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
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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
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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
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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 ]
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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 ]
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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
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