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HomeMy WebLinkAboutARCH-0161-2019 2021_04_08_SLO_French_VMT_Memo_FINAL MBI PN 179280 1 | P a g e TECHNICAL MEMORANDUM To: Jennifer Rice, City of San Luis Obispo From: Carla Dietrich, Michael Baker International CC: Tom Tracy, Michael Baker International Date: April 8, 2021 (Final, Updated from February 4, 2021) Subject: French Hospital Medical Center Expansion VMT Assessment Introduction The purpose of this memorandum is to document a VMT assessment for the proposed French Hospital Medical Center expansion project (Project) located in the City of San Luis Obispo, California. A separate Focused Multimodal Transportation Study has also been prepared for this project. The existing French Hospital Medical Center currently exists at 1911 Johnson Avenue in the City of San Luis Obispo. The proposed French Hospital Medical Center expansion includes a new 82-bed wing, a chapel, a lab, and a parking structure. This memorandum has been prepared to support the Transportation component of the California Environmental Quality Act (CEQA) process. Exhibit 1 shows the location of the project and Exhibit 2 shows the conceptual site plan. Exhibit 1: Project Location 2 | P a g e Exhibit 2: Site Plan Analysis Guidelines The City of San Luis Obispo Multimodal Transportation Impact Study Guidelines (June 2020, 2nd Edition) (City Guidelines) and the Governor’s Office of Planning and Research (OPR) Technical Advisory on Evaluating Transportation Impacts in CEQA, December 2018 (Technical Advisory) have been utilized in the development of this analysis. Screening Criteria Per City Guidelines and Technical Advisory, land use projects that meet the screening thresholds identified in Table 1 are assumed to result in a less-than-significant transportation impact under CEQA and do not require a detailed quantitative VMT assessment. The project does not meet any of the Screening Criteria for land use projects which would allow a determination of a less-than-significant impact on VMT, thus a project-specific VMT assessment is required. 3 | P a g e Table 1: Screening Criteria for Land Use Projects Exempt from VMT Analysis Project Type OPR Recommended Threshold Project Evaluation Result Small Development Projects Projects anticipated to generate < 110 daily vehicle trips (11 peak hour vehicle trips) may be assumed to cause a less-than-significant impact, unless substantial evidence indicates that a project would generate a potentially significant level of VMT or create inconsistency with the SLOCOG RTP Sustainable Communities Strategy (SCS). Project is anticipated to generate 1,876 daily trips. Does Not Meet Criteria Medium-Sized Residential & Employment- Based (Office, Business Park, Industrial, etc.) Development Projects Map-based screening may be used for projects that generate <100 peak hour vehicle trips. Baseline VMT per capita/employee heat maps are developed based on data from the SLO TDM, showing existing average Residential and Work VMT for each area of the City. Where proposed projects that generate <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. Project is anticipated to generate 155 AM Peak Hour trips and 159 PM Peak Hour trips. Does Not Meet Criteria Local Serving Retail & Public Facilities Retail development projects with ≤ 50,000 sqft. gross floor area with reasonable justification that uses will be local-serving may be assumed to cause a less-than- significant impact. 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. Project does not include local serving retail or public facilities. Does Not Meet Criteria Affordable Housing Adding affordable housing in infill locations generally improves jobs-housing balance, in turn shortening commutes and reducing VMT. A project consisting of a high percentage of affordable housing (>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 (see Appendix A) or where supporting evidence is provided that demonstrates low VMT-generating characteristics of similar affordable housing sites within the City. Project does not include any residential housing. Does Not Meet Criteria Transit-Oriented Development Per CEQA Guidelines, residential, retail, office and mixed-use projects that are located within a ½ mile of an existing major transit stop or an existing stop along a high- quality transit corridor may be assumed to cause a less-than-significant impact on VMT (see Note 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. No locations within the City of San Luis Obispo currently meet these transit service levels. Does Not Meet Criteria Notes: 1. A “major transit stop” is 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. 4 | P a g e VMT Threshold of Significance Table 2 shows the thresholds of significance per the City Guidelines. The “Other Development Projects” category was chosen as the appropriate category for the medical facility expansion based on coordination with City staff. The threshold identified for this category is developed on a case-by-case basis. Based on available guidance and coordination with City staff, it was determined that the appropriate threshold for this project is based on VMT/service population (SP), specifically 15% below the existing regional (County) average VMT per service population, or 17.43 VMT per service population. Service population is defined as the combination of employee and residential trips produced (P) or attracted (A) within the region. Table 2: VMT Thresholds of Significance Project Type Evaluation Criteria Threshold1 Residential 15% below baseline Regional (County) average Residential VMT per capita. Applies to single-family, multi-family and mobile homes. 14.25 VMT per capita Office / Business Park / Industrial / Warehousing / Manufacturing 15% below existing Regional (County) average Work VMT per employee. 12.45 VMT per employee Retail / Hotel / School Net increase in total Regional (County) VMT. Small local- serving retail may be presumed to 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. No set threshold, increase in total VMT would trigger impact Mixed-Use Evaluate each component of a mixed-use project independently, applying significance threshold 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. Apply Residential, Office & Retail Thresholds above Redevelopment Projects Where a development replaces an existing VMT- generating 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. No set threshold Other Development Projects City may apply adopted residential, office or retail VMT thresholds to other development 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. No set threshold. Evaluated on case-by-case basis based on OPR guidance Notes: 1. Quantitative thresholds will be updated as required with subsequent updates to the City Travel Demand Model and/or per revisions to CEQA Guidelines or OPR Technical Advisory on VMT analysis. 5 | P a g e Project Level VMT Assessment Michael Baker enlisted the assistance of Translutions to conduct project specific travel demand modeling for the Project using the City’s Travel Demand Model (SLO TDM). The model was provided by the City for use on this project in August 2020. The Project is located within TAZ 212. The model was run by adding the area of expansion to the existing TAZ (90,000 square feet of hospital use). The modeling and calculations were conducted consistent to the methodology included in Appendix B: SLO TDM Technical Guide - Calculating VMT (Cambridge Systematics) of the City of San Luis Obispo Multimodal Transportation Impact Study Guidelines, 2nd Edition (June 2020). The Baseline (Year 2016) travel demand model results are shown in Table 3 and a summary of the findings are shown in Table 4. The results show that the Project VMT per service population of 20.50 is greater than the significance threshold (17.42 VMT per service population), and is 100.05% of the Average Regional VMT (20.49 VMT per service population) therefore the project is anticipated to result in a significant transportation impact. Table 3: Project VMT Model Results Category San Luis Obispo (County) VMT per Service Population No Project With Project Total P VMT 8,083,328 8,087,846 Total A VMT 8,083,328 8,087,846 Total PA VMT 8,083,328 8,087,846 Total Population 280,101 * 280,101 * Total Employment 114,304 * 114,349 ** Service Population 394,405 394,450 VMT / Service Population 20.49 20.50 * Regional value obtained from 2019 Regional Transportation Plan (Connecting Communities) Policy Element, Figure 2-2: San Luis Obispo Region by the Numbers; pg 2-6. ** Equals regional value plus Project anticipated number of employees (45). Table 4: Project VMT Impact Summary Category VMT per Service Population Summary VMT per Service Population (With Project) 20.50 VMT per Service Population (Regional Average) 20.49 VMT per Service Population Threshold (15% Below Regional Average) 17.42 Percentage Reduction in VMT Required to Shift Project to Below Threshold 15.05% 6 | P a g e Mitigation Measures With the finding of a significant transportation impact, potential mitigation measures are evaluated under this section. To mitigate the impact, the project would need to identify Transportation Demand Management (TDM) elements to help reduce reliance on auto or provide means by which to either reduce the length of vehicle trips or reduce the number of vehicle trips. Attachment 1 contains a list of potential VMT mitigation measures. The mitigation measures and their potential impact evaluated in this analysis are a combination of the City Guidelines, the California Air Pollution Control Officers Association (CAPCOA) Quantifying Greenhouse Gas Mitigation Measures (August 2010), and the Western Riverside Council of Governments (WRCOG) SB 743 Implementation TDM Strategy Assessment (Fehr & Peers, February 26, 2019). The list of TDM strategies that are relevant to development projects and evaluated in terms of the French Hospital Medical Center expansion project are shown in Table 5. Each of the TDM strategies were evaluated in terms of its potential applicability to the proposed Project in an attempt to mitigate the VMT impact identified, as summarized in Table 6. In some cases the mitigation measures identified are currently in place, as shown in each of the tables. Also, the analysis includes the consideration of low-level implementation and high-level implementation. High-level implementation includes regular monitoring to ensure the efficacy of the TDM strategies including a determination of adequacy and adjustments to the program if the actual level of trip reduction is determined to be insufficient. Table 5: Evaluation of Potential TDM Strategies TDM Strategy Evaluation Applicability to the Proposed Project Low-Level High-Level 1 Provide pedestrian network improvements Orienting the project towards transit, bicycle, and pedestrian facilities could result in a 0.25% - 0.50% reduction in VMT. The Project site and expansion supports the use of bicycle and pedestrian activity. Sidewalks are provided adjacent to and onto the site. A trail exists along the property that connects Breck Street to Iris Street. The project proposes to maintain the high level of bicycle and pedestrian accommodation. Applicable – A VMT reduction is in place given the existing robust bicycle and pedestrian network (TDM Measure Currently in Place) 0.25% 0.25% 2 Provide traffic calming measures and low-stress bicycle network improvements Implementing traffic calming is anticipated to result in a 0.25% - 1.00% reduction in VMT. Bicycle lanes currently existing along Johnson Avenue. Bicycle accommodations on-site are provided via the shared travel ways and the trail that extends through the site from Breck Street to Iris Street. The expansion traffic will benefit from this condition. Applicable – A VMT reduction is in place given the measures provided (TDM Measure Currently in Place) 0.25% 0.25% 3 Provide bicycle parking Providing bicycle parking is anticipated to result in a 0.625% reduction in VMT for non-residential projects. It is recommended that the hospital expansion project provide dedicated bicycle parking on-site. Applicable – A VMT reduction is in place given existing conditions (TDM Measure Currently in Place) 0.625% 0.625% 4 Locate project near transit Locating a project near transit is anticipated to result in a 0.5% - 24.6% VMT reduction. Transit service is provided along Johnson Avenue by SLO Transit via Route 1A/1B. Applicable – A reduction in VMT is in place due to the proximity to transit (TDM Measure Currently in Place) 5% 5% 7 | P a g e TDM Strategy Evaluation Applicability to the Proposed Project Low-Level High-Level 5 Increase transit service frequency and speed Increasing transit service frequency/speed is projected to result in a 0.02% - 2.5% reduction in VMT. This type of measure requires regional or local agency implementation and coordination to provide transit beyond what is currently available and thus it is not applicable for individual development projects. Not Applicable 0% 0% 6 Provide parking or roadway pricing or cash- out programs Providing employee parking cash-out programs is anticipated to result 0.6% - 7.7% commute VMT reduction. This strategy allows the employer to provide employees with a choice of forgoing subsidized/free parking for a cash payment equivalent to the cost of the parking space. Potential VMT reduction values are based on jurisdictional size. Applicable – A reduction in VMT is projected based on implementation (Additional TDM Measure Recommended) 3.5% 3.5% 7 Implement car- sharing program Implementing a car-sharing program is projected to result in a 0.4% - 0.7% reduction in VMT. The nature of the project would be a candidate for a car-sharing program between employees that work the same shift. However, this type of measure requires private market support as well as regional or local agency implementation and coordination. Thus, it is not applicable for individual development projects unless an established program is in place. Not Applicable 0% 0% 8 Encourage telecommuting and alternative work schedules Telecommuting programs are employment-based strategies. Given the service nature of the hospital, telecommuting options would be limited to administrative tasks such as billing or scheduling, which would have limited impact. Not Applicable 0% 0% 9 Provide ride- sharing programs Implementing employment-based ride-sharing strategies is projected to result in a 1% - 15% commute VMT reduction. CAPCOA page 253 (TRT-11 and TRT-12) indicates that a low range % VMT reduction would occur with a low implementation/small employer while a high range % VMT reduction would occur with a high implementation/large employer. Ride-sharing programs work best in conditions where work schedules are fixed and regular. Swapping shifts and the requirement for doctors to visit admitted patients at various times would limit the VMT reduction. While some benefit from a ride-sharing program can get anticipated, the nature and locale would likely result in a lower level of VMT reduction. Applicable – A total 1% reduction given the nature and location of the land use (TDM Measure Currently in Place [0.5% reduction]; Additional TDM Measure Recommended identified with a slight expansion of the existing activities [0.5% reduction]) Applicable – A total 2.5% reduction given the nature and location of the land use (TDM Measure Currently in Place [0.5% reduction]; Additional TDM Measure Recommended identified through an expansion of the existing activities to include regular monitoring to ensure TDM strategy efficacy [2% reduction]) 1% 2.5% 10 Implement commute trip reduction marketing Implementing Commute Trip Reduction Marketing is projected to result in a 4% - 5% reduction in commute vehicle trips with full- scale employer support. Implementing commute trip reduction strategies without a complementary marketing effort results in a lower VMT reduction. Applicable – A 1% reduction in VMT is anticipated with a moderate marketing efforts (Additional TDM Measure Recommended) Applicable – A 4% reduction in VMT is anticipated with full implementation of a robust marketing effort (Additional TDM Measure Recommended) 1% 4% 8 | P a g e TDM Strategy Evaluation Applicability to the Proposed Project Low-Level High-Level 11 Increase diversity of land uses Increasing the mix of uses within a project could result in a 9% - 30% reduction in VMT. Since the project is an expansion of the existing building and existing use, adding a mix of uses would create inconsistency. Not Applicable 12 Land Use Mix Incorporating a mix of land uses to increase access to common goods and services has the potential to reduce VMT, however the project is an expansion of an existing use and the goal of the project is to accommodate the medical uses. Not Applicable 13 Relocate Project Locating the project in a lower-VMT area of the City is a potential mitigation, however the Project is an expansion of an existing use and relocation of the hospital or separation of services is not feasible. Not Applicable Table 6: Mitigation Summary Category VMT Summary Low-Level High-Level Percentage Reduction in VMT Required to Shift Project to Below Threshold -15.05% TDM Measures Currently in Place Locate project near transit -5% -5% Provide bicycle parking -0.625% -0.625% Provide pedestrian network improvements -0.25% -0.25% Provide traffic calming measures and low-stress bicycle network improvements -0.25% -0.25% Employer-implemented ride-sharing program (existing measures) -0.5% -0.5% Subtotal -6.625% -6.625% Additional TDM Measures Recommended Provide parking cash-out programs -3.5% -3.5% Employer-implemented ride-sharing program (expansion of existing measures) -0.5% -2.5% Implement commute trip reduction marketing strategies -1% -4% Subtotal -5.000% -10% Mitigation Summary TDM Measures Currently in Place -6.625% -6.625% Additional TDM Measures Recommended -5% -10% Total Reduction Achieved -11.625% -16.625% Remaining Unmitigated Impact 3.425% -- Finding: VMT reduction impact does not achieve the required 15.05% reduction in VMT per service population under the low-level implementation scenario, however, the VMT reduction impact is projected to be achieved under the high- level implementation scenario. 9 | P a g e An alternative to TDM programs is the establishment of mitigation fee programs and mitigation banks/exchanges for projects that are unable to fully mitigate their VMT impacts. These programs would fund a pool of projects that would improve VMT at a regional level. However, VMT fee programs and mitigation banks have not yet been implemented and are currently not a mitigation option for this project. Additionally, there is the potential to directly fund and implement transportation improvements or measures that reduce VMT, such as funding off-site pedestrian/bicycle infrastructure, or increasing transit service frequency to/from the hospital through either private shuttle service or working with SLO Transit to increase their service frequencies. Other types of improvements that reduce VMT beyond those mentioned above may also be considered. Based on this analysis, the Project is unable to mitigate the VMT impacts through TDM alone under the low-level scenario, and without further actions to reduce VMT, the transportation impact is identified as significant and unmitigated. However, as identified under the high-level scenario, the Project is able to mitigate the VMT impacts through TDM strategies with regular monitoring to ensure efficacy of the program. Conclusions The VMT evaluation of the French Hospital Medical Center located in the City of San Luis Obispo shows that the project does not meet the screening criteria and thus a VMT assessment was required. Evaluation of the project TAZ and the VMT per service population demonstrated that the project TAZ does not meet the VMT threshold of 85% of the VMT per service population. As such, the project will result in a significant transportation impact. While implementing additional TDM strategies under the low-level scenario at the French Hospital Medical Center would partially mitigate this impact, the applicable TDM measures alone are unable to satisfy the required change in VMT to meet the threshold. However, with the high-level implementation scenario including a regular monitoring program, the project's transportation impact has been identified as mitigated. 10 | P a g e Attachment 1 – Potential VMT Mitigation Measures Reduction Measure Implementation Lead Effectiveness Source Scale/Magnitude Orient the project toward transit, bicycle, and pedestrian facilities Applicant 0.25 – 0.5% reduction in VMT CAPCOA page 179, LUT‐7 Within Project Locate the project in an area of the region that already exhibits low VMT Applicant 10‐65% VMT reduction CAPCOA page 159, LUT‐2 Site specific Shifting single occupancy vehicle trips to carpooling or vanpooling, for example providing ride‐matching services Employer 0.3 – 13.4% commute VMT reduction CAPCOA page 227, TRT‐3 Based on size of development Limit or eliminate parking supply Applicant 5 – 12.5% vehicle miles travelled (VMT) reduction CAPCOA page 207, PDT‐1 Within Project Unbundle parking costs Applicant 2.6 – 13% VMT reduction CAPCOA page 210, PDT‐2 Within Project Provide parking or roadway pricing or cash‐out programs Applicant/ landlord / company 0.1 – 19.7% commute VMT reduction, cash‐ out: 0.6 – 7.7% commute VMT reduction CAPCOA page 261, TRT‐14 and 15 Varies, potentially high Provide Bike Parking in Non‐Residential Projects Applicant 0.625% reduction in VMT CAPCOA page 202, SDT‐6 Within Project Provide Bike Parking with Multi‐Unit Residential Projects Applicant Not Quantified CAPCOA page 204, SDT‐7 Within Project Incorporate affordable housing into the project Applicant Not Quantified Within Project Locate the project near transit Applicant 0.5 – 24.6% VMT reduction CAPCOA page 171, LUT‐5 Site specific Increase project density Applicant 0.8 – 30.0% VMT reduction CAPCOA page 155, LUT‐1 Within Project Increase the mix of uses within the project or within the project's surroundings Applicant 9‐30% VMT reduction CAPCOA page 162, LUT‐3 Within Project Increase connectivity and/or intersection density on the project site Applicant Not Quantified Within Project Integrate Affordable and Below Market Rate Housing Applicant 0.04 – 1.20% VMT reduction CAPCOA page 176, LUT‐6 Within Project Locate Project near Bike Path/Bike Lane Applicant 0.625% reduction in VMT CAPCOA page 181, LUT‐8 Site specific Incorporate Bike Lane Street Design (on‐site) Applicant 1% increase in share of workers commuting by bicycle (for each additional mile of bike lanes per square mile) CAPCOA page 200, SDT‐5 Within Project Increase access to common goods and services, such as groceries, schools, and daycare Local Agency 2% Trip Reduction Based on location Implement or provide access to a commute reduction program Applicant/ landlord / company 1.0 – 6.2% commute VMT Reduction CAPCOA page 210, TRT‐1 Providing on‐site amenities at places of work, such as priority parking for carpools and vanpools, secure bike parking, and showers and locker rooms Applicant/ landlord / company Not quantified CAPCOA page 244, TRT‐8 Implement Commute Trip Reduction Marketing Applicant/ landlord / company 4‐5% commute vehicle trips reduced with full‐ scale employer support CAPCOA page 240, TRT‐7 Within Project Tolling new lanes to encourage carpools and fund transit improvements Caltrans Strong effect on travel patterns Very large scale undertaking Converting existing general purpose lanes to HOV or HOT lanes Caltrans Tolling effect Very large scale undertaking 11 | P a g e Reduction Measure Implementation Lead Effectiveness Source Scale/Magnitude Implementing Intelligent Transportation Systems (ITS) strategies to improve passenger throughput on existing lanes Caltrans, Local Agency, LA County DPW 0 ‐ 45% reduction in GHG emissions CAPCOA page 291, RPT‐2 High dependent on affected roadways Implement Commute Trip Reduction Program – Required Implementation/Monitoring Employer 4.2 – 21.0% commute VMT reduction CAPCOA page 223, TRT‐2 Within Project Provide transit passes. [to Metro services] Employer Not quantified Providing telework options Employer 0.07 – 5.50% commute VMT CAPCOA page 236, TRT‐6 Low scale Providing employee transportation coordinators at employment sites Employer Not Quantified Within Project Providing a guaranteed ride home service to users of non‐auto modes Employer Not Quantified Within Project Provide car‐sharing, bike sharing, and ride‐ sharing programs Employer or franchise through local agency 1 – 15% commute VMT reduction CAPCOA page 253, TRT‐11 and TRT‐12 Implement Car‐Sharing Program Employer or franchise through local agency 0.4 – 0.7% VMT reduction and therefore 0.4 – 0.7% reduction in GHG emissions CAPCOA page 245, TRT‐9 Likely beyond the site area to be effective Increase access to common goods and services, such as groceries, schools, and daycare Local Agency 2% Trip Reduction Based on location Incorporate neighborhood electric vehicle network Local Agency 0.5‐12.7% VMT reduction CAPCOA page 194, SDT‐3 Potentially very large scale to be effective Provide Pedestrian Network Improvements Local Agency 0 ‐ 2% VMT reduction CAPCOA page 186, SDT‐1 Dependent on affected area Provide traffic calming Local Agency 0.25 – 1.00% VMT reduction and therefore 0.25 – 1.00% reduction in GHG emissions CAPCOA page 190, SDT‐2 Generally low, and localized Implement Market Price Public Parking (On‐ Street) Local Agency 2.8 – 5.5% VMT reduction CAPCOA page 213, PDT‐3 Likely on adjacent roadways Reduction Measures on a Programmatic Level Expand Transit Network Metro and other Transit Agencies 0.1 – 8.2% vehicle miles travelled (VMT) reduction CAPCOA page 276, TST‐3 Very High Increase Transit Service Frequency/Speed Metro and other Transit Agencies 0.02 – 2.5% VMT reduction CAPCOA page 280, TST‐4 Purchase of new vehicles or more vehicles run Provide a Bus Rapid Transit System Metro and other Transit Agencies 0.02 – 3.2% VMT reduction CAPCOA page 270, TST‐1 High, if new system Providing incentives or subsidies that increase the use of modes other than single‐occupancy vehicle Metro and other Agencies 0.3 – 20.0% commute VMT reduction CAPCOA page 230, TRT‐4 Improve or increase access to transit. Local Agency in coordination with Metro Not quantified CAPCOA page 275, TST‐2 Small investments in pedestrian and bicycle connections, may include park and ride improvements Implementing or funding off‐site travel demand management Various including Metro Not Quantified Variable Increase Destination Accessibility Metro and other Transport. Agencies 6.7 – 20% VMT reduction CAPCOA page 167, LUT‐4 Site specific Deploy management strategies (e.g., pricing, vehicle occupancy requirements) on roadways or roadway lanes Local Agency Not Quantified Likely on adjacent roadways Create Urban Non‐Motorized Zones Local Agency 0.01 – 0.2% annual VMT reduction Likely on adjacent roadways Source: Analysis of VMT Mitigation Measures Pursuant to SB 743 (February 23, 2018, Prepared by Iteris, Inc. for Metro)