CC 2020-09-08_11a CEQA VMT PolicyMEMORANDUM
TO: CITY COUNCIL
FROM: WHITNEY McDONALD, ACTING DEPUTY CITY
MANAGER/COMMUNITY DEVELOPMENT DIRECTOR
SUBJECT: DISCUSSION AND CONSIDERATION OF POLICY ESTABLISHING
THRESHOLDS OF SIGNIFICANCE FOR EVALUATING
TRANSPORTATION IMPACTS UNDER THE CALIFORNIA
ENVIRONMENTAL QUALITY ACT PURSUANT TO SB 743
DATE: SEPTEMBER 8, 2020
SUMMARY OF ACTION:
Discuss, consider and adopt a proposed policy establishing thresholds of significance for
evaluating transportation impacts under the California Environmental Quality Act (CEQA)
pursuant to SB 743.
IMPACT ON FINANCIAL AND PERSONNEL RESOURCES:
Financial impacts include consultant and staff time and resources to prepare the
proposed VMT Thresholds.
RECOMMENDATION:
It is recommended the City Council adopt the proposed Resolution adopting the policy
establishing thresholds of significance for evaluating transportation impacts under CEQA
in compliance with SB 743.
BACKGROUND:
SB 743 was signed into law in 2013, with the intent of better aligning California
Environmental Quality Act (CEQA) practices with statewide sustainability goals related to
efficient land use, greater multi-modal transportation choices, and greenhouse gas
reductions. SB 743 included amendments to CEQA that required the Office of Planning
and Research (OPR) to develop new guidelines for measuring a project’s transportation
impacts. Under these new guidelines, automobile delay, traditionally measured as level
of service (LOS), will no longer be considered an environmental impact under CEQA.
Instead, impacts will be determined based on an evaluation of the extent to which a
project generates vehicle miles traveled (VMT). These changes were effective as of July
1, 2020.
The City’s current Transportation Impact Analysis Report Guidelines (TIAR Guidelines)
are used to evaluate the traffic impacts of proposed development projects and determine
Item 11.a. - Page 1
CITY COUNCIL
DISCUSSION AND CONSIDERATION OF POLICY ESTABLISHING THRESHOLDS
OF SIGNIFICANCE FOR EVALUATING TRANSPORTATION IMPACTS UNDER THE
CALIFORNIA ENVIRONMENTAL QUALITY ACT PURSUANT TO SB 743
SEPTEMBER 8, 2020
PAGE 2
the extent to which such impacts may create potentially significant impacts under CEQA.
Because these guidelines are based largely on LOS considerations and do not contain
thresholds or directions for evaluating a project’s VMT contributions, additional guidelines
and thresholds are recommended to ensure that the City’s review of projects is consistent
with SB 743.
What is LOS and why is it no longer used as a CEQA threshold?
Traffic level of service (LOS) is a metric used to qualitatively describe the operating
conditions of a road or intersection from a driver’s perspective based on speed, travel
time, delay, or other measures of congestion. LOS is reported using one of six letter
designations, ranging from LOS A to F, with LOS A representing the “best” operation
conditions with little delay, and LOS F representing the “worst” conditions with significant
delays/ congestion.
LOS analysis and mitigation measures typically support strategies that encourage
roadway capacity expansion to encourage faster automobile travel times and reduced
congestion and delays for drivers at peak travel times. An LOS-centric approach to
evaluating transportation impacts has historically resulted in increased use of single-
occupant vehicle travel, a greater propensity for sprawling development in low-density
greenfield areas, and land use and transportation investments that increase the rate of
greenhouse gas emissions.
OPR has identified additional problems with LOS as a primary measure of transportation
impacts:
o LOS inhibits infill development by punishing “last-in” development for localized
congestion.
o Pushing development outward and farther away from key destinations and
multimodal transportation options.
o “Solving” local congestion but exacerbating regional congestion.
o LOS measures auto mobility but not access to transportation or mobility of
persons.
o LOS standards often lead to more road widening and construction than local
agencies can afford to build and/or maintain.
o Optimal LOS for motor vehicles often inhibits active transportation and transit
modes.
The following images depict examples of roadway configurations that promote LOS A and
LOS F conditions:
Item 11.a. - Page 2
CITY COUNCIL
DISCUSSION AND CONSIDERATION OF POLICY ESTABLISHING THRESHOLDS
OF SIGNIFICANCE FOR EVALUATING TRANSPORTATION IMPACTS UNDER THE
CALIFORNIA ENVIRONMENTAL QUALITY ACT PURSUANT TO SB 743
SEPTEMBER 8, 2020
PAGE 3
Pursuant to SB 743, 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.” (Pub. Res. Code
§21099.) In light of this directive, OPR determined that vehicle miles traveled (VMT) is
the most appropriate metric to evaluate a project’s transportation impacts. Automobile
delay, as measured by “level of service” and other similar metrics, no longer constitutes
a significant environmental effect under CEQA.
What is VMT and why does it matter?
VMT measures the number and length of vehicle trips made on a daily basis. It represents
the total number of vehicle trips multiplied by the total distance each vehicle travels.
Measuring VMT requires estimating or measuring the full length of vehicle trips by
purpose, such as commutes, deliveries, or shopping trips that often cross between cities,
counties, or states. For this reason, regional travel demand models, large data sources,
and household travel surveys that are less limited by local agency boundaries are the
preferred tools to estimate VMT under SB 743.
The use of VMT is intended to guide analysis of development and transportation projects
in a manner that encourages growth and investment in travel-efficient locations where
proximity to other key destinations, services, and transportation options results in shorter
trips and less greenhouse gas (GHG) emissions.
As explained by the California Air Resources Board in its 2017 Climate Change Scoping
Plan, VMT is the new metric of choice under CEQA because VMT reductions are needed
to achieve our long-term GHG emissions reduction goals:
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CITY COUNCIL
DISCUSSION AND CONSIDERATION OF POLICY ESTABLISHING THRESHOLDS
OF SIGNIFICANCE FOR EVALUATING TRANSPORTATION IMPACTS UNDER THE
CALIFORNIA ENVIRONMENTAL QUALITY ACT PURSUANT TO SB 743
SEPTEMBER 8, 2020
PAGE 4
“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.”
Key benefits of utilizing VMT as a primary metric for analyzing transportation impacts
include:
o Removal of a key barrier to infill and transit- oriented development.
o Incentivizes development and investment in areas with greater access to existing
jobs, services and transportation infrastructure. Incentivizes projects that positively
affect existing jobs-housing imbalances.
o VMT-based analysis and mitigation strategies typically lead to less roadway
expansion and widening, reducing infrastructure capital and maintenance costs for
local agencies.
o More effectively assesses contributions to regional congestion.
o Encourages projects that improve access to active transportation and transit.
o Supports overarching statewide initiative to reduce greenhouse gas emissions,
which helps combat climate change, while reducing impacts to air quality and
community health.
OPR Technical Advisory
In December 2018, OPR released its final Technical Advisory on Evaluating
Transportation Impacts under CEQA following the enactment of SB 743. Generally, OPR
recommends that a reduction of 15% or more in VMT should be the target. OPR’s
recommended VMT impact thresholds and methodologies for land use projects include
the following:
o Residential (VMT/capita) – A proposed project exceeding a level of 15% below
existing regional VMT per capita may indicate a significant transportation impact.
o Office (VMT/employee) - A proposed project exceeding a level of 15% below
existing regional VMT per employee may indicate a significant transportation
impact.
o Retail (net VMT) – A proposed project that results in a net increase in total area
VMT may indicate a significant transportation impact.
o Mixed-Use - Evaluate each component independently using above thresholds.
o Redevelopment Projects - Measured based on net change in VMT for total area.
Item 11.a. - Page 4
CITY COUNCIL
DISCUSSION AND CONSIDERATION OF POLICY ESTABLISHING THRESHOLDS
OF SIGNIFICANCE FOR EVALUATING TRANSPORTATION IMPACTS UNDER THE
CALIFORNIA ENVIRONMENTAL QUALITY ACT PURSUANT TO SB 743
SEPTEMBER 8, 2020
PAGE 5
OPR’s Technical Advisory also provides a list of screening thresholds, which may be
applied to screen out certain projects from requiring further VMT analysis. These types of
development projects are presumed to have a less-than-significant impact on VMT and,
therefore, a less-than-significant impact on transportation, including:
o Projects that are consistent with the Sustainable Communities Strategy (SCS) or
General Plan and generate or attract fewer than 110 daily trips;
o Map-based screening for residential and office projects located in low VMT areas,
and that incorporate similar features (density, mix of uses, transit accessibility);
o Certain projects within ½ mile of an existing major transit stop or an existing stop
along a high-quality transit corridor; however, this will not apply if information
indicates that the project will still generate high levels of VMT; and
o Locally-serving retail projects, typically less than 50,000 square feet.
ANALYSIS OF ISSUES:
CEQA Thresholds
Under CEQA, a lead agency is required to determine the significance of environmental
impacts created by a project (CEQA Guidelines Section 15064). A threshold of
significance for an environmental impact defines the level of effect above which the lead
agency will consider impacts to be significant, and below which it will consider impacts to
be less than significant. Section 16064.7 of the CEQA Guidelines defines a threshold of
significance to be:
An identifiable quantitative, qualitative 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 will normally be determined to be less than
significant.
Lead agencies have discretion to formulate their own significance thresholds, which can
be formally adopted thresholds consistently applied to all projects. Adopting clearly
established thresholds promotes predictability and consistency for the environmental
review process and can increase defensibility of the lead agency’s significance
determinations.
The City contracted with GHD to develop proposed thresholds of significance that utilize
VMT as the metric for evaluating transportation impacts in compliance with SB 743. As
part of this process, GHD prepared an analysis of existing VMT patterns and developed
the baseline VMT numbers proposed for use in an adopted VMT policy. GHD’s analysis
is detailed in the attached Baseline VMT Methodology & Estimation Memorandum
(Attachment 2).
Item 11.a. - Page 5
CITY COUNCIL
DISCUSSION AND CONSIDERATION OF POLICY ESTABLISHING THRESHOLDS
OF SIGNIFICANCE FOR EVALUATING TRANSPORTATION IMPACTS UNDER THE
CALIFORNIA ENVIRONMENTAL QUALITY ACT PURSUANT TO SB 743
SEPTEMBER 8, 2020
PAGE 6
Baseline VMT
The proposed baseline VMT amount was calculated using the travel demand model
currently in development by the San Luis Obispo Council of Governments (SLOCOG) and
representing the countywide average, including incorporated cities. The proposed
baseline VMT per capita is 20.2 for residential projects and the proposed baseline VMT
per employee is 14.0 for non-residential projects. These baseline numbers are based on
full trips and are not limited by jurisdictional boundaries.
Proposed VMT Thresholds of Significance
It is recommended that the City generally adopt the screening criteria and thresholds of
significance suggested by OPR in its December 2018 Technical Advisory and stated in
the CEQA Guidelines. The policy provided in Attachment 1 incorporates these criteria
and thresholds, with one distinction, as described in more detail below.
o Proposed screening criteria
Projects that meet the following criteria are assumed to have less than significant
environmental impacts and would not require further CEQA review as it relates to
transportation.
A) Projects that are consistent with the Sustainable Communities Strategy (SCS) or
the General Plan and generate fewer than 110 daily trips based on the most current
edition of the Institute of Traffic Engineer’s Trip Generation Manual.
B) Projects that are within ½ mile of a transit stop at the intersection of two transit
routes with 15 minute or less headways, unless the project:
a. Has a floor to area ratio (FAR) of less than 0.75, or
b. Includes more parking than required under the City’s zoning code, or
c. Is inconsistent with the region’s Sustainable Communities Strategy, City
Zoning Code, or City Land Use Policies, including the City’s General Plan
or any applicable Specific Plan, or
d. Replaces affordable housing with a smaller number of moderate- or high-
income residential units.
C) Local-serving retail projects, which are generally defined as projects within the City
that are less than 50,000 square feet in size. The determination of whether a retail
project is local-serving or regional-serving shall be made by City staff on a case by
case to determine whether they are likely to attract regional trips. For instance,
Item 11.a. - Page 6
CITY COUNCIL
DISCUSSION AND CONSIDERATION OF POLICY ESTABLISHING THRESHOLDS
OF SIGNIFICANCE FOR EVALUATING TRANSPORTATION IMPACTS UNDER THE
CALIFORNIA ENVIRONMENTAL QUALITY ACT PURSUANT TO SB 743
SEPTEMBER 8, 2020
PAGE 7
auto dealerships and specialty retailers may propose less than 50,000 square feet
of retail space but be deemed regional serving.
D) Transportation projects that are expected to reduce or have no impact on VMT will
not require a quantitative VMT analysis. These projects include, but are not limited
to, road diets (traffic lane reductions/narrowing), roundabouts, roadway
rehabilitation and maintenance, safety improvements that do not substantially
increase auto capacity, installation or reconfiguration of lanes not for through traffic
(addition of left/right turn lanes, etc.), timing of traffic signals, removal of on-street
parking, addition or enhancement of pedestrian, bicycle and transit facilities and
services.
One distinction of note between OPR’s Technical Advisory and the proposed City policy
is that affordable housing projects are not currently included in the City’s screening criteria
whereas OPR suggests that these projects, where proposed in infill areas, may be
presumed to create less-than-significant transportation impacts. OPR explains that infill
affordable housing projects are presumed to improve the jobs/housing balance and that
low-income workers are more likely to choose to live close to their places of employment.
It is unclear, however, that incorporating these assumptions into the City’s screening
criteria would be supported by substantial evidence at this time. As a result, the proposed
City policy does not screen out affordable housing projects at this time.
o Proposed Thresholds of Significance for Projects not Meeting Screening
Criteria
For projects that do not otherwise meet the screening criteria described above, the
following thresholds of significance would apply:
Residential Projects
Project VMT per capita shall be calculated by performing a run of the SLOCOG travel
demand model and comparing the total regional VMT with and without the project to
determine total project VMT. Total project VMT then shall be divided by the proposed
dwelling units multiplied by the City’s average persons per household from the US Census
(2.54 Average Persons Per Household).
ሺܶݐ݈ܽ ܴ݈݁݃݅݊ܽ ܸܯܶሻ
ሺܲݎݏ݁݀ ܦݓ݈݈݁݅݊݃ ܷ݊݅ݐݏሻݔ ሺܣݒ݁ݎܽ݃݁ ܲ݁ݎݏ݊ݏ ݁ݎ ܪݑݏ݄݈݁݀ሻ
Significance Criteria: Project VMT per capita exceeds 17.2, 15% below the existing
regional average VMT per capita (20.2).
Office Projects
Project VMT per capita shall be calculated by performing a run of the SLOCOG travel
demand model and comparing the total regional VMT with and without the project to
Item 11.a. - Page 7
CITY COUNCIL
DISCUSSION AND CONSIDERATION OF POLICY ESTABLISHING THRESHOLDS
OF SIGNIFICANCE FOR EVALUATING TRANSPORTATION IMPACTS UNDER THE
CALIFORNIA ENVIRONMENTAL QUALITY ACT PURSUANT TO SB 743
SEPTEMBER 8, 2020
PAGE 8
determine total project VMT.
Total project VMT then shall be
divided by the proposed office
square feet divided by an
estimate of the average square
feet per office worker. An
Employment Density Report
prepared for the Southern
California Association of
Governments by the Natelson
Company is recommended as
guidance for estimating this
value. The appropriate table
from this report is shown in
Figure 1 to the right.
ሺܶݐ݈ܽ ܴ݈݁݃݅݊ܽ ܸܯܶሻ
ሺܲݎݏ݁݀ ܱ݂݂݅ܿ݁ ܵݍ .ܨݐ .ሻ/ ሺܣݒ݁ݎܽ݃݁ ܵݍ.ܨݐ.݁ݎ ܱ݂݂݅ܿ݁ ܹݎ݇݁ݎሻ
Significance Criteria: Project VMT exceeds 11.9 VMT / Employee, 15% below the existing
regional average VMT per employee (14.0).
Retail, Industrial, & Other Projects Not Otherwise Addressed
Project VMT per capita shall be calculated by performing a run of the SLOCOG travel
demand model and comparing the total regional VMT with and without the project to
determine total project VMT.
Significance Criteria: Project VMT results in a total net increase of the regional VMT.
Transportation Projects
For transportation projects that increase auto capacity, such as addition of through lanes
on existing or new highways, which would likely lead to a measurable and substantial
increase in VMT, quantitative analysis is required to calculate the amount of additional
vehicle travel anticipated. For transportation projects that have already been evaluated
for VMT at a programmatic level, such as within a General Plan or Specific Plan, the City
may tier from that analysis. For transportation projects located within the City that are
anticipated to increase vehicle travel, the VMT threshold of significance shall be evaluated
and determined on a case-by-case basis, while ensuring that the analysis addresses:
A) Direct, indirect and cumulative effects of the transportation project, including
potential for induced demand (CEQA Guidelines §15064(d) and (h));
Figure 1: SCAG 2001 Employment Density Report Table 1A
Item 11.a. - Page 8
Derivation of Square Feet pe r Em p loy ee Based on :
--MEDIAN EMPLOYEES PER ACRE
--M EDIAN FAR
FIVE COUNTY REGION Net/Gross Adjustment Factor: 0 .75
#of Employees/ Building Square Feet/
Land Use Ca tego[)l Records FAR Acre Effic ienc~ Emg lo~ee
Regional Retai l 27 0 .59 14 .99 0 .80 1,023
Other Retai l/Svc . 101 3 0 .28 13.49 0 .85 585
Low-Rise Office 349 0 .36 22 .91 0 .90 466
Hi gh -Rise Office 46 1.19 116.32 0 .90 300
Hotel /Motel 16 0 .61 11 .04 N/A 1,804
R & D/Flex Space 70 0 .31 18 .13 0 .95 527
Li gh t Manufactu ri ng 1047 0 .35 11 .63 0 .95 924
Heavy Ma nufacuring 0 17 .05 N/A
Warehouse 121 0.42 10 .63 0 .95 1,225
Government Offi ces 32 0 .37 16.23 0 .90 672
CITY COUNCIL
DISCUSSION AND CONSIDERATION OF POLICY ESTABLISHING THRESHOLDS
OF SIGNIFICANCE FOR EVALUATING TRANSPORTATION IMPACTS UNDER THE
CALIFORNIA ENVIRONMENTAL QUALITY ACT PURSUANT TO SB 743
SEPTEMBER 8, 2020
PAGE 9
B) Near-term and long-term effects of the transportation project (CEQA Guidelines
§§15063(a)(1), 15126. 2(a));
C) The transportation project’s consistency with State greenhouse gas reduction
goals (Pub. Res. Code §21099);
D) The impact of the transportation project on the development of multimodal
transportation networks (Pub. Res. Code §21099); and
E) The impact of the transportation project on the development of a diversity of land
uses (Pub. Res. Code §21099).
Mixed-Use Projects
The proposed policy directs that each proposed use included in a project will be analyzed
separately and compared to the corresponding threshold. Alternatively, the City may
consider only the project’s dominant use where doing so will not underestimate potential
transportation impacts resulting from the project. In the analysis of each use, a project
should take credit for internal capture.
VMT Mitigation Strategies
The new CEQA Guidelines and OPR guidance identify a series of potential mitigation
measures to address project-related VMT impacts. In order to ensure flexibility and
ingenuity in the methods that may be employed to mitigate potentially-significant VMT
impacts for future projects, these measures are not included in the proposed VMT policy.
However, the following measures will be considered as potential mechanisms for
mitigating VMT impacts:
o Development of a Transportation Demand Management Program (TDM).
o Improve or increase access to transit.
o Incorporate a mix of land uses to increase access to common goods and
services, such as groceries, neighborhood retail, schools and childcare
services.
o Locating the project in lower-VMT areas of the City.
o Improve or increase access to active transportation facilities.
o Provide car-sharing, bike-sharing, ride-sharing, neighborhood electric vehicle
charging stations, or other on-site amenities to increase access and use of
greenhouse gas reducing transportation modes.
o Participate in an in-lieu fee program to fund City-wide improvements to
sustainable transportation modes.
Item 11.a. - Page 9
CITY COUNCIL
DISCUSSION AND CONSIDERATION OF POLICY ESTABLISHING THRESHOLDS
OF SIGNIFICANCE FOR EVALUATING TRANSPORTATION IMPACTS UNDER THE
CALIFORNIA ENVIRONMENTAL QUALITY ACT PURSUANT TO SB 743
SEPTEMBER 8, 2020
PAGE 10
Retention of LOS to evaluate consistency with the City’s General Plan
While LOS or other measures of roadway congestion are no longer accepted as CEQA
metrics for transportation analysis, local agencies may continue to require LOS analysis
as a local requirement for evaluating a project’s consistency with their general plans. Staff
recommends that the City continue to apply LOS analysis thresholds, as established in
the City’s General Plan, Circulation Element, and TIAR Guidelines, to support an
evaluation and determination of a project’s consistency with the City’s General Plan.
Project-level LOS analysis would be required consistent with the City’s TIAR Guidelines,
which require focused traffic analysis for development projects that generate projected
trips during any peak hour equal to or greater than 20 trips during either the weekday AM
or PM peak hour, or the weekend peak hour. The amount of traffic generated by the
project will continue to be calculated using the methodology and guidelines of the latest
edition of the ITE Trip Generation Manual (currently the 9th Edition). The City may require
TIAR for projects with a peak hour trip generation of less than 20 trips because of safety
and/or access concerns, public opposition to the project, or when existing service levels
on area streets are at or approaching unacceptable levels. In addition, staff recommends
that project-level safety analyses, including evaluation of intersection queuing and access
management, continue to be required, along with LOS, as part of a local General Plan
conformity assessment. The proposed policy provided in Attachment 1 includes a section
that ensures these analyses will continue to be conducted.
By retaining LOS for non-CEQA analysis, future development projects would continue to
demonstrate that they do not create traffic demands or conditions that are inconsistent
with the traffic safety and performance thresholds established in the City’s Circulation
Element. In turn, the Planning Commission and City Council would continue to have
flexibility and discretion to make findings and conditions, and approve or deny projects,
based on General Plan LOS requirements. Projects that are inconsistent with General
Plan LOS standards could be conditioned to ensure that LOS standards are met through
direct infrastructure improvements or fair share contributions to improvements.
Planning Commission Recommendation
The Planning Commission considered the proposed VMT policy at its regular meeting
held on July 21, 2020. Following a presentation by staff and the City’s consultant, the
Commission voted unanimously to recommend approval of the policy by the City Council.
The Commission also recommended one addition to the policy to ensure that the baseline
VMT numbers are updated periodically, consistent with updates to SLOCOG’s data. This
change has been incorporated into the proposed policy presented in Attachment 1.
Additional changes to the policy were made by staff to clarify language in some portions
of the policy as well.
Item 11.a. - Page 10
CITY COUNCIL
DISCUSSION AND CONSIDERATION OF POLICY ESTABLISHING THRESHOLDS
OF SIGNIFICANCE FOR EVALUATING TRANSPORTATION IMPACTS UNDER THE
CALIFORNIA ENVIRONMENTAL QUALITY ACT PURSUANT TO SB 743
SEPTEMBER 8, 2020
PAGE 11
ALTERNATIVES:
The following alternatives are provided for the Commission’s consideration:
1. Adopt the Resolution adopting the VMT policy; or
2. Make modifications to the VMT policy and adopt the Resolution; or
3. Provide further direction to staff.
ADVANTAGES:
Adoption of the VMT policy will establish thresholds of compliance for purposes of
evaluating projects’ transportation impacts under the CEQA consistent with SB 743.
DISADVANTAGES:
There are no disadvantages identified with review of the VMT policy.
ENVIRONMENTAL REVIEW:
In accordance with the California Environmental Quality Act (CEQA) and the State CEQA
Guidelines, it has been determined that this item is not a “project” as defined in State
CEQA Guidelines Section 15378 and is, therefore, exempt from CEQA pursuant to CEQA
Guidelines Section 15060(c)(3).
PUBLIC NOTIFICATION:
The Agenda was posted at City Hall and on the City’s website in accordance with
Government Code Section 54954.2.
Attachments:
1. GHD Baseline VMT Methodology & Estimation Memorandum
2. DRAFT Minutes of the July 21, 2020 Planning Commission Meeting
Item 11.a. - Page 11
RESOLUTION NO.
A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF ARROYO
GRANDE ADOPTING A POLICY ESTABLISHING THRESHOLDS OF
SIGNIFICANCE FOR EVALUATING TRANSPORTATION IMPACTS
UNDER THE CALIFORNIA ENVIRONMENTAL QUALITY ACT
PURSUANT TO SB 743
WHEREAS, SB 743 was signed into law in 2013, with the intent of better aligning
California Environmental Quality Act (CEQA) practices with statewide sustainability goals
related to efficient land use, greater multi-modal transportation choices, and greenhouse
gas reductions; and
WHEREAS, SB 743 included amendments to CEQA that required the Office of Planning
and Research (OPR) to develop new guidelines for measuring a project’s transportation
impacts under which automobile delay, traditionally measured as level of service (LOS),
will no longer be considered an environmental impact under CEQA and, instead, a
project’s generated vehicle miles traveled (VMT) will determine a project’s transportation
impacts; these changes were effective as of July 1, 2020; and
WHEREAS, OPR adopted new guidelines consistent with SB 743 that became effective
on July 1, 2020; and
WHEREAS, under CEQA, lead agencies have discretion to formulate their own
significance thresholds and may do so through formally adopted thresholds that are
consistently applied to all projects, which promotes predictability and consistency for the
environmental review process and increases defensibility of the lead agency’s
significance determinations; and
WHEREAS, the City desires to adopt a policy establishing thresholds of significance for
the evaluation of transportation impacts that is consistent with SB 743, CEQA, and the
State CEQA Guidelines and that is supported by substantial evidence in the record.
NOW, THEREFORE, BE IT RESOLVED, by the City Council of the City of Arroyo Grande
as follows:
1. The City Council finds and declares that substantial evidence exists to support
the thresholds of significance and policies set forth in Exhibit A, as described
in the staff report presented to the City Council on September 8, 2020, its
attachments, all supporting memoranda, and all materials referenced therein,
which are incorporated herein by reference as though set forth in full.
2. The Policy Establishing Thresholds of Significance for Evaluating
Transportation Impacts under the California Environmental Quality Act
Consistent with SB 743 attached hereto and incorporated herein as Exhibit A
is hereby adopted.
3. This Resolution is effective immediately upon adoption.
Item 11.a. - Page 12
RESOLUTION NO.
PAGE 2
On motion of Council Member , seconded by Council Member , and
on the following roll call vote, to wit:
AYES:
NOES:
ABSENT:
the foregoing Resolution was passed and adopted this 8th day of September, 2020.
Item 11.a. - Page 13
RESOLUTION NO.
PAGE 3
CAREN RAY RUSSOM, MAYOR
ATTEST:
KELLY WETMORE, CITY CLERK
APPROVED AS TO CONTENT:
____________________________________
BILL ROBESON, ACTING CITY MANAGER
APPROVED AS TO FORM:
TIMOTHY J. CARMEL, CITY ATTORNEY
Item 11.a. - Page 14
1
Exhibit A
Policy Establishing Thresholds of Significance
for Evaluating Transportation Impacts under the
California Environmental Quality Act Consistent with SB 743
The following standards and thresholds of significance shall be used to evaluate potential transportation
impacts of projects subject to the California Environmental Quality Act (CEQA), in compliance with SB
743, Public Resources Code section 21099, and CEQA Guidelines section 15064.3, which are hereby
incorporated by reference.
1. Vehicle Miles Traveled (VMT)
Generally, vehicle miles traveled (VMT) is the most appropriate measure of transportation impacts. For
purposes of this policy, “vehicle miles traveled” or “VMT” 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. A project’s effect on automobile delay does not constitute a significant
environmental impact. However, a project’s effect on roadway levels of service will be considered in
determining a project’s consistency with the City’s General Plan, as described further in Section 3 below.
1.1 Projects Assumed to be Less Than Significant
The California Office of Planning & Research (OPR) Technical Advisory has established the following
thresholds under which development projects are presumed to have less than significant impacts on
vehicle miles traveled, which are hereby adopted. Projects that meet these screening criteria are
assumed to have less than significant environmental impacts and do not require further CEQA review as
it relates to transportation.
A) Projects that are consistent with the Sustainable Communities Strategy (SCS) or the General
Plan and generate fewer than 110 daily trips based on the most current edition of the Institute
of Traffic Engineer’s Trip Generation Manual.
B) Projects that are within ½ mile of a transit stop at the intersection of two transit routes with 15
minute or less headways, unless the project:
a. Has a floor to area ratio (FAR) of less than 0.75;
b. Includes more parking than required under the City’s zoning code;
c. Is inconsistent with the region’s Sustainable Communities Strategy, City Zoning Code,
or City Land Use Policies, including the City’s General Plan or any applicable Specific
Plan; or
d. Replaces affordable housing with a smaller number of moderate- or high-income
residential units.
C) Local-serving retail projects, which are generally defined as projects within the City that are
less than 50,000 square feet in size. The determination of whether a retail project is local-
serving or regional-serving shall be made by City staff on a case by case to determine whether
Item 11.a. - Page 15
2
they are likely to attract regional trips. For instance, auto dealerships and specialty retailers
may propose less than 50,000 square feet of retail space but be deemed regional serving.
D) Transportation projects that are expected to reduce or have no impact on VMT will not require
a quantitative VMT analysis. These projects include, but are not limited to, road diets (traffic
lane reductions/narrowing), roundabouts, roadway rehabilitation and maintenance, safety
improvements that do not substantially increase auto capacity, installation or reconfiguration of
lanes not for through traffic (addition of left/right turn lanes, etc.), timing of traffic signals,
removal of on-street parking, addition or enhancement of pedestrian, bicycle and transit
facilities and services.
2. Thresholds of Significance
2.1 Baseline VMT
Baseline VMT is established as the countywide average, including incorporated cities, as calculated by
the San Luis Obispo Council of Governments (SLOCOG) travel demand model.
The baseline VMT per capita is 20.2 for residential projects and the proposed baseline VMT per
employee is 14.0 for non-residential projects. These baselines shall be updated periodically, consistent
with updates to the SLOCOG Regional Transportation Demand/Sustainable Communities Strategy and
Regional Transportation Demand Model.
2.2 Residential Projects and Uses
Project VMT per capita shall be calculated by performing a run of the SLOCOG travel demand model and
comparing the total regional VMT with and without the project to determine total project VMT. Total
project VMT then shall be divided by the proposed dwelling units multiplied by the City’s average persons
per household from the US Census (2.54 Average Persons Per Household).
ሺܶݐ݈ܽ ܴ݈݁݃݅݊ܽ ܸܯܶሻ
ሺܲݎݏ݁݀ ܦݓ݈݈݁݅݊݃ ܷ݊݅ݐݏሻݔ ሺܣݒ݁ݎܽ݃݁ ܲ݁ݎݏ݊ݏ ݁ݎ ܪݑݏ݄݈݁݀ሻ
Significance Criteria: Project VMT per capita exceeds 17.2, 15% below the existing regional average VMT
per capita (20.2).
2.3 Office Projects
Project VMT per capita shall be
calculated by performing a run of the
SLOCOG travel demand model and
comparing the total regional VMT
with and without the project to
determine total project VMT. Total
project VMT then shall be divided by
the proposed office square feet
divided by an estimate of the average
square feet per office worker. An
Employment Density Report prepared
Figure 1: SCAG 2001 Employment Density Report Table 1A
Item 11.a. - Page 16
Derivation of Square Feet per Emp loyee Base d on :
--MED IAN EMPLOYEES PER ACRE
--MED IAN FAR
FIVE COU NTY REGIO N Net/Gross Adjustment Factor: 0.75
#of Employees/ Buildi ng Square Feet/
Land Use Categoty Records FAR Acre Effi ciency Em~loyee
Regional Retai l 27 0.59 14 .99 0.80 1,023
Other Reta il /Svc. 1013 0.28 13.49 0 .85 585
Low-Rise Office 349 0.36 22 .91 0 .90 466
Hi gh -Rise Office 46 1.19 116 .32 0 .90 300
Hotel /Motel 16 0.61 1 1.04 N/A 1,804
R & D/Flex Space 70 0.31 18.13 0 .95 527
Li gh t Manufacturi ng 1047 0.35 11.63 0 .95 924
Heavy Ma nu facuring 0 17 .05 N/A
Ware house 121 0.42 10.63 0 .95 1,225
Government Offi ces 32 0.37 16 .23 0 .90 672
3
for the Southern California Association of Governments by the Natelson Company is recommended as
guidance for estimating this value. The appropriate table from this report is shown in Figure 1 to the right.
ሺܶݐ݈ܽ ܴ݈݁݃݅݊ܽ ܸܯܶሻ
ሺܲݎݏ݁݀ ܱ݂݂݅ܿ݁ ܵݍ.ܨݐ.ሻ/ ሺܣݒ݁ݎܽ݃݁ ܵݍ.ܨݐ.݁ݎ ܱ݂݂݅ܿ݁ ܹݎ݇݁ݎሻ
Significance Criteria: Project VMT exceeds 11.9 VMT / Employee, 15% below the existing regional
average VMT per employee (14.0).
2.4 Retail, Industrial, & Other Projects Not Otherwise Addressed
Project VMT per capita shall be calculated by performing a run of the SLOCOG travel demand model and
comparing the total regional VMT with and without the project to determine total project VMT.
Significance Criteria: Project VMT results in a total net increase of the regional VMT.
2.5 Transportation Projects
For transportation projects that increase auto capacity, such as the addition of through lanes on existing
or new highways, which would likely lead to a measurable and substantial increase in VMT, quantitative
analysis is required to calculate the amount of additional vehicle travel anticipated. For transportation
projects that have already been evaluated for VMT at a programmatic level, such as within a General
Plan or Specific Plan, the City may tier from that analysis. For transportation projects located within the
City that are anticipated to increase vehicle travel, the VMT threshold of significance shall be evaluated
and determined on a case-by-case basis, while ensuring that the analysis addresses:
A) Direct, indirect and cumulative effects of the transportation project, including potential for induced
demand (CEQA Guidelines §15064(d) and (h));
B) Near-term and long-term effects of the transportation project (CEQA Guidelines §§15063(a)(1),
15126. 2(a));
C) The transportation project’s consistency with state greenhouse gas reduction goals (Pub. Res.
Code §21099);
D) The impact of the transportation project on the development of multimodal transportation
networks (Pub. Res. Code §21099); and
E) The impact of the transportation project on the development of a diversity of land uses (Pub. Res.
Code §21099).
2.6 Mixed-Use Projects
Each proposed use will be analyzed separately and compared to the corresponding threshold.
Alternatively, the City may consider only the project’s dominant use where doing so will not underestimate
potential transportation impacts resulting from the project. In the analysis of each use, a project should
take credit for internal capture.
Item 11.a. - Page 17
4
2.7 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 apply.
3. Level of Service
A project’s impacts to transportation levels of service (LOS), roadway safety, intersection queuing and
access management, and multimodal transportation infrastructure (collectively referred to hereafter as
“transportation infrastructure”) will be considered in determining consistency with the City’s General Plan
and land use policies. Project-level analysis of potential impacts to transportation infrastructure will be
completed consistent with the City’s General Plan, Circulation Element, and Traffic Impact Analysis
Guidelines. The results of these analyses will be considered in determining the project’s consistency with
the City’s General Plan and land use policies. Where impacts to transportation infrastructure are
identified, projects may be conditioned to ensure that the standards stated in the City’s General Plan and
land use policies, including but not limited to the City’s Circulation Element and Traffic Impact Analysis
Guidelines, are met through direct infrastructure improvements or fair share contributions to
improvements.
Item 11.a. - Page 18
Memorandum
GHD
943 Reserve Drive Roseville California 95678 United States
T +1 916 782 8688 F +1 916 782 8689 W www.ghd.com
June 8, 2020
To: City of Arroyo Grande Project: City of Arroyo Grande CEQA
Transportation Impact Thresholds
From: Todd Tregenza,
Rosanna Southern
Ref/Job No.: 11144936
CC: File No.: C1584MEM005.DOCX
Subject: Baseline VMT Methodology & Estimation
1.Introduction
The City has contracted GHD to develop procedures for assessing transportation impacts under CEQA, per
SB 743 and update the City’s Environmental Thresholds and Guidelines Manual. GHD will develop baseline
VMT estimates, project screening criteria, thresholds of significance, and methodologies for evaluating land
development and transportation infrastructure using VMT as the primary impact criterion. GHD will also
develop a sketch-planning tool for City and project applicant use.
1.1 Memorandum Purpose
The purpose of this memorandum is to review guidance, options, resources, and analytical methodologies
for evaluating VMT in the City of Arroyo Grande that can be used to establish baseline VMT. The lite rature
review includes the Governor’s Office of Planning and Research (OPR) Technical Advisory on Evaluating
Transportation Impacts in CEQA (December 2018), the Caltrans Draft VMT-Focused Transportation Impact
Study Guide (February 2020), and the San Luis Obispo Council of Governments (SLOCOG) Transition from
LOS to VMT Staff Report (October 2019).
The data sources and technical review includes the SLOCOG Regional Travel Demand Model (RTDM), US
Census’s Longitudinal Employer-Housing Dynamics (LEHD) data, Census Transportation Planning Products
(CTPP) data, and published data for the region.
2.Regulatory and Planning Framework
SB 743 was signed into law in 2013, with the intent to better align California Environmental Quality Act
(CEQA) practices with statewide sustainability goals related to efficient land use, greater multi-modal
choices, and greenhouse gas reductions. The provisions of SB 743 become effective Statewide on July 1,
2020. Under SB 743, automobile delay, traditionally measured as level of service (LOS), will no longer be
considered an environmental impact under CEQA. Instead, impacts will be determined by changes to VMT.
ATTACHMENT 1
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C1584MEM005.docx 2
VMT measures the number and length of vehicle trips made on a daily basis. VMT is a useful indicator of
overall land use and transportation efficiency, where the most efficient system is one that minimizes VMT by
encouraging shorter vehicle trip lengths, more walking and biking, or increased carpooling and transit.
Measuring VMT requires estimating or measuring the full length of vehicle trips by purpose, such as
commutes, deliveries, or shopping trips that often cross between cities, counties, or states. For this reason,
regional travel demand models, “big data,” and household travel surveys that are less limited by local agency
boundaries are the preferred tools to estimate VMT under SB 743.
2.1 Governor’s Office of Planning and Research (OPR) Technical Advisory
In December 2018, OPR released its final Technical Advisory on Evaluating Transportation Impacts in
CEQA. Generally, OPR recommends that a reduction of 15% or more in VMT should be the target. Below is
a summary of OPR’s recommended VMT impact thresholds and methodologies for land use projects:
Residential (VMT/capita) – A proposed project exceeding a level of 15% below existing regional 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 th an regional VMT per capita)
should not cumulatively exceed the number of units specified in the Sustainable Communities Strategy
(SCS) for that city, and should be consistent with the SCS.
Office (VMT/employee) - A proposed project exceeding a level of 15% below existing regional VMT per
employee may indicate a significant transportation impact.
Retail (net VMT) – A proposed project that results in a net increase in total area VMT may indicate a
significant transportation impact.
Mixed-Use - Evaluate each component independently using above thresholds.
Redevelopment Projects - Measured based on net change in VMT for total area.
2.1.1 OPR Recommended Screening Thresholds
OPR’s Technical Advisory lists the following screening thresholds for land use projects. These types of
development projects are presumed to have a less-than-significant impact on vehicle miles traveled and
therefore, a less than significant adverse impact on transportation. OPR’s Technical Advisory suggests that
lead agencies may screen out VMT impacts using project size, maps, transit availability, and provision of
affordable housing.
- Projects that are consistent with the Sustainable Communities Strategy (SCS) or General Plan and
generate or attract fewer than 110 daily trips.
- Map-based screening for residential and office projects located in low VMT areas, and that
incorporate similar features (density, mix of uses, transit accessibility).
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C1584MEM005.docx 3
- Certain projects within ½ mile of an existing major transit stop1 or an existing stop along a high
quality transit corridor. However, this will not apply if information indicates that the project will still
generate high levels of VMT.
- Affordable Housing Development in infill locations.
- Locally-serving retail projects, typically less than 50,000 square feet.
2.2 Caltrans Draft VMT-Focused Transportation Impact Study Guidelines
Caltrans recently published a draft update for their Transportation Impact Study Guidelines (Draft TISG,
February 28, 2020), which is in a 30-day informal review period through March 30th. The Caltrans’ Draft
TISG is intended for use in preparing a transportation impact analysis of land use projects or plans they may
impact or affect the State Highway System. It is not clear when Caltrans review of a CEQA document would
be required under SB 743, since it was previously triggered by a project’s potential trip generation and
impact to automobile delay on a State Highway.
The Draft TISG heavily references OPR’s Technical Advisory as a basis for its guidance. The Draft TISG
recommends use of OPR’s recommended thresholds for land use projects (15% below existing city or
regional VMT per capita or per employee). As each lead agency develops and adopts its own VMT
thresholds for land use projects, Caltrans will review them for consistency with OPR’s recommendations, and
with the state’s GHG emissions reduction targets and CARB Scoping Plan.
Caltrans identifies a possible mitigation framework for projects found to have a potentially significant impact
on VMT. These include the following programmatic measures:
Impact fee programs that contain a demonstrated nexus and proportionality between a fee and
capital projects that result in VMT reduction;
VMT mitigation bank programs; and,
VMT mitigation exchange programs.
Caltrans also indicates that a future update to the Draft TISG will include the basis for requesting
transportation impact analysis that is not based on VMT (including multimodal conflict/access management
issues). GHD will monitor future updates for consideration as part of this effort for the City.
2.3 SLOCOG Transition from LOS to VMT Staff Report
Using the SLOCOG RTDM, SLOCOG developed advisory regional baseline VMT values and thresholds for
the consideration of its member jurisdictions. The staff report also included baseline information for the
incorporated Cities, County communities, and unincorporated County as a whole. The methodology utilized
to establish VMT was developed using boundary-based VMT. A trip-based methodology is more consistent
1 “major transit stop” - A major transit stop is a "site containing an existing rail, a ferry terminal served by bus or rail
transit service, or intersection of two or more major bus routes with a frequency of service interval of 15 minutes or
less during morning and evening peak hour commute". (OPR 2018)
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C1584MEM005.docx 4
with the regulatory and planning framework established by OPR and supported by Caltrans. The baseline
VMT metrics presented in the Staff Report per jurisdiction are for informational use. The Regional Average
and Citywide Baseline VMT information is outlined in the Staff Report dated October 2, 2019 and is shown in
Table 2.1.
Table 2.1 SLOCOG Staff Report – Average Baseline VMT
Area Residential VMT per
Capita
Work VMT per
Employee
Arroyo Grande Citywide Average 9.5 7.0
15% below Citywide Average 8.08 5.95
SLO Regional Average 13.43 8.59
Regional Threshold of 15% below Regional Average 11.42 7.30
In addition to the above baseline averages and regional thresholds presented, the SLOCOG Staff Report
presents recommendations for VMT evaluation methodology on other projects, which are consistent with
OPR’s Technical Advisory:
Retail Projects
- Project results in a net increase in total area VMT.
Mixed Use
- Evaluate each component independently using above thresholds, considering credit for internal
capture. Alternatively, a lead agency may consider only the project’s dominant use. Combining
different land uses and applying one threshold to those land uses may result in an inaccurate impact
assessment.
3. Proposed VMT Evaluation Criteria
GHD has recommended a variation on the OPR Technical Advisory land use type criteria to account for uses
commonly found in the City. GHD proposes that the City of Arroyo Grande assess land development projects
according to the primary proposed land use type, as follows:
Residential VMT – Establish baseline VMT and threshold on a per capita basis. “Residential” uses include,
but are not limited to, single-family, multi-family, and mobile homes.
Work VMT – Establish baseline VMT and threshold on a per employee basis. “Work” uses include, but are
not limited to, office, office parks, light industrial, industrial, warehousing, manufacturing, and business parks.
Retail VMT – Measure net VMT within boundary, and determine threshold based on net change. “Retail”
uses include, but are not limited to, supermarkets, restaurants, gas stations, wineries, agriculture tourism,
and hotels. Public and recreational uses such as parks, hospitals, libraries, and public services may also be
assessed in this way, if needed.
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C1584MEM005.docx 5
Mixed-Use Projects – Evaluate each component independently using the above thresholds, considering
credit for internal capture, OR evaluate dominant use.
Redevelopment Projects - Measured based on net change in VMT for total area.
Screening Criteria – Use OPR’s proposed screening criteria. GHD will develop m aps to show the
Residential VMT per capita and Work VMT per employee for each traffic analysis zone (TAZ) within the City
(SLOCOG model). These maps can be used to compare to the VMT thresholds, once determined by the
City, and screen out projects from needing to prepare detailed VMT analysis.
4. Baseline VMT Data Sources
Project-level VMT is assessed against statewide, regional, or local averages , per capita or per employee
depending on the Project type. It is critical, therefore, that the City carefully considers and establishes
baseline averages that reflect the travel behavior of their residents and employees. This baseline will be the
measuring stick that all future projects will be measured against, until baselines are updated. GHD
recommends updating the baseline VMT estimates every 5 years, concurrent with an upd ate to the
SLOCOG RTP/SCS and RTDM.
4.1 SLOCOG RTDM
The regional SLOCOG model was utilized to estimate trip-based Residential and Work baseline VMT for the
City of Arroyo Grande and Arroyo Grande Fringe. The recently updated model has a base year of 2015 and
a forecast year of 2045 (model updated December 2019). The base year 2015 model was utilized to
estimate baseline VMT utilizing the updated land uses. The sole use of the SLOCOG model inputs and trip
purposes for evaluation of VMT is limited to the boundary of the model (SLO County boundary). The
SLOCOG RTDM produces trips by different trip purposes and modes, and outputs VMT throughout the
County. To estimate trips associated with Residential VMT, all Home-Based vehicular trips (HBx2) were
selected for evaluation of VMT per capita. To estimate trips associated with Work VMT, only Home-Base-
Work (HBW) vehicular trips were selected for evaluation. Table 4.1 and Table 4.2 present the trip purposes
used for Residential and Work VMT evaluations, respectively.
2 HBx refers to any “Home based” trip, including work, shop, K-12, college, and other.
Item 11.a. - Page 23t,j § id
C1584MEM005.docx 6
Table 4.1 Selected Trip Purposes for Residential VMT
Trip Purpose Categories
(SLOCOG RTDM)
Mode Type
SOV HOV2 HOV3 Transit Walk Bike Truck
HBW Home based work USED USED USED x x x
HBS Home based shop USED USED USED x x x
HBK Home based K-12 USED USED USED x x x
HBC Home based college USED USED USED x x x
HBO Home based other USED USED USED x x x
W BO Work based other x x x x x x
OBO Other based other x x x x x x
EE External to external x x x x x x
TS Light duty truck x
TM Medium duty truck x
TH Heavy duty truck x
Table 4.2 Selected Trip Purposes for Work VMT
Trip Purpose Categories
(SLOCOG RTDM)
Mode Type
SOV HOV2 HOV3 Transit Walk Bike Truck
HBW Home based work USED USED USED x x x
HBS Home based shop x x x x x x
HBK Home based K-12 x x x x x x
HBC Home based college x x x x x x
HBO Home based other x x x x x x
W BO Work based other x x x x x x
OBO Other based other x x x x x x
EE External to external x x x x x x
TS Light duty truck x x x x
TM Medium duty truck x x x x
TH Heavy duty truck x x x x
4.2 LEHD Data
Journey-to-work data is also available from the Longitudinal Employer-Household Dynamics (LEHD)
program. The primary source of data used in the LEHD program is the enhanced Quarterly Census of
Employment and Wages (QCEW) microdata files obtained from each participating Local Employment
Dynamics (LED) state. The employer-based QCEW data is merged with additional worker-based
administrative data collected by the US Census Bureau to create integrated employer -worker data, available
through two different databases, Quarterly Workforce Indicators (QWI) and LEHD Origin-Destination
Employment Statistics (LODES).
Item 11.a. - Page 24
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C1584MEM005.docx 7
Unlike sample-based surveys (such as the U.S. Census’s American Community Survey or CTPP), the LEHD
data provides a nearly complete enumeration of home-to-work flows covering over 90% of all workers and
employers in the United States3. The LEHD data does not contain details on the work trips such as mode
choice, route, or travel times. The LEHD data does not include federal workers, self-employed or the military,
and workplace location is assigned algorithmically for people who work for a business with multiple locations
in a county. Since the SLOCOG model provides information on mode choice, and does its own assignment
of trips, the additional comm ute and socio-economic data from CTPP is not needed to determine VMT. The
LEHD data provides many more origin-destination pairs than collected through sampled data, and provides
sufficient data for home-to-work flows.
4.2.1 Development of LEHD Model for City of Arroyo Grande
The LEHD LODES data was utilized within the SLOCOG model to determine Home-Based-Work trips and
estimate baseline “Work” VMT. 2015 LEHD (LODES) data was downloaded by census block level,
aggregated by TAZ, and then imported into an origin-destination matrix within the SLOCOG model software
(TransCAD). This origin-destination trip matrix was used to calculate “internal” VMT utilizing the SLOCOG
model network, and “external” VMT. If one end of the work trip was in an adjacent county, then the work trip
was assigned to the logical SLOCOG external station. An approximation of the "external" portion of the trip's
VMT, and total trip length, was estimated by using the distance (via roadway network travel outside of the
model) to the SLOCOG external station. The "distance" of each external station was modified to account for
the average distance travelled before/after leaving/entering the County. This methodology was used to best
capture the full length of vehicle trips.
Utilizing the LEHD data allows for a comparison of SLOCOG’s HBW trip purposes and calculated Work
VMT. Since the LEHD data only provides home-to-work or work-to-home information, other home-based
trips (HBx) cannot be calculated utilizing the LEHD data, and the full residential -generated VMT per capita is
not calculated utilizing solely the LEHD data. However, the LEHD data can be utilized to supplement the
HBW trip portion of the residential VMT analysis. Doing so would provide trip origins and destinations outside
of the model boundary. The total trip length for home-based trips and associated VMT would then be
calculated, assuming other home-based trips are localized trips within the model boundary.
4.3 CEQA Baseline Considerations
Under CEQA, project impacts must be evaluated by comparing environmental conditions after project
implementation to conditions at a point in time referred to as the baseline. The CEQA Guidelines Section
15125 provides the following guidance for establishing the baseline:
An EIR must include a description of the physical environmental conditions in the vicinity of the
project. This environmental setting will normally constitute the baseline physical conditions by which
a lead agency determines whether an impact is significant… The purpose of this requirement is to
3 “Improving Employment Data for Transportation Planning”, NCRHP 08-36, Task 098. Cambridge Systematics, Inc.
September 2011. http://onlinepubs.trb.org/onlinepubs/nchrp/docs/NCHRP08-36(98)_FR.pdf
Item 11.a. - Page 25t,j § id
C1584MEM005.docx 8
give the public and decision makers the most accurate and understandable picture practically
possible of the project's likely near-term and long-term impacts.
The CEQA Guidelines goes on to state that generally, the baseline is the environmental conditio n that exists
at the time the notice of preparation is published or environmental analysis is commenced, from both a local
and regional perspective. However, a lead agency may define the baseline by referencing historic conditions,
as long as substantial evidence is provided that such a baseline is necessary to provide the most accurate
picture practically possible of the project’s impacts given that existing conditions change or fluctuate over
time.
The baseline provided in this memorandum is estimated from the most recently updated SLOCOG RTDM
model, which has a base year of 2015. Utilizing the 2015 base year scenario to evaluate baseline VMT also
presents a conservative analysis. The update to the Environmental Thresholds Guidelines will need to
ensure that each VMT analysis prepared in the future provides substantial evidence for the applicability of
older baseline data. Updating the baseline VMT estimates every 5 years, concurrent with an update to the
SLOCOG RTP/SCS and RTDM, as recommended in this mem orandum will be an important component of
ensuring that the VMT thresholds remain defensible under CEQA.
4.4 CEQA Threshold Considerations
Under CEQA, a lead agency is required to determine the significance of all environmental impacts (CEQA
Guidelines Section 15064). A threshold of significance for an environmental impact defines the level of effect
above which the lead agency will consider impacts to be significant, and below which it will consider impacts
to be less than significant. Section 16064.7 of the CEQA Guidelines defines a threshold of significance to be:
An identifiable quantitative, qualitative 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 will normally be determined to be less than significant.
Lead agencies have discretion to formulate their own significance thresholds, which can be formally adopted
thresholds consistently applied to all projects. Adopting clearly established thresholds promotes predictability
and consistency for the environmental review process and can increase defensibility of significance
determinations in the lead agencies documents.
The VMT thresholds and screening criteria provided in this section are recommended based on the most
recent guidance on VMT thresholds from the Office of Planning and Research. The VMT analysis completed
for this study serves as substantial evidence for the validity of the VMT thresholds and screening criteria
recommended for the City of Arroyo Grande. Specifically defining terms and parameters used in the VMT
thresholds, such as locally-serving retail, will be important in ensuring that the VMT thresholds remain
defensible under CEQA.
4.4.1 Setting VMT Significance Thresholds
A lead agency has the discretion to set or apply their own thresholds of significance, provided the decision to
adopt those thresholds is supported by substantial evidence. However, Section 21099 of the Public
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C1584MEM005.docx 9
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. OPR recommends a 15% reduction from baseline VMT per capita or per employee, which is
consistent with SB 743’s direction to select a threshold that will help the State achieve its climate goals .
While OPR’s Technical Advisory is not binding on public agencies , a significance threshold for the City
should be selected that aligns with state law on all three of the aforementioned criteria. GHD recommends
the City to utilize the 15% reduction in baseline VMT per capita or per employee as the threshold of
significance, consistent with OPR recommendations and State climate goals.
5. Draft Baseline VMT Analysis Findings & Recommendations
The City has the discretion to determine thresholds including the appropr iate geography to set thresholds by.
Therefore, Citywide and Countywide baseline VMT rates have been calculated as part of this effort, based
on the methodology for estimating baseline VMT as described within this memorandum, Table 5.1 presents
a summary of the baseline Residential VMT analysis for the City Average and the Countywide Regional
Average (including cities), utilizing the SLOCOG RTDM. Table 5.2 and Table 5.3 present a summary of the
baseline Work VMT analysis for the City Average and the Countywide Regional Average, utilizing the
SLOCOG RTDM model and the LEHD model developed as part of this effort.
Table 5.1 Residential Baseline VMT
Area Name
City of Arroyo
Grande
15% below
City Baseline
Countywide
Total
15% below County
Baseline Threshold
Residential VMT 249,912.93 5,108,878.73
Population 17,355 252,599
VMT per Capita 14.40 12.24 20.23 17.19
Table 5.2 SLOCOG RTDM Work Baseline VMT
Area Name
City of Arroyo
Grande
15% below
City Baseline
Countywide
Total
15% below County
Baseline Threshold
Work VMT (SLOCOG Model) 22,876.52 1,613,336.12
Employment 6,422 115,188
VMT per Employee 3.56 3.03 14.01 11.91
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Table 5.3 LEHD-SLOCOG Work Baseline VMT
Area Name
City of Arroyo
Grande
15% below
City Baseline
Countywide
Total
15% below County
Baseline Threshold
Work VMT (LEHD Model) 155,932.91 3,091,313.72
Employment 6,230 109,723
VMT per Employee 25.03 21.27 28.17 23.95
Following, are Figures 5.1 through 5.5 which show the Residential VMT per capita, Work VMT per employee
(SLOCOG model), Job Destinations based on the SLOCOG model, Work VMT per employee (LEHD model),
and Job Destinations based on the LEHD model, shown for each TAZ.
Figure 5.1– Residential VMT per capita by TAZ
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__ J
------// '
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VMT p~ Capila
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D 15 -30
□ 30 so
□ 50 -75
I!:'.! 100 -150
II 150 -200 -t-
C1584MEM005.docx 11
Figure 5.2 – Work VMT per capita (SLOCOG model) by TAZ
Figure 5.3 – Job Destinations (SLOCOG model) by TAZ
Item 11.a. - Page 29
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C1584MEM005.docx 12
Figure 5.4 – Work VMT per capita (LEHD model) by TAZ
Figure 5.5 – Job Destinations (LEHD model) by TAZ
Item 11.a. - Page 30
«1:11 § ,
legend
,:I Arroyo Grande City Limits
-Roadways
VMT by TAZ
VMT per Em ployee (LEHO)
D 0.0 · 1.0
D 1.0 -20.0
20.0 -30.0
30.0 · 40.0
40.0 · 50.0
50.0 -60.0
70.0 · 80.0
~ Arroyo Grdn<k= Cit'/ Limits
-Roadways
-----
Job Desltnaliom; (LEHO rncdel)
D 0.0-0.0
C1584MEM005.docx 13
5.1 Baseline VMT Considerations and Recommendations
The LEHD data showed extensive interaction with areas outside of the model boundary, near Santa Maria in
Santa Barbara County. Based on the SLOCOG model results, the reported Work VMT is much lower when
utilizing the SLOCOG inputs (land uses and resulting trips by trip purpose). This is due to the model resulting
in shorter distances to match the origin-destination pairs for home-based-work trips. The number of
employees for both SLOCOG and LEHD are however, comparable. Utilizing the LEHD data for work VMT
would account for longer home-based-work trips, and a more accurate assessment of the origin-destination
pairs throughout the model. However, the SLOCOG model presented a wider spread of the employment
base throughout the TAZ’s Citywide: 25% of TAZ’s had no employment, compared to 48% of the TAZ’s
based on the LEHD data. Although the SLOCOG model presents shorter home-based-work trips compared
to the LEHD data model, the SLOCOG model has more accurate representation of where jobs are located
within the City. Therefore, the use of the SLOCOG model is recommended to establish baseline Work VMT.
Additionally, the LEHD data has outliers for workplace locations outside of the County. The SLOCOG model
inputs result in lower baseline Work VMT within the incorporated cities of the County, including the City of
Arroyo Grande.
Variations in home-based-work trips and in total employment between SLOCOG and LEHD exist on the
TAZ level. The SLOCOG model best represents actual workplace locations within the City of Arroyo
Grande.
GHD recommends using Countywide Average to establish Baseline VMT.
GHD recommends using the SLOCOG model for estimating baseline Residential and Work VMT.
6. Conclusion
Based on discussion with the City, the City of Arroyo Grande has selected to utilize the Countywide average
for establishing both Residential and Work baseline VMT metrics, based on the SLOCOG travel demand
model outputs, and 15% below baseline as the VMT threshold for Residential and Work land use types .
Retail land use types will be measured by net VMT, where the threshold is zero net change in total VMT.
The following lists the proposed metrics:
Baseline Residential VMT per capita: 20.2
- Threshold of 15% below baseline: 17.2
Baseline Work VMT per employee: 14.0
- Threshold of 15% below baseline: 11.9
Item 11.a. - Page 31t,j § id
PLANNING COMMISSION PAGE 2
MINUTES
JULY 21, 2020
9. NON-PUBLIC HEARINGS
9.a CONSIDERATION OF POLICY ESTABLISHING THRESHOLDS OF SIGNIFICANCE FOR
EVALUATING TRANSPORTATION IMPACTS UNDER THE CALIFORNIA ENVIRONMENTAL
QUALITY ACT PURSUANT TO SB 743
Recommended Action: It is recommended that the Planning Commission consider the proposed
policy establishing thresholds of significance implementing SB 743 and provide a recommendation
to the City Council for adoption of the policy.
Community Development Director McDonald presented the staff report and responded to
Commissioner questions regarding level of service, general plan conformance and VMT baselines.
Action: Chair Martin moved and Commissioner Montes seconded the motion to recommend the City
Council adopt the proposed policy establishing thresholds of significance implementing SB 743 with
the following addition:
1.Ensure that local compliance remains current with regional and statewide baseline changes
The motion passed on the following roll-call vote:
AYES: Martin, Maraviglia, Montes, Sage and Schiro
NOES: None
ABSENT: None
10.ADM INISTRATIVE DECISIONS SINCE JULY 7, 2020
Case No. Applicant Address Description Action Planner
PPR20-009 Linda Ruberto,
Star Brows
522-A
Paulding
Circle
Establishment of a
personal service
business in the VMU
district
A 07/24/2020
PPR 20-010 Robin Barnes,
Remember
When
Storybook
Photography
133 E. Branch
Street
Establishment of a
professional office in
the VCD district
A 07/24/2020
PPR 20-013 Jeff Dobbs,
Costal
Behavior
Consulting,
Inc.
518 Paulding
Circle
Establishment of a
professional office in
the VMU district
A 07/24/2020
11.COMMISSION COMMUNICATIONS
Vice Chair Schiro expressed appreciation for City staff members and local politicians of the area to
assist with businesses conducting business outdoors.
12.STAFF COMMUNICATIONS
Community Development Director McDonald thanked Vice Chair Schiro and informed the community
about the process for conducting business outdoors.
13.ADJOURNMENT
The meeting adjourned at 7:22 p.m.
ATTACHMENT 2
Item 11.a. - Page 32