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HomeMy WebLinkAboutBaker_Webb_Response to Comments (VMT) Urban Planning ■ Due Diligence ■ Entitlements ■ CEQA/NEPA ■ Development Services ■ Management ■ Public Outreach 3333 Michaelson Drive, Suite 500 ■ Irvine, Calif. 92612 949.794.1180 ■ info@epdsolutions.com 12/06/2024 Paul Fizer, Senior Civil Engineer City of Lake Elsinore Kawai Mang, Project Engineer Albert A. Webb Associates RE: Planning Application No. 2020-103 – Baker Street – VMT Comments Dear Mr. Fizer and Ms. Mang, Below are responses to the CEQA Comments related to VMT dated November 25, 2024. 1. “We understand the City and CEQA team want to ensure that the project is eligible to screen out from VMT analysis by applying the low VMT criteria, including all sub criteria. The applicant or engineer should provide documentation showing that the project is consistent with underlying land use and modeling assumptions in the RIVCOM TAZ.” RESPONSE: The project’s potential impact to VMT was assessed utilizing the City of Lake Elsinore Transportation Study Guidelines, which state that projects located in a low VMT- generating area would be presumed to have a less than significant VMT impact and would be screened out from further VMT analysis. The project site has General Plan Land Use designations of Limited Industrial and Floodway. The Limited Industrial designated area is the portion of the site that is proposed to be developed. This Land Use designation provides “for industrial parks, warehouses, manufacturing, research and development, public and quasi-public uses, and similar and compatible uses” at a maximum Floor Area Ratio (FAR) of 0.45. The proposed project would include the construction and operation of two warehouses totaling 1,000,451 square feet on 65.81 acres, which would result in a FAR of 0.35. Therefore, the proposed project is consistent with the underlying land use assumptions. The City’s VMT Guidelines employ WRCOG travel forecasting model (RIVCOM) to measure VMT performance for individual traffic analysis zones (TAZs). The City of Lake Elsinore uses this WRCOG VMT Evaluation tool to determine whether a Project is located in a low VMT generating area, and if it would have a less than significant VMT impact. The RIVCOM TAZs are consistent with SCAG 2020 Regional Transportation Plan/Sustainable Communities Strategy (RTP/SCS) that is based on General Plan Land Use designations and data from local Baker St, Lake Elsinore 12/06/24 Submittal Response Letter Page 2 jurisdictions1, such as the City of Lake Elsinore. As the project is consistent with the General Plan land use, it would be consistent with both the RTP/SCS data and the modeling assumptions in the RIVCOM TAZ. Based on the WRCOG VMT tool, the proposed Project is located in a low VMT-generation area, as proposed the Project site’s VMT-generation is 31.3, which is 11.9% less than the City’s threshold (35.5). The project is in RIVCOM TAZ #962. The 2018 base model for TAZ #962 includes a population of 855 and employment of 8. The 2045 buildout model for TAZ #962 includes Population of 3,368 and Employment of 99, as listed below. The green areas delineated below are the TAZ boundaries, and the orange rectangle is the project site. As shown in the snip below, TAZ #962 is a large zone. The area south of the project site includes several residential projects that generate home based VMT and are included in the VMT of the TAZ. Overall, the project is consistent with underlying land use and modeling assumptions in the RIVCOM TAZ, which identify that the site is in a low VMT area; and would therefore, result in a less than significant VMT related impact. 1 https://scag.ca.gov/sites/main/files/file-attachments/mtf052621-rivcom.pdf?1621974436 TAZ Population Employment Enrollment 2018 962 855 8 0 2045 962 3368 99 0 Baker St, Lake Elsinore 12/06/24 Submittal Response Letter Page 3 2. “There is a question regarding the application of the VMT screen-out in consideration of air quality/greenhouse gas analysis results. Does the EIR or CEQA technical studies show a significant impact in GHG?” RESPONSE: Impacts related to air quality and greenhouse gas have separate and mutually exclusive thresholds that involve additional emission sources beyond those generated from VMT (such as construction, stationary sources, onsite mobile equipment, consumer products, landscaping, solid waste, water wastewater). The City of Lake Elsinore Transportation Study Guidelines do not identify air quality or greenhouse gas emission levels as criteria or thresholds related to VMT. As detailed in CEQA Guidelines Section 15064.3, subdivision (a), “For the purposes of this section, ‘vehicle miles traveled’ refers to the amount and distance of automobile travel attributable to a project.” Here, the term “automobile” refers to on-road passenger vehicles, specifically cars and light trucks; and heavy-duty truck trips are not included. In addition, CEQA Guidelines Section 15064.3, subdivision (b) provides criteria for analyzing VMT that involve project location in a transit area, proximity to destinations, and estimations of miles traveled, and do not include a comparison of project generated air quality or greenhouse gas emissions. Further, CEQA Guidelines Section 15064.3, subdivision (b)(4) states that “A lead agency has discretion to choose the most appropriate methodology to evaluate a project’s vehicle miles traveled, including whether to express the change in absolute terms, per capita, per household or in any other measure. A lead agency may use models to estimate a project’s vehicle miles traveled, and may revise those estimates to reflect professional judgment based on substantial evidence. As detailed previously, the City’s VMT methodology for determining if a project is within a low VMT generating area is based on RIVCOM modeling, which reflects professional judgment and substantial evidence. The VMT Screening Analysis prepared for the project is consistent with the City of Lake Elsinore Transportation Study Guidelines and was approved by the City. Therefore, no changes to the VMT analysis methodology or thresholds are warranted. Previously, a concern that was raised in relation to a recent case - Sacramento Investment without Displacement, Inc (Petitioner) v. Board of Regents of the University of California (Respondent). However, there was no case decision and the case was settled. The Settlement Agreement2 did not mention VMT nor GHG. Therefore, this case did not result in caselaw related to GHG emissions resulting in a VMT impact. The greenhouse gas emissions technical study is not yet finalized. However, due to the size of the project site (65.81 acres) and proposed development (that is within the allowable FAR), the Project is likely to exceed SCAQMD’s numerical thresholds. The EIR should include 2 https://sacramento.granicus.com/MetaViewer.php?view_id=22&clip_id=4942&meta_id=628404 Baker St, Lake Elsinore 12/06/24 Submittal Response Letter Page 4 an analysis of Project compliance with air quality and greenhouse gas related plans and policies. Respectfully submitted, Meghan Macias, TE EPD Solutions, Inc meghan@epdsolutions.com (949) 794-1186 Renee Escario EPD Solutions, Inc renee@epdsolutions.com (949) 981-3864