HomeMy WebLinkAboutItem 13 - CEQA Transportation Impact Thresholds UpdateItem 13
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Council- d. Report
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Department Name:
Cost Center:
For Agenda of:
Placement:
Estimated Time:
FROM: Matt Horn, Acting Public Works Director
Prepared By: Luke Schwartz, Transportation Manager
Public Works
5010
June 16, 2020
Public Hearing
20 Minutes
SUBJECT: PUBLIC HEARING - CEQA TRANSPORTATION IMPACT THRESHOLDS
UPDATE: TRANSITION FROM AUTO LEVEL OF SERVICE (LOS) TO
VEHICLE MILES TRAVELED (VMT)
RECOMMENDATION
1. Adopt a resolution (Attachment A) to replace Level of Service (LOS) with Vehicle Miles
Traveled (VMT) as the City's performance measure for CEQA analysis of transportation
impacts; and
2. Adopt a resolution (Attachment B) approving revisions to the City's Multimodal
Transportation Impact Study Guidelines.
REPORT -IN -BRIEF
California Senate Bill 743 (SB 743) was adopted in 2013 and changes the way that transportation
impacts will now be measured under the California Environmental Quality Act (CEQA). Under
SB 743, vehicle miles traveled (VMT) would replace level of service (LOS) or other measures of
vehicle congestion or delay as the primary metric for evaluation transportation impacts under
CEQA. The shift to VMT-based performance measures brings the CEQA process in line with
other State measures to promote the reduction of greenhouse gas emissions by encouraging land
use and transportation investments that reduce reliance on single -occupant vehicle travel,
develop multimodal transportation networks, provide a diversity of land uses, and incentivize
development in locations where residents, employees and visitors have more efficient access to
housing, jobs and destinations.
The California Governor's Office of Planning and Research (OPR) published final technical
guidelines for implementing SB 743 in December of 2018. These guidelines require that local
agencies begin implementing SB 743 by July 2020 but provide lead agencies with the discretion
to develop and adopt their own VMT thresholds or rely on thresholds recommended by OPR or
other regional agencies. City staff has monitored the development of SB 743 and technical
guidance provided by OPR. Based on this guidance, staff has utilized the City's Travel Demand
Model (SLO TDM) to develop recommended VMT thresholds for use in CEQA analysis of land
use and transportation projects located within the City. In turn, staff has updated the City
Multimodal Transportation Study Guidelines for consistency with the new analysis requirements
introduced in SB 743. The purpose of this report is to provide additional background discussion
regarding this transition, present the recommended VMT thresholds and updated Multimodal
Transportation Impact Study Guidelines for Council consideration and potential adoption.
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DISCUSSION
Background
In 2013, Governor Brown signed California Senate Bill (SB) 743 into law, which revolutionized
the way that transportation impacts will now be measured under the California Environmental
Quality Act (CEQA). Under SB 743, the California Office of Planning and Research (OPR) was
tasked with developing new guidelines for evaluating transportation impacts under CEQA using
methods that no longer focus on measures of automobile delay and congestion —historically
measured using a metric called auto level of service (LOS). Instead, alternate performance
measures were to be developed to promote the reduction of greenhouse gas emissions, the
development of multimodal transportation networks, and diversity of land uses. Since 2014, the
OPR has identified vehicle miles traveled (VMT) as the most appropriate metric to replace LOS
as the primary measure of transportation impacts. In December 2018, the State finalized updates
to the CEQA guidelines to reflect the transition from LOS to VMT and required lead agencies to
adopt and utilize a VMT-based performance measures for CEQA analysis by July 1, 2020.
The purpose of this report is to:
a) Provide more background on how VMT is measured and why VMT-based performance
measures are recommended for CEQA analysis.
b) Present recommended VMT-based thresholds of significance for Council consideration
and potential adoption for use in CEQA analysis of projects within the City of San Luis
Obispo.
c) Describe how the City will evaluate land use and transportation projects using VMT-
based metrics for CEQA analysis, and existing multi -modal LOS thresholds for General
Plan conformity analysis.
d) Present the City's updated Multimodal Transportation Impact Study Guidelines for
Council consideration and potential adoption.
LOS vs. VMT: Definitions, Benefits and Disadvantages
Benefits and Disadvantages of LOS
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 would typically support strategies that encourage roadway capacity
expansion to encourage faster automobile travel times, reduced congestion and delays for drivers
at peak travel times. A 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. Per the California OPR, other
problems with LOS as a primary measure of transportation impacts include:
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1. It inhibits infill development, punishing "last -in" development for localized congestion,
pushing development outward and further from key destinations and multimodal
transportation options.
2. It "solves" local congestion but exacerbates regional congestion.
3. It measures auto mobility, not access or person -mobility.
4. Often leads to more road widening and construction than local agencies can afford to build
and/or maintain.
5. Optimal LOS for motor vehicles often inhibits active transportation and transit modes.
LOS A LOS F
While the disadvantages of using auto LOS as the sole metric for transportation impact analysis
are well -documented, LOS can be a useful informational tool for guiding transportation system
planning decisions and access management designs. For example, there is value in using LOS to
evaluate when a stop -controlled intersection should be upgraded to a traffic signal or roundabout,
for communicating projected levels of congestion to community members, and for evaluating
whether queuing may spill back from a turn pocket and increase potential for rear -end collisions.
Benefits and Disadvantages of VMT
VMT is a measurement of the amount of travel for all vehicles in a defined area, such as within
the city or county boundaries. It represents the total number of vehicle trips multiplied by the
total distance each vehicle travels. 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 emissions. Many agencies are already familiar with
accounting for VMT in connection with long-range planning or as part of CEQA analysis for
evaluation of greenhouse gas emissions or energy impacts. VMT is typically calculated using a
local or regional travel demand forecasting model.
Key benefits of utilizing VMT as a primary metric for analyzing transportation impacts includes:
1. It removes a key barrier to infill and transit -oriented development.
2. It incentivizes development and investment in areas with greater access to existing jobs,
services and transportation infrastructure. Incentivizes projects that positively affect existing
housing jobs imbalances.
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3. VMT-based analysis and mitigation strategies typically lead to less roadway expansion and
widening, reducing infrastructure capital and maintenance costs for local agencies.
4. More effectively assesses contributions to regional congestion.
5. Encourages projects that improve access to active transportation and transit.
6. Supports overarching Statewide initiative to reduce greenhouse gas emissions, which helps
combat climate change, while reducing impacts to air quality and community health.
The primary disadvantages of VMT-based analyses are that (a) they may not provide all of the
information desired by local officials for local system planning and operations, and (b) VMT-
based performance measures may be more difficult to communicate to community members and
decision -makers. For example, project -level VMT analysis for a particular land use proposal may
indicate a net reduction to VMT per capita, but that information alone may not indicate when a
traffic signal needs to be installed for local access, or when increasing roadway congestion
warrants other system improvements to retain transit system performance. A local resident may
be able to comprehend what a change from auto LOS A to LOS F looks like from a driver's
perspective, where it is much more difficult to explain how an increase/decrease in VMT would
be perceived to a typical road user. While local agencies are required to adopt and utilize a VMT
threshold for CEQA transportation analysis by July 1, 2020, they may still require LOS analysis
for local -level planning and/or general plan compliance purposes.
Recommended VMT Impact Thresholds — Development Projects
OPR Guidance
In December 2018, the California OPR released its Technical Advisory on Evaluating
Transportation Impacts in CEQA. This document is provided for reference in the attachments.
OPR's Technical Advisory recommended the following thresholds of significance for land use
projects:
Table 1: OPR Guidance on Setting VMT Thresholds for Development Proiects
Project .
OPR Recommended
Residential
(VMT per capita) - Project VMT that exceeds a level 15% below the existing VMT per
capita may indicate a significant transportation impact. Existing VMT per capita may be
measured as regional or as city VMT per capita.
Office
(VMT per employee) - Project VMT that exceeds a level 15% below the existing
regional VMT per employee may indicate a significant transportation impact.
Retail
(Net VMT) - A net increase in total area VMT may indicate a significant transportation
impact. Because local -serving retail development tends to shorten trips and reduce
VMT, lead agencies generally may presume such development creates a less -than -
significant transportation impact. Regional -serving retail development may lead to
substitution of shorter trips for longer ones, which may create a significant impact.
Where such development is found to decrease total are VMT, lead agencies should
consider the impact to be less -than -significant.
Mixed -Use
Local agencies should evaluate each component of a mixed -use project independently
and apply the above significance threshold for each land use type included.
Alternatively, a lead agency may consider only the project's dominant use.
Other
Lead agencies may apply adopted residential, office or retail VMT thresholds to other
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Development development projects that have predominant operating characteristics similar to those
Projects uses. Alternately, lead agencies may use more location -specific information to develop
specific thresholds for other land use types. In doing so, lead agencies should consider
the information described in the CEQA Guidelines (Section 15064.7) on the
development of thresholds of significance.
Recommended City Thresholds
Per OPR guidance, models and methodologies used to develop VMT thresholds and conduct
project -level VMT analysis should be consistent (i.e. the same tool used to calculate VMT
thresholds should be used to calculate project -level VMT). The City of San Luis Obispo Travel
Demand Model (SLO TDM) is the preferred tool for developing project -level traffic volume and
VMT projections within the City, as the SLO TDM includes more refined land use data and a
more sophisticated multimodal network than other available tools, such as the SLOCOG
Regional Travel Demand Model (RTDM). For this reason, the SLO TDM was used to develop
VMT-based thresholds of significance for analysis of CEQA projects located within the City.
With technical support from two of the City's on -call traffic engineering consultants, GHD and
Cambridge Systematics, City staff used the SLO TDM to extract existing (base year model is
calibrated to Year 2016) VMT data for Residential and Office land uses. See Attachment D
(Baseline VMT Methodology & Estimation Memorandum, GHD) for greater detail regarding the
methodology used in extracting model VMT data and developing recommended thresholds.
Figure 1 below illustrates the existing baseline (2016) Daily VMT averages for both the citywide
and regional (county) averages.
20.00
17.98
v
18.00 16.76
16.00 14.65
0
a 14.00
E
12.00
Q 10.00 8.51
8.00
Q 6.00
4.00
2.00
0.00
Residential (Daily VMT/capita) Office (Daily VMT/employee)
■ City Average ■ Regional (County) Average
Figure 1: Existing (2016) Residential and Office VMT
As shown in Figure 1, the SLO TDM data indicates that average existing Residential VMT per
capita for land uses within the City is roughly 50% lower than average regional (County)
Residential VMT per capita. Meanwhile, average existing Office, or work based VMT, per
employee for land uses within the City is similar to the regional (Countywide) average.
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This relationship is as expected and consistent with an overall jobs -to -housing imbalance within
the City, where work -based land uses within the City draw longer commute trips from
throughout the County, while residential trips generated within the City are generally captured
within and around the City.
Based on OPR's Technical Advisory and existing baseline VMT data extracted from the SLO
TDM, staff has developed the following VMT thresholds for analysis of development projects
within the City:
Table 2: City Recommended VMT Thresholds
Project p•
Evaluation Criteria
Threshold
Residential
15% below baseline regional (County) average Residential
14.25 VMT per capita
VMT per capita. Applies to single-family, multi -family and
mobile homes
Office / Business
15% below existing regional (County) average Work VMT
12.45 VMT per employee
Park / Industrial
per employee.
/ Warehousing /
Manufacturing
Retail /
Net increase in total regional (County) VMT. Small local-
No set threshold, increase in
Hotel /
serving retail may be presumed to cause less -than-
total VMT would trigger
School
significant impacts. Larger, regional -serving retail will
impact
require quantitative analysis using the SLO TDM and
project -specific information, such as market studies or
analysis of anticipated customer travel behavior.
Mixed -Use
Evaluate each component of a mixed -use project
Apply Residential, Office &
independently, applying significance threshold for each
Retail Thresholds above
land use type. Alternately, the City may choose to analyze
VMT for only the dominant use. Analysis should take
credit for internal capture between uses.
Redevelopment
Where a development replaces an existing VMT-generation
No set threshold
Projects
land use, if the replacement total VMT leads to a net
overall decrease in VMT, the project is assumed to have a
less -than -significant impact. If net new VMT exceeds the
existing land use, apply the thresholds described above.
Other
City may apply adopted residential, office or retail VMT
No set threshold. Evaluated
Development
thresholds to other development projects that have
on case -by -case basis based
Projects
predominant operating characteristics similar to those uses.
on OPR guidance
Alternately, City may use more location -specific
information to develop specific thresholds for other land
use types. In doing so, analysis should consider the
information described in the CEQA Guidelines (Section
15064.7) on the development of thresholds of significance.
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As shown in Table 2, the recommended VMT thresholds for Residential and Office/Work-based
uses are based on the Regional (County) baseline VMT minus 15%. While the OPR guidance
provides lead agencies the discretion to set thresholds based on existing Q1Y or Regional
Count VMT per capita/employee, the guidance generally recommends using the regional
average for setting thresholds, especially where local VMT is inherently low. One of the primary
objectives of SB 743 is to incentivize development —particularly new housing —to occur in job -
rich areas where VMT is already low due to land use patterns and access to transportation
options. OPR suggests that lead agencies take a regional viewpoint when establishing VMT
thresholds, avoiding overly -stringent targets in travel -efficient locations, such as the City of San
Luis Obispo, which may encourage development to shift to less travel -efficient locations
elsewhere in the County.
Recommended VMT Impact Thresholds — Transportation Projects
Per the OPR Technical Advisory, transportation projects that are expected to reduce or have no
impact on VMT should be presumed to have a less -than -significant transportation impact. Such
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. Projects that
fall within these categories will not require a quantitative VMT analysis.
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, OPR recommends that lead agencies require quantitative analysis to calculate the amount
of additional vehicle travel anticipated, but have the discretion to determine the appropriate
thresholds of significance on a case -by -case basis consistent with CEQA Guidelines and
applicable technical guidance. For transportation projects that have already been evaluated for
VMT at a programmatic level, such as within a General Plan or Specific Plan, a lead agency may
tier from that analysis. For transportation projects located within the City that are anticipated to
increase vehicle travel, staff is recommending that VMT thresholds of significance be evaluated
on a case -by -case basis, while ensuring that the analysis addresses:
• Direct, indirect and cumulative effects of the transportation project, including potential
for induced demand (CEQA Guidelines, § 15064, subds. (d), (h))
• Near -term and long-term effects of the transportation project (CEQA Guidelines, §§
15063, subd. (a)(1), 15126.2, subd. (a))
• The transportation project's consistency with state greenhouse gas reduction goals (Pub.
Resources Code, § 21099)34
• The impact of the transportation project on the development of multimodal transportation
networks (Pub. Resources Code, § 21099)
• The impact of the transportation project on the development of a diversity of land uses
(Pub. Resources Code, § 21099)
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VMT Screening Thresholds for Project Exemptions
Per OPR guidance, lead agencies may use screening thresholds to quickly identify when a
project can be assumed to result in a less -than -significant transportation impact without requiring
a detailed analysis. Based on OPR guidance, staff is recommending the following screening
criteria for project exemptions from focused VMT analysis as summarized in Table 3. Detailed
quantitative VMT analysis would be required for projects that do not meet these screening
criteria.
Table 3: City Recommended VMT Screening Criteria for Proiect Exemptions
Project p.
OPR Recommended
Small
Projects anticipated to generate less than 110 daily vehicle trips may be assumed to cause a
Development
less -than -significant impact, unless substantial evidence indicates that a project would
Projects
generate a potentially significant level of VMT or create inconsistency with the SLOCOG
Sustainable Communities Strategy (SCS).
Residential &
Map -based screening may be used for projects that generate less than 100 peak hour vehicle
Office/Work
trips. Baseline VMT per capita/employee heat maps are developed based on data from the
Development
SLO TDM, showing average VMT for residential and office/work-based on existing uses
Projects'
within the City. Where proposed projects that generate less than 100 peak hour trips are
located within areas of the map with existing VMT at least 10% below adopted thresholds,
and are generally similar to existing uses within that area (i.e. density, mix of uses, access to
multimodal transportation), these projects can be assumed to cause a less -than -significant
transportation impacts.
Local Serving
Retail development projects with less than or equal to 50,000 square feet of gross floor area
Retail &
with reasonable justification that uses will be local -serving may be assumed to cause a less -
Public
than -significant impact.
Facilities
Similarly, local -serving public facilities, such as Police and Fire Stations, libraries,
neighborhood parks without sporting fields, etc., may be assumed to cause a less -than -
significant impact.
Affordable
Adding affordable housing to infill locations generally improves jobs -housing balance, in
Housing
turn shortening commutes and reducing VMT. A project consisting of a high percentage of
affordable housing (greater than 50%) may be assumed to cause a less -than -significant
impact on VMT if located within a low-VMT area per the City's VMT screening maps'.
Other affordable housing projects, or mixed -use projects with affordable housing
components may be screened from detailed VMT analysis if supporting evidence is
provided demonstrating low VMT-generating characteristics of similar affordable housing
sites within the City.
Transit-
Per CEQA Guidelines, residential, retail, office and mixed -use projects that are located
Oriented
within a '/2 mile of an existing major transit stop or an existing stop along a high -quality
Development2
transit corridor may be assumed to cause a less -than -significant impact on VMT (see Note 2
below). If project -specific or location -specific information indicates that the project would
still generate significant levels of VMT, focused VMT analysis may still be required. No
locations within the City of San Luis Obispo currently meet these transit service levels.
Notes:
1. See Attachment C for Draft VMT Screening Maps.
2. Per California Public Resources Code, a "major transit stop" is legally defined as a site containing an existing rail
station, a ferry terminal serviced by bus or rail transit, or the intersection of two or more major bus routes with a
frequency of 15 minutes or less during commute periods. A "high -quality transit corridor" refers to a corridor with
fixed -route bus service with frequencies of 1 minutes or less during peak commute hours.
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VMT Mitigation Strategies
The new CEQA Guidelines and OPR guidance identifies a series of potential mitigation
measures to address project -related VMT impacts. The list includes, but is not limited to:
• Development of a Transportation Demand Management Program (TDM).
• Improve or increase access to transit.
• Incorporate a mix of land uses to increase access to common goods and services, such as
groceries, neighborhood retail, schools and childcare services.
• Locate project in lower-VMT area of the City.
• Improve or increase access to active transportation facilities.
• 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.
• Participate in an in -lieu fee program to fund City-wide improvements to sustainable
transportation modes.
LOS as a Local -Level Metric
As stated previously, 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 general plan conformity. Staff recommends that the City
continue to apply multimodal (auto, bike, pedestrian, transit) LOS analysis thresholds, as
established in the General Plan Circulation Element, for project -level analysis for general plan
consistency only. Project -level LOS analysis would be required consistent with the City's
Multimodal Transportation Impact Study Guidelines, which require focused traffic analysis for
development projects that are anticipated to generate over 100 peak hour trips or where location -
specific considerations or operational concerns warrant detailed analysis.
By retaining LOS for non-CEQA analysis, future developments would continue to demonstrate
that they do not create traffic demands or conditions that are inconsistent with the multimodal
performance thresholds established in the Circulation Element. In turn, the City Council would
continue to have additional flexibility and discretion to make findings, approve or deny projects
based on general plan LOS requirements. Similarly, OPR recommends that project -level safety
concerns be address at a programmatic level outside of project -specific CEQA analysis. Staff
recommends that project -level safety analysis, including evaluation of intersection queuing and
access management, continue to be evaluated along with multimodal LOS as part of a local
general plan conformity assessment.
Updates to the City's Multimodal Transportation Impact Study Guidelines
The Transportation Division is responsible for maintaining the City's Multimodal Transportation
Impact Study (MMTIS) Guidelines. These guidelines set forth required tools and methodologies
for transportation analysis of land use and transportation projects proposed within the City.
These standards are updated regularly for consistency with CEQA guidelines, State
requirements, and industry best practices for conducting analysis of transportation impacts. The
current edition of the City's MMTIS Guidelines was developed in 2015, following adoption of
the City's General Plan Circulation Element. In order to provide consistency with CEQA updates
per SB 743, and to improve efficiency and effectiveness for practitioners in using these
guidelines, the MMTIS Guidelines have been updated as follows:
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• Added discussion on analysis methodology, thresholds of significance, and mitigation
strategies for CEQA analysis of VMT impacts.
• Added discussion on what analysis elements are required for CEQA vs. which elements
are required for local general plan conformity only.
• Allows the use of Bicycle Level of Traffic Stress as an acceptable methodology for
analyzing bicycle impacts on roadway segments, if approved by the Transportation
Division on a case -by -case basis.
• Allows the use of a streamlined analysis methodology for evaluating potential transit
impacts using existing load factors and projected ridership demand in lieu of more
calculation -intensive transit LOS calculations, if approved by the Transportation Division
on a case -by -case basis.
• Additional discussion regarding consideration of contextual significance when evaluating
vehicle queuing impacts and impacts to unsignalized intersections.
A copy of the updated MMTIS Guidelines is provided for reference in Attachment C, which
includes a resolution adopting the updated Guidelines and granting authority to the
Transportation Manager to approve future administrative/ministerial revisions to this document.
A current copy of the MMTIS Guidelines will continue to be published on the City's website.
Policy Context
While the approval of SB 743 is the primary catalyst driving the conversion to VMT as the
primary metric for transportation impact analysis under CEQA, there are several goals and
policies established within existing City planning documents that support the common objective
to reduce greenhouse gas emissions and motor vehicle travel. For example, the General Plan
Land Use and Circulation Elements (adopted 2014) include specific goals and objectives to
reduce community reliance on single -occupant motor vehicle use by supporting and promoting
alternatives such as walking, riding buses and bicycles, and using carpools. These policies also
encourage infill development and other land use strategies that reduce regional VMT by mixing
land uses and incentivizing growth in locations that provides more efficient access to housing,
jobs and services. Similarly, the City's currently adopted Climate Action Plan (2012) identifies
several recommended policies and strategies to support reductions in citywide VMT. The Plan
acknowledges that transportation and land use are the most significant contributors to current
City greenhouse gas emissions; thus, actions that directly reduce Citywide VMT represent some
of the most effective methods that the City can utilize to reduce local greenhouse gas production.
Public Engagement
Consistent with the City's Public Engagement and Noticing (PEN) Manual and the City's
Municipal Code, this report was made public one week prior to this Council Hearing date, and
this item was noticed via legal advertisements posted in the San Luis Obispo New Times 10 days
prior to this City Council hearing.
CONCURRENCE
The City Attorney's office, Public Works and Community Development Departments concur
with the recommendations contained within this report.
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ENVIRONMENTAL REVIEW
The proposed adoption of new Transportation Performance Measures and Thresholds of
Significance for CEQA is not a "project' pursuant to the California Environmental Quality Act
(CEQA) as defined in State CEQA Guidelines Section 15378 and is, therefore, exempt from
CEQA pursuant to CEQA Guidelines Section 15060 (c)(3). Instead, they are proposed thresholds
of significance published pursuant to CEQA Guidelines Section 15064.7. That Section provides:
a. Each public agency is encouraged to develop and publish thresholds of significance that the
agency uses in the determination of the significance of environmental effects. A threshold of
significance is 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.
b. Thresholds of significance to be adopted for general use as part of the lead agency's
environmental review process must be adopted by ordinance, resolution, rule, or regulation,
and developed through a public review process and be supported by substantial evidence.
c. When adopting thresholds of significance, a lead agency may consider thresholds of
significance previously adopted or recommended by other public agencies or recommended
by experts, provided the decision of the lead agency to adopt such thresholds is supported by
substantial evidence."
Section 15064.7(b) of the CEQA Guidelines provides that thresholds of significance must be
formally adopted through a public review process and supported by substantial evidence if, as in
this case, they are to be placed in general use. There is no requirement in CEQA that any other
environmental review is prerequisite prior to adopting a threshold. The reason for this is that the
preparation of an EIR or other CEQA document would largely duplicate the extensive public
review process set forth above, and the "substantial evidence" standard set forth in Section
15064.7.
FISCAL IMPACT
Budgeted: No Budget Year: N/A
Funding Identified: No
Fiscal Analysis:
Funding Sources
Current FY Cost
Annualized
On -going Cost
Total Project
Cost
General Fund
N/A
State
Federal
Fees
Other:
Total
There is no direct fiscal impact associated with this action.
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ALTERNATIVES
1. The City Council could make changes to the proposed recommendations. Council could
direct staff to modify the proposed recommendations, which could include consideration of
alternate thresholds of significance for CEQA VMT analysis or additional updates to the
City's Multimodal Transportation Impact Analysis Study Guidelines.
2. Continue approval of proposed recommendations to a future date. Council could direct
staff to conduct additional research and/or provide additional details regarding the
recommendations and continue Council action on this item to a future meeting date.
3. Decline to adopt proposed recommendations. Council could direct staff to halt efforts to
update the City's policies on analysis of transportation impacts under CEQA.
The State has established a deadline requiring local agencies to update transportation impact
analysis policies and procedures consistent with SB 743 prior to July 1, 2020. Each of the
abovementioned alternatives could result in potential delays, making it difficult for the City to
meet the State's established deadline. For this reason, these alternatives are not recommended by
staff.
Attachments:
a - Draft Resolution - Revised Thresholds for Analysis of Transportation Impacts
b - Draft Resolution - Adopting Updated TIS Guidelines
c - COUNCIL READING FILE - Multimodal Transportation Impact Study Guidelines
(June 2020)
d - Technical Memo Baseline VMT Methodology & Estimation (GHD)
e - California OPR: Technical Advisory on Evaluating Transportation Impacts in CEQA
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RESOLUTION NO. (2020 SERIES)
A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF SAN LUIS
OBISPO, CALIFORNIA, ADOPTING REVISED THRESHOLDS OF
SIGNIFICANCE FOR ANALYSIS OF TRANSPORTATION IMPACTS
UNDER THE CALIFORNIA ENVIRONMENTAL QUALITY ACT
PURSUANT TO SENATE BILL 743
WHEREAS, the Governor Edmund G. Brown signed Senate Bill (SB) 743 in 2013, and
directed the Office of Planning and Research (OPR) to develop updated criteria for measuring
transportation impacts using alternative metrics that promote a reduction in greenhouse gases, the
development of multimodal transportation networks, and a diversity of land uses; and
WHEREAS, in December 2018, the California Natural Resources Agency certified and
adopted updates to the California Environmental Quality Act (CEQA) per SB 743, establishing
Vehicle Miles Traveled (VMT) as the preferred performance measure for analysis of transportation
impacts under CEQA; and
WHEREAS, in December 2018, the California Governor's Office of Planning and
Research (OPR) published a Technical Advisory on Evaluating Transportation Impacts under
CEQA, which contains OPR's technical recommendations regarding assessment of VMT,
thresholds of significance, and mitigation measures; and
WHEREAS, CEQA Guidelines Section 15064.7(b) allows lead agencies to adopt
thresholds of significance for the lead agency's general use in its environmental review process;
and
WHEREAS, the City of San Luis Obispo Transportation Division and Community
Development Department have prepared proposed Transportation Thresholds of Significance,
pursuant to SB 743 and CEQA Guidelines Section 15064.3, for the City Council's consideration
and adoption; and
WHEREAS, the proposed Transportation Thresholds of Significance are consistent with
updated CEQA Guidelines and the recommendations presented in OPR's Technical Advisory on
Evaluating Transportation Impacts under CEQA; and
WHEREAS, the proposed Transportation Thresholds of Significance are consistent with
the goals presented in the City's General Plan Circulation Element that emphasize the reduction
of greenhouse gas emissions and reliance on motor vehicle travel, development of multimodal
transportation systems, and diversity of land uses; and
WHEREAS, the City Council held a duly noticed meeting on the proposed Transportation
Thresholds of Significance for analysis of transportation impacts under CEQA on June 16, 2020.
NOW, THEREFORE, BE IT RESOLVED by the Council of the City of San Luis Obispo
as follows:
Packet Page 255
Item 13
Resolution No. (2020 Series) Page 2
SECTION 1. The proposed Transportation Thresholds of Significance based on Vehicle
Miles Traveled (VMT), attached hereto as Attachment A and incorporated herein by this reference,
are hereby approved as the City's thresholds of significance for evaluating transportation -related
environmental impacts pursuant to CEQA, replacing all existing City transportation thresholds of
significance for CEQA analysis based on auto level of service (LOS) or other measures of vehicle
congestion or delay.
SECTION 2. The Transportation Division, in consultation with the Director of
Community Development, is authorized to update the adopted Thresholds of Significance for land
use and transportation projects as necessary and appropriate, provided any update is consistent
with the intent of Senate Bill 743 and in compliance with procedural and substantive requirements
of CEQA and all other applicable state and local laws.
SECTION 3. The Transportation Division is directed to update the City's Multimodal
Transportation Impact Study Guidelines within sixty days herefrom, to provide consistency with
the proposed Transportation Thresholds of Significance and pursuant to revised CEQA Guidelines
and technical guidance published by the OPR.
Packet Page 256
Resolution No. (2020 Series)
Item 13
Page 3
SECTION 4. Environmental Review. The proposed adoption of new Transportation
Thresholds of Significance for CEQA is not a "project' pursuant to the California Environmental
Quality Act (CEQA) as defined in State CEQA Guidelines Section 15378 and is, therefore, is
exempt from CEQA pursuant to CEQA Guidelines Section 15060 (c)(3).
Upon motion of , seconded by
and on the following roll call vote:
AYES:
NOES:
ABSENT:
The foregoing resolution was adopted this day of
Mayor Heidi Harmon
ATTEST:
Teresa Purrington
City Clerk
APPROVED AS TO FORM:
J. Christine Dietrick
City Attorney
2020.
IN WITNESS WHEREOF, I have hereunto set my hand and affixed the official seal of the City
of San Luis Obispo, California, on
Teresa Purrington
City Clerk
Packet Page 257
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Attachment A
City of San Luis Obispo
Vehicle Miles Traveled (VMT) Thresholds of Significance for CEQA Analysis
Project Type
Evaluation Criteria
Threshold
Residential
15% below baseline regional (County) average
14.25 VMT per capita
Residential VMT per capita. Applies to single-
family, multi -family and mobile homes
Office /
15% below existing regional (County) average
12.45 VMT per employee
Business Park /
work VMT per employee.
Industrial /
Warehousing /
Manufacturing
Retail /
Net increase in total regional (County) VMT.
No set threshold, increase in total
Hotel /
Small local -serving retail may be presumed to
VMT would trigger impact
School
cause less -than -significant impacts. Larger,
regional -serving retail will require quantitative
analysis using the SLO TDM and project -
specific information, such as market studies or
analysis of anticipated customer travel behavior.
Mixed -Use
Evaluate each component of a mixed -use project
Apply Residential, Office & Retail
independently, applying significance threshold
Thresholds above
for each land use type. Alternately, the City may
choose to analyze VMT for only the dominant
use. Analysis should take credit for internal
capture between uses.
Redevelopment
where a development replaces an existing
No set threshold
Projects
VMT-generation land use, if the replacement
total VMT leads to a net overall decrease in
VMT, the project is assumed to have a less -than -
significant impact. If net new VMT exceeds the
existing land use, apply the thresholds described
above.
Other
City may apply adopted residential, office or
No set threshold. Evaluated on case -
Development
retail VMT thresholds to other development
by -case basis based on OPR guidance
Projects
projects that have predominant operating
characteristics similar to those uses. Alternately,
City may use more location -specific information
to develop specific thresholds for other land use
types. In doing so, analysis should consider the
information described in the CEQA Guidelines
(Section 15064.7) on the development of
thresholds of significance.
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Transportation Where a transportation project involves
Projects improvements that may result in a measurable
and substantial increase in vehicle travel, such as
the addition of through lanes on existing or new
highways and arterial streets, the estimated
change in VMT should be quantified to evaluate
potential for induced traffic demand. No
standard significance thresholds have been
adopted for induced traffic analysis; thus, the
City shall evaluate potential impacts on a case -
by -case basis consistent with CEQA Guidelines
and applicable technical guidance while
ensuring that the analysis addresses:
• Direct, indirect and cumulative effects of the
transportation project, including potential
for induced demand (CEQA Guidelines, §
15064, subds. (d), (h))
• Near -term and long-term effects of the
transportation project (CEQA Guidelines,
§§ 15063, subd. (a)(1), 15126.2, subd. (a))
• The transportation project's consistency
with state greenhouse gas reduction goals
(Pub. Resources Code, § 21099)34
• The impact of the transportation project on
the development of multimodal
transportation networks (Pub. Resources
Code, § 21099)
• The impact of the transportation project on
the development of a diversity of land uses
(Pub. Resources Code, § 21099)
No set threshold. Evaluated on case -
by -case basis based on OPR guidance
Packet Page 259
Item 13
RESOLUTION NO. (2020 SERIES)
A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF SAN LUIS
OBISPO, CALIFORNIA, APPROVING REVISED MULTIMODAL
TRANSPORTATION IMPACT STUDY GUIDELINES
WHEREAS, the Transportation Division is responsible for maintaining Multimodal
Transportation Impact Study Guidelines establishing analysis tools, methods and procedures for
preparation of transportation impact studies; and
WHEREAS, the Multimodal Transportation Impact Study Guidelines are necessary for
consistent application of City standards, policies and practices for transportation analysis of land
development and transportation projects; and
WHEREAS, the current edition of the City's Multimodal Transportation Impact Study
Guidelines, last updated March 2015, is no longer consistent with the transportation performance
measures and methodologies required for analysis of transportation impacts under the California
Environmental Quality Act (CEQA) as modified with adoption of Senate Bill (SB) 743; and
WHEREAS, the Multimodal Transportation Impact Study Guidelines must be periodically
updated to account for changes in regulatory policy and industry best practices for analysis of
transportation impacts for CEQA and local transportation system planning; and
WHEREAS, the Multimodal Transportation Impact Study Guidelines have been revised
to be consistent with the amendments to CEQA Guidelines prescribed in SB 743; and
WHEREAS, the City Council held a duly noticed meeting on the proposed revisions to
the Multimodal Transportation Impact Study Guidelines on June 16, 2020.
NOW, THEREFORE, BE IT RESOLVED by the Council of the City of San Luis Obispo
as follows:
SECTION 1. The City of San Luis Obispo Multimodal Transportation Impact Study
Guidelines, dated and effective June 2020, copies of which are on file at the Office of the City
Clerk, are hereby approved.
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Item 13
Resolution No. (2020 Series) Page 2
SECTION 2. The Transportation Manager is authorized to approve future administrative
revisions to the Multimodal Transportation Impact Study Guidelines so long as the policy
framework contained in the guidelines remains consistent with the June 2020 edition approved by
the City Council and any such revisions are documented in writing and provided to the City Clerk
to be maintained with this Resolution in a manner that reflects the scope of changes made.
Upon motion of , seconded by
and on the following roll call vote:
AYES:
NOES:
ABSENT:
The foregoing resolution was adopted this day of
Mayor Heidi Harmon
ATTEST:
Teresa Purrington
City Clerk
APPROVED AS TO FORM:
J. Christine Dietrick
City Attorney
2020.
IN WITNESS WHEREOF, I have hereunto set my hand and affixed the official seal of the City
of San Luis Obispo, California, on
Teresa Purrington
City Clerk
Packet Page 261
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May 31, 2020
To: City of San Luis Obispo Project: City CEQA Transportation Impact
Thresholds
From: Jake Hudson, Senior Transportation Ref/Job No.: 11211936
Planner/Engineer GHD
CC: File No.: 11211936-MEM001.DOCX
Subject: Baseline VMT Methodology & Estimation
1. Introduction
The City has contracted GHD and Cambridge Systematics, to provide staff support in the development of
procedures for assessing transportation impacts under CEQA, per SB 743 and in updating of the City's
Multimodal Transportation Impact Study Guidelines. GHD in developed baseline VMT estimates based on
the City and County geographies using both the City travel demand model as well as the SLOCOG travel
demand model. These baselines are provided with recommendations for City consideration in adopting its
VMT thresholds. The next phase of this work, update of the City's Multimodal Transportation Impact Study
Guidelines will include evaluation and recommendations for project screening criteria, thresholds of
significance, and methodologies for evaluating land development and transportation infrastructure using
VMT as the primary impact criterion.
The purpose of this memorandum is to review guidance, options, resources, and analytical methodologies
for evaluating project VMT in the City of San Luis Obispo that can be used to establish baseline VMT. The
literature 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 SLOCOG Transition from LOS to VMT Staff
Report (October 2019).
The data sources and technical review includes the City of San Luis Obispo Travel Demand Model (SLO
TDM), 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. This technical memorandum summarizes the results of the VMT analysis and provides GHD's
recommendations for the City's baseline VMT and thresholds of significance.
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,
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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.
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.
VMT unlike LOS measures overall regional travel trends and does not report project effects on local
operations and specific facilities. This has raised questions and concerns about transparency and disclosure
regarding what effects a project may have on specific intersections and segments for all modes of traffic.
SB743 does not preclude agencies from maintaining level of service as a local policy outside of CEQA to
address this if an agency determines it's necessary or for the purposes as maintaining the basis for its
Impact Fee Programs to ensure that new development is paying for the infrastructure necessary to support
it. Most agencies in the region that are in the process of adopting their VMT thresholds are also maintain
level of service as local policy, impacts would instead be classified as policy inconsistencies and mitigations
would instead be applied as conditions of approval, giving agencies significantly more flexibility in how those
standards are applied and protection from CEQA challenges. GHD recommends that the City of San Luis
Obispo retain Multimodal Level of Service as a policy threshold outside of CEQA.
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 than 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.
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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 (per CEQA).
- Map -based screening for residential and office projects located in low VMT areas, and incorporate
similar features (density, mix of uses, transit accessibility).
- Certain projects within '/z 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.
- Affordable Housing Development in infill locations.
- Locally -serving retail projects, typically less than 50,000 square feet.
GHD recommends that these Screening Criteria be further assessed and validated for the City of San Luis
Obispo prior to adoption. For example, the presumption that low-income housing generates fewer trip is
based on a state wide housing study that found low income housing generates lower trips because they are
occupied by a higher proportion of non -workforce individuals. These conditions should be validated for the
City before establishing this as a screening threshold.
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:
' "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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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 County.
2.3 October 2"d, 2019 SLOCOG Transition from LOS to VMT Staff Report
In October of 2019 SLOCOG reported Countywide VMT as well as VMT for incorporated areas. The VMT
results produced were boundary based. OPR has since emphasized the need to measure VMT as a function
of the entire trip which is different than methodology originally reported by SLOCOG. These results have
been updated as part of the County's efforts for establishing their VMT threshold and are expected to be
refined as part of the multi -county model currently in development by SLOCOG.
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 San Luis Obispo 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.
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.
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
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measuring stick that all future projects will be measured against, until baselines are updated. GHD
recommends updating the baseline VMT estimates concurrent with updates the model or tool used to
evaluate projects.
4.1 SLO City Travel Demand Model
The local SLO City Travel Demand model includes the entire County of San Luis Obispo within its
boundaries, however unlike the SLOCOG model the City model aggregates zones outside the City SOI into
larger "super zones" that reflect incorporated areas and geographies of unincorporated areas that have
similar land use and trip generation characteristics. The SLO City model was utilized to estimate trip -based
Residential and Work Baseline VMT for both the City and the entire County. The recently updated model
(updated May 2020) has a base year of 2016 and a forecast year of 2040. The base year 2016 model was
utilized to estimate baseline VMT utilizing the updated land uses. The City Travel Demand model produces
trips by different trip purposes and modes, and outputs VMT throughout the City and 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 4.3T'"�T and Table 4.4T'h�2 present the trip purposes used for
Residential and Work VMT evaluations, respectively.
Table 4.1 Selected Trip Purposes for Residential VMT
HBW
Home based work
HBS
Home based shop
HBK
Home based K-123
HBC
Home based college
HBO
Home based other
WBO
Work based other
OBO
Other based other
EE
External to external
TS
Light duty truck
TM
Medium duty truck
TH
Heavy duty truck
USED
USED
USED
x
x x
USED
USED
USED
x
x x
USED
USED
USED
x
x x
USED
USED
USED
x
x x
USED
USED
USED
x
x x
x
x
x
x
x x
x
x
x
x
x x
x
x
x
x
x x
2 HBx refers to any "Home based" trip, including work, shop, K-12, college, and other.
3 HBK trips are included as part of HBO trips in the City Travel Model.
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Table 4.2 Selected Trip Purposes for Work VMT
HBW
Home based work
USED
USED
USED
HBS
Home based shop
x
x
x
HBK
Home based K-12
x
x
x
HBC
Home based college
x
x
x
HBO
Home based other
x
x
x
WBO
Work based other
x
x
x
OBO
Other based other
x
x
x
EE
External to external
x
x
x
TS
Light duty truck
x
x
x
TM
Medium duty truck
x
x
x
TH
Heavy duty truck
x
x
x
Model External Trips
The sole use of the City's model inputs and trip purposes for evaluation of VMT is limited to the boundary of
the model (County boundary). Based on the City model inputs and selected trip purposes, approximately 5%
of the residential -based and work -based trips generated by zones within the City limits have at least one trip
end external to the County. Due to the small share of external trips along with the City's centralized location
within the county, the portion of VMT occurring outside of the county is unlikely to be a differentiating factor
when considering proposed land use projects.
4.2 SLOCOG RTDM
The regional SLOCOG model was utilized to estimate trip -based Residential and Work Baseline VMT for the
entire County. 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 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 (HBx4) 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 4.3T'"�T and Table
4.4Table 4.2 present the trip purposes used for Residential and Work VMT evaluations, respectively.
4 HBx refers to any "Home based" trip, including work, shop, K-12, college, and other.
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Table 4.34Selected Trip Purposes for Residential VMT
HBW
Home based work
HBS
Home based shop
HBK
Home based K-12
HBC
Home based college
HBO
Home based other
WBO
Work based other
OBO
Other based other
EE
External to external
TS
Light duty truck
TM
Medium duty truck
TH
Heavy duty truck
USED
USED
USED
x
x x
USED
USED
USED
x
x x
USED
USED
USED
x
x x
USED
USED
USED
x
x x
USED
USED
USED
x
x x
x
x
x
x
x x
x
x
x
x
x x
x
x
x
x
x x
Table 4.42Selected Trip Purposes for Work VMT
HBW
Home based work
USED
USED
USED
HBS
Home based shop
x
x
x
HBK
Home based K-12
x
x
x
HBC
Home based college
x
x
x
HBO
Home based other
x
x
x
WBO
Work based other
x
x
x
OBO
Other based other
x
x
x
EE
External to external
x
x
x
TS
Light duty truck
x
x
x
TM
Medium duty truck
x
x
x
TH
Heavy duty truck
x
x
x
County External Trips
The sole use of the SLOCOG model inputs and trip purposes for evaluation of VMT is limited to the
boundary of the model (County boundary). Based on the SLOCOG model inputs and selected trip purposes
for the unincorporated County areas, approximately 5% of the residential -based and work -based trips are
external to the County. However, the SLOCOG model is currently over forecasting VMT as compared LEHD
and therefore GHD is not recommending it as the baseline methodology. Adding external trip length would
only exacerbate the deviation.
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4.3 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)
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 States5. 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 City and SLOCOG models provides information on mode choice, and does its own
assignment of trips, the additional commute 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.
4.3.1 LEHD DATA.
LEHD, or longitudinal Employment Household Dynamics Data, provides the most complete enumerated
information on household to employment origins and destinations. However this data on its own does not
report VMT. In order to calculate VMT from LEHD data the origin/destination data was applied to the regional
transportation network within the SLOCOG model in order to produce VMT. The methodology for exercise is
as follows. 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 both the City and SLOCOG's model 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
a "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
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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.
4.4 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
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 condition 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 and City
travel demand models, which have a base year of 2016 & 2015, respectively. 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 concurrent with the travel demand model, as recommended in this memorandum will be an
important component of ensuring that the VMT thresholds remain defensible under CEQA.
5. Draft Baseline VMT Analysis Findings
City and Countywide baseline VMTs using the City and SLOCOG Travel Demand Models as well as LEHD
data have been calculated as part of this effort. Based on the methodology for estimating Baseline VMT as
described within this memorandum, Tables 5.1 & 5.2 present a summary of the Baseline VMT analysis
utilizing the sources for both Residential and Work VMT, and Work VMT using the LEHD model developed
as part of this effort.
Table 5.1 Summary of Baseline Residential VMT
Residential VMT per Capita 8.51 16.76
9.12 16.30
d -Technical Memo Baseline VMT Methodoloov & Estimation (GHD)^ ^ -1-1,1001-de
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Packet Page 270
Item 13
Table 5.2 Summary of Baseline Work VMT
Work VMT per Employee (model data) 17.98
Work VMT per Employee (LEHD model) -
Table 5.3 Summary of Net VMT
14.65 25.23 14.01
- 15.45 28.17
NET VMT 1,030,000 8,490,000
Note: Due minor variations in model run results Net VMT is rounded to the nearest 10,000.
5.1 Baseline VMT Considerations and Recommendations
Mode/ Selection
Based on the LEHD, SLOCOG Model & SLOCITY model data sources, relatively short residential VMT is
reported for the City of SLO vs relatively longer Work VMT. This relationship is as expected consistent with
an overall jobs -to -housing imbalance, where work -based land uses within the City draws longer commute
traffic and overall residential based trips are mostly captured within and around the City. For Residential
VMT, the City and County models produce similar results for both the regional and city geographies.
However, for Work -based VMT, the SLOCOG model produces significantly higher work VMT for the City
geography and significantly lower work VMT for the Regional geography as compared to both the City model
& LEHD. The City model is more closely representative of LEHD travel patterns, include multimodal
networks, and is sensitive to a broader range of potential mitigation measures such as multimodal
improvements. Therefore, GHD is recommending the City model for Calculating VMT baseline and
evaluating project VMT.
The SLO City Model does however deviate from LEHD for work -based VMT similar to the SLOCOG model
however to a lesser degree. This is somewhat anticipated as the City' travel demand model is based on
SLOCOG model data for TAZ's outside the City.
One of the most significant issues with the SLOCOG model as compared to LEHD data, the SLOCOG model
overestimates City Work VMT and underestimates Countywide VMT. Whereas the City model forecasts
these VMT proportionally consistent with LEHD data as compared to the SLOCOG model. This is the
primary factor in GHD's recommendation to use the City's model as the VMT estimation and forecasting tool.
Because this analysis is effectively measuring delta VMT as a result of the project, if the same model that
establishes the baseline is used to estimate project VMT and that model is proportionally accurate it is
sufficient and the most accurate tool available at this time.
d- Technical Memo Baseline VMT Methodology & Estimation (GHD)^"07547MEM001AG Packet Page 271 10
Item 13
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Its recommended that the City's model be further calibrated to LEHD & ACS data as part of the next
scheduled update; however, the City's model is still the most accurate and valid tool currently available for
VMT analysis.
Baseline Geography
Under SB743 The City has its own discretion in which geography baseline (i.e. City only, County
incorporated Cities, County unincorporated areas, entirety of County both incorporated and unincorporated.
This is a critically important decision as it effectively establishes how strict the City chooses to set it standard
and would directly result in more or less significant impacts as the result of development project. For
example if the City were to choose its own residential VMT averages as the baseline this threshold would be
twice as restrictive as a residential baseline threshold based on SLO County regional averages. Under a City
based average VMT threshold most residential growth areas identified in the City's general plan would have
a VMT impact because they can't achieve a low average which includes influences from dense mixed -uses
in the downtown core and other residential near the University. In order to reach San Luis Obispo's housing
production goals and implement its General Plan GHD is recommending the baseline threshold be
established based on total regional averages including incorporated Cities. This threshold is consistent with
the intent SB743's intent to focus development is VMT efficient areas and reduce automobile travel as a
whole from a regional perspective and is a specific example threshold provided within OPR guidance.
Recommended City Model / Regional Average Baseline & Significance Threshold
Regional Residential Baseline VMT: 16.76 VMT/Capita
15% below baseline significance threshold: 14.25 VMT/Capita
Regional Work Baseline VMT: 14.65 VMT/Capita
15% below baseline significance threshold: 12.45 VMT/Employee
Other Project Baseline VMT: 8,092,852 Regional Net VMT
Net Increase Significance threshold: 8,490,000 VMT
For purposes of calculating dwelling unit
to employee ratios and work square
footage to employee ratios on a project
by project basis, the American
Community Survey and SCAG
employment density report shown at the
right should be considered. The City
should retain discretion for determining
the appropriate ratio assumptions for
each project application.
Table 1A
Derivation of Square Feet per Employee Based on:
--MEDIAN EMPLOYEES PER ACRE
--MEDIAN FAR
FIVE COUNTY REGION NeVGross Adjustment Factor 0.75
Land Use Cateoory
4 of
Records
FAR
Employees!
Acre
Building
Efficiency
Square Feet)
Employee
Regional Retail
27
0.59
14.99
0.80
1,023
Other Retail/Svc.
1013
0.28
13.49
0.85
585
Low -Rise Office
349
0.36
22.91
0.90
466
High -Rise Office
46
1.19
116.32
0.90
300
Hotel[Motel
16
0.61
11.04
NIA
1,804
R & D)Flex Space
70
0.31
18.13
0.95
527
Light Manufacturing
1047
0.35
11.63
0.95
924
Heavy Manufacuring
0
--
17A5
NIA
--
Warehouse
121
0.42
10.63
0.95
1,225
Govemment Ctrices
32
0.37
16.23
0.90
672
d - Technical Memo Baseline VMT Methodology & Estimation (GHD) Packet Page 272 11
- -__ CEQA Transportation Impact
Thresholds Update: Transition from
- Auto Level of Service (LOS) to
Vehicle Miles Traveled (VMT)
Luke Schwartz, P.E.
Transportation Manager
Public Works Department
IschwartzCa-)-slocit r�org
Agenda
1. Background
2. LOS vs. VMT
3. Proposed CEQA Impact Thresholds
4. Process for Evaluating Projects
5. Staff Recommendations
Background
■ CA Senate Bill 743 (SB 743) signed into law in 2013
Replaces Level of Service (LOS) with Vehicle
Miles Traveled (VMT)
Promotes reduction in GHG emissions:
Diversity & mixing of land uses
Develop multimodal transportation networks
Incentivize growth where users have more
efficient access to housing, jobs, destinations
■ Technical Guidance Published December 2018
■ Requires statewide implementation by July 1, 2020
Background
CALIFORNIA GHG EMISSIONS BY SOURCE
Source: California Air Resources Board, 2016
Transportation -Related Industrial Emissions
9.9 °a ff
plf'C.�Irl S
5 .3%
Petroleum Refining and
HydrogeR Produ6on
35.7
Oil and Gas Extraction
5%
1
Total % Related to Transportation ~ 50%
8°
12%
■ Electricity Generation
(In -State)
a Electricity Generation
(Imports)
Transportation
■ Industrial
8% ■ Commercial
Residential
Agriculture and
Forestry
LOS vs. VMT
■ What is LOS and what are the advantages & disadvantages?
Measures driver congestion/delay (A — best; F —worst)
Prioritizes car mobility, not person mobility
Disincentivizes infill, incentivizes sprawl
Leads to more road widening, more GHG, more $$$
IllollIN-W-V 0
LOSA
LOS F
LOS vs. VMT
What is VMT and what are the benefits & disadvantages?
# of Auto Trips X Trip Length
Better indicator of GHG emissions
Removes a key barrier to infill, transit and active
transportation projects
More difficult to visualize
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Analysis of
development using LOS
Relatively little vehicle
travel loaded onto the
network
...but numerous LOS
impacts
Source: CA Governor's Office of
Planning & Research
F!
e
Analysis of greenfielr-
development using LOS
a'.
Source: CA Governor's Office of "`
Planning & Research-
1
wM
Analysis of greenfielr-
development using LOS
Typically three to four
times the vehicle travel
loaded onto the
network relative to infil;
development
Source: CA Governor's Office of
Planning & Research
Analysis of greenfielr-
development using LOS
Typically three to four
times the vehicle travel
loaded onto the
network relative to infil;
development
...but relatively few
LOS impacts —
Traffic generated by the
project is disperse enough by
the time it reaches congested
areas that it doesn't trigger
LOS thresholds, even though it
contributes broadly to regional
congestion.
Recommended VMT Thresholds for
Land Use Projects
■ Residential
15%.below existing regional (County)
residential VMT per capita
■ Work (Office, Business Park, Industrial, etc.)
15% below existing regional (County) VMT
per employee
■ Retail
No Net Increase in existing regional
(County) VMT
■ Mixed -Use
Evaluate each component
Recommended VMT Thresholds for
Land Use Projects
EXISTING RESIDENTIAL AND OFFICE VMT AVERAGES
20.00
18.00 16.76
a)
0 16.00 15% below 14.25
E
Q 12.00
coOW
Q 10.00 8.51
U 8.00
6.00 IV
4.00
2.00
A M
Residential (Daily VMT/capita)
17.98
14.65
15% below 12.4
Office (Daily VMT/employee)
City Average Regional (County) Average
Source: City of San Luis Obispo Travel Demand Model (SLO TDM)
VMT Screening for Land Use Projects
■ Small Projects: < 110 daily auto trips (< 11 peak hour trips)
11 SF homes / 18 MF homes
10,000 sqft. office
2, 000-3, 000 sqft. retail
■ Medium Residential & Work Projects: <100 peak hour trips
Map -based screening
■ Locally -Serving Retail: < 50,000 sqft.
Reasonable justification that use is locally -serving
■ Transit -Oriented Development
<'/2-mile from major transit stop or high -quality transit
corridor (No locations w/ frequency of 15 min or less)
Evaluating Transportation Project
■ Increases auto capacity (adds thru lanes on exi
thoroughfare)?
Requires quantitative analysis for induced t
■ Reduced or negligible change in VMT?
EXEMPT
Bicycle, pedestrian and transit projects
Maintenance
Road diets
Transit projects
Safety improvements
New local streets w/ pedestrian facilities
New traffic signals, roundabouts
Process for Evaluating Projects
If required, Transportation Impact Study (TIS) will include 2
parts:
VMT Analysis Auto LOS
Safety Analysis
Plan/Policy Consistency
Outcome:
Impacts & Mitigation Measures
Pedestrian LOS
Bicycle LOS
Transit LOS
Access Management
Neighborhood Traffic
Outcome:
Local Policy Deficiencies &
Recommended COAs to Address
Case Studv A
Hypothetical residential development on Laurel Lane
consisting of 100 apartment units.
■ Auto Trip Generation: 660 daily / 62 peak hour
■ Does not meet screening criteria for "Small Project"
■ Meets criteria for "Medium Residential Project"
Eligible for Map -Based VMT Screening
Case Studv A
City of San Luis Obispo
Residential VMT Screening Map
Residential VMT Per Capita
Regional Average = 16.76
85% of Regional Average (Impact Threshold) = 14.25
s 85% of Average VMT
85% -100% of Average VMT
100% - 115% of Average VMT
>115% of Average VMT
Too Little Data - Further Analysis Needed
AV-
Cityl-imit
flala Source. City of San Lys 9btspo Travel ❑ermnd Model
Last UpdatedF012020
I
r sa�i Luis
Oh.spa
Case Studv A
Hypothetical residential development on Laurel Lane
consisting of 100 apartment units.
■ Auto Trip Generation: 660 daily / 62 peak hour
■ Does not meet screening criteria for "Small Project"
■ Meets criteria for "Medium Residential Project"
Eligible for Map -Based VMT Screening
Results — VMT impact assumed to be less
than significant
■ If Transportation Division has no other concerns with
traffic safety, access management, local policy
thresholds, no focused TIS required
Case Study B
Hypothetical office development on Tank Farm Road,
with 100,000 sgft. gross leasable area
■ Auto Trip Generation: 1,100 daily / 156 peak hour
■ Does not meet screening criteria for "Small Project"
■ Does not meet screening criteria for "Medium Project'
where screening maps could be used
Requires Focused TIS w/ VMT Analysis
■ Project VMT/employee 10% over adopted threshold
VMT Impact — Requires Mitigation
■ Project causes Bicycle LOS to exceed GP target
Local Policy Deficiency — Project COA
VMT Mitigation Strategies
■ Revise project (i.e. incorporate mix of land uses)
■ Locate project in lower-VMT area of the City
■ Improve or increase access to active transportation
facilities
■ Improve or increase access to transit service
■ Participate in an in -lieu fee program to fund City-wide
improvements to sustainable transportation
■ Transportation Demand Management (TDM)
■ Provide car -share, bike -share, EV charging
Staff Recommendations
1. Adopt a resolution (Attachment A) to replace Auto Level
of Service (LOS) with Vehicle Miles Traveled (VMT) as
the City's performance measure for CEQA analysis of
transportation impacts; and
2. Adopt a resolution (Attachment B) approving revisions to
the City's Multimodal Transportation Impact Study
Guidelines
Alternatives:
1. Adopt the proposed recommendations with changes.
Council could direct staff to modify proposed VMT
thresholds and/or TIS Guidelines.
2. Continue item to a future date.
3. Decline to adopt staff recommendations at this time.
City of San Luis Obispo
, N
Residential VMT Screening Ma'
�"�' •'='
0 1.250 2.500 5.000
40
Aw
Residential VMT Per Capita
/ OMspo
% ,n LII
Regional Average = 16.76
85% of Regional Average (Impact Threshold) = 14.25
i "�
f •.^ �
s 85% of Average VMT
85°Io 100% of Average VMT
-
100% - 115% of Average VMT
-115% of Average VMT
Too Little Data - Further Analysis Needed
L--� (-ityl-imit
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Dala SDame: City of San Lws ONTO Travel Demand Model
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Work VMT Screening Map
EEEME777� Feet
--------------
ti� or•yn.ri i...
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Work VMT Per Employee
Regional Average = 14-85
85% of Regional Average (Impact Threshold7=12.45
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85% - 100% of Average VMT
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100°f° - 115% of Average VMT
;
.
115% - 130% of Average VMT
- }130% of Average VMT
Too Little Data - Further Analysis Needed
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