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HomeMy WebLinkAbout8118RESOLUTION NO 8118 A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF REDLANDS ADOPTING LOCAL "VEHICLE MILES TRAVELED THRESHOLD OF SIGNIFICANCE' AND THE `CITY OF REDLANDS CEQA ASSESSMENT VMT ANALYSIS GUIDELINES' FOR THE PURPOSE OF ANALYZING TRANSPORTATION IMPACTS UNDER THE CALIFORNIA ENVIRONMENTAL QUALITY ACT WHEREAS, the California Environmental Quality Act ("CEQA') Guidelines encourage public agencies to develop and publish generally applicable "thresholds of significance' to be used in determining the significance of a project's environmental effects; and WHEREAS, CEQA Guidelines section 15064 7(a) defines a threshold of significance as 'an identifiable quantitative, qualitative or performance level of a particular environmental effect, noncompliance 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; and WHEREAS, CEQA Guidelines section 15064 7(b) requires that thresholds of significance must be adopted by ordinance, resolution, rule, or regulation, developed through a public review process, and be supported by substantial evidence; and WHEREAS, pursuant to CEQA Guidelines section 15064 7(c), when adopting thresholds of significance, a public agency may consider thresholds of significance adopted or recommended by other public agencies, provided that the decision of the agency is supported by substantial evidence; and WHEREAS, Senate Bill 743 enacted in 2013 and codified in Public Resources Code section 2019 required changes to the CEQA Guidelines regarding the criteria for determining the significance of transportation impacts of development projects; and WHEREAS, in 2018, the Governor's Office ofPlanning and Research ("OPR") proposed, and the California Natural Resources Agency certified and adopted, new CEQA Guidelines section 15064.3 that identifies vehicle miles traveled ("VMT") — meaning the amount and distance of automobile travel attributable to a project — as the most appropriate metric to evaluate a project's transportation impacts; and WHEREAS, as a result, automobile delay as measured by `level of service' ("LOS") and other similar metrics, will generally no longer Constitute a significant environmental effect under CEQA, and WHEREAS, CEQA Guidelines section 15064.3 requires agencies to stop treating automobile delay/LOS as an environmental impact effective on July 1 2020, though public agencies may elect to be governed by this section immediately and 1 1:\Resolutions\Res 8100-8199\8118 Local CEQA Thresholds for Vehicle Miles Traveled.do WHEREAS, CEQA Guidelines sections 15061(b)(3) and 15378(a) provide for an exemption from environmental review under the CEQA, as there is no possibility of any environmental effects as a result of adopting this Resolution, and WHEREAS, following a pubhc process consistmg of staff presentations before the Planning Coirunission, the Planning Commission voted unanimously at its regular meeting on June 23, 2020, recommending to the City Council the adoption of City of the City of Redlands local "Vehicle Miles Traveled Threshold of Significance" and the "City of Redlands CEQA Assessment VMT Analysis Guidelines," NOW, THEREFORE, BE IT RESOLVED BY THE CITY COUNCIL OF THE CITY OF REDLANDS AS FOLLOWS Section 1 The action is exempt from further environmental review in accordance with the CEQA Guidehnes sections 15061(b)(3) and 15378(a) Section 2 The City Council hereby adopts the following 1 The City shall utilize the San Bernardino County Travel Demand Model (SBTAM) as its preferred methodology to measure VMT 2 The City shall utili7e the San Bernardino County Travel Demand Model (SBTAM) as its preferred method to analyze a project's VMT impact 3 The City shall utilize a threshold consistent with Table 1 in Exhibit A Section 3 The City Council adopts the "Vehicle Miles Traveled Threshold of Significance" attached hereto as Exhibit "A," and the "City of Redlands CEQA Assessment VMT Analysis Guidehnes" attached hereto as Exhibit "B " Section 4 This resolution shall become effective upon adoption ADOPTED, SIGNED AND APPROVED this 21st day of July, 2020 ATTEST Donaldson, City Clerk 2 I 1Resolutions`Res 8100-819918118 Local CEQA Thresholds for Vehicle Miles Traveled.doc aul W Foster, Mayor I, Jeanne Donaldson, City Clerk of the City of Redlands, do hereby certify that the foregoing Resolution was duly adopted by the City Council at a regular meeting thereof held on the 21st day of July, 2020, by the following vote AYES Councilmembers Tejeda, Momberger, Davis, Mayor Foster NOES None ABSENT Councilmember Barich ABSTAIN None 3 E lResolutcous\Res 8100 8199/8118 Local CEQA Thresholds for Vehicle Miles Traveled,doc anne Donaldson, City Clerk EXHIBIT A Vehicle Miles Traveled Threshold of Significance [ Attached ] 4 1: \Resolutions \Res 8100-8199\8118 Local CEQA Thresholds fo Vehicle Miles Travolcd.doc Exhibit A Table 1 VMT Impact Thresholds Met hods Project Threshold Cumulative Threshold Land Use Plans (such as General Plans and Specific Plans) San Bernardino Traffic Analysis Model (SBTAM) forecast of total daily VMT/ SP. To capture project effect, the same cumulative year population and employment growth totals should be used. The 'proiect' only influences land use allocation. A significant impact would occur if the proiect VMT/ SP (for the land use plan) exceeds 15% below the Countywide average. A significant impact would occur if the project caused total daily VMT within the City to be higher than the no project alternative under cumulative conditions. Consistency check with SCAG RTP/ SCS. Is the proposed project within the growth projections in the RTP/ SCS? NA A significant impact would occur if the project is determined to be inconsistent with the RTP/ SCS. Land Use Projects Transit Priority Area (TPA) screening. Presumed less than significant VMT impact for proiects located in TPAs. Project presumption applies under cumulative conditions as long as project is consistent with SCAG RTP/ SCS. Low VMT area screening. Presumed less than significant VMT impact for projects located in low VMT generating model traffic analysis zones (TAZs). These TAZs generate total daily VMT/ SP that is 15% less than the baseline level for the County. Project presumption applies under cumulative conditions as long as project is consistent with SCAG RTP/ SCS Project type screening. Local serving retail projects (per OPR's Technical Advisory, with stores less than 50,000 square ft.) and neighborhood schools, banks community institutions, affordable or supportive housing, senior Project presumption applies under cumulative conditions as long as project is consistent with SCAG RTP/ SCS, Planning Commission Resolution No. 1516 Page 1 of 2 housing, and other local serving uses listed in the City of Redlands CEQA Assessment VMT Analysis Guidelines, and proiects that generate less than 3,000 MT of CO2e per year are presumed to have a less than significant VMT impact. Proiects consistent with the 2035 General Plan and Climate Action Plan Baseline proiect generated VMT impact analysis required. A significant impact would occur if the proiect VMT/ SP (for the land use plan) exceeds 15% below the Countywide average. Presumed less than significant VMT impact in the cumulative condition only. Presumed less than significant VMT impact in the cumulative condition for projects that are consistent with the 2035 General Plan and Climate Action Plan. Projects inconsistent with the 2035 General Plan and Climate Action Plan A significant impact would occur if the project VMT/SP (for the land use plan) exceeds 15% below the Countywide average. A significant impact would occur if the proiect caused total daily VMT within the City to be higher than the no proiect alternative under cumulative conditions. ns o tion 'o'ectS.fhre;roId ra a.. :fo SB74 SBTAM forecast of total citywide daily VMT' A significant impact would occur if the proiect increased the baseline VMT within the City. A significant impact would occur if the project caused total daily VMT within the City to be higher than the no build alternative under cumulative conditions. Consistency check with SCAG RTP/ SCS NA A significant impact would occur if the project is determined to be inconsistent wit h t he RTP/ SCS. 1 It is recommended that SBTAM is used to develop VMT estimates for transportation project impact assessment However the analyst must verify the model results for sensitivity to changes in VMT Alternatively if the model is not deemed appropriate, Robert Cevero's research on lane -mile elasticity and its relationship to VMT can be referenced. Planning Commission Resolution No. 1516 Page 2 of 2 EXHIBIT B City of Redlands CEQA Assessment VMT Analysis Guidelines [ Attached ] 5 1:Utesoluions\Res 8100-8199\8118 Local CEQA Thresholds for Vehicle Miles Tiaveled.do City of Redlands CEQA Assessment VMT Analysis Guidelines A key element of SB 743, signed in 201 3, is the elimination of automobile delay and LOS as the sole basis of determining CEQA impacts The most recent CEQA guidelines, released in December 2018, recommend VMT as the most appropriate measure of project transportation impacts However, SB 743 does not prevent a city or county from continuing to analyze delay or LOS as part of other plans (i e, the general plan), studies, or ongoing network monitoring. The following recommendations assist in determining VMT impact thresholds and mitigation requirements for various land use projects' TIAs Analysis Methodology For purposes of SB 743 compliance, a VMT analysis should be conducted for land use projects as deemed necessary by the Traffic Division and would apply to protects that have the potential to increase the average VMT per service population (i e. population plus employment) compared to the SBCTA region or the City boundary. Normalizing VMT per service population essentially provides a transportation efficiency metric that the analysis is based on Using this efficiency metric allows the user to compare the project to the region for purposes of identifying transportation impacts. These guidelines are based on the SBCTA SB 743 Implementation Study which provides options for both methodologies and VMT screening The methodologies and significance thresholds presented below are based on SBCTA recommendations from the Implementation Study, lead agencies may wish to modify these thresholds with alternative thresholds of significance and methodologies as appropriate Project Screening There are three types of screening that lead agencies can apply to effectively screen projects from project -level assessment These screening steps are summarized below Step 1 Transit Priority Area (TPA) Screening Projects located within a TPA' may be presumed to have a less than significant impact absent substantial evidence to the contrary This presumption may NOT be appropriate if the project • Has a Floor Area Ratio (FAR) of less than 0.75; 1 A TPA is defined as a half mile area around an existing maior transit stop or an existing stop along a high- quality transit corridor per the definitions below 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 maior bus routes with a frequency of service interval of 15 minutes or less during the morning and afternoon peak commute periods 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 • 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), or • Replaces affordable residential units with a smaller number of moderate- or high-income residential units Step 2 Low VMT Area Screening Residential and office projects located within a low VMT-generating area may be presumed to have a less than significant impact absent substantial evidence to the contrary In addition, other employment-related and mixed-use projects may qualify for the use of screening if the protect can reasonably be expected to generate VMT per resident, per worker, or per service population that is similar to the existing land uses in the low VMT area For this screening in the SBCTA area, the SBTAM travel forecasting model was used to measure VMT performance for individual jurisdictions and for individual traffic analysis zones (TAZs) TAZs are geographic polygons similar to Census block groups used to represent areas of homogenous travel behavior Total daily VMT per service population (population plus employment) was estimated for each TAZ This presumption may not be appropriate if the project land uses would alter the existing built environment in such a way as to increase the rate or length of vehicle trips To identify if the project is in a low VMT-generating area, the analyst may review the SBCTA screening tool and apply the appropriate threshold (identified later in this chapter) within the tool Additionally, as noted above, the analyst must identify if the project is consistent with the existing land use within that TAZ and use professional judgement that there is nothing unique about the project that would otherwise be mis-represented utilizing the data from the travel demand model The SBCTA screening tool can be accessed at the following location: https://devapps fehrandpeers.com/SBCTAVMT/ Step 3 Project Type Screening Local serving retail projects with stores Tess than 50,000 square feet may be presumed to have a less than significant impact absent substantial evidence to the contrary Local serving retail generally improves the convenience of shopping close to home and has the effect of reducing vehicle travel Additional screening for retail projects is discussed below In addition to local serving retail, the following uses can also be presumed to have a less than significant impact absent substantial evidence to the contrary as their uses are local serving in nature • Local -serving K-12 schools • Local parks • Day care centers • Local -serving gas stations • Local -serving banks • Local -serving hotels (e g non -destination hotels) • Student housing protects on or adjacent to college campuses • Local -serving assembly uses (places of worship, community organizations) • Community institutions (Public libraries, fire stations, local government) • Local serving community colleges that are consistent with the assumptions noted in the RTP/SCS • Affordable or supportive housing • Assisted living facilities • Senior housing (as defined by HUD) Projects which generate less than 3,000 MT CO2e per year can be presumed to have a less than significant impact on VMT Projects which generate less than 3,000 MT CO2e per year include the following- • Single family residential — 167 Dwelling Units or fewer • Multifamily residential (low-rise) — 232 Dwelling Units or fewer • Multifamily residential (mid -rise) — 299 Dwelling Units or fewer • Office — 59,100 square feet or less • Local Serving Retail — 112,400 square feet or less (no stores larger than 50,000 square feet) • Warehousing — 463,600 square feet or less • Light Industrial — 74,600 square feet or less Additional detail is provided in Substanhal Evidence for Trip -Based Screening Threshold, provided in the attachments VMT Assessment for Non -Screened Development Projects not screened through the steps above should complete VMT analysis and forecasting through the SBTAM model to determine if they have a significant VMT impact This analysis should include the following scenarios Note that protects that are consistent with the General Plan would not need to prepare a Cumulative analysis, since the General Plan has been found to be consistent with the City's threshold of VMT per capita that rs 15 percent below baseline conditions • Baseline conditions - This data is already available in the web screening map • Baseline plus project for the project - The protect land use would be added to the protect TAZ or a separate TAZ would be created to contain the protect land uses. A full base year model run would be performed and VMT changes would be isolated for the project TAZ and across the full model network The model output must include reasonableness checks of the production and attraction balancing to ensure the project effect rs accurately captured If this scenario results in a less -than -significant impact, then additional cumulative scenario analysis may not be required (more information about this outcome can be found in the Thresholds Evaluation discussion later in this chapter) • Cumulative no protect - This data is available from SBCTA • Cumulative plus protect - The protect land use would either be added to the protect TAZ or a separate TAZ would be created to contain the protect land uses A full buildout year model run would be performed and VMT changes would be isolated for the project TAZ and across the full model network The model output must include reasonableness checks of the production and attraction balancing to ensure the project effect is accurately captured Cumulative plus Project VMT evaluation will include VMT/SP and project effect on VMT, as discussed below The Cumulative plus project scenario noted above will summarize two types of VMT (1) project generated VMT per service population and comparing it back to the appropriate benchmark noted in the thresholds of significance, and (2) the project effect on VMT, comparing how the project changes VMT on the network looking at Citywide VMT per service population and comparing it to the no project condition. Project -generated VMT shall be extracted from the travel demand forecasting model using the origin -destination trip matrix and shall multiply that matrix by the final assignment skims The project -effect on VMT shall be estimated using the City boundary and extracting the total link - level VMT for both the no project and with project condition Both project -generated VMT and Citywide link -level VMT shall be reported per service population In some cases, it may be appropriate to extract the Project -generated VMT using the production - attraction trip matrix This may be appropriate when a project is entirely composed of retail or office uses, and there is a need to isolate the home -based -work (HBW) VMT for the purposes of isolating commute VMT The City should evaluate the appropriate methodology based on the project land use types and context A detailed description of this process is attached to these guidelines CEQA VMT Impact Thresholds The SBCTA Implementation Study provided several options related to VMT thresholds of significance and guidance/substantial evidence related to thresholds of significance Lead agencies should refer to that document for guidance/options VMT Impacts An example of how VMT thresholds would be applied to determine potential VMT impacts is provided below A project would result in a significant project -generated VMT impact if either of the following conditions are satisfied The baseline project -generated VMT per service population exceeds a level 15 percent below the San Bernardino County regional average VMT per service population, or For projects that are inconsistent with the City's General Plan, the cumulative project - generated VMT per service population exceeds a level 15 percent below the San Bernardino County regional average VMT per service population, A prosect would result in a significant project effect on VMT impact if either of the following conditions are satisfied For projects that are inconsistent with the City's General Plan, the protect causes total daily VMT per service population within the City to be higher than the no project alternative under Cumulative conditions Please note that the cumulative no project shall reflect the adopted RTP/SCS, cis such, if a protect is consistent with the regional RTP/SCS, then the cumulative impacts shall be considered less than significant subject to consideration of other substantial evidence VMT Mitigation Measures To mitigate VMT impacts, the following choices are available to the applicant • Modify the project's - built environment characteristics to reduce VMT generated by the project • Implement transportation Demand Management (TDM) measures to reduce VMT generated by the project • Participate in an available VMT fee program and/or VMT mitigation exchange/banking program (if they exist) to reduce VMT from the project or other land uses to achieve acceptable levels • Implement Pedestrian and sidewalk improvements consistent with the Transit Villages Specific Pian (TVSP) within the plan area (i e, wider than typical 5'0" sidewalks for high -pedestrian traffic areas) • Outside of the TVSP area, implement pedestrian and sidewalk improvements that meet or exceed the minimum requirements of the Redlands Municipal Code. • If constructing pedestrian network improvements is not necessary or feasible on or adjacent to the project site, then provide a fair share payment to a fund designated for off-site pedestrian network improvements somewhere else in the City (may require a nexus study). • Construct bicycle network improvements along the project's frontage consistent with the Bicycle Master Plan and/or Sustainable Mobility Plan (pending adoption in 2021). • If constructing bicycle network improvements is not necessary or feasible on or adjacent to the project site, then provide a fair share payment to fund designated off-site bicycle network improvements somewhere else in the City (may require a nexus study) • Provide a Passenger Loading Zone adjacent to the project's frontage consistent with the Redlands Municipal Code (e g., for rideshare services, etc ) • Construct one or more improvements listed in RMC Chapter 18 224 (Transportation Control Measures) including bicycle racks, etc. • Provide a payment or facility to Omnitrans for one or more off-site improvements listed in RMC Chapter 18 224 such as a new bus pad and shelter (if applicable), etc • Provide any other feasible and simple real property improvements that can be provided by a developer on or adjacent to the project site • Provide voluntary payment to the City to "buy down" VMT impacts by funding construction of off-site infrastructure that supports alternative transportation modes. As part of the SBCTA Implementation Study, key TDM measures that are appropriate to the region were identified Measures appropriate for most of the SBCTA region are summarized in Attachment B of the of the 5B743 Implementation Mitigation and TDM Strategy Assessment memo {provided as Attachment 3). Evaluation of VMT reductions should be evaluated using state -of -the -practice methodologies recognizing that many of the TDM strategies are dependent on building tenant performance over time As such, actual VMT reduction cannot be reliably predicted and monitoring may be necessary to gauge performance related to mitigation expectations CEQA Assessment - Active Transportation and Public Transit Analysis Potential impacts to public transit, pedestrian facilities and travel, and bicycle facilities and travel can be evaluated using the following criteria A significant impact occurs if the project conflicts with adopted policies, plans, or programs regarding public transit, bicycle, or pedestrian facilities, or otherwise decreases the performance or safety of such facilities Therefore, the TIA should include analysis of a project to examine if it is inconsistent with adopted policies, plans, or programs regarding active transportation or public transit facilities, or otherwise decreases the performance or safety of such facilities and make a determination as to whether it has the potential to conflict with existing or proposed facilities supporting these travel modes Attachment 1 - Substantial Evidence for Trip -Based Screening Threshold Backg round 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 71 2, 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 kind 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, cis 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) ) It should be noted that SB 743 (the legislation) does not specify any screening thresholds or impact criteria for transportation impacts using VMT. In fact, the legislation does not even specify VMT as the metric — but directs the OPR to identify the appropriate metric The OPR evaluated several metrics including VMT, Automobile Trips Generated, Multimodal LOS, Fuel Use, and Motor Vehicle Hours Traveled, and ultimately settled on VMT SB 743 includes legislative intent to help guide the development of the new criteria for transportation impacts to align with Green House Gas (GHG) reduction For example, Section 1 of the legislation states- "New methodologies under the California Environmental Quality Act are needed for evaluating transportation impacts that are better able to promote the state's goals of reducing greenhouse gas emissions and traffic -related air pollution, promoting the development of a multinodal transportation system, and providing clean, efficient access to destinations" Further, subdivision (b) of the new Section 21099 requires that the new criteria "promote the reduction of greenhouse gas emissions, the development of multimodal transportation networks, and a diversity of land uses" OPR'S Technical Advisory To assist in the process, the OPR released several technical advisories. The technical advisory states that " (rt) is one in a series of advisories provided by the Governor's Office of Planning and Research (OPR) as a service to professional planners, kind 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, § 2 l 000 et seq) (Gov Code, § 65040, subds (g), (1), (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." Screening Thresholds Recommended by OPR 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. The Technical Advisory recommends the following thresholds 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 prolect 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 day generally may be assumed to cause a less than significant transportation impact Analysis To set this 110 trip threshold, the OPR uses a CEQA exemption for additions to existing structures of up to 10,000 square feet The Technical Advisory states, "CEQA provides a categorrcal 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 (t e, general office building, single tenant office building, office park, and busyness park) generate or attract an additional 1 10-124 trips per 10,000 square feet Therefore, absent substantial evidence otherwise, it is reasonable to conclude that the addition of 170 or fewer trips could be considered not to lead to a significant impact" it should be noted that, for a similar size building, many land uses generate significantly higher trips than the 110 daily -trip threshold For example, a 10,000 square foot Drive -In Bank generates 1,000 daily trips. Similarly, a 10,000 square foot drugstore with drive through window would generate 1,092 daily trips, and a typical Post Office would generate 1,039 trips Therefore, there are many land -uses where the 10,000 square foot exemption would result in substantially higher trips than the 110 -trip threshold used by the OPR Recommendation. Based on the intent and stated goals of SB 743, the City has evaluated land uses in the City from a GHG emissions perspective In San Bernardino County, there are two Air Quality Management Districts — the Mohave Desert AQMD (MDAQMD) and the South Coast AQMD (SCAQMD) The MDAQMD uses a threshold of 100,000 Metric Tons (MT) of CO2 Equivalents (CO2e) per year as a threshold to identify significant impacts2 The SCAQMD in its Interim CEQA GHG Significance Threshold for Stationary Sources, Rules and Planss recommends a screening threshold of 3,000 MT of CO2e per year for residential and commercial sectors and 10,000 MT of CO2e per year for industrial protects Understanding that the SCAQMD's recommendations are the most stringent in the region, and the City is within the SCAQMD region, the City evaluated various land uses using City specific average trip lengths by 2 MDAQMD California Environmental Quality Act (CEQA) And Federal Conformity Guidelines (http //www mdagmd ca gov/home/showdocument?id=538) 3 hftp•//www aqmd gov/docs/default source/cega/handbook/greenhouse gases (ghg) cepa-significance thresholds/ghgboardsynopsis.pdf?sf vrsn=2 8 trip purpose from the San Bernardino Transportation Analysis Model (SBTAM). Specifically, the following land uses were evaluated — Single family residential • Multifamily residential (low-rise, one or two levels) • Multifamily residential (mid -rise, between three and 10 levels) • Office • Retail Warehousing • Light Industrial Table A summarizes the findings of the evaluation. The GHG emissions were calculated based on 100 units (DU or 1,000 square feet). The resulting emissions were compared to the SCAQMD threshold of 3,000 MT CO2e/year and the number of units to trigger the threshold was calculated. Land Use Units Mobile CO2e' Total CO2e' Trip Rate2 Size that Triggers Threshold Daily Trips Single Family DU 100 DU 1212 1799 9.44 167 1574.21 Multifamily DU (low-rise) 100 DU 947 1294 7.32 232 1697.06 Multifamily DU (mid -rise) 100 DU 672 1005 5.44 299 1623.88 Office 100 TSF 4963 5076 9.74 59.102 575.65 Retail 100 TSF 2144 2669 37 75 112.402 4243.16 Warehouse (unrefrigerated) 100 TSF 386 647 1.74 463.679 806.80 General Light Industrial 100 TSF 2964 4018 4.96 74.664 370.33 Calculated using CaIEEMod. 2 Based on Trip Rates from the Institute of Transportation Engineers, Trip Generation, 10th Edition and SBTAM trip lengths. Based on this analysis, the City recommends that projects up to the size indicated in the following list be considered exempt from preparation of a VMT analysis. These projects would generate less than 3,000 MT CO2e/year and would not have a significant impact on CO2e, based on SCAQMD Guidelines. Additionally, these projects would fall below the screening threshold proposed by SCAQMD. • Single family residential — 167 Dwelling Units or fewer • Multifamily residential (low-rise) — 232 Dwelling Units or fewer • Multifamily residential (mid -rise) — 299 Dwelling Units or fewer • Office — 59 100 square feet or less • Retail — 1 12,400 square feet or less Warehousing —463,600 square feet or less • Light Industrial — 74,600 square feet or less 9 Attachment 2 - Detailed VMT Forecasting Information Most trip -based models generate daily person trip -ends for each TAZ across various trip purposes (HBW, HBO, and NHB, for example) based on population, household, and employment variables This may create challenges for complying with the VMT guidance because trip generation is not directly tied to specific kind use categories The following methodology addresses this particular challenge among others Production and attraction trip -ends are separately calculated for each zone, and generally production trip -ends are generated by residential land uses and attraction trip -ends are generated by non-residential land uses. OPR's guidance addresses residential, office, and retail land uses. Focusing on residential and office land uses, the first step to forecasting VMT requires translating the land use into model terms, the closest approximations are • Residential• home-based production trips • Office home-based work attraction trips Note that this excludes all non -home-based trips including work -based other and other -based other trips The challenges with computing VMT for these two types of trips in a trip -based model are 1) production and attraction trip -ends are not distinguishable after the PA to OD conversion process and 2) trip purposes are not maintained after the mode choice step For these reasons, it not possible to use the VMT results from the standard vehicle assignment (even using a select zone re- assignment) A separate post -process must be developed to re -estimate VMT for each zone that includes trip -end types and trip purposes. • Re -skim final loaded congested networks for each mode and time period • Run a custom PA to OD process that replicates actual model steps, but • Keeps departure and return trips separate • Keeps trip purpose and mode separate • Converts person trips to vehicle trips based on auto occupancy rates and isolates automobile trips • Factors vehicle trips into assignment time periods • Multiply appropriate distance skim matrices by custom OD matrices to estimate VMT • Sum matrices by time period, mode, and trip purpose to calculate daily automobile VMT • Calculate automobile VMT for individual TAZs using marginal totals • Residential (home-based) - row of departure matrix plus column of return matrix • Office (home-based work) - column of departure matrix plus row of return matrix Appropriateness Checks Regardless of which method is used, the number of vehicle trips from the custom PA to OD process and the total VMT should match as closely as possible with the results from the traditional model process The estimated results should be checked against the results from a full model run to understand the degree of accuracy. Note that depending on how each model is setup, these custom 10 processes may or may not include IX/XI trips, truck trips, or special generator trips (airport, seaport, stadium, etc.). When calculating VMT for comparison at the study area, citywide, or regional geography the same methodology that was used to estimate project -specific VMT should be used. The VMT for these comparisons can be easily calculated by aggregating the row or column totals for all zones that are within the desired geography 11 Attachment 3 - Attachment 13 from the SB743 Implementation Mitigation and TDM Strategy Assessment Memo Sj 4a 9z CIIi'i'E_'mNyY( E a z 1 c � a f 1 3 J $ a 1 �a arrs. 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