (1974) 13 Cal.3d 68; San Joaquin Raptor/Wildlife Center v. County of Stanislaus (1996) 42 Cal.App.4th 608; Gentry v. City of Murrieta (1995) 36 Cal.App.4th 1359; Laurel Heights Improvement Assn. v. Regents of the University of California (1993) 6 Cal.4th 1112; Communities for a Better Environment v.

California Resources Agency (2002) 103 Cal.App.4th 98; Protect the Historic Amador Waterways v. Amador Water Agency (2004) 116 Cal. App. 4th 1099; and Rominger v. County of Colusa (2014) 229 Cal.App.4th 690.

SECTION 15064.3. DETERMINING THE SIGNIFICANCE OF TRANSPORTATION IMPACTS (a) Purpose.

This section describes specific considerations for evaluating a project’s transportation impacts.

Generally, vehicle miles traveled is the most appropriate measure of transportation impacts. For the purposes of this section, “vehicle miles traveled” refers to the amount and distance of automobile travel attributable to a project. Other relevant considerations may include the effects of the project on transit and non-motorized travel. Except as provided in subdivision (b)(2) below (regarding roadway capacity), a project’s effect on automobile delay shall not constitute a significant environmental impact.
(b) Criteria for Analyzing Transportation Impacts.

Land Use Projects. Vehicle miles traveled exceeding an applicable threshold of significance may indicate a significant impact. Generally, projects within one-half mile of either an existing major transit stop or a stop along an existing high quality transit corridor should be presumed to cause a less than significant transportation impact. Projects that decrease vehicle miles traveled in the project area compared to existing conditions should be presumed to have a less than significant transportation impact. (2) Transportation Projects. Transportation projects that reduce, or have no impact on, vehicle miles traveled should be presumed to cause a less than significant transportation impact. For roadway capacity projects, agencies have discretion to determine the appropriate measure of transportation impact consistent with CEQA and other applicable requirements. To the extent that such impacts have already been adequately addressed at a programmatic level, such as in a regional transportation plan EIR, a lead agency may tier from that analysis as provided in Section 15152.
(3) Qualitative Analysis. If existing models or methods are not available to estimate the vehicle miles traveled for the particular project being considered, a lead agency may analyze the project’s vehicle miles traveled qualitatively. Such a qualitative analysis would evaluate factors such as the availability of transit, proximity to other destinations, etc. For many projects, a qualitative analysis of construction traffic may be appropriate. (4) Methodology. 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 absolute terms, per capita, per household or in any other measure. A lead agency may use models to estimate a project’s vehicle miles traveled, and may revise those estimates to reflect professional judgment based on substantial evidence. Any assumptions used to estimate vehicle miles traveled and any revisions to model outputs should be documented and explained in the environmental document prepared for the project. The standard of adequacy in Section 15151 shall apply to the analysis described in this section.

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CEQA Guidelines Association of Environmental Professionals 2020 155
(c) Applicability. The provisions of this section shall apply prospectively as described in section 15007. A lead agency may elect to be governed by the provisions of this section immediately.

Beginning on July 1, 2020, the provisions of this section shall apply statewide.

Note: Authority cited: Sections 21083 and 21099, Public Resources Code. Reference: Sections 21099 and 21100, Public Resources Code; Cleveland National Forest Foundation v. San Diego Association of Governments (2017) 17 Cal.App.5th 413; Ukiah Citizens for Safety First v. City of Ukiah (2016) 248 Cal.App.4th 256; California Clean Energy Committee v. City of Woodland (2014) 225 Cal. App. 4th 173.
15064.4. DETERMINING THE SIGNIFICANCE OF IMPACTS FROM GREENHOUSE GAS

EMISSIONS
(a) The determination of the significance of greenhouse gas emissions calls for a careful judgment by the lead agency consistent with the provisions in section 15064. A lead agency shall make a good-faith effort, based to the extent possible on scientific and factual data, to describe, calculate or estimate the amount of greenhouse gas emissions resulting from a project. A lead agency shall have discretion to determine, in the context of a particular project, whether to:
(1) Quantify greenhouse gas emissions resulting from a project; and/or (2) Rely on a qualitative analysis or performance based standards. (b) In determining the significance of a project’s greenhouse gas emissions, the lead agency should focus its analysis on the reasonably foreseeable incremental contribution of the project’s emissions to the effects of climate change. A project’s incremental contribution may be cumulatively considerable even if it appears relatively small compared to statewide, national or global emissions. The agency’s analysis should consider a timeframe that is appropriate for the project. The agency’s analysis also must reasonably reflect evolving scientific knowledge and state regulatory schemes. A lead agency should consider the following factors, among others, when determining the significance of impacts from greenhouse gas emissions on the environment:
(1) The extent to which the project may increase or reduce greenhouse gas emissions as compared to the existing environmental setting;
(2) Whether the project emissions exceed a threshold of significance that the lead agency determines applies to the project.
(3) The extent to which the project complies with regulations or requirements adopted to implement a statewide, regional, or local plan for the reduction or mitigation of greenhouse gas emissions (see, e.g., section 15183.5(b)). Such requirements must be adopted by the relevant public agency through a public review process and must reduce or mitigate the project’s incremental contribution of greenhouse gas emissions. If there is substantial evidence that the possible effects of a particular project are still cumulatively considerable notwithstanding compliance with the adopted regulations or requirements, an EIR must be prepared for the project. In determining the significance of impacts, the lead agency may consider a project’s consistency with the State’s long-term climate goals or strategies, provided that substantial evidence supports the agency’s analysis of how those goals or strategies address the project’s incremental contribution to climate change and its conclusion that the project’s incremental contribution is not cumulatively considerable. (c) A lead agency may use a model or methodology to estimate greenhouse gas emissions resulting from a project. The lead agency has discretion to select the model or methodology it considers most appropriate to enable decision makers to intelligently take into account the project’s incremental contribution to climate change. The lead agency must support its selection of a Attachment 1
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ON EVALUATING TRANSPORTATION

IMPACTS IN CEQA

TECHNICAL ADVISORY
December 2018
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Contents
A. Introduction ...................................................................................................................................... 1 B. Background ....................................................................................................................................... 2 C. Technical Considerations in Assessing Vehicle Miles Traveled......................................................... 4

1. Recommendations Regarding Methodology ................................................................................ 4 D. General Principles to Guide Consideration of VMT .......................................................................... 7 E. Recommendations Regarding Significance Thresholds.................................................................... 8

1. Screening Thresholds for Land Use Projects...............................................................................12

2. Recommended Numeric Thresholds for Residential, Office, and Retail Projects.......................15

3. Recommendations Regarding Land Use Plans............................................................................18

4. Other Considerations..................................................................................................................19 F. Considering the Effects of Transportation Projects on Vehicle Travel ...........................................19

1. Recommended Significance Threshold for Transportation Projects..........................................22

2. Estimating VMT Impacts from Transportation Projects .............................................................23 G. Analyzing Other Impacts Related to Transportation ......................................................................25 H. VMT Mitigation and Alternatives....................................................................................................26 Appendix 1. Considerations About Which VMT to Count .......................................................................29 Appendix 2. Induced Travel: Mechanisms, Research, and Additional Assessment Approaches ............32 Attachment 2
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A. Introduction
This technical advisory is one in a series of advisories provided by the Governor’s Office of Planning and Research (OPR) as a service to professional planners, land use officials, and CEQA practitioners. OPR issues technical assistance on issues that broadly affect the practice of land use planning and the California Environmental Quality Act (CEQA) (Pub. Resources Code, § 21000 et seq.). (Gov. Code, § 65040, subds. (g), (l), (m).) The purpose of this document is to provide advice and recommendations, which agencies and other entities may use at their discretion. This document does not alter lead agency discretion in preparing environmental documents subject to CEQA. This document should not be construed as legal advice.

Senate Bill 743 (Steinberg, 2013), which was codified in Public Resources Code section 21099, required changes to the guidelines implementing CEQA (CEQA Guidelines) (Cal. Code Regs., Title 14, Div. 6, Ch. 3, § 15000 et seq.) regarding the analysis of transportation impacts. As one appellate court recently explained: “During the last 10 years, the Legislature has charted a course of long-term sustainability based on denser infill development, reduced reliance on individual vehicles and improved mass transit, all with the goal of reducing greenhouse gas emissions. Section 21099 is part of that strategy . . . .” (Covina Residents for Responsible Development v. City of Covina (2018) 21 Cal.App.5th 712, 729.) Pursuant to Section 21099, the criteria for determining the significance of transportation impacts must “promote the reduction of greenhouse gas emissions, the development of multimodal transportation networks, and a diversity of land uses.” (Id., subd. (b)(1); see generally, adopted CEQA Guidelines, § 15064.3, subd. (b) [Criteria for Analyzing Transportation Impacts].) To that end, in developing the criteria, OPR has proposed, and the California Natural Resources Agency (Agency) has certified and adopted, changes to the CEQA Guidelines that identify vehicle miles traveled (VMT) as the most appropriate metric to evaluate a project’s transportation impacts. With the California Natural Resources Agency’s certification and adoption of the changes to the CEQA Guidelines, automobile delay, as measured by “level of service” and other similar metrics, generally no longer constitutes a significant environmental effect under CEQA. (Pub. Resources Code, § 21099, subd. (b)(3).)

This advisory contains technical recommendations regarding assessment of VMT, thresholds of significance, and mitigation measures. Again, OPR provides this Technical Advisory as a resource for the public to use at their discretion. OPR is not enforcing or attempting to enforce any part of the recommendations contained herein. (Gov. Code, § 65035 [“It is not the intent of the Legislature to vest in the Office of Planning and Research any direct operating or regulatory powers over land use, public works, or other state, regional, or local projects or programs.”].) This December 2018 technical advisory is an update to the advisory it published in April 2018. OPR will continue to monitor implementation of these new provisions and may update or supplement this advisory in response to new information and advancements in modeling and methods.

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B. Background
VMT and Greenhouse Gas Emissions Reduction. Senate Bill 32 (Pavley, 2016) requires California to reduce greenhouse gas (GHG) emissions 40 percent below 1990 levels by 2030, and Executive Order B16-12 provides a target of 80 percent below 1990 emissions levels for the transportation sector by 2050.

The transportation sector has three major means of reducing GHG emissions: increasing vehicle efficiency, reducing fuel carbon content, and reducing the amount of vehicle travel. The California Air Resources Board (CARB) has provided a path forward for achieving these emissions reductions from the transportation sector in its 2016 Mobile Source Strategy. CARB determined that it will not be possible to achieve the State’s 2030 and post-2030 emissions goals without reducing VMT growth. Further, in its 2018 Progress Report on California’s Sustainable Communities and Climate Protection Act, CARB found that despite the State meeting its 2020 climate goals, “emissions from statewide passenger vehicle travel per capita [have been] increasing and going in the wrong direction,” and “California cannot meet its [long-term] climate goals without curbing growth in single-occupancy vehicle activity.”1 CARB also found that “[w]ith emissions from the transportation sector continuing to rise despite increases in fuel efficiency and decreases in the carbon content of fuel, California will not achieve the necessary greenhouse gas emissions reductions to meet mandates for 2030 and beyond without significant changes to how communities and transportation systems are planned, funded, and built.”2

Thus, to achieve the State’s long-term climate goals, California needs to reduce per capita VMT. This can occur under CEQA through VMT mitigation. Half of California’s GHG emissions come from the transportation sector3
, therefore, reducing VMT is an effective climate strategy, which can also result in co-benefits.
4 Furthermore, without early VMT mitigation, the state may follow a path that meets GHG targets in the early years, but finds itself poorly positioned to meet more stringent targets later. For example, in absence of VMT analysis and mitigation in CEQA, lead agencies might rely upon verifiable offsets for GHG mitigation, ignoring the longer-term climate change impacts resulting from land use development and infrastructure investment decisions. As stated in CARB’s 2017 Scoping Plan:
“California’s future climate strategy will require increased focus on integrated land use planning to support livable, transit-connected communities, and conservation of agricultural and other lands. Accommodating population and economic growth through travel- and energy-efficient land use provides GHG-efficient growth, reducing GHGs from both transportation and building energy use. GHGs can be further reduced at the project level through implementing energyefficient construction and travel demand management approaches.”5 (Id. at p. 102.)

1 California Air Resources Board (Nov. 2018) 2018 Progress Report on California’s Sustainable Communities and Climate Protection Act, pp. 4, 5, available at https://ww2.arb.ca.gov/sites/default/files/2018-11/Final2018Report_SB150_112618_02_Report.pdf. 2 Id., p. 28. 3 See https://ca50million.ca.gov/transportation/ 4 Fang et al. (2017) Cutting Greenhouse Gas Emissions Is Only the Beginning: A Literature Review of the Co-Benefits of Reducing Vehicle Miles Traveled. 5 California Air Resources Board (Nov. 2017) California’s 2017 Climate Change Scoping Plan, p. 102, available at https://www.arb.ca.gov/cc/scopingplan/scoping_plan_2017.pdf.

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In light of this, the 2017 Scoping Plan describes and quantifies VMT reductions needed to achieve our long-term GHG emissions reduction goals, and specifically points to the need for statewide deployment of the VMT metric in CEQA:
“Employing VMT as the metric of transportation impact statewide will help to ensure GHG reductions planned under SB 375 will be achieved through on-the-ground development, and will also play an important role in creating the additional GHG reductions needed beyond SB 375 across the State. Implementation of this change will rely, in part, on local land use decisions to reduce GHG emissions associated with the transportation sector, both at the project level, and in long-term plans (including general plans, climate action plans, specific plans, and transportation plans) and supporting sustainable community strategies developed under SB 375.”6

VMT and Other Impacts to Health and Environment. VMT mitigation also creates substantial benefits (sometimes characterized as “co-benefits” to GHG reduction) in both in the near-term and the longterm. Beyond GHG emissions, increases in VMT also impact human health and the natural environment.

Human health is impacted as increases in vehicle travel lead to more vehicle crashes, poorer air quality, increases in chronic diseases associated with reduced physical activity, and worse mental health.

Increases in vehicle travel also negatively affect other road users, including pedestrians, cyclists, other motorists, and many transit users. The natural environment is impacted as higher VMT leads to more collisions with wildlife and fragments habitat. Additionally, development that leads to more vehicle travel also tends to consume more energy, water, and open space (including farmland and sensitive habitat). This increase in impermeable surfaces raises the flood risk and pollutant transport into waterways.7
VMT and Economic Growth. While it was previously believed that VMT growth was a necessary component of economic growth, data from the past two decades shows that economic growth is possible without a concomitant increase in VMT. (Figure 1.) Recent research shows that requiring development projects to mitigate LOS may actually reduce accessibility to destinations and impede economic growth.8,9

6 Id. at p. 76. 7 Fang et al. (2017) Cutting Greenhouse Gas Emissions Is Only the Beginning: A Literature Review of the Co-Benefits of Reducing Vehicle Miles Traveled, available at https://ncst.ucdavis.edu/wpcontent/uploads/2017/03/NCST-VMT-Co-Benefits-White-Paper_Fang_March-2017.pdf. 8 Haynes et al. (Sept. 2015) Congested Development: A Study of Traffic Delays, Access, and Economic Activity in Metropolitan Los Angeles, available at http://www.its.ucla.edu/wpcontent/uploads/sites/6/2015/11/Haynes_Congested-Development_1-Oct-2015_final.pdf. 9 Osman et al. (Mar. 2016) Not So Fast: A Study of Traffic Delays, Access, and Economic Activity in the San Francisco Bay Area, available at http://www.its.ucla.edu/wpcontent/uploads/sites/6/2016/08/Taylor-Not-so-Fast-04-01-2016_final.pdf.

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Figure 1. Kooshian and Winkelman (2011) VMT and Gross Domestic Product (GDP), 1960-2010.

C. Technical Considerations in Assessing Vehicle Miles Traveled Many practitioners are familiar with accounting for VMT in connection with long-range planning, or as part of the CEQA analysis of a project’s greenhouse gas emissions or energy impacts. This document provides technical information on how to assess VMT as part of a transportation impacts analysis under CEQA. Appendix 1 provides a description of which VMT to count and options on how to count it.

Appendix 2 provides information on induced travel resulting from roadway capacity projects, including the mechanisms giving rise to induced travel, the research quantifying it, and information on additional approaches for assessing it.

1. Recommendations Regarding Methodology
Proposed Section 15064.3 explains that a “lead agency may use models to estimate a project’s vehicle miles traveled . . . .” CEQA generally defers to lead agencies on the choice of methodology to analyze impacts. (Santa Monica Baykeeper v. City of Malibu (2011) 193 Cal.App.4th 1538, 1546; see Laurel Heights Improvement Assn. v. Regents of University of California (1988) 47 Cal.3d 376, 409 [“the issue is not whether the studies are irrefutable or whether they could have been better” … rather, the “relevant issue is only whether the studies are sufficiently credible to be considered” as part of the lead agency’s overall evaluation].) This section provides suggestions to lead agencies regarding methodologies to analyze VMT associated with a project.

Vehicle Types. Proposed Section 15064.3, subdivision (a), states, “For the purposes of this section, ‘vehicle miles traveled’ refers to the amount and distance of automobile travel attributable to a project.” Here, the term “automobile” refers to on-road passenger vehicles, specifically cars and light trucks. Heavy-duty truck VMT could be included for modeling convenience and ease of calculation (for example, where models or data provide combined auto and heavy truck VMT). For an apples-to-apples Attachment 2
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comparison, vehicle types considered should be consistent across project assessment, significance thresholds, and mitigation.

Residential and Office Projects. Tour- and trip-based approaches10 offer the best methods for assessing VMT from residential/office projects and for comparing those assessments to VMT thresholds. These approaches also offer the most straightforward methods for assessing VMT reductions from mitigation measures for residential/office projects. When available, tour-based assessment is ideal because it captures travel behavior more comprehensively. But where tour-based tools or data are not available for all components of an analysis, a trip-based assessment of VMT serves as a reasonable proxy.

Models and methodologies used to calculate thresholds, estimate project VMT, and estimate VMT reduction due to mitigation should be comparable. For example:
• A tour-based assessment of project VMT should be compared to a tour-based threshold, or a trip-based assessment to a trip-based VMT threshold.
• Where a travel demand model is used to determine thresholds, the same model should also be used to provide trip lengths as part of assessing project VMT. • Where only trip-based estimates of VMT reduction from mitigation are available, a trip-based threshold should be used, and project VMT should be assessed in a trip-based manner.

When a trip-based method is used to analyze a residential project, the focus can be on home-based trips. Similarly, when a trip-based method is used to analyze an office project, the focus can be on home-based work trips.

When tour-based models are used to analyze an office project, either employee work tour VMT or VMT from all employee tours may be attributed to the project. This is because workplace location influences overall travel. For consistency, the significance threshold should be based on the same metric: either employee work tour VMT or VMT from all employee tours.

For office projects that feature a customer component, such as a government office that serves the public, a lead agency can analyze the customer VMT component of the project using the methodology for retail development (see below).

Retail Projects. Generally, lead agencies should analyze the effects of a retail project by assessing the change in total VMT11 because retail projects typically re-route travel from other retail destinations. A retail project might lead to increases or decreases in VMT, depending on previously existing retail travel patterns.

10 See Appendix 1, Considerations About Which VMT to Count, for a description of these approaches. 11 See Appendix 1, Considerations About Which VMT to Count, “Assessing Change in Total VMT” section, for a description of this approach.

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Considerations for All Projects. 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 discounting the VMT from a trip that crosses a jurisdictional boundary. CEQA requires environmental analyses to reflect a “good faith effort at full disclosure.” (CEQA Guidelines, § 15151.) Thus, where methodologies exist that can estimate the full extent of vehicle travel from a project, the lead agency should apply them to do so. Where those VMT effects will grow over time, analyses should consider both a project’s short-term and long-term effects on VMT.

Combining land uses for VMT analysis is not recommended. Different land uses generate different amounts of VMT, so the outcome of such an analysis could depend more on the mix of uses than on their travel efficiency. As a result, it could be difficult or impossible for a lead agency to connect a significance threshold with an environmental policy objective (such as a target set by law), inhibiting the CEQA imperative of identifying a project’s significant impacts and providing mitigation where feasible.

Combining land uses for a VMT analysis could streamline certain mixes of uses in a manner disconnected from policy objectives or environmental outcomes. Instead, OPR recommends analyzing each use separately, or simply focusing analysis on the dominant use, and comparing each result to the appropriate threshold. Recommendations for methods of analysis and thresholds are provided below.

In the analysis of each use, a mixed-use project should take credit for internal capture.

Any project that includes in its geographic bounds a portion of an existing or planned Transit Priority Area (i.e., the project is within a ½ mile of an existing or planned major transit stop or an existing stop along a high quality transit corridor) may employ VMT as its primary metric of transportation impact for the entire project. (See Pub. Resources Code, § 21099, subds. (a)(7), (b)(1).) Cumulative Impacts. A project’s cumulative impacts are based on an assessment of whether the “incremental effects of an individual project are considerable when viewed in connection with the effects of past projects, the effects of other current projects, and the effects of probable future projects.” (Pub. Resources Code, § 21083, subd. (b)(2); see CEQA Guidelines, § 15064, subd. (h)(1).) When using an absolute VMT metric, i.e., total VMT (as recommended below for retail and transportation projects), analyzing the combined impacts for a cumulative impacts analysis may be appropriate. However, metrics such as VMT per capita or VMT per employee, i.e., metrics framed in terms of efficiency (as recommended below for use on residential and office projects), cannot be summed because they employ a denominator. A project that falls below an efficiency-based threshold that is aligned with long-term environmental goals and relevant plans would have no cumulative impact distinct from the project impact. Accordingly, a finding of a less-than-significant project impact would imply a less than significant cumulative impact, and vice versa. This is similar to the analysis typically conducted for greenhouse gas emissions, air quality impacts, and impacts that utilize plan compliance as a threshold of significance. (See Center for Biological Diversity v. Department of Fish & Wildlife (2015) 62 Cal.4th 204, 219, 223; CEQA Guidelines, § 15064, subd. (h)(3).) Attachment 2
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D. General Principles to Guide Consideration of VMT
SB 743 directs OPR to establish specific “criteria for determining the significance of transportation impacts of projects[.]” (Pub. Resources Code, § 21099, subd. (b)(1).) In establishing this criterion, OPR was guided by the general principles contained within CEQA, the CEQA Guidelines, and applicable case law.

To assist in the determination of significance, many lead agencies rely on “thresholds of significance.” The CEQA Guidelines define a “threshold of significance” to mean “an identifiable quantitative, qualitative12 or performance level of a particular environmental effect, non-compliance with which means the effect will normally be determined to be significant by the agency and compliance with which means the effect normally will be determined to be less than significant.” (CEQA Guidelines, § 15064.7, subd. (a) (emphasis added).) Lead agencies have discretion to develop and adopt their own, or rely on thresholds recommended by other agencies, “provided the decision of the lead agency to adopt such thresholds is supported by substantial evidence.” (Id. at subd. (c); Save Cuyama Valley v. County of Santa Barbara (2013) 213 Cal.App.4th 1059, 1068.) Substantial evidence means “enough relevant information and reasonable inferences from this information that a fair argument can be made to support a conclusion, even though other conclusions might also be reached.” (Id. at § 15384 (emphasis added); Protect the Historic Amador Waterways v. Amador Water Agency (2004) 116 Cal.App.4th 1099, 1108-1109.)
Additionally, the analysis leading to the determination of significance need not be perfect. The CEQA Guidelines describe the standard for adequacy of environmental analyses:

An EIR should be prepared with a sufficient degree of analysis to provide decision makers with information which enables them to make a decision which intelligently takes account of environmental consequences. An evaluation of the environmental effects of a proposed project need not be exhaustive, but the sufficiency of an EIR is to be reviewed in the light of what is reasonably feasible. Disagreement among experts does not make an EIR inadequate, but the EIR should summarize the main points of disagreement among the experts. The courts have looked not for perfection but for adequacy, completeness, and a good faith effort at full disclosure.
(CEQA Guidelines, § 15151 (emphasis added).)
These general principles guide OPR’s recommendations regarding thresholds of significance for VMT set forth below.

12 Generally, qualitative analyses should only be conducted when methods do not exist for undertaking a quantitative analysis.

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E. Recommendations Regarding Significance Thresholds
As noted above, lead agencies have the discretion to set or apply their own thresholds of significance. (Center for Biological Diversity v. California Dept. of Fish & Wildlife (2015) 62 Cal.4th 204, 218-223 [lead agency had discretion to use compliance with AB 32’s emissions goals as a significance threshold]; Save Cuyama Valley v. County of Santa Barbara (2013) 213 Cal.App.4th at p. 1068.) However, Section 21099 of the Public Resources Code states that the criteria for determining the significance of transportation impacts must promote: (1) reduction of greenhouse gas emissions; (2) development of multimodal transportation networks; and (3) a diversity of land uses. It further directed OPR to prepare and develop criteria for determining significance. (Pub. Resources Code, § 21099, subd. (b)(1).) This section provides OPR’s suggested thresholds, as well as considerations for lead agencies that choose to adopt their own thresholds.

The VMT metric can support the three statutory goals: “the reduction of greenhouse gas emissions, the development of multimodal transportation networks, and a diversity of land uses.” (Pub. Resources Code, § 21099, subd. (b)(1), emphasis added.) However, in order for it to promote and support all three, lead agencies should select a significance threshold that aligns with state law on all three. State law concerning the development of multimodal transportation networks and diversity of land uses requires planning for and prioritizing increases in complete streets and infill development, but does not mandate a particular depth of implementation that could translate into a particular threshold of significance.

Meanwhile, the State has clear quantitative targets for GHG emissions reduction set forth in law and based on scientific consensus, and the depth of VMT reduction needed to achieve those targets has been quantified. Tying VMT thresholds to GHG reduction also supports the two other statutory goals.

Therefore, to ensure adequate analysis of transportation impacts, OPR recommends using quantitative VMT thresholds linked to GHG reduction targets when methods exist to do so.

Various legislative mandates and state policies establish quantitative greenhouse gas emissions reduction targets. For example:
• Assembly Bill 32 (2006) requires statewide GHG emissions reductions to 1990 levels by 2020 and continued reductions beyond 2020.
• Senate Bill 32 (2016) requires at least a 40 percent reduction in GHG emissions from 1990 levels by 2030.
• Pursuant to Senate Bill 375 (2008), the California Air Resources Board GHG emissions reduction targets for metropolitan planning organizations (MPOs) to achieve based on land use patterns and transportation systems specified in Regional Transportation Plans and Sustainable Community Strategies (RTP/SCS). Current targets for the State’s largest MPOs call for a 19 percent reduction in GHG emissions from cars and light trucks from 2005 emissions levels by 2035.
• Executive Order B-30-15 (2015) sets a GHG emissions reduction target of 40 percent below 1990 levels by 2030.

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• Executive Order S-3-05 (2005) sets a GHG emissions reduction target of 80 percent below 1990 levels by 2050.
• Executive Order B-16-12 (2012) specifies a GHG emissions reduction target of 80 percent below 1990 levels by 2050 specifically for transportation.
• Executive Order B-55-18 (2018) established an additional statewide goal of achieving carbon neutrality as soon as possible, but no later than 2045, and maintaining net negative emissions thereafter. It states, “The California Air Resources Board shall work with relevant state agencies to develop a framework for implementation and accounting that tracks progress toward this goal.”
• Senate Bill 391 requires the California Transportation Plan to support 80 percent reduction in GHGs below 1990 levels by 2050.
• The California Air Resources Board Mobile Source Strategy (2016) describes California’s strategy for containing air pollutant emissions from vehicles, and quantifies VMT growth compatible with achieving state targets.
• The California Air Resources Board’s 2017 Climate Change Scoping Plan Update: The Strategy for Achieving California’s 2030 Greenhouse Gas Target describes California’s strategy for containing GHG emissions from vehicles, and quantifies VMT growth compatible with achieving state targets.

Considering these various targets, the California Supreme Court observed:

Meeting our statewide reduction goals does not preclude all new development. Rather, the Scoping Plan … assumes continued growth and depends on increased efficiency and conservation in land use and transportation from all Californians. (Center for Biological Diversity v. California Dept. of Fish & Wildlife, supra, 62 Cal.4th at p. 220.) Indeed, the Court noted that when a lead agency uses consistency with climate goals as a way to determine significance, particularly for long-term projects, the lead agency must consider the project’s effect on meeting long-term reduction goals. (Ibid.) And more recently, the Supreme Court stated that “CEQA requires public agencies . . . to ensure that such analysis stay in step with evolving scientific knowledge and state regulatory schemes.” (Cleveland National Forest Foundation v. San Diego Assn. of Governments (2017) 3 Cal.5th 497, 504.)
Meeting the targets described above will require substantial reductions in existing VMT per capita to curb GHG emissions and other pollutants. But targets for overall GHG emissions reduction do not translate directly into VMT thresholds for individual projects for many reasons, including:
• Some, but not all, of the emissions reductions needed to achieve those targets could be accomplished by other measures, including increased vehicle efficiency and decreased fuel carbon content. The CARB’s First Update to the Climate Change Scoping Plan explains:

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“Achieving California’s long-term criteria pollutant and GHG emissions goals will require four strategies to be employed: (1) improve vehicle efficiency and develop zero emission technologies, (2) reduce the carbon content of fuels and provide market support to get these lower-carbon fuels into the marketplace, (3) plan and build communities to reduce vehicular GHG emissions and provide more transportation options, and (4) improve the efficiency and throughput of existing transportation systems.”13 CARB’s 2018 Progress Report on California’s Sustainable Communities and Climate Protection Act states on page 28 that “California cannot meet its climate goals without curbing growth in single-occupancy vehicle activity.” In other words, vehicle efficiency and better fuels are necessary, but insufficient, to address the GHG emissions from the transportation system. Land use patterns and transportation options also will need to change to support reductions in vehicle travel/VMT. • New land use projects alone will not sufficiently reduce per-capita VMT to achieve those targets, nor are they expected to be the sole source of VMT reduction. • Interactions between land use projects, and also between land use and transportation projects, existing and future, together affect VMT.
• Because location within the region is the most important determinant of VMT, in some cases, streamlining CEQA review of projects in travel efficient locations may be the most effective means of reducing VMT.
• When assessing climate impacts of some types of land use projects, use of an efficiency metric (e.g., per capita, per employee) may provide a better measure of impact than an absolute numeric threshold. (Center for Biological Diversity, supra.) Public Resources Code section 21099 directs OPR to propose criteria for determining the significance of transportation impacts. In this Technical Advisory, OPR provides its recommendations to assist lead agencies in selecting a significance threshold that may be appropriate for their particular projects. While OPR’s Technical Advisory is not binding on public agencies, CEQA allows lead agencies to “consider thresholds of significance . . . recommended by other public agencies, provided the decision to adopt those thresholds is supported by substantial evidence.” (CEQA Guidelines, § 15064.7, subd. (c).) Based on OPR’s extensive review of the applicable research, and in light of an assessment by the California Air Resources Board quantifying the need for VMT reduction in order to meet the State’s long-term climate goals, OPR recommends that a per capita or per employee VMT that is fifteen percent below that of existing development may be a reasonable threshold.

Fifteen percent reductions in VMT are achievable at the project level in a variety of place types.14 Moreover, a fifteen percent reduction is consistent with SB 743’s direction to OPR to select a threshold that will help the State achieve its climate goals. As described above, section 21099 states that the

13 California Air Resources Board (May 2014) First Update to the Climate Change Scoping Plan, p. 46 (emphasis added).
14 CAPCOA (2010) Quantifying Greenhouse Gas Mitigation Measures, p. 55, available at http://www.capcoa.org/wp-content/uploads/2010/11/CAPCOA-Quantification-Report-9-14-Final.pdf.

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criteria for determining significance must “promote the reduction in greenhouse gas emissions.” In its document California Air Resources Board 2017 Scoping Plan-Identified VMT Reductions and Relationship to State Climate Goals15, CARB assesses VMT reduction per capita consistent with its evidence-based modeling scenario that would achieve State climate goals of 40 percent GHG emissions reduction from 1990 levels by 2030 and 80 percent GHG emissions reduction levels from 1990 by 2050. Applying California Department of Finance population forecasts, CARB finds per-capita light-duty vehicle travel would need to be approximately 16.8 percent lower than existing, and overall per-capita vehicle travel would need to be approximately 14.3 percent lower than existing levels under that scenario. Below these levels, a project could be considered low VMT and would, on that metric, be consistent with 2017 Scoping Plan Update assumptions that achieve climate state climate goals.

CARB finds per capita vehicle travel would need to be kept below what today’s policies and plans would achieve.

CARB’s assessment is based on data in the 2017 Scoping Plan Update and 2016 Mobile Source Strategy.

In those documents, CARB previously examined the relationship between VMT and the state’s GHG emissions reduction targets. The Scoping Plan finds:
“While the State can do more to accelerate and incentivize these local decisions, local actions that reduce VMT are also necessary to meet transportation sector-specific goals and achieve the 2030 target under SB 32. Through developing the Scoping Plan, CARB staff is more convinced than ever that, in addition to achieving GHG reductions from cleaner fuels and vehicles, California must also reduce VMT. Stronger SB 375 GHG reduction targets will enable the State to make significant progress toward needed reductions, but alone will not provide the VMT growth reductions needed; there is a gap between what SB 375 can provide and what is needed to meet the State’s 2030 and 2050 goals.”16
Note that, at present, consistency with RTP/SCSs does not necessarily lead to a less-than-significant VMT impact.17 As the Final 2017 Scoping Plan Update states, VMT reductions are necessary to achieve the 2030 target and must be part of any strategy evaluated in this Plan. Stronger SB 375 GHG reduction targets will enable the State to make significant progress toward this goal, but alone will not provide all of the VMT growth reductions that will be needed. There is a gap between what SB 375 can provide and what is needed to meet the State’s 2030 and 2050 goals.”18

15 California Air Resources Board (Jan. 2019) California Air Resources Board 2017 Scoping Plan-Identified VMT Reductions and Relationship to State Climate Goals, available at https://ww2.arb.ca.gov/resources/documents/carb-2017-scoping-plan-identified-vmt-reductions-andrelationship-state-climate. 16 California Air Resources Board (Nov. 2017) California’s 2017 Climate Change Scoping Plan, p. 101. 17 California Air Resources Board (Feb. 2018) Updated Final Staff Report: Proposed Update to the SB 375 Greenhouse Gas Emission Reduction Targets, Figure 3, p. 35, available at https://www.arb.ca.gov/cc/sb375/sb375_target_update_final_staff_report_feb2018.pdf. 18 California Air Resources Board (Nov. 2017) California’s 2017 Climate Change Scoping Plan, p. 75.

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Also, in order to capture the full effects of induced travel resulting from roadway capacity projects, an RTP/SCS would need to include an assessment of land use effects of those projects, and the effects of those land uses on VMT. (See section titled “Estimating VMT Impacts from Transportation Projects” below.) RTP/SCSs typically model VMT using a collaboratively-developed land use “vision” for the region’s land use, rather than studying the effects on land use of the proposed transportation investments.

In summary, achieving 15 percent lower per capita (residential) or per employee (office) VMT than existing development is both generally achievable and is supported by evidence that connects this level of reduction to the State’s emissions goals.

1. Screening Thresholds for Land Use Projects
Many agencies use “screening thresholds” to quickly identify when a project should be expected to cause a less-than-significant impact without conducting a detailed study. (See e.g., CEQA Guidelines, §§ 15063(c)(3)(C), 15128, and Appendix G.) As explained below, this technical advisory suggests that lead agencies may screen out VMT impacts using project size, maps, transit availability, and provision of affordable housing.

Screening Threshold for Small Projects
Many local agencies have developed screening thresholds to indicate when detailed analysis is needed.

Absent substantial evidence indicating that a project would generate a potentially significant level of VMT, or inconsistency with a Sustainable Communities Strategy (SCS) or general plan, projects that generate or attract fewer than 110 trips per day19 generally may be assumed to cause a less-thansignificant transportation impact.

Map-Based Screening for Residential and Office Projects Residential and office projects that locate in areas with low VMT, and that incorporate similar features (i.e., density, mix of uses, transit accessibility), will tend to exhibit similarly low VMT. Maps created with VMT data, for example from a travel survey or a travel demand model, can illustrate areas that are

19 CEQA provides a categorical exemption for existing facilities, including additions to existing structures of up to 10,000 square feet, so long as the project is in an area where public infrastructure is available to allow for maximum planned development and the project is not in an environmentally sensitive area. (CEQA Guidelines, § 15301, subd. (e)(2).) Typical project types for which trip generation increases relatively linearly with building footprint (i.e., general office building, single tenant office building, office park, and business park) generate or attract an additional 110-124 trips per 10,000 square feet.

Therefore, absent substantial evidence otherwise, it is reasonable to conclude that the addition of 110 or fewer trips could be considered not to lead to a significant impact.

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currently below threshold VMT (see recommendations below). Because new development in such locations would likely result in a similar level of VMT, such maps can be used to screen out residential and office projects from needing to prepare a detailed VMT analysis.

Figure 2. Example map of household VMT that could be used to delineate areas eligible to receive streamlining for VMT analysis. (Source: City of San José, Department of Transportation, draft output of City Transportation Model.)
Presumption of Less Than Significant Impact Near Transit Stations Proposed CEQA Guideline Section 15064.3, subdivision (b)(1), states that lead agencies generally should presume that certain projects (including residential, retail, and office projects, as well as projects that are a mix of these uses) proposed within ½ mile of an existing major transit stop20 or an existing stop

20 Pub. Resources Code, § 21064.3 (“‘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 interval of 15 minutes or less during the morning and afternoon peak commute periods.”).

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along a high quality transit corridor21 will have a less-than-significant impact on VMT. This presumption would not apply, however, if project-specific or location-specific information indicates that the project will still generate significant levels of VMT. For example, the presumption might not be appropriate if the project:
● Has a Floor Area Ratio (FAR) of less than 0.75
● Includes more parking for use by residents, customers, or employees of the project than required by the jurisdiction (if the jurisdiction requires the project to supply parking) ● Is inconsistent with the applicable Sustainable Communities Strategy (as determined by the lead agency, with input from the Metropolitan Planning Organization) ● Replaces affordable residential units with a smaller number of moderate- or high-income residential units
A project or plan near transit which replaces affordable residential units22 with a smaller number of moderate- or high-income residential units may increase overall VMT because the increase in VMT of displaced residents could overwhelm the improvements in travel efficiency enjoyed by new residents.23 If any of these exceptions to the presumption might apply, the lead agency should conduct a detailed VMT analysis to determine whether the project would exceed VMT thresholds (see below).

Presumption of Less Than Significant Impact for Affordable Residential Development Adding affordable housing to infill locations generally improves jobs-housing match, in turn shortening commutes and reducing VMT.
24,25 Further, “… low-wage workers in particular would be more likely to choose a residential location close to their workplace, if one is available.”26 In areas where existing jobshousing match is closer to optimal, low income housing nevertheless generates less VMT than market-

21 Pub. Resources Code, § 21155 (“For purposes of this section, a high-quality transit corridor means a corridor with fixed route bus service with service intervals no longer than 15 minutes during peak commute hours.”).
22 Including naturally-occurring affordable residential units. 23 Chapple et al. (2017) Developing a New Methodology for Analyzing Potential Displacement, Chapter 4, pp. 159-160, available at https://www.arb.ca.gov/research/apr/past/13-310.pdf. 24 Karner and Benner (2016) The convergence of social equity and environmental sustainability: Jobshousing fit and commute distance (“[P]olicies that advance a more equitable distribution of jobs and housing by linking the affordability of locally available housing with local wage levels are likely to be associated with reduced commuting distances”).
25 Karner and Benner (2015) Low-wage jobs-housing fit: identifying locations of affordable housing shortages.
26 Karner and Benner (2015) Low-wage jobs-housing fit: identifying locations of affordable housing shortages.

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rate housing.
27,28 Therefore, a project consisting of a high percentage of affordable housing may be a basis for the lead agency to find a less-than-significant impact on VMT. Evidence supports a presumption of less than significant impact for a 100 percent affordable residential development (or the residential component of a mixed-use development) in infill locations. Lead agencies may develop their own presumption of less than significant impact for residential projects (or residential portions of mixed use projects) containing a particular amount of affordable housing, based on local circumstances and evidence. Furthermore, a project which includes any affordable residential units may factor the effect of the affordability on VMT into the assessment of VMT generated by those units.

2. Recommended Numeric Thresholds for Residential, Office, and Retail Projects
Recommended threshold for residential projects: A proposed project exceeding a level of 15 percent below existing VMT per capita may indicate a significant transportation impact. Existing VMT per capita may be measured as regional VMT per capita or as city VMT per capita. Proposed development referencing a threshold based on city VMT per capita (rather than regional VMT per capita) should not cumulatively exceed the number of units specified in the SCS for that city, and should be consistent with the SCS.

Residential development that would generate vehicle travel that is 15 or more percent below the existing residential VMT per capita, measured against the region or city, may indicate a less-thansignificant transportation impact. In MPO areas, development measured against city VMT per capita (rather than regional VMT per capita) should not cumulatively exceed the population or number of units specified in the SCS for that city because greater-than-planned amounts of development in areas above the region-based threshold would undermine the VMT containment needed to achieve regional targets under SB 375.

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 population-weighted VMT per capita of all cities in the region. In MPO areas, development in unincorporated areas measured against aggregate city VMT per capita (rather than regional VMT per capita) should not cumulatively exceed the population or number of units specified in the SCS for that city because greater-than-planned amounts of development in areas above the regional threshold would undermine achievement of regional targets under SB 375.
27 Chapple et al. (2017) Developing a New Methodology for Analyzing Potential Displacement, available at https://www.arb.ca.gov/research/apr/past/13-310.pdf. 28 CAPCOA (2010) Quantifying Greenhouse Gas Mitigation Measures, pp. 176-178, available at http://www.capcoa.org/wp-content/uploads/2010/11/CAPCOA-Quantification-Report-9-14-Final.pdf.

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These thresholds can be applied to either household (i.e., tour-based) VMT or home-based (i.e., tripbased) VMT assessments. 29 It is critical, however, that the agency be consistent in its VMT measurement approach throughout the analysis to maintain an “apples-to-apples” comparison. For example, if the agency uses a home-based VMT for the threshold, it should also be use home-based VMT for calculating project VMT and VMT reduction due to mitigation measures.

Because new retail development typically redistributes shopping trips rather than creating new trips, 30 estimating the total change in VMT (i.e., the difference in total VMT in the area affected with and without the project) is the best way to analyze a retail project’s transportation impacts.

By adding retail opportunities into the urban fabric and thereby improving retail destination proximity, local-serving retail development tends to shorten trips and reduce VMT. Thus, lead agencies generally may presume such development creates a less-than-significant transportation impact. Regional-serving retail development, on the other hand, which can lead to substitution of longer trips for shorter ones, may tend to have a significant impact. Where such development decreases VMT, lead agencies should consider the impact to be less-than-significant.

Many cities and counties define local-serving and regional-serving retail in their zoning codes. Lead agencies may refer to those local definitions when available, but should also consider any project-

29 See Appendix 1 for a description of these approaches. 30 Lovejoy, et al. (2013) Measuring the impacts of local land-use policies on vehicle miles of travel:

The case of the first big-box store in Davis, California, The Journal of Transport and Land Use.

Recommended threshold for retail projects: A net increase in total VMT may indicate a significant transportation impact.

Office projects that would generate vehicle travel exceeding 15 percent below existing VMT per employee for the region may indicate a significant transportation impact. 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 refer to a smaller geography, such as the county, that includes the area over which nearly all workers would be expected to live.

Office VMT screening maps can be developed using tour-based data, considering either total employee VMT or employee work tour VMT. Similarly, tour-based analysis of office project VMT could consider either total employee VMT or employee work tour VMT. Where tour-based information is unavailable for threshold determination, project assessment, or assessment of mitigation, home-based work trip VMT should be used throughout all steps of the analysis to maintain an “apples-to-apples” comparison.

Recommended threshold for office projects: A proposed project exceeding a level of 15 percent below existing regional VMT per employee may indicate a significant transportation impact.

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specific information, such as market studies or economic impacts analyses that might bear on customers’ travel behavior. Because lead agencies will best understand their own communities and the likely travel behaviors of future project users, they are likely in the best position to decide when a project will likely be local-serving. Generally, however, retail development including stores larger than 50,000 square feet might be considered regional-serving, and so lead agencies should undertake an analysis to determine whether the project might increase or decrease VMT.

Mixed-Use Projects
Lead agencies can evaluate each component of a mixed-use project independently and apply the significance threshold for each project type included (e.g., residential and retail). Alternatively, a lead agency may consider only the project’s dominant use. In the analysis of each use, a project should take credit for internal capture. Combining different land uses and applying one threshold to those land uses may result in an inaccurate impact assessment.

Other Project Types
Of land use projects, residential, office, and retail projects tend to have the greatest influence on VMT.

For that reason, OPR recommends the quantified thresholds described above for purposes of analysis and mitigation. Lead agencies, using more location-specific information, may develop their own more specific thresholds, which may include other land use types. In developing thresholds for other project types, or thresholds different from those recommended here, lead agencies should consider the purposes described in section 21099 of the Public Resources Code and regulations in the CEQA Guidelines on the development of thresholds of significance (e.g., CEQA Guidelines, § 15064.7).

Strategies and projects that decrease local VMT but increase total VMT should be avoided. Agencies should consider whether their actions encourage development in a less travel-efficient location by limiting development in travel-efficient locations.

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 a less-than-significant transportation impact. If the project leads to a net overall increase in VMT, then the thresholds described above should apply.

As described above, a project or plan near transit which replaces affordable31 residential units with a smaller number of moderate- or high-income residential units may increase overall VMT, because

31 Including naturally-occurring affordable residential units.

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displaced residents’ VMT may increase.
32 A lead agency should analyze VMT for such a project even if it otherwise would have been presumed less than significant. The assessment should incorporate an estimate of the aggregate VMT increase experienced by displaced residents. That additional VMT should be included in the numerator of the VMT per capita assessed for the project.

If a residential or office project leads to a net increase in VMT, then the project’s VMT per capita (residential) or per employee (office) should be compared to thresholds recommended above. Per capita and per employee VMT are efficiency metrics, and, as such, apply only to the existing project without regard to the VMT generated by the previously existing land use.

If the project leads to a net increase in provision of locally-serving retail, transportation impacts from the retail portion of the development should be presumed to be less than significant. If the project consists of regionally-serving retail, and increases overall VMT compared to with existing uses, then the project would lead to a significant transportation impact.

RTP/SCS Consistency (All Land Use Projects)
Section 15125, subdivision (d), of the CEQA Guidelines provides that lead agencies should analyze impacts resulting from inconsistencies with regional plans, including regional transportation plans. For this reason, if a project is inconsistent with the Regional Transportation Plan and Sustainable Communities Strategy (RTP/SCS), the lead agency should evaluate whether that inconsistency indicates a significant impact on transportation. For example, a development may be inconsistent with an RTP/SCS if the development is outside the footprint of development or within an area specified as open space as shown in the SCS.

3. Recommendations Regarding Land Use Plans
As with projects, agencies should analyze VMT outcomes of land use plans across the full area over which the plan may substantively affect travel patterns, including beyond the boundary of the plan or jurisdiction’s geography. And as with projects, VMT should be counted in full rather than split between origin and destination. (Emissions inventories have sometimes spit cross-boundary trips in order to sum to a regional total, but CEQA requires accounting for the full impact without truncation or discounting).

Analysis of specific plans may employ the same thresholds described above for projects. 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. Where the lead agency tiers from a general plan EIR pursuant to CEQA Guidelines sections 15152 and 15166, the lead agency generally focuses on the environmental impacts that are specific to the later project and were not analyzed as significant impacts in the prior EIR. (Pub. Resources Code, § 21068.5; Guidelines, § 15152, subd. (a).) Thus, in analyzing the later project, the lead agency

32 Chapple et al. (2017) Developing a New Methodology for Analyzing Potential Displacement, Chapter 4, pp. 159-160, available at https://www.arb.ca.gov/research/apr/past/13-310.pdf.

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would focus on the VMT impacts that were not adequately addressed in the prior EIR. In the tiered document, the lead agency should continue to apply the thresholds recommended above.

Thresholds for plans in non-MPO areas may be determined on a case-by-case basis.

4. Other Considerations
Rural Projects Outside of MPOs
In rural areas of non-MPO counties (i.e., areas not near established or incorporated cities or towns), fewer options may be available for reducing VMT, and significance thresholds may be best determined on a case-by-case basis. Note, however, that clustered small towns and small town main streets may have substantial VMT benefits compared to isolated rural development, similar to the transit oriented development described above.

Impacts to Transit
Because criteria for determining the significance of transportation impacts must promote “the development of multimodal transportation networks” pursuant to Public Resources Code section 21099, subd. (b)(1), lead agencies should consider project impacts to transit systems and bicycle and pedestrian networks. For example, a project that blocks access to a transit stop or blocks a transit route itself may interfere with transit functions. Lead agencies should consult with transit agencies as early as possible in the development process, particularly for projects that are located within one half mile of transit stops.

When evaluating impacts to multimodal transportation networks, lead agencies generally should not treat the addition of new transit users as an adverse impact. An infill development may add riders to transit systems and the additional boarding and alighting may slow transit vehicles, but it also adds destinations, improving proximity and accessibility. Such development also improves regional vehicle flow by adding less vehicle travel onto the regional network.

Increased demand throughout a region may, however, cause a cumulative impact by requiring new or additional transit infrastructure. Such impacts may be adequately addressed through a fee program that fairly allocates the cost of improvements not just to projects that happen to locate near transit, but rather across a region to all projects that impose burdens on the entire transportation system, since transit can broadly improve the function of the transportation system.

F. Considering the Effects of Transportation Projects on Vehicle Travel Many transportation projects change travel patterns. A transportation project which leads to additional vehicle travel on the roadway network, commonly referred to as “induced vehicle travel,” would need to quantify the amount of additional vehicle travel in order to assess air quality impacts, greenhouse gas emissions impacts, energy impacts, and noise impacts. Transportation projects also are required to Attachment 2
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examine induced growth impacts under CEQA. (See generally, Pub. Resources Code, §§ 21065 [defining “project” under CEQA as an activity as causing either a direct or reasonably foreseeable indirect physical change], 21065.3 [defining “project-specific effect” to mean all direct or indirect environmental effects], 21100, subd. (b) [required contents of an EIR].) For any project that increases vehicle travel, explicit assessment and quantitative reporting of the amount of additional vehicle travel should not be omitted from the document; such information may be useful and necessary for a full understanding of a project’s environmental impacts. (See Pub. Resources Code, §§ 21000, 21001, 21001.1, 21002, 21002.1 [discussing the policies of CEQA].) A lead agency that uses the VMT metric to assess the transportation impacts of a transportation project may simply report that change in VMT as the impact. When the lead agency uses another metric to analyze the transportation impacts of a roadway project, changes in amount of vehicle travel added to the roadway network should still be analyzed and reported. 33 While CEQA does not require perfection, it is important to make a reasonably accurate estimate of transportation projects’ effects on vehicle travel in order to make reasonably accurate estimates of GHG emissions, air quality emissions, energy impacts, and noise impacts. (See, e.g., California Clean Energy Com. v. City of Woodland (2014) 225 Cal.App.4th 173, 210 [EIR failed to consider project’s transportation energy impacts]; Ukiah Citizens for Safety First v. City of Ukiah (2016) 248 Cal.App.4th 256, 266.) Appendix 2 describes in detail the causes of induced vehicle travel, the robust empirical evidence of induced vehicle travel, and how models and research can be used in conjunction to quantitatively assess induced vehicle travel with reasonable accuracy.

If a project would likely lead to a measurable and substantial increase in vehicle travel, the lead agency should conduct an analysis assessing the amount of vehicle travel the project will induce. Project types that would likely lead to a measurable and substantial increase in vehicle travel generally include:
• Addition of through lanes on existing or new highways, including general purpose lanes, HOV lanes, peak period lanes, auxiliary lanes, or lanes through grade-separated interchanges Projects that would not likely lead to a substantial or measurable increase in vehicle travel, and therefore generally should not require an induced travel analysis, include:
• 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) and that do not add additional motor vehicle capacity
• Roadside safety devices or hardware installation such as median barriers and guardrails

33 See, e.g., California Department of Transportation (2006) Guidance for Preparers of Growth-related, Indirect Impact Analyses, available at http://www.dot.ca.gov/ser/Growthrelated_IndirectImpactAnalysis/GRI_guidance06May_files/gri_guidance.pdf.

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• 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 one mile in length designed to improve roadway safety • Installation, removal, or reconfiguration of traffic lanes that are not for through traffic, such as left, right, 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 to use only by transit vehicles • Reduction in 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., HOV, HOT, or trucks) from general vehicles • Installation, removal, or reconfiguration of traffic control devices, including Transit Signal Priority (TSP) features
• 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 new transit service
• Conversion of streets from one-way to two-way operation with no net increase in 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 nonmotorized 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 Attachment 2
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1. Recommended Significance Threshold for Transportation Projects As noted in Section 15064.3 of the CEQA Guidelines, lead agencies for roadway capacity projects have discretion, consistent with CEQA and planning requirements, to choose which metric to use to evaluate transportation impacts. This section recommends considerations for evaluating impacts using vehicle miles traveled. Lead agencies have discretion to choose a threshold of significance for transportation projects as they do for other types of projects. As explained above, Public Resources Code section 21099, subdivision (b)(1), provides that criteria for determining the significance of transportation impacts must promote the reduction of greenhouse gas emissions, the development of multimodal transportation networks, and a diversity of land uses. (Id.; see generally, adopted CEQA Guidelines, § 15064.3, subd. (b) [Criteria for Analyzing Transportation Impacts].) With those goals in mind, OPR prepared and the Agency adopted an appropriate transportation metric.

Whether adopting a threshold of significance, or evaluating transportation impacts on a case-by-case basis, a lead agency should ensure that the analysis addresses:
• Direct, indirect and cumulative effects of the transportation project (CEQA Guidelines, § 15064, subds. (d), (h))
• Near-term and long-term effects of the transportation project (CEQA Guidelines, §§ 15063, subd. (a)(1), 15126.2, subd. (a))
• The transportation project’s consistency with state greenhouse gas reduction goals (Pub.

Resources Code, § 21099)34
• The impact of the transportation project on the development of multimodal transportation networks (Pub. Resources Code, § 21099)
• The impact of the transportation project on the development of a diversity of land uses (Pub.

Resources Code, § 21099)
The CARB Scoping Plan and the CARB Mobile Source Strategy delineate VMT levels required to achieve legally mandated GHG emissions reduction targets. A lead agency should develop a project-level threshold based on those VMT levels, and may apply the following approach:

1. Propose a fair-share allocation of those budgets to their jurisdiction (e.g., by population);

34 The California Air Resources Board has ascertained the limits of VMT growth compatible with California containing greenhouse gas emissions to levels research shows would allow for climate stabilization. (See The 2017 Climate Change Scoping Plan: The Strategy for Achieving California’s 2030 Greenhouse Gas Target (p. 78, p. 101); Mobile Source Strategy (p. 37).) CARB’s Updated Final Staff Report on Proposed Update to the SB 375 Greenhouse Gas Emission Reduction Targets illustrates that the current Regional Transportation Plans and Sustainable Communities Strategies will fall short of achieving the necessary on-road transportation-related GHG emissions reductions called for in the 2017 Scoping Plan (Figure 3, p. 35). Accordingly, OPR recommends not basing GHG emissions or transportation impact analysis for a transportation project solely on consistency with an RTP/SCS.

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2. Determine the amount of VMT growth likely to result from background population growth, and subtract that from their “budget”;

3. Allocate their jurisdiction’s share between their various VMT-increasing transportation projects, using whatever criteria the lead agency prefers.

2. Estimating VMT Impacts from Transportation Projects
CEQA requires analysis of a project’s potential growth-inducing impacts. (Pub. Resources Code, § 21100, subd. (b)(5); CEQA Guidelines, § 15126.2, subd. (d).) Many agencies are familiar with the analysis of growth inducing impacts associated with water, sewer, and other infrastructure. This technical advisory addresses growth that may be expected from roadway expansion projects.

Because a roadway expansion project can induce substantial VMT, incorporating quantitative estimates of induced VMT is critical to calculating both transportation and other impacts of these projects.

Induced travel also has the potential to reduce or eliminate congestion relief benefits. An accurate estimate of induced travel is needed to accurately weigh costs and benefits of a highway capacity expansion project.

The effect of a transportation project on vehicle travel should be estimated using the “change in total VMT” method described in Appendix 1. This means that an assessment of total VMT without the project and an assessment with the project should be made; the difference between the two is the amount of VMT attributable to the project. The assessment should cover the full area in which driving patterns are expected to change. As with other types of projects, the VMT estimation should not be truncated at a modeling or jurisdictional boundary for convenience of analysis when travel behavior is substantially affected beyond that boundary.

Transit and Active Transportation Projects
Transit and active transportation projects generally reduce VMT and therefore are presumed to cause a less-than-significant impact on transportation. This presumption may apply to all passenger rail projects, bus and bus rapid transit projects, and bicycle and pedestrian infrastructure projects. Streamlining transit and active transportation projects aligns with each of the three statutory goals contained in SB 743 by reducing GHG emissions, increasing multimodal transportation networks, and facilitating mixed use development.

Roadway Projects
Reducing roadway capacity (for example, by removing or repurposing motor vehicle travel lanes) will generally reduce VMT and therefore is presumed to cause a less-than-significant impact on transportation. Generally, no transportation analysis is needed for such projects.

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Building new roadways, adding roadway capacity in congested areas, or adding roadway capacity to areas where congestion is expected in the future, typically induces additional vehicle travel. For the types of projects previously indicated as likely to lead to additional vehicle travel, an estimate should be made of the change in vehicle travel resulting from the project.

For projects that increase roadway capacity, lead agencies can evaluate induced travel quantitatively by applying the results of existing studies that examine the magnitude of the increase of VMT resulting from a given increase in lane miles. These studies estimate the percent change in VMT for every percent change in miles to the roadway system (i.e., “elasticity”). 35 Given that lead agencies have discretion in
choosing their methodology, and the studies on induced travel reveal a range of elasticities, lead agencies may appropriately apply professional judgment in studying the transportation effects of a particular project. The most recent major study, estimates an elasticity of 1.0, meaning that every percent change in lane miles results in a one percent increase in VMT.36 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 the 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 percent increase in lane miles by the existing VMT, and then multiply that by the elasticity from the induced travel literature:
[% increase in lane miles] x [existing VMT] x [elasticity] = [VMT resulting from the project] A National Center for Sustainable Transportation tool can be used to apply this method:
https://ncst.ucdavis.edu/research/tools
This method would not be suitable for rural (non-MPO) locations in the state which are neither congested nor projected to become congested. It also may not be suitable for a new road that provides new connectivity across a barrier (e.g., a bridge across a river) if it would be expected to substantially 35 See U.C. Davis, Institute for Transportation Studies (Oct. 2015) Increasing Highway Capacity Unlikely to Relieve Traffic Congestion; Boarnet and Handy (Sept. 2014) Impact of Highway Capacity and Induced Travel on Passenger Vehicle Use and Greenhouse Gas Emissions, California Air Resources Board Policy Brief, available at https://www.arb.ca.gov/cc/sb375/policies/hwycapacity/highway_capacity_brief.pdf. 36 See Duranton and Turner (2011) The Fundamental Law of Road Congestion: Evidence from US cities, available at http://www.nber.org/papers/w15376.

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shorten existing trips. If it is likely to be substantial, the trips-shortening effect should be examined explicitly.

The effects of roadway capacity on vehicle travel can also be applied at a programmatic level. For example, in a regional planning process the lead agency can use that program-level analysis to streamline later project-level analysis. (See CEQA Guidelines, § 15168.) A program-level analysis of VMT should include effects of the program on land use patterns, and the VMT that results from those land use effects. In order for a program-level document to adequately analyze potential induced demand from a project or program of roadway capacity expansion, lead agencies cannot assume a fixed land use pattern (i.e., a land use pattern that does not vary in response to the provision of roadway capacity). A proper analysis should account for land use investment and development pattern changes that react in a reasonable manner to changes in accessibility created by transportation infrastructure investments (whether at the project or program level).

Mitigation and Alternatives
Induced VMT has the potential to reduce or eliminate congestion relief benefits, increase VMT, and increase other environmental impacts that result from vehicle travel.37 If those effects are significant, the lead agency will need to consider mitigation or alternatives. In the context of increased travel that is induced by capacity increases, appropriate mitigation and alternatives that a lead agency might consider include the following:
• Tolling new lanes to encourage carpools and fund transit improvements • Converting existing general purpose lanes to HOV or HOT lanes • Implementing or funding off-site travel demand management • Implementing Intelligent Transportation Systems (ITS) strategies to improve passenger throughput on existing lanes
Tolling and other management strategies can have the additional benefit of preventing congestion and maintaining free-flow conditions, conferring substantial benefits to road users as discussed above.

G. Analyzing Other Impacts Related to Transportation
While requiring a change in the methodology of assessing transportation impacts, Public Resources Code section 21099 notes that this change “does not relieve a public agency of the requirement to analyze a project’s potentially significant transportation impacts related to air quality, noise, safety, or any other impact associated with transportation.” OPR expects that lead agencies will continue to

37 See National Center for Sustainable Transportation (Oct. 2015) Increasing Highway Capacity Unlikely to Relieve Traffic Congestion, available at
http://www.dot.ca.gov/newtech/researchreports/reports/2015/10-12-2015- NCST_Brief_InducedTravel_CS6_v3.pdf; see Duranton and Turner (2011) The Fundamental Law of Road Congestion: Evidence from US cities, available at http://www.nber.org/papers/w15376.

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address mobile source emissions in the air quality and noise sections of an environmental document and the corresponding studies that support the analysis in those sections. Lead agencies should continue to address environmental impacts of a proposed project pursuant to CEQA’s requirements, using a format that is appropriate for their particular project.

Because safety concerns result from many different factors, they are best addressed at a programmatic level (i.e., in a general plan or regional transportation plan) in cooperation with local governments, metropolitan planning organizations, and, where the state highway system is involved, the California Department of Transportation. In most cases, such an analysis would not be appropriate on a projectby-project basis. Increases in traffic volumes at a particular location resulting from a project typically cannot be estimated with sufficient accuracy or precision to provide useful information for an analysis of safety concerns. Moreover, an array of factors affect travel demand (e.g., strength of the local economy, price of gasoline), causing substantial additional uncertainty. Appendix B of OPR’s General Plan Guidelines summarizes research which could be used to guide a programmatic analysis under CEQA.

Lead agencies should note that automobile congestion or delay does not constitute a significant environmental impact (Pub. Resources Code, §21099(b)(2)), and safety should not be used as a proxy for road capacity.

H. VMT Mitigation and Alternatives
When a lead agency identifies a significant impact, it must identify feasible mitigation measures that could avoid or substantially reduce that impact. (Pub. Resources Code, § 21002.1, subd. (a).) Additionally, CEQA requires that an environmental impact report identify feasible alternatives that could avoid or substantially reduce a project’s significant environmental impacts.

Indeed, the California Court of Appeal recently held that a long-term regional transportation plan was deficient for failing to discuss an alternative which could significantly reduce total vehicle miles traveled.

In Cleveland National Forest Foundation v. San Diego Association of Governments, et al. (2017) 17 Cal.App.5th 413, the court found that omission “inexplicable” given the lead agency’s “acknowledgment in its Climate Action Strategy that the state’s efforts to reduce greenhouse gas emissions from on-road transportation will not succeed if the amount of driving, or vehicle miles traveled, is not significantly reduced.” (Cleveland National Forest Foundation, supra, 17 Cal.App.5th at p. 436.) Additionally, the court noted that the project alternatives focused primarily on congestion relief even though “the [regional] transportation plan is a long-term and congestion relief is not necessarily an effective longterm strategy.” (Id. at p. 437.) The court concluded its discussion of the alternatives analysis by stating:
“Given the acknowledged long-term drawbacks of congestion relief alternatives, there is not substantial evidence to support the EIR’s exclusion of an alternative focused primarily on significantly reducing vehicle trips.” (Ibid.)
Several examples of potential mitigation measures and alternatives to reduce VMT are described below.

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the lead agency, and mitigation measures may vary, depending on the proposed project and significant impacts, if any. Further, OPR expects that agencies will continue to innovate and find new ways to reduce vehicular travel.

Potential measures to reduce vehicle miles traveled include, but are not limited to:
• Improve or increase access to transit.
• Increase access to common goods and services, such as groceries, schools, and daycare. • Incorporate affordable housing into the project.
• Incorporate neighborhood electric vehicle network.
• Orient the project toward transit, bicycle and pedestrian facilities. • Improve pedestrian or bicycle networks, or transit service. • Provide traffic calming.
• Provide bicycle parking.
• Limit or eliminate parking supply.
• Unbundle parking costs.
• Provide parking cash-out programs.
• Implement roadway pricing.
• Implement or provide access to a commute reduction program. • Provide car-sharing, bike sharing, and ride-sharing programs. • Provide transit passes.
• Shifting single occupancy vehicle trips to carpooling or vanpooling, for example providing ridematching services. • Providing telework options.
• Providing incentives or subsidies that increase the use of modes other than single-occupancy vehicle.
• Providing on-site amenities at places of work, such as priority parking for carpools and vanpools, secure bike parking, and showers and locker rooms.
• Providing employee transportation coordinators at employment sites. • Providing a guaranteed ride home service to users of non-auto modes.

Notably, because VMT is largely a regional impact, regional VMT-reduction programs may be an appropriate form of mitigation. In lieu fees have been found to be valid mitigation where there is both a commitment to pay fees and evidence that mitigation will actually occur. (Save Our Peninsula Committee v. Monterey County Bd. of Supervisors (2001) 87 Cal.App.4th 99, 140-141; Gentry v. City of Murrieta (1995) 36 Cal.App.4th 1359; Kings County Farm Bureau v. City of Hanford (1990) 221 Cal.App.3d 692, 727–728.) Fee programs are particularly useful to address cumulative impacts. (CEQA Guidelines, § 15130, subd. (a)(3) [a “project’s incremental contribution is less than cumulatively considerable if the project is required to implement or fund its fair share of a mitigation measure or measures designed to alleviate the cumulative impact”].) The mitigation program must undergo CEQA evaluation, either on the program as a whole, or the in-lieu fees or other mitigation must be evaluated Attachment 2
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on a project-specific basis. (California Native Plant Society v. County of El Dorado (2009) 170 Cal.App.4th 1026.) That CEQA evaluation could be part of a larger program, such as a regional transportation plan, analyzed in a Program EIR. (CEQA Guidelines, § 15168.)
Examples of project alternatives that may reduce vehicle miles traveled include, but are not limited to:
• Locate the project in an area of the region that already exhibits low VMT. • Locate the project near transit.
• Increase project density.
• Increase the mix of uses within the project or within the project’s surroundings. • Increase connectivity and/or intersection density on the project site. • Deploy management strategies (e.g., pricing, vehicle occupancy requirements) on roadways or roadway lanes.

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Appendix 1. Considerations About Which VMT to Count
Consistent with the obligation to make a good faith effort to disclose the environmental consequences of a project, lead agencies have discretion to choose the most appropriate methodology to evaluate project impacts.38 A lead agency can evaluate a project’s effect on VMT in numerous ways. The purpose of this document is to provide technical considerations in determining which methodology may be most useful for various project types.

Background on Estimating Vehicle Miles Traveled
Before discussing specific methodological recommendations, this section provides a brief overview of modeling and counting VMT, including some key terminology.

Here is an illustrative example of some methods of estimating vehicle miles traveled. Consider the following hypothetical travel day (all by automobile):

1. Residence to Coffee Shop

2. Coffee Shop to Work

3. Work to Sandwich Shop

4. Sandwich Shop to Work

5. Work to Residence

6. Residence to Store

7. Store to Residence
Trip-based assessment of a project’s effect on travel behavior counts VMT from individual trips to and from the project. It is the most basic, and traditionally the most common, method of counting VMT. A trip-based VMT assessment of the residence in the above example would consider segments 1, 5, 6 and

7. For residential projects, the sum of home-based trips is called home-based VMT.

A tour-based assessment counts the entire home-back-to-home tour that includes the project. A tourbased VMT assessment of the residence in the above example would consider segments 1, 2, 3, 4, and 5 in one tour, and 6 and 7 in a second tour. A tour-based assessment of the workplace would include segments 1, 2, 3, 4, and 5. Together, all tours comprise household VMT.

38 The California Supreme Court has explained that when an agency has prepared an environmental impact report:
[T]he issue is not whether the [lead agency’s] studies are irrefutable or whether they could have been better. The relevant issue is only whether the studies are sufficiently credible to be considered as part of the total evidence that supports the [lead agency’s] finding[.]
(Laurel Heights Improvement Assn. v. Regents of the University of California (1988) 47 Cal.3d 376, 409; see also Eureka Citizens for Responsible Gov’t v. City of Eureka (2007) 147 Cal.App.4th 357, 372.) Attachment 2
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Both trip- and tour-based assessments can be used as measures of transportation efficiency, using denominators such as per capita, per employee, or per person-trip.

Trip- and Tour-based Assessment of VMT
As illustrated above, a tour-based assessment of VMT is a more complete characterization of a project’s effect on VMT. In many cases, a project affects travel behavior beyond the first destination. The location and characteristics of the home and workplace will often be the main drivers of VMT. For example, a residential or office development located near high quality transit will likely lead to some commute trips utilizing transit, affecting mode choice on the rest of the tour.

Characteristics of an office project can also affect an employee’s VMT beyond the work tour. For example, a workplace located at the urban periphery, far from transit, can require an employee to own a car, which in turn affects the entirety of an employee’s travel behavior and VMT. For this reason, when estimating the effect of an office development on VMT, it may be appropriate to consider total employee VMT if data and tools, such as tour-based models, are available. This is consistent with CEQA’s requirement to evaluate both direct and indirect effects of a project. (See CEQA Guidelines, § 15064, subd. (d)(2).)
Assessing Change in Total VMT
A third method, estimating the change in total VMT with and without the project, can evaluate whether a project is likely to divert existing trips, and what the effect of those diversions will be on total VMT.

This method answers the question, “What is the net effect of the project on area VMT?” As an illustration, assessing the total change in VMT for a grocery store built in a food desert that diverts trips from more distant stores could reveal a net VMT reduction. The analysis should address the full area over which the project affects travel behavior, even if the effect on travel behavior crosses political boundaries.

Using Models to Estimate VMT
Travel demand models, sketch models, spreadsheet models, research, and data can all be used to calculate and estimate VMT (see Appendix F of the preliminary discussion draft). To the extent possible, lead agencies should choose models that have sensitivity to features of the project that affect VMT.

Those tools and resources can also assist in establishing thresholds of significance and estimating VMT reduction attributable to mitigation measures and project alternatives. When using models and tools for those various purposes, agencies should use comparable data and methods, in order to set up an “apples-to-apples” comparison between thresholds, VMT estimates, and VMT mitigation estimates.

Models can work together. For example, agencies can use travel demand models or survey data to estimate existing trip lengths and input those into sketch models such as CalEEMod to achieve more Attachment 2
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accurate results. Whenever possible, agencies should input localized trip lengths into a sketch model to tailor the analysis to the project location. However, in doing so, agencies should be careful to avoid double counting if the sketch model includes other inputs or toggles that are proxies for trip length (e.g., distance to city center). Generally, if an agency changes any sketch model defaults, it should record and report those changes for transparency of analysis. Again, trip length data should come from the same source as data used to calculate thresholds to be sure of an “apples-to-apples” comparison.

Additional background information regarding travel demand models is available in the California Transportation Commission’s “2010 Regional Transportation Plan Guidelines,” beginning at page 35.

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Appendix 2. Induced Travel: Mechanisms, Research, and Additional Assessment Approaches Induced travel occurs where roadway capacity is expanded in an area of present or projected future congestion. The effect typically manifests over several years. Lower travel times make the modified facility more attractive to travelers, resulting in the following trip-making changes:
● Longer trips. The ability to travel a long distance in a shorter time increases the attractiveness of destinations that are farther away, increasing trip length and vehicle travel. ● Changes in mode choice. When transportation investments are devoted to reducing automobile travel time, travelers tend to shift toward automobile use from other modes, which increases vehicle travel.
● Route changes. Faster travel times on a route attract more drivers to that route from other routes, which can increase or decrease vehicle travel depending on whether it shortens or lengthens trips.
● Newly generated trips. Increasing travel speeds can induce additional trips, which increases vehicle travel. For example, an individual who previously telecommuted or purchased goods on the internet might choose to accomplish those tasks via automobile trips as a result of increased speeds.
● Land Use Changes. Faster travel times along a corridor lead to land development farther along that corridor; that new development generates and attracts longer trips, which increases vehicle travel. Over several years, this induced growth component of induced vehicle travel can be substantial, making it critical to include in analyses.

Each of these effects has implications for the total amount of vehicle travel. These effects operate over different time scales. For example, changes in mode choice might occur immediately, while land use changes typically take a few years or longer. CEQA requires lead agencies to analyze both short-term and long-term effects.

Evidence of Induced Vehicle Travel. A large number of peer reviewed studies39 have demonstrated a causal link between highway capacity increases and VMT increases. Many provide quantitative estimates of the magnitude of the induced VMT phenomenon. Collectively, they provide high quality evidence of the existence and magnitude of the induced travel effect.

39 See, e.g., Boarnet and Handy (Sept. 2014) Impact of Highway Capacity and Induced Travel on Passenger Vehicle Use and Greenhouse Gas Emissions, California Air Resources Board Policy Brief, available at https://www.arb.ca.gov/cc/sb375/policies/hwycapacity/highway_capacity_brief.pdf; National Center for Sustainable Transportation (Oct. 2015) Increasing Highway Capacity Unlikely to Relieve Traffic Congestion, available at
http://www.dot.ca.gov/research/researchreports/reports/2015/10-12-2015- NCST_Brief_InducedTravel_CS6_v3.pdf.

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Most of these studies express the amount of induced vehicle travel as an “elasticity,” which is a multiplier that describes the additional vehicle travel resulting from an additional lane mile of roadway capacity added. For example, an elasticity of 0.6 would signify an 0.6 percent increase in vehicle travel for every 1.0 percent increase in lane miles. Many of these studies distinguish “short run elasticity” (increase in vehicle travel in the first few years) from “long run elasticity” (increase in vehicle travel beyond the first few years). Long run elasticity is larger than short run elasticity, because as time passes, more of the components of induced vehicle travel materialize. Generally, short run elasticity can be thought of as excluding the effects of land use change, while long run elasticity includes them. Most studies find a long run elasticity between 0.6 and just over 1.0, 40 meaning that every increase in lanes
miles of one percent leads to an increase in vehicle travel of 0.6 to 1.0 percent. The most recent major study finds the elasticity of vehicle travel by lanes miles added to be 1.03; in other words, each percent increase in lane miles results in a 1.03 percent increase in vehicle travel. 41 (An elasticity greater than 1.0
can occur because new lanes induce vehicle travel that spills beyond the project location.) In CEQA analysis, the long-run elasticity should be used, as it captures the full effect of the project rather than just the early-stage effect.

Quantifying Induced Vehicle Travel Using Models. Lead agencies can generally achieve the most accurate assessment of induced vehicle travel resulting from roadway capacity increasing projects by applying elasticities from the academic literature, because those estimates include vehicle travel resulting from induced land use. If a lead agency chooses to use a travel demand model, additional analysis would be needed to account for induced land use. This section describes some approaches to undertaking that additional analysis.

Proper use of a travel demand model can capture the following components of induced VMT:
• Trip length (generally increases VMT)
• Mode shift (generally shifts from other modes toward automobile use, increasing VMT) • Route changes (can act to increase or decrease VMT)
• Newly generated trips (generally increases VMT)
o Note that not all travel demand models have sensitivity to this factor, so an off-model estimate may be necessary if this effect could be substantial.

However, estimating long-run induced VMT also requires an estimate of the project’s effects on land use. This component of the analysis is important because it has the potential to be a large component of

40 See Boarnet and Handy (Sept. 2014) Impact of Highway Capacity and Induced Travel on Passenger Vehicle Use and Greenhouse Gas Emissions, California Air Resources Board Policy Brief, p. 2, available at https://www.arb.ca.gov/cc/sb375/policies/hwycapacity/highway_capacity_brief.pdf. 41 Duranton and Turner (2011) The Fundamental Law of Road Congestion: Evidence from US cities, available at http://www.nber.org/papers/w15376.

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the overall induced travel effect. Options for estimating and incorporating the VMT effects that are caused by the subsequent land use changes 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 the 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 should 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, and 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 project which provides new connectivity across a barrier, such as a new bridge across a river, may provide a shortened path between existing origins and destinations, thereby shortening existing trips. In rare cases, this trip-shortening effect might be substantial enough to reduce the amount of vehicle travel resulting from the project below the range found in the elasticities in the academic literature, or even lead a net reduction in vehicle travel overall. In such cases, the trip-shortening effect could be examined explicitly.

Whenever employing a travel demand model to assess induced 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 the 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.

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Analyzing Vehicle
Miles Traveled for
CEQA Compliance
SB 743 IMPLEMENTATION GUIDELINES FOR THE

CITY OF WATSONVILLE
Adopted September 27, 2022
Resolution No. ___-22 (CM)
Community Development Department | Public Works & Utilities Department 250 Main Street
Watsonville, CA 95076
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2 SB 743 Implementation Guidelines
City of Watsonville
Background
In 2013, SB 743 was signed into law by California Governor Jerry Brown with a goal of reducing Greenhouse Gas (GHG) emissions, promoting the development of infill land use projects and multimodal transportation networks, and to promote a diversity of land uses within developments. One significant outcome resulting from this statute is that automobile delay, as measured by “level of service” (LOS) and other similar metrics, generally no longer constitutes a significant environmental effect under the California Environmental Quality Act (CEQA). (Pub. Resources Code, § 21099(b)(2)). This change in the analysis of transportation impacts went into effect when the CEQA Guidelines were updated to make the revisions called for in SB 743 and were certified by the Natural Resources Agency in December, 2018.

The Governor’s Office of Planning and Research (OPR) selected Vehicle Miles Traveled (VMT) as the principal measure to replace LOS for determining significant transportation impacts. VMT is a measure of total vehicular travel that accounts for the number of vehicle trips and the length of those trips. OPR selected VMT, in part, because jurisdictions are already familiar with this metric. VMT is already used in CEQA to study other potential impacts such as GHG, air quality, and energy impacts and is used in planning for regional Sustainable Communities Strategies (SCS). As of July 1, 2020, agencies analyzing the transportation impacts of new projects must look at VMT as a metric known as vehicle miles traveled (VMT) instead of LOS.

VMT also allows for an analysis of a project’s impact throughout the jurisdiction rather than only in the vicinity of the proposed project allowing for a better understanding of the full extent of a project’s transportation-related impact.

As California has a number of regulations regarding GHG emissions that are often confused with each other, Appendix G provides additional background information on two key laws – AB 32 and SB 375 – and how they align with strategies for the Association of Monterey Bay Area Governments (AMBAG) region to reduce VMT regionally.

Use of this Document
This document has been developed to serve both as the basis of SB 743 implementation and VMT analysis within the City. While this document includes footnotes and references to other documents, the use of this document does not require the reader to reference the footnotes unless they are interested in understanding the technical basis of elements of this document’s preparation. The analysis guidelines are separated into two distinct approaches, those that relate to land use projects and those that relate to transportation improvement projects. If a project includes both land use and transportation improvement elements, analysis would be required to be carried out for both. Projects not subject to CEQA are not required to follow these guidelines. This includes projects that are reviewed under existing ministerial or administrative processes, site plan review, and other actions that do not require environmental review.

This policy shall be administered by the Zoning Administrator and City Engineer, who shall be responsible for all determinations required as part of its implementation. For example, the Zoning Administrator would make a determination whether a land use project meets any of the screening criteria listed in Exhibit 2. Whereas, the City Engineer would decide on whether a transportation project has been prescreened, as further discussed on page 11. Generally speaking, the Zoning Administrator would address questions concerning land use projects, and the City Engineer would address questions Attachment 3
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3 SB 743 Implementation Guidelines
City of Watsonville
concerning transportation improvement projects. The City Engineer would also be responsible for making determinations on technical questions, such appropriate Institute of Transportation Engineers (ITE) trip generation rates.

Land Use Projects
The approach included within this document identify transportation impacts under CEQA for land-use projects that closely align with guidance provided within the OPR Technical Advisory on Evaluating Transportation Impacts in CEQA (2018).

While the OPR guidance related to SB 743 has been a helpful introduction to using VMT to evaluate projects, it does not provide a complete solution. There are a multitude of complex practical issues that are not addressed by the OPR guidance. OPR Guidance does not specifically address land uses beyond residential, office and retail, and it provides latitude on some elements of implementation. In response to this, a specific series of analytical steps for SB 743 project evaluation have been developed to clarify requirements and reduce potential confusion. Exhibit 1 provides a graphical representation of this analytical process.

Step 1: Evaluate Land Use Type
During the initial step, a land use project will need to be evaluated for the following considerations:
 Land use type. For the purposes of analysis, the ITE land use codes serve as the basis of land use definitions. Although it is recognized that VMT evaluation tools and methodologies are typically not fully sensitive to some of the distinctions between some ITE categories, the use of ITE land use codes is useful for maintaining consistency across analyses, determining trip generation for other planning level tools, and maintaining a common understanding of trip making characteristics amongst transportation professionals. The ITE land use code is also used as an input into the sketch planning tool.
 Mixed use. If there are multiple distinct land uses within the project (residential, office, retail, etc.), they will be required to be analyzed separately unless they are determined to be insignificant to the total VMT. Mixed use projects are permitted to account for internal capture which depending on the methodology may require a distinct approach not covered in this documentation.
 Redevelopment projects. As described under the Non-Significant Screening Criteria section, redevelopment projects which have lower VMT than the existing on-site use can be determined to have a non-significant impact.

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4 SB 743 Implementation Guidelines
City of Watsonville
Exhibit 1 – Process for CEQA VMT Analysis for Land Use Projects Attachment 3
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5 SB 743 Implementation Guidelines
City of Watsonville
Step 2: Screen for Non-Significant Transportation Impact The purpose of this step is to determine if a presumption of a non-significant transportation impact can be made on the facts of the project. The guidance in this section is primarily intended to avoid unnecessary analysis and findings that would be inconsistent with the intent of SB 743. A detailed CEQA transportation analysis will not be required for land use projects that meet the screening criteria shown in Exhibit 2. If a project is mixed use in nature, only those elements of the project that do not meet any of the criteria in Exhibit 2 would require further evaluation to determine transportation significance for CEQA purposes.

Exhibit 2 – Land Use Project Screening Criteria
Screening Criteria1Impact Analysis
SMALL PROJECTS2 Presumed to cause a less-than-significant impact:
 Project generation is less than 110 trips per day
Unless:
 It is inconsistent with the current General Plan and Metropolitan Transportation Plan/Sustainable Communities Strategy (MTP/SCS)

PROJECTS NEAR HIGH
QUALITY TRANSIT3
Presumed to cause a less-than-significant impact:
 Within a ½ mile of an existing major transit stop, which maintains a service interval frequency of 15 minutes or less during the morning and afternoon peak commute periods.

Unless:
 Has a Floor Area Ratio (FAR) of less than 0.75
 Includes more parking for use by residents, customers, or employees of the project than required by the City of Watsonville  It is inconsistent with the current General Plan and MTP/SCS  Replaces affordable residential units with a smaller number of moderate- or high-income residential units

1 When the Screening Criteria are met no further transportation analysis of VMT impacts under CEQA is necessary. 2 Office of Planning and Research (2018), OPR Technical Advisory on Evaluating Transportation Impacts in CEQA, p. 12, available at https://opr.ca.gov/docs/20190122-743_Technical_Advisory.pdf. 3 Ibid., p. 13.

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Screening Criteria Impact Analysis

LOCAL-SERVING
RETAIL4
Presumed to cause a less-than-significant impact:
 No single store on-site exceeds 50,000 square feet
 Project is local-serving
Unless:
 If the nature of the service is regionally focused5

AFFORDABLE
HOUSING6
Presumed to cause a less-than-significant impact:
 The residential component of a project consists of 100-percent affordable residential units
Unless:
 The percentage of affordable housing is less than 100 percent of the residential element of a project

LOCAL ESSENTIAL
SERVICE7
Presumed to cause less-than-significant impact:
 Day care center
 Public K-12 School
 Police or Fire facility
 Medical/Dental office building
 Assisted living / memory care facility
 Government offices (in-person services such as post office, library, and utilities)
Unless:
 The nature of the service is regionally focused

4 Ibid., p. 16. For purposes of these Guidelines, “Local Serving” shall mean retail operations that primarily serve nearby residential neighborhoods within the City of Watsonville. A determination that a project is “Local Serving” may be supported by a market study or other studies of similar uses elsewhere in the City.
5 For purposes of these Guidelines, “Regionally Focused” shall mean retail operations that primarily serve a regional customer base. A determination that a project is “Regionally Focused” may be supported by a market study or other studies of similar uses elsewhere in the region surrounding the City.
6 OPR (2018), p. 14. As described, “Evidence supports a presumption of less than significant impact for a 100 percent affordable residential development (or the residential component of a mixed-use development) in infill locations. Lead agencies may develop their own presumption of less than significant impact for residential projects (or residential portions of mixed-use projects) containing a particular amount of affordable housing, based on local circumstances and evidence.”
7 Based on assumption that, like local-serving retail, the addition of necessary local in-person services will reduce VMT given that trips to these locations will be made irrespective of distance given their non-discretionary nature.

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Screening Criteria Impact Analysis

MAP-BASED
SCREENING8
Presumed to cause a less-than-significant impact:
 Area of development is under threshold as shown on a screening map included in Appendix B
Unless:
 Represent significant growth as to substantially change regional travel patterns

REDEVELOPMENT
PROJECTS9
Presumed to cause a less-than-significant impact:
 Project replaces an existing VMT-generating land use and does not result in a net overall increase in VMT
Unless:
 Project replaces an existing VMT-generating land use and results in a net overall increase in VMT
Step 3: Significance Threshold and Methodology
The purpose of this step is to determine the appropriate threshold of significance for a land use project.

Significance thresholds are based on land use type and are broadly grouped into two categories: efficiency and net change metrics. Efficiency metrics include VMT/capita and Work VMT/employee. 10 As shown in
Exhibit 1, projects involving residential and office land uses would be evaluated using efficiency metrics; whereas, projectsthat include a significant customer/user base, such as retail and other commercial uses, would be evaluated based on the net change in regional VMT based on customer/user trips. Exhibit 3 provides a few examples of the variety of uses that have similar characteristics for using Efficiency or Net Change metrics.

Exhibit 3 - Significance Threshold and Methodology
Threshold Basis Efficiency Net Change
Example Land Uses
Residential, Professional Office,
Industrial Retail, Medical Office, Sports Venue
Example VMT Thresholds Per capita, per employee Regional VMT change Customer/User Component
(Primary source of VMT) No Yes

8 OPR (2018), p. 12.
9 Ibid., p. 18.
10 Work VMT specifically applies to commute trips as represented by the attractions in the Travel Demand Model. Refer to Appendix A for additional information.

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Threshold Basis Efficiency Net Change
Allowable Methods
Non-Significant Screening Criteria,
The City of Watsonville Sketch
Planning Tool, Travel Demand
Model
Non-Significant Screening Criteria,
Travel Demand Model
For projects with a large customer/user base, it is typically appropriate to separate employee trip characteristics from the customer base trip characteristics. Under these circumstances, it is most appropriate to evaluate the total of the delta in regional VMT resulting from the customer base plus the delta of VMT resulting from employees based on the following formula:
(number of employees) x (estimated VMT/employee – threshold VMT/employee) The threshold of significance will accordingly correspond to the “Net Change” threshold as described in Exhibit 3. Under these circumstances, it is most appropriate to evaluate this total Net Change as the basis for evaluating the outcome of mitigations. As with mixed use projects, each element of the project should be tallied and evaluated separately.

VMT Thresholds of Significance
OPR recommends a 15 percent VMT reduction relative to existing development may be a reasonable threshold. While OPR’s Technical Advisory is not binding on public agencies, CEQA allows lead agencies to “consider thresholds of significance . . . recommended by other public agencies, provided the decision to adopt those thresholds is supported by substantial evidence.”11 According to OPR, achieving 15 percent lower per capita (for residential development) or per employee (for office development) VMT compared with VMT resulting from existing development is both generally achievable and is supported by evidence that connects this level of reduction to the State’s emissions goals.
12 The thresholds of significance recommended by OPR, as they relate to the City of Watsonville, are summarized in Exhibit 4.

Exhibit 4 - OPR suggested VMT Thresholds of Significance Land Use OPR Guidance13
Residential 15% below existing county-wide average VMT per capita Office 15% below existing county-wide average VMT per employee Retail Net increase in total VMT
Exhibit 5 provides the City’s VMT thresholds of significance for residential, office, retail, and related land use projects based on these criteria.

11 CEQA Guidelines, § 15064.7(c).
12 OPR (2018), pp. 10-12.
13 Ibid., pp. 15-16.

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Exhibit 5 - VMT Thresholds of Significance
Land Use VMT Threshold Basis
Residential 8.9 VMT/capita14 15% below existing county-wide average VMT per capita Office 7.4 Work VMT/employee15 15% below existing county-wide average Work VMT per employee
Retail No net increase Using the county-wide VMT as the basis Other
Customer
No net increase Using the county-wide VMT as the basis for similar land uses
Other
Employment Work VMT/employee16 15% below existing county-wide average Work VMT per employee for similar land uses Note that the inclusion of “Other Employment” and “Other Customer” refers to all other service and goods providers that are not included in the basic office/retail categories. As shown, they follow a similar approach to the office/retail categories with the principal difference being that the average/basis for the threshold would be the aggregation of the specific “other” land use across the County (i.e., an industrial project would use industrial uses, etc.).

Based on improvements to methods and data as well as other modeling modifications there will be periodic updates to the numerical threshold values shown, however the relative approach for calculating them should remain the same. The values in the current sketch planning tool, discussed in the next section, will supersede the information provided in the table above. Additional thresholds for various employment types are also provided in the sketch planning tool.

Sketch Planning Tool
The City of Watsonville has developed a sketch planning tool for use in SB 743 land use project analysis.

The purpose of the tool is to enable staff to calculate VMT for a land use project. The sketch planning tool allows the user to enter project information, such as a land use type, amount of development (in terms of units for residential projects and square feet for commercial or other types of non-residential projects), and then generate a VMT output. If above a VMT threshold of significance, applicable Transportation Demand Management (TDM) strategies (from Appendix C) can be applied to reduce the project’s overall VMT and evaluate their effectiveness. The tool also includes presumption overrides for land use projects that meet screening criteria in Exhibit 2, such as projects that provide affordable housing units or local serving retail space up to but not exceeding 50,000 square feet in floor area.

As with any sketch planning tool, there are distinct limitations in terms of its application including limits on the type and size of development that the tool can be applied to. Note that this tool is intended for

14 Residential VMT specifically applies to all Home-Based trips as represented in the Travel Demand Model. Refer to Appendix A for additional information.
15 Work VMT specifically applies to commute trips as represented in the Travel Demand Model. Refer to Appendix A for additional information. 16 Work VMT specifically applies to commute trips as represented in the Travel Demand Model. Refer to Appendix A for additional information.

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projects involving up to 2,000 trips. (For projects involving more than 2,000 trips, the Travel Demand Model would need to be run to accurately estimate VMT.) Note further that it is anticipated that the tool will continue to evolve in response to data or methodological changes and as such, it isimportant that the most current version of the tool be utilized. Broadly, the sketch planning tool provides the following information:
 Institute of Transportation Engineers (ITE) Trip Generation  Vehicle Miles Traveled (VMT) Threshold Analysis
 Greenhouse Gas (GHG) Estimation
 Transportation Demand Management (TDM) Evaluation
The VMT Analysis methodology utilized by the sketch planning tool is summarized in Appendix A.

Agreement Prior to Conducting a VMT Analysis
Prior to undertaking VMT analysis, a scope of work that is compliant with the City of Watsonville’s requirements should be prepared and submitted by the Applicant for approval by City staff. Given the potential complexities of some uses, particularly those not identified as residential, retail, or office, an agreement regarding the threshold and methodology is important to avoid analysis that is not compliant with CEQA and the City of Watsonville’s standards.

Step 4: VMT Analysis
If a proposed project does not meet one of the screening criteria in Exhibit 2, a VMT analysis shall be conducted for the project in accordance with the City’s requirements. During this step, the analysis agreed to under Step 3 would be completed. Along with the results of the VMT analysis, relevant documentation must be provided with enough detail to understand assumptions used in conducting the analysis and confirm and/or replicate the methods used in performing the analysis for the proposed project.

Step 5: Mitigation Measures
If a significant transportation impact is identified, the City of Watsonville, as lead agency, must consider mitigation or alternatives. CEQA requires that the mitigation measures or alternatives be included in the project’s environmental assessment analysis. OPR provides a list of potential measures to reduce VMT but gives a lead agency full discretion in the selection of mitigation measures.

The type and size of the project will determine the most appropriate mitigation strategies for VMT impacts. For large projects such as general plans or specific plans, VMT mitigations should concentrate on the project’s density and land use mix, site design, regional policies, and availability of transit, bicycle, and pedestrian facilities. For smaller projects such as an individual development project, VMT mitigations will typically require the preparation of a TDM program. A TDM program is a combination of strategies to reduce VMT. The program is created by an applicant for their land use project based on a list of strategies agreed to by the Zoning Administrator and City Engineer.

The City of Watsonville has developed a list of potential TDM strategies appropriate for the City and quantifies the magnitude of VMT reduction that could be achieved. The selection process was guided by the California Air Pollution Control Officers Association (CAPCOA) recommendations found in the 2010 Attachment 3
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publication Quantifying Greenhouse Gas Mitigation Measures. The area context of the City of Watsonville also influenced the type of TDM strategies that were selected. CAPCOA has found strategies with the largest VMT reduction in suburban areas include vanpools, telecommute or alternative work schedules, and master planned communities with design and land-use diversity to encourage intra-community travel.

Based on empirical evidence, CAPCOA found the cross-category maximum for all transportation-related mitigation measures is 15% for suburban settings.

Appendix C summarizes available TDM strategies, along with the maximum VMT reduction, applicable land use application, and complementary strategies. The City of Watsonville’s sketch planning tool includes the TDMs summarized in Appendix C.

Step 6: Monitoring Mitigation
As required by CEQA, the City of Watsonville will require ongoing mitigation monitoring and reporting when mitigation measures are adopted as part of an approved project. The specifics of this will be developed on a project-by-project basis. As an example, the City may require the determination of a “trip cap” (the number of vehicle trips entering/existing the site that would correspond with the threshold VMT estimate) as part of the mitigation plan. Subsequently, the project could be required to provide annual reporting of driveway counts collected by an acceptable third party to demonstrate the effectiveness of the adopted mitigation measures.

Transportation Projects
Depending on the specific nature of a transportation project it can alter trip patterns, trip lengths, and even trip generation. Research has determined that capacity-enhancing projects can and often do increase VMT. This phenomenon is commonly referred to as “induced demand”. While methods are generally less developed for the analysis of induced demand compared to other areas of transportation analysis, there is still the need to quantify and understand its impact to the transportation system considering the requirements of SB 743.

Similar to land use projects, the approach to transportation project analysis closely aligns with the 2018 OPR Guidance. In terms of analysis, the analyst should first determine whether the transportation project has been prescreened and determined to have a non-significant impact as described in the following section.

Screen for Non-Significant Transportation Impact
The following non-significant impact examples are provided directly from the 2018 OPR Guidance17:
 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) and that do not add additional motor vehicle capacity;
 Roadside safety devices or hardware installation such as median barriers and guardrails;

17 OPR (2018), p. 20.

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 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 one mile in length designed to improve roadway safety;  Installation, removal, or reconfiguration of traffic lanes that are not for through traffic, such as left, right, 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 to use only by transit vehicles;  Reduction in number of through lanes (“road diet”);
 Grade separation to separate vehicles from rail, transit, pedestrians or bicycles, or to replace a lane in order to separate preferential vehicles (e.g., HOV, HOT, or trucks) from general vehicles;  Installation, removal, or reconfiguration of traffic control devices, including Transit Signal Priority (TSP) features;
 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 new transit service;
 Conversion of streets from one-way to two-way operation with no net increase in 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; Attachment 3
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 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 nonmotorized travel;  Installation of publicly available alternative fuel/charging infrastructure; and  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.

Significance Threshold and Methodology
For projects that increase roadway capacity and are not identified under the Non-Significant Screening Criteria in the prior section, the significance criterion should be “Net Change” in regional VMT. A finding of a significant impact would be determined if a transportation project results in a net increase in regional VMT.

VMT Mitigation Banking Program
This section discusses a programmatic approach to respond to the need for feasible VMT mitigation within the City of Watsonville. In suburban areas such as the City of Watsonville, VMT impact analyses can result in a finding of a significant adverse transportation impact, particularly in undeveloped areas, due to a lack of land use density and diversity. In addition, with fewer transportation options compared to more urbanized areas, mitigating impacts in suburban areas can prove to be more difficult than under the former LOS methodology for analyzing traffic impacts. For many jurisdictions like the City of Watsonville, the switch to the VMT methodology under SB 743 is resulting in a reversal in the results of transportation impact significance findings as compared to the analyses conducted under the former LOS-based methodology.

As a practical matter, the new VMT methodology is also a more restrictive approach to identifying transportation impacts both because of the basis for setting an impact threshold and limited mitigation opportunities. In terms of the threshold of significance, OPR recommends that projects consisting of residential or general employment category land uses effectively need to be located in an area where they are 15 percent less than the average VMT for similar uses.18 Effectively this means that new projects must be located in an area where they are more efficient than 65-percent of similar uses from a VMT standpoint. Given the suburban nature of Watsonville and elsewhere in the region, there is a need for additional feasible mitigation solutions.

To date, VMT mitigation across the State has relied heavily on TDM measures. These measures generally represent two basic approaches: infrastructure and policy. The documents produced by CAPCOA regarding VMT mitigation represent the primary bases for estimating the effectiveness of TDM mitigation in California.19,20 Although CAPCOA is an invaluable resource, many of the TDM mitigation options

18 OPR (2018), pp. 12 & 15.
19 CAPCOA (2010), Quantifying Greenhouse Gas Mitigation Measures. 20 CAPCOA (2021), Handbook for Analyzing Greenhouse Gas Emission Reductions, Assessing Climate Vulnerabilities, and Advancing Health & Equity.

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provided have questionable efficacy in suburban and rural settings, as they are more effective in urban settings with high quality transit and a mix of land uses in close proximity to one another. TDMs can also be challenging from the standpoint of mitigation monitoring and are often unpopular with project applicants because they may need to be managed and paid for in perpetuity. These limitations have led jurisdictions, including the City of Watsonville, to increasingly consider programmatic approaches, in addition to TDMs, for VMT mitigation. Programmatic approaches can allow for collectively funding larger mitigation projects such that a development or transportation project can obtain an amount of mitigation commensurate with their impact with a single monetary payment. Programmatic approaches can also provide a public benefit in terms of funding transportation improvements that would not otherwise be constructed, resulting in improvements to congestion, GHG emissions, increased transportation choices, and additional opportunities for active transportation.

The City of Watsonville has developed a VMT Mitigation Banking Program to help address the need for additional VMT mitigation. A mitigation bank attempts to create a monetary value for VMT reduction such that a developer could purchase VMT reduction credits—i.e., these credits are purchased for the purposes of mitigating VMT in excess of determined impact thresholds. The underlying projects may be either regionally or locally beneficial to the area in which the project is located.

VMT Mitigation Need
The locations of future development, the quantity of development, and the extent of mitigation needs based on individual Traffic Analysis Zone (TAZ) output are invaluable input into determining the magnitude of VMT mitigation needed in the future. This type of dataset is both invaluable to understanding potential revenue and the amount that differing spatial areas may require in mitigation terms.

Using Santa Cruz County’s Travel Demand Model and the thresholds established within this document for the City of Watsonville, the total potential VMT to be mitigated was calculated by calculating the difference between the VMT per capita and VMT per employee for each Traffic Analysis Zone (TAZ) that is over the established thresholds. The difference was then multiplied by the population and total employees for each TAZ to develop a total VMT per TAZ to be mitigated, which then allows for a City-wide total to be calculated. Based on these forecasts, Exhibit 6 below presents an estimate of the amount of VMT that will need to be mitigated through 2040. More detailed mapping showing the spatial location of VMT mitigation needs is provided in Appendix D. Although this data does not account for the potential level of site specific VMT mitigation that will occur, it does present a clear need for mitigation more than what can be achieved through TDMs or similar site-based mitigation approaches.

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Exhibit 6 – VMT Summary for Anticipated Growth and Needed Mitigation through 2040 Category #
Future Households over Threshold 678
Future Employment over Threshold 8,997
2040 Total Residential VMT 476,757
2040 Total Employment-Based VMT 333,755
2040 Total Residential VMT for VMT/capita over threshold 237,613 2040 Total Employment-Based VMT for VMT/employee over threshold 333,755 Feasible Mitigation
This section discusses how CEQA and the State of California treat cases in which a project has a significant transportation impact and therefore is required to provide feasible mitigation. Based on research conducted by CAPCOA, the maximum reduction in VMT that can be feasibly attained using exclusively site-specific mitigation measures in a suburban context such as the City of Watsonville, is 15-percent.21 Site-specific solutions most often rely on TDM measures, as discussed in the previous section, although project land use modifications can also be utilized to mitigate impacts. Therefore, projects that exceed the VMT significant impact thresholds by more than 15-percent must rely on non-site-specific approaches if full mitigation is to be achieved. If full mitigation is not possible, CEQA nonetheless requires that feasible mitigation measures be imposed to reduce the severity of the impact even if the impact remains significant with the mitigation.

Based on this, if a project exceeds the City’s VMT threshold by more than 15 percent, it will require a combination of site-specific measures and non-site-specific measures, including the VMT Mitigation Bank as discussed in the next section, in order to achieve mitigation. This could mean using only site-specific mitigation measures to reach the 15-percent threshold, using only the VMT Mitigation Bank to reach the 15-percent threshold, or using both to reach the 15-percent threshold, such as using TDM measures to reduce VMT by 6-percent and then using the VMT Mitigation Bank to reduce VMT by the remaining 9 percent.

VMT Banking Projects
Exhibit 7 below provides information on the VMT banking projects that development and transportation projects can contribute funds for the purpose of mitigating their VMT impacts. The primary focus of these projects is to construct or improve active transportation facilities that will replace vehicular trips thereby reducing VMT. Note that the City may, at its discretion, add additional projects to this list which may alter the then current fee structure discussed in the Maximum Banking Credit Rate provided later in this document. Cost estimate details are provided in Appendix E.

21 CAPCOA (2010), Quantifying Greenhouse Gas Mitigation Measures.

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Exhibit 7 – VMT Banking Projects
Trail
ID
Type Name of
Project
Description Length/Number
of Improvements
Cost
Estimate

8.2 Bike/Ped Lower
Watsonville
Slough Loop
Provide a new slough trail at the following
segments to create a new loop:
- Main Street to Ford Street
- San Luis Avenue to the existing Watsonville
slough loop

0.11 mi $9,475,000

8.5 Bike/Ped La Brisas
Connector Trail
Provide connection along San Luis Avenue & Santa
Victoria Avenue to the existing trail

0.13 mi $4,000

8.7 Bike/Ped Manabe-Ow
Connector Trail
Provide bridge from Manabe-Ow to existing trail 0.10 mi $16,400,000

9.1 Bike/Ped Upper Struve
Slough Trail
Slough trail connecting Pennsylvania Drive to South
Green Valley Road

0.47 mi $2,410,000

9.3 Bike/Ped Rolling Hills
Connector Trail
Trail loop along Eileen Street, SR 152, South Green
Valley Road, and Melwood Court

0.33 mi $720,000

9.4 Bike/Ped Upper
Watsonville
Slough
Slough trail from Main Street to Freedom
Boulevard

1.05 mi $15,790,000
Total $44,799,000
Maximum VMT Banking Credit Rate and Nexus:

The four steps to identify the VMT Mitigation Banking projects and calculate the VMT Banking credit rate are as follows:

1. Identify appropriate mitigation projects;

2. Determine the cost of construction of the mitigation projects;

3. Determine the total VMT that can be mitigated by the projects; and

4. Calculate the maximum mitigation credit rate per VMT by dividing total cost of the mitigation projects by the total VMT mitigated by the projects to determine the rate per unit of VMT.

The approach outlined above results in a calculation of the maximum rate per VMT mitigated based on the list of projects identified above. The full cost of funding these improvements is used to calculate the maximum VMT Mitigation Banking credit rate per VMT the City could apply to all new residential and nonresidential development in the City between 2022 and 2032 that result in VMT impacts.

As part of this analysis, a nexus evaluation was undertaken to support the basis of the VMT Mitigation Bank’s development and credit rate. Consistent with California’s Mitigation Fee Act, to develop a fee program a local agency must identify the purpose of the fee (Gov’t Code § 66001(a)(1)). The City of Watsonville’s policy is that new development shall contribute to the VMT banking credit rate, if needed for mitigation of their VMT impacts. In addition, the costs of constructing the improvements to help mitigate VMT citywide will be implemented through the VMT Mitigation Banking Program administered by the City of Watsonville.

As noted above, the projects that are included in the City of Watsonville’s VMT Mitigation Banking Program will fund the construction of facilities that support active transportation (cycling and walking) to Attachment 3
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mitigate VMT impacts from new development by moving trips from automobiles to bike or pedestrian facilities. As these projects’ benefit could not be sufficiently analyzed using the Travel Demand Model given limitations within the model related to the representation of bike and pedestrian facilities, the projects were analyzed using off-model techniques. Specifically, bicycle improvements were evaluated based on NCHRP 552 Guidelines for Analysis of Investments in Bicycle Facilities. This approach relies on spatial analysis techniques to determine the likely number of new active transportation users resulting from the introduction of a new bicycle improvement. This approach also removes the number of new users who will use the facility for exercising as exercise will not replace vehicle trips and thus, will not reduce existing VMT. Based on survey data of bicyclists throughout the United States, both for adults and children, the percentage of those cycling for commute purposes was estimated to be 11-percent of all riders and those cycling for exercise was estimated to be 28-percent of all riders. Child cyclists are included in the analysis as they may use the new facility to access schools, friends, or stores among other destinations that previously they would need a parent to drive them to. Thus, with the removal of riders for exercise, only riders that would use the facilities to replace vehicle trips were included in the analysis.

The resultant bike ridership estimates are provided in Appendix F. Note that although the projects will provide benefits to pedestrians, those were not quantified for the purposes of this analysis given that the nature and location of these projects is not anticipated to significantly result in walking trips replacing vehicle-based trips. Exhibit 8 shows the comparison between the existing ridership and future induced riders based on the construction of the projects.

Exhibit 8 – Existing and Future Daily Bicycle Ridership Demand
(facility users)
Existing Riders Induced Riders Total Future Riders
(existing + induced)
Adult Bicyclists 5,264 5,606 10,870
Child Bicyclists 1,629 1,743 3,372
Total 6,893 7,349 14,242
As shown in Exhibit 8, the bicycle improvement projects could add almost 7,350 bicycle riders per day throughout the City in the future (by model year 2032), which would roughly double existing bicycle ridership to over 14,000 bicycle trips throughout the City and provide an alternative to congested vehicular travel along with significant health and recreational benefits. While not related to VMT mitigation, it should also be noted that construction of the pedestrian and bicycle improvements will result in additional safety benefits by reducing the potential for vehicle-bicycle and vehicle-pedestrian conflicts.

Total VMT Reduction
The total VMT reduction per project for the bicycle and pedestrian projects was calculated by multiplying the average bicycle trip length taken by new riders induced by the construction of a project by the total number of new riders and the project’s lifecycle. For the purposes of this analysis, the average trip length used was four miles, based on industry standard assumptions. In addition, the project lifecycle was assumed to be ten years to cover the analysis period between 2022 and 2032. The number of new bicycle riders for each project was multiplied by the average trip length to obtain the total daily VMT reduction Attachment 3
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for each project. Each project’s VMT reduction was added together to determine the total VMT reduction for all bicycle and pedestrian projects, which for the projects listed in Exhibit 7 total 29,392.

Maximum Banking Credit Rate
To determine the maximum overall credit rate, the total project costs of $44,799,000 was divided by the total VMT reduction of 29,392 daily VMT. This calculation resulted in a maximum cost per VMT reduction of $1,524.21. Note that this rate does not include any non-fee funding sources (grants, etc.). The addition of any funding sources for these projects could reduce the cost to fully implement projects included in Exhibit 7.

VMT Mitigation Banking Program Administration and Monitoring The City of Watsonville shall set up a separate account for the purpose of tracking the collection of payments into the VMT Mitigation Banking Program. This account shall be monitored by the City Engineer to ensure purchased VMT credits are used for constructing appropriate projects, as identified in Exhibit 7, to achieve the intended VMT reduction. As part of the annual Capital Improvement Program (CIP) reporting to Planning Commission and City Council, the City Engineer shall include a progress report on any funds accumulated in the VMT Mitigation Banking Program and expenditures on constructing or improving active transportation facilities providing additional VMT-reducing investments that would not have occurred if bank funding were not available.

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Appendix A
VMT Analysis Methodology
Travel Demand Models are broadly considered to be amongst the most accurate of available tools to assess regional and sub-area VMT. While the Association of Monterey Bay Area Governments (AMBAG) maintains the regional travel demand model as a part of the Metropolitan Transportation Plan/Sustainable Communities Strategy program (MTP/SCS), the jurisdictions in Santa Cruz County maintain their own travel demand model (SCC TDM) for the analysis of local conditions. The latest available version of the SCC TDM was developed in 2020.

The 2019 Base Year model scenario from this model was used for the baseline conditions and 2040 Future Year model scenario is used for cumulative conditions analysis. The four incorporated cities included in the model (City of Capitola, City of Santa Cruz, City of Scotts Valley, and the City of Watsonville) are major contributors of the trips throughout the County during a typical weekday.

As many of the County’s daily trips originate from or are destined for areas outside of the County such as the Bay area and Monterey County (external trips), their total length could not be computed solely using the SCC TDM, additional analysis was required. The length of these trips was determined using two main processes, using Big Data and SCC TDM output files. The Big Data firm from which data was obtained was Teralytics, which uses triangulated cell phone data to determine origin-destination locations for vehicle trips, aggregated at the Census Tract level. The data that was obtained from Teralytics summarized the number of trips to and from the County to the surrounding counties at the Census Tract level for the entire month of October 2019. The distance between each Census Tract in the County and the surrounding counties was determined by using the TransCAD software, the modeling platform the SCC TDM runs on.

The multipath analysis function within the TransCAD software was used to determine the point to point distance between the centroid of each Census Tract using the internal pathing algorithm that determines the shortest path along the roadway network between the centroid of each Census Tract pair. The shortest path between each individual Santa Cruz County Census Tract and every non-Santa Cruz County Census Tract that contained at least one trip was multiplied by the share of the total trips to and from each individual Santa Cruz County Census Tract to determine the average trip length to and from the individual County Census Tract. The average trip length was applied to each SCC TDM TAZ within the individual Santa Cruz County Census Tract and multiplied by the number of external trips to and from that TAZ to determine the total external VMT by TAZ.

To calibrate the external distance calculated using the Teralytics data, the distance between the internal Santa Cruz County Census Tracts was calculated. The distances were calculated using the process outlined above which included using the TransCAD pathing algorithm to determine the shortest path between Census Tract centroids. The distances between the internal Santa Cruz County Census Tracts were aggregated down to the SCC TDM TAZs to allow for comparison with the SCC TDM data. One of the SCC TDM output files is the peak-period skim file in which the shortest path between two SCC TDM TAZs is calculated during congested (peak) periods of the day.

To determine a calibration factor for the external trip distances, the distance between TAZs calculated by the SCC TDM was compared to the distances calculated using the Teralytics data. The comparison was completed on a TAZ by TAZ basis and the calibration factor was calculated at the County level by averaging Attachment 3
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the difference in distances between the Teralytics data and the SCC TDM data. It was determined that the distances calculated using the Teralytics data were, on average, 16-percent longer than the distance calculated by the SCC TDM. Therefore, the external trip distances were reduced by 16-percent when calculating the VMT for the external trips.

Model Zone Structure
VMT was computed at Traffic Analysis Zone (TAZ) level to determine the thresholds as well as to allow for comparisons among different areas throughout the County. There are 696 TAZs within the County, including 364 TAZs within the unincorporated parts of the County.

Socio-Economic Data
Socioeconomic data (SED) and other model inputs are associated with each TAZ. Out of several different variables in the model SED, the VMT analysis mainly focused on population, the number of households, the number of students, and types of employment that are used in the trip generation component of the model. VMT computation was focused on the number of households in each TAZ and employment variables by 6 industries to determine rest of the trips. Employment variables used in the model are listed below.

Employment by Industry type:

1. Agriculture

2. Construction

3. Industrial and Manufacturing

4. Retail and Food

5. Service (White Collar, non-government jobs)

6. Public Administration (Government jobs)
Trip Generation
The SCC TDM runs a series of complex steps to estimate daily trip productions and attractions by various trip purposes for each TAZ. The trip purposes are listed below.

Model Trip Purpose:

1. Home-Based Work (HW)

2. Home-Based Other (HO)

3. Home-Based School, K-12 (HK)

4. Home-Based College (HC)

5. Home-Based Shopping (HS)

6. Work-Based Other (WO)

7. Other-Based Other (OO)
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The production model uses several variables such as number of workers, household income, age, household size and car availability depending on the trip purpose. Trip productions for every TAZ in the model were compiled separately by each trip purpose. The attraction model uses employment categories for the HW trip purpose, whereas it uses the employment categories and number of students (K-12 and University) for all non-HW trip purposes. The attraction model estimates trip attractions to each TAZ by regression coefficients that vary by employment type. Trip attractions for every TAZ were compiled by each purpose and by each employment type based on these regression coefficients.

Person Trips, Vehicle Occupancy, Trip Distance
Trip productions and attractions were compiled after the mode choice step, and only auto trips were used for the analysis. After the vehicle trip productions and attractions were computed for each trip purpose, trip lengths were applied for each zone pair from the skim matrices in the model to compute the production and attraction VMT by purpose.

VMT by Land Use Type
The residential VMT was computed by combining the production VMT for all the Home-Based trip purposes. VMT for non-residential land uses was computed from the attraction VMT by appropriate trip purposes and regression coefficients used in the attraction model.

Residential and non-residential VMT by each TAZ were computed and average VMT were determined by City, County and Region levels to determine City’s thresholds.

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Appendix B
Screening Maps
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Appendix C
City of Watsonville | Transportation Demand Management (TDM) Measures # TDM Measure Description TDM Type Max VMT
Reduction
VMT
Reduction
Type
Transit Strategies
1 Transit Stops
Coordinate with local
transit agency to
provide bus stop near
the site. Real time
transportation
information displays
support on-the-go
decision making to
support sustainable trip
making. Only get a
reduction on a nonHQT line, cannot get
both.

Infrastructure 3% All
2 Safe and Well-Lit
Access to Transit
Enhance the route for
people walking or
bicycling to nearby
transit (typically offsite). Provide
Emergency 911
phones along these
routes to enhance
safety.

Infrastructure 1% All
3 Implement
Neighborhood
Shuttle
Implement projectoperated or projectsponsored
neighborhood shuttle
serving residents,
employees, and visitors
of the project site.

Incentive 5% All
4 Transit Subsidies
Involves the
subsidization of transit
fare for residents and
employees of the
project site. This
strategy assumes
transit service is
already present in the
project area. Incentive 5% All
Pays for employees to
use local transit. This
could either be a
discounted ticket or a
full-reimbursed transit
ticket.

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City of Watsonville | Transportation Demand Management (TDM) Measures # TDM Measure Description TDM Type Max VMT
Reduction
VMT
Reduction
Type
Communication & Information Strategies
5 Mandatory Travel
Behavior Change
Program
Involves the
development of a travel
behavior change
program that targets
individuals’ attitudes,
goals, and travel
behaviors, educating
participants on the
impacts of their travel
choices and the
opportunities to alter
their habits. Provide a
web site that allows
employees to research
other modes of
transportation for
commuting. Employeefocused travel behavior
change program that
targets individuals
attitudes, goals, and
travel behaviors,
educating participants
on the impacts of their
travel choices and the
opportunities to alter
their habits.

Incentive
4%
All
6 Promotions &
Marketing
Involves the use of
marketing and
promotional tools to
educate and inform
travelers about sitespecific transportation
options and the effects
of their travel choices
with passive
educational and
promotional materials.

Marketing and public
information campaign
to promote awareness
of TDM program with
an on-site coordinator
to monitor program.

Incentive All
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City of Watsonville | Transportation Demand Management (TDM) Measures # TDM Measure Description TDM Type Max VMT
Reduction
VMT
Reduction
Type
Commuting Strategies
7 Employer Sponsored
Vanpool or Shuttle
Implementation of
employer-sponsored
employee vanpool or
shuttle providing new
opportunities for
access to connect
employees to the
project site.

Incentive /
Infrastructure 5% Commute
8 Preferential Carpool
/ Vanpool Parking
Spaces
Reserved carpool /
vanpool spaces closer
to the building
entrance.

Infrastructure 1%
9 Passenger Loading
Zones for Carpool /
Vanpool
Provide easy access
for carpools or
vanpools.

Infrastructure 1%
10 On-site Carts or
Shuttles or bikes
Provide on-site cart or
shuttle for employees
to travel across
campus.

Incentive /
Infrastructure 2% All
11 Emergency Ride
Home (ERH)
Program
Provides an occasional
subsidized ride to
commuters who use
alternative modes.

Guaranteed ride home
for people if they need
to go home in the
middle of the day due
to an emergency or
stay late and need a
ride at a time when
transit service is not
available. Ecology
Action is preferred
vendor. This
supplemental to the
other trip reduction
strategies. ADD to 5
and 6.

Incentive 4% Commute
12 On-site Childcare
Provides on-site
childcare to remove the
need to drive a child to
daycare at a separate
location.

Infrastructure 4% All
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Watsonville City CouncilMarch 14, 2023

Watsonville City Council
March 14, 2023