California Environmental Quality Act (CEQA) Transportation Impact Analysis for the project in City of Manhattan Beach

Section 3: California Environmental Quality Act (CEQA) Transportation Impact Analysis

The California Environmental Quality Act (CEQA) requires the use of vehicle miles traveled (VMT) as the metric to evaluate transportation impacts resulting from development projects, transportation plans, and infrastructure developments. These guidelines, aligned with recommendations from the Office of Planning and Research (OPR) and the California Air Resources Board (CARB), outline procedures to measure VMT, establish thresholds of significance, and provide recommendations for mitigation measures. The guidelines apply to projects within the City and are intended to ensure compliance with CEQA for transportation impact analyses.

Section 3.1: CEQA Transportation Impact Analysis (TIA) for Development Projects

For development projects, the primary goal of the CEQA TIA is to determine whether a proposed project or plan reduces total VMT in a manner that avoids significant environmental impacts. The City has developed criteria for screening and impact analysis to guide this process. The screening criteria assess whether a TIA is required, while impact criteria determine when significant transportation impacts are expected. Any interpretation of these guidelines for a specific project shall be made in coordination with the City.

Section 3.1.1: Screening Criteria

3.1.1.1 Non-Retail Project Trip Generation Screening

According to CEQA Guidelines (§15301(e)(2)), certain project types, such as general office buildings and business parks, generate a relatively linear increase in trip generation proportional to the building footprint, typically producing 110-124 trips per 10,000 square feet. Projects adding 110 or fewer trips are presumed to have less-than-significant transportation impacts unless there is substantial evidence to the contrary.

Projects meeting these conditions may qualify for a CEQA categorical exemption, provided the development occurs in areas with sufficient public infrastructure and avoids environmentally sensitive areas. In such cases, no further analysis is required if the answer to the following question is NO:

• Does the non-retail project generate a net increase of 110 or more daily vehicle trips?

To determine trip generation, the most recent edition of the Institute of Transportation Engineers (ITE) Trip Generation Manual should be used. If the project land use is not included in the ITE Manual, a customized trip generation study must be reviewed and approved by the City Traffic Engineer.

3.1.1.2 Retail Project Site Plan Screening

Local-serving retail projects generally have a less-than-significant VMT impact unless the retail portion exceeds 50,000 square feet of gross floor area. If the answer to the following question is NO, the project’s retail component can be determined to have a less-than-significant VMT impact:

• Does the retail project exceed 50,000 square feet of gross floor area?

For mixed-use projects that include retail components exceeding the screening threshold, the entire project must be evaluated for VMT impacts.

3.1.1.3 Proximity to Transit Screening

CEQA Guidelines (§15064.3(b)(1)) suggest that projects located within ½ mile of a major transit stop or a high-quality transit corridor generally have less-than-significant VMT impacts. A major transit stop includes rail stations or intersections with frequent bus service (15-minute intervals or less during peak hours). The Metro C Line Douglas Station is the only major transit stop within Manhattan Beach.

The following question should be considered to determine if the project qualifies for a presumption of less-than-significant VMT impact:

• Is the project located within ½ mile of a major transit stop or a high-quality transit corridor?

If the answer is YES, the following additional questions should be answered to confirm that the project meets transit-oriented criteria:

• Does the project have a floor area ratio (FAR) less than 0.75?
• Does the project provide more parking than required by the City?
• Is the project inconsistent with the SCAG Regional Transportation Plan/Sustainable Communities Strategy (RTP/SCS)?
• Does the project replace lower-income housing with fewer market-rate units?

If all answers are NO, further analysis is not required, and a less-than-significant determination can be made.

3.1.1.4 Residential Land Use Screening

Residential projects that generate fewer than 110 net vehicle trips per day are assumed to have a less-than-significant transportation impact. No further analysis is required if the following condition is met:

• Does the residential development generate a net increase of 110 or more daily vehicle trips?

Section 3.1.2: Impact Criteria

A project has a potentially significant VMT impact if it meets one or more of the following criteria:

• Residential Projects: The project's residential VMT per capita is not at least 16.8% below the current baseline.
• Non-Retail/Office Projects: The project’s employment VMT per employee is not at least 16.8% below the current baseline.
• Regional Serving Retail Projects: The project results in a net increase in total VMT.
• Land Use Plans: The plan’s VMT per service population (residents and employees) is not at least 16.8% below the baseline.

For other land use types, developers should consult the City Traffic Engineer to determine applicable thresholds of significance.

Table 3-1: VMT Impact Criteria (16.8% Below Baseline)

Section 3.1.3: Methodology

The SCAG RTP/SCS serves as the regional transportation plan to ensure compliance with air quality and greenhouse gas (GHG) reduction goals. The City utilizes the RTP/SCS Travel Demand Forecast Model, which accurately estimates VMT on a regional scale without respect to local boundaries. The model helps calculate VMT for development projects, considering transportation demand management (TDM) strategies incorporated into the project design.

3.1.3.1 Project Impact Determination

• Residential Projects: Estimate daily vehicle trips, VMT, and residential VMT per capita using the SCAG RTP/SCS model.
• Office Projects: Estimate daily vehicle trips, VMT, and employment VMT per employee using the SCAG RTP/SCS model.
• Regional Serving Retail Projects: Use either a market-study-based transportation analysis or the SCAG RTP/SCS model to estimate VMT, as outlined in the TIA Scope of Work document.
• Land Use Plans: Estimate daily vehicle trips, VMT, and VMT per service population using the SCAG RTP/SCS model.
• Unique Land Uses: For projects that do not fit into the above categories, a customized approach may be required. The developer’s traffic consultant, in consultation with the City Traffic Engineer, should propose the methodology and thresholds in the TIA Scope of Work.

Mixed-use projects should be evaluated for VMT impacts across all land uses, considering internal trip capture rates. If any component exceeds the impact criteria, the entire project’s VMT may need mitigation.

3.1.3.2 Cumulative Impacts Determination

In addition to short-term project effects, cumulative impacts should be evaluated based on consistency with the SCAG RTP/SCS. Projects that align with the RTP/SCS in terms of development location, density, and intensity are considered to have a less-than-significant cumulative VMT impact.

For projects not consistent with the RTP/SCS or demonstrating significant VMT impacts, further analysis is required. The SCAG RTP/SCS model can be run with both "no project" and "plus project" scenarios to determine the project's long-term impact on regional VMT. Significant deviations from RTP/SCS projections would indicate a significant cumulative impact.

Section 3.1.4: Mitigation

3.1.4.1 Development Project Mitigations

Mitigation measures for development projects with significant VMT impacts may include transportation demand management (TDM) strategies, such as:

• Commute trip reduction programs with monitoring
• Ridesharing programs and transit subsidies
• Reducing parking supply or unbundling parking
• Improving transit access and reducing headways
• Promoting car-sharing or bike-sharing programs
• Enhancing pedestrian and bicycle infrastructure

The effectiveness of TDM measures must be supported by substantial evidence and tailored to the specific project.

3.1.4.2 Land Use Plans Mitigations

For land use plans, mitigation measures may include:

• Reallocation of land uses to increase density and diversity in transportation-efficient areas
• Enhancing public transit systems and connections, including active transportation infrastructure
• Reducing automobile reliance by promoting alternative transportation modes
• Expanding bicycle or low-speed vehicle networks

By implementing these mitigation strategies, projects can reduce VMT impacts and contribute to achieving regional transportation and environmental goals.

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