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REPORT TO PLANNING COMMISSION
To: Honorable Chairman and Members of the Planning Commission
From: Justin Kirk, Assistant Community Development Director
Prepared by: Richard J. MacHott, Planning Manager
Date: June 2, 2020
Subject: Adoption of Vehicle Miles Traveled Thresholds for California
Environmental Quality Act Compliance
Recommendation
Receive Public Input and Provide Direction to Staff, if any.
Background
Senate Bill 743 (Steinberg) was signed into law by Governor Brown on September 27, 2013. This
legislation directed the Governor’s Office of Planning and Research (OPR) to develop alternative
metrics to replace the use of vehicular “Level of Service” (LOS) for evaluating transportation
impacts under the California Environmental Quality Act (CEQA).
Historically, Level of Service (LOS) has been used for the environmental review of transportation
impacts under CEQA. LOS focuses on the delay that vehicles experience at intersections and on
roadway segments. Traffic mitigation for increased delay usually involves increasing roadway
width, redesigning intersections by adding lanes or signalization. Although these mitigation
measures are intended to improve traffic flow, they also have the effect of potentially increasing
vehicle use and emissions and discouraging alternative forms of transportation.
SB 743 changes the focus of transportation analysis prepared for projects in accordance with
CEQA from LOS to “Vehicle Miles Traveled” or VMT. The VMT metric measures the amount and
distance people drive by motorized vehicle to a destination. Other relevant considerations include
the effects of the project on transit, bicycle and pedestrian modes, and the safety of all travelers.
The shift to VMT will align CEQA analysis more closely with other State goals, most particularly
greenhouse gas emission reduction goals. The shift is also intended to promote the development
of multimodal transportation networks (i.e., networks that serve a variety of users including
pedestrians, bicyclists, transit riders and drivers) and diversity of land uses.
All cities are required to switch to use VMT for CEQA analysis purposes by July 1, 2020.
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Discussion
Updated Traffic Impact Analysis Guidelines
To implement SB 743, the City determined appropriate VMT methodologies, thresholds, and
feasible mitigation measures. Since VMT is a new methodology to analyze transportation
impacts, there was a need to update the City’s Traffic Impact Analysis (TIA) Guidelines for projects
subject to environmental review. The revised guidelines are to ensure that all projects subject to
review by the City use the same data, approaches, and analytical tools. A copy of the revised TIA
Guidelines is attached to this report.
The TIA Guidelines incorporate VMT guidance consistent with the information from the WRCOG
SB 743 Implementation Pathway Study. The guidelines require the use of VMT analysis and
forecasting through the latest version of the Riverside County Travel Demand Model (RIVTAM)
or the RIVCOM model (once complete) to determine if proposed projects have a significant VMT
impact.
The traffic impacts of proposed developments will require two separate reports. One report, using
VMT analysis will be used for CEQA purposes in order to determine the significance of the
project’s traffic impacts, and to determine appropriate mitigation. The second report will use the
traditional LOS analysis to determine project impacts on transportation infrastructure and to
determine consistency with the General Plan. The LOS report will not be used for CEQA
purposes.
Proposed VMT Impact Thresholds
In order to implement SB 743, staff will be asking the City Council to adopt by resolution both the
methodology that will be used to measure a project’s VMT and its CEQA impacts, and the
threshold that will be used to determine whether those impacts are significant. Specifically, staff
will recommend that the City Council adopt the following at its June 23, 2020 meeting:
1. Utilizing the Riverside County Travel Demand Model (RIVTAM/RIVCOM) as its
methodology to measure VMT.
2. Utilizing the Riverside County Travel Demand Model (RIVTAM/RIVCOM) as its method to
analyze a project’s VMT impact.
3. Utilizing a threshold consistent with the City’s current average VMT per service population
(population plus employment).
As described in more detail in the TIA Guidelines, a project would result in a significant project-
generated VMT impact if either of the following conditions are satisfied:
1. The baseline project-generated VMT per service population exceeds the City’s baseline
VMT per service population, or
2. The cumulative project-generated VMT per service population exceeds the City’s baseline
VMT per service population.
The project’s effect on VMT would be considered significant if it resulted in either of the following
conditions to be satisfied:
1. The baseline link-level boundary VMT per service population (City boundary) to increase
under the plus project condition compared to the no project condition, or
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2. The cumulative link-level boundary VMT per service population (City boundary) to
increase under the plus project condition compared to the no project condition.
Please note that the cumulative no project shall reflect the adopted Regional Transportation
Plan/Sustainable Communities Strategy; as such, if a project is consistent with the regional
RTP/SCS, then the cumulative impacts shall be considered less than significant subject to
consideration of other substantial evidence.
Exhibits:
A. TIA Guidelines – May 2020