Background information to Development of TIA Guidelines for City of Buena Park

Background Information

Senate Bill 743 (SB 743), signed by the Governor in 2013, significantly altered the way transportation impacts are identified and assessed under the California Environmental Quality Act (CEQA). The bill directed the Office of Planning and Research (OPR) to explore alternative metrics for evaluating transportation-related environmental impacts, moving away from traditional methods that primarily focused on vehicle delay. In December 2018, OPR released its final guidelines, identifying Vehicle Miles Traveled (VMT) as the preferred metric for determining transportation impacts. Subsequently, the Natural Resources Agency completed the rulemaking process to incorporate these changes into the CEQA Guidelines in December 2018. Under these revised guidelines, all lead agencies were required to adopt VMT as the new transportation metric for evaluating land use project impacts by July 2020.

Recognizing the need for a coordinated and informed approach to the implementation of VMT-based impact analysis, seven North Orange County cities—Fullerton, La Habra, Brea, Buena Park, Orange, Placentia, and Yorba Linda—formed a collaborative effort. This coalition initiated the North Orange County Cities (NOCC) SB 743 Implementation Study to address key questions surrounding the methodology, significance thresholds, and mitigation strategies for VMT impact assessment. The NOCC study consists of the following primary components:

• Thresholds Evaluation Memorandum – This document outlines potential thresholds of significance that North Orange County cities could consider when establishing VMT assessment criteria.

• Sample Projects Memorandum – This memorandum examines different project types that could be subject to VMT impact assessment and provides guidance on how these assessments should be conducted.

• Tools Evaluation Memorandum – This report evaluates various tools available for estimating VMT, highlighting the advantages and disadvantages of each.

• Mitigation Memorandum – This document identifies potential mitigation strategies for addressing VMT impacts.

• VMT Screening and Mitigation Testing Tool – A spreadsheet-based tool currently under development, intended to facilitate VMT screening for proposed projects. Once completed, this tool will be available for use by all seven participating cities.

Each of the North Orange County cities can use the findings from the NOCC Implementation Study to develop and adopt their own methodologies and significance thresholds for CEQA compliance. According to CEQA Guidelines Section 15064.7(b), lead agencies are encouraged to formally adopt their thresholds of significance as part of their environmental review process. The guidelines emphasize that thresholds adopted for general application should be developed through a public review process and supported by substantial evidence. Lead agencies also retain the flexibility to determine thresholds on a case-by-case basis as permitted under CEQA Guidelines Section 15064(b)(2).

To ensure compliance with SB 743 and the revised CEQA Guidelines, the City of Buena Park has developed these Transportation Impact Analysis (TIA) Guidelines. This document outlines the steps necessary for evaluating transportation impacts using VMT and aligns these requirements with the city's general plan consistency standards related to level of service (LOS).

Importance of Level of Service (LOS) in Transportation Planning

While SB 743 shifts CEQA transportation impact assessment from LOS to VMT, the City of Buena Park continues to maintain LOS standards for evaluating local infrastructure performance. LOS standards apply to discretionary approvals of new land use and transportation projects. Consequently, these TIA guidelines include provisions for conducting LOS analyses consistent with the city's requirements, even though LOS is no longer the primary determinant of CEQA transportation impacts.

Guidelines Organization

This document is structured to provide a clear and logical approach to transportation impact assessment under SB 743 and CEQA. The sections are organized as follows:

1. Introduction

2. Non-CEQA Transportation Assessment

3. CEQA Assessment - VMT Analysis

4. CEQA Assessment - Active Transportation and Public Transit Analysis

5. Transportation Impact Analysis Format

VMT Guidelines and Requirements

Federal and state laws mandate that land use intensities outlined in a city’s General Plan must be compatible with the capacity of the local transportation network. To ensure compliance with these legal requirements, the City of Buena Park requires a Traffic Impact Analysis (TIA) for proposed developments. A TIA helps assess the effects of a project on the existing and future circulation system and ensures adherence to CEQA and Congestion Management Program (CMP) guidelines.

The TIA requirements outlined in this document apply to any individual or entity proposing development in the City of Buena Park. Developers must use these guidelines in conjunction with the city’s local CEQA Guidelines and Municipal Code to navigate the project review and approval process.

Shifts in CEQA Requirements Due to SB 743

Traditionally, the TIA process was integrated into CEQA review, with assessments primarily focusing on intersection and roadway segment LOS. However, with the enactment of SB 743, the TIA process has evolved. In some cases, a TIA may now be required as a stand-alone document separate from the CEQA process. While this document may still contain valuable information for decision-makers, it no longer serves as the primary basis for CEQA impact determination.

The primary purpose of these TIA Guidelines is to provide a structured approach for analyzing the transportation impacts of proposed development projects. These guidelines present the recommended methodologies and formatting standards that should generally be followed in the preparation of TIAs.

Key Changes Introduced by SB 743

Since the last update to the City of Buena Park's TIA Guidelines, the passage of SB 743 has fundamentally changed the way transportation impacts are evaluated under CEQA. A crucial aspect of this legislative change is the elimination of auto delay, LOS, and other traditional measures of vehicular capacity or congestion as the basis for determining the significance of environmental impacts. This shift aims to better align transportation impact analysis with statewide goals related to:

• Promoting infill development

• Enhancing public health through increased active transportation

• Reducing greenhouse gas (GHG) emissions

SB 743 and Congestion Management Planning

SB 743 also introduced amendments to California’s congestion management laws, granting cities and counties the ability to opt out of LOS standards that would otherwise apply under local Congestion Management Plans (CMPs). While many regions, including Orange County, still use CMPs, the legislative changes allow local jurisdictions to shift their focus toward VMT-based analysis without conflicting with state congestion management requirements.

Additionally, SB 743 directed OPR to update the CEQA Guidelines and establish criteria for determining the significance of transportation impacts. Following extensive public engagement and input from government agencies, organizations, and stakeholders, OPR finalized its recommendations in December 2018. These guidelines identified VMT as the most suitable metric for evaluating transportation impacts of land use projects and land use plans. For transportation infrastructure projects, lead agencies retain the flexibility to choose their preferred impact assessment metric, provided they substantiate their decision with substantial evidence that aligns with CEQA expectations.

Retention of LOS for Non-CEQA Purposes

Although SB 743 mandates the use of VMT for CEQA transportation impact analysis, cities and counties may continue using LOS metrics for other planning and policy purposes. LOS analysis remains relevant for:

• General Plan transportation planning

• Development impact fee programs

• Corridor studies

• Congestion mitigation efforts

• Ongoing transportation network monitoring

However, under SB 743, LOS can no longer be the sole criterion for determining CEQA transportation impacts.

Conclusion

SB 743 represents a fundamental shift in how transportation impacts are evaluated in California. By replacing LOS with VMT as the primary CEQA transportation metric, the legislation supports broader state goals related to reducing congestion, encouraging sustainable development, and mitigating climate change. The City of Buena Park's updated TIA Guidelines provide a structured framework for implementing these changes while ensuring continued compliance with CEQA and local transportation planning requirements. Developers and consultants should remain informed about updates to CEQA regulations and consult with city staff to ensure they are using the most current guidelines for assessing transportation impacts in Buena Park.

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