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CEQA Assessment – Land Use Project VMT Analysis for City of Fountain Valley

VMT Analysis and Transportation Impact Guidelines

Overview

A key provision of SB 743, signed into law in 2013, is the shift away from automobile delay and Level of Service (LOS) as the sole basis for determining transportation impacts in California Environmental Quality Act (CEQA) documents. Instead, the most recent CEQA guidelines, released in December 2018, recommend Vehicle Miles Traveled (VMT) as the preferred metric for assessing project transportation impacts. While SB 743 eliminates LOS from CEQA analysis, cities and counties may continue to analyze delay or LOS for other purposes, such as general plans, studies, or network monitoring.

This document provides recommendations for determining VMT impact thresholds and mitigation requirements for Transportation Impact Analyses (TIAs) for various land use projects. These guidelines aim to ensure compliance with SB 743 and align with the City of Fountain Valley’s transportation and land use objectives.

VMT Analysis Methodology

To comply with SB 743, VMT analysis should be conducted for land use projects identified by the City Engineer and/or Public Works Director as having the potential to increase the average VMT per service population (population plus employment) relative to the City of Fountain Valley boundary. This metric provides a measure of transportation efficiency and allows for comparison between a proposed project and the city as a whole to identify transportation impacts.

Steps in VMT Assessment

  1. Project Screening: Evaluate if a full VMT assessment is required based on project type or location.

  2. Full VMT Impact Assessment: If a project is not screened out, conduct a detailed analysis using the OCTA travel forecasting model.

  3. Mitigation: Implement measures to address significant VMT impacts, as needed.

Project Screening

Projects may qualify for screening under three criteria:

Step 1: Transit Priority Area (TPA) Screening

Projects located entirely within a TPA can be presumed to have a less-than-significant impact unless substantial evidence suggests otherwise. TPAs are defined as areas within a half-mile of:

  • An existing major transit stop (e.g., rail transit station, ferry terminal, or intersection of major bus routes with service intervals of 15 minutes or less during peak hours).

  • A high-quality transit corridor with fixed-route bus service at intervals of 15 minutes or less during peak hours.

Projects in TPAs will not qualify for screening if they:

  1. Have a Floor Area Ratio (FAR) below 0.75.

  2. Include more parking than required by the City.

  3. Are inconsistent with the applicable Sustainable Communities Strategy.

  4. Replace affordable housing with fewer moderate- or high-income units.

Step 2: Low VMT Area Screening

Projects located in low VMT-generating areas can be presumed to have a less-than-significant impact unless substantial evidence suggests otherwise.

  • Low VMT-generating areas are identified using the OCTAM travel forecasting model, which measures VMT performance for individual Traffic Analysis Zones (TAZs) in the City and Orange County.

  • Analysts must verify that the project’s land use is consistent with the TAZ’s existing land use and does not uniquely increase trip rates or lengths.

Step 3: Project Type Screening

Local-serving projects that inherently reduce vehicle trips may be presumed to have a less-than-significant impact. Examples include:

  • Local-serving retail under 50,000 square feet.

  • Local-serving K-12 schools, parks, daycares, and community institutions (e.g., libraries, fire stations).

  • Affordable housing, senior housing, and assisted living facilities.

  • Projects generating fewer than 110 net new daily vehicle trips (e.g., 11 single-family homes, 16 multi-family units, or 10,000 sq. ft. of office).

  • Minor expansions, interior modifications, or re-tenanting of existing non-residential space.

VMT Assessment for Non-Screened Projects

Projects that do not meet screening criteria must complete a detailed VMT analysis. The analysis must estimate project-generated VMT and project effects on citywide VMT under the following scenarios:

  • Baseline Conditions: Data already available from OCTAM.

  • Baseline Plus Project: Add the project to the baseline model and compare VMT changes for the project’s TAZ and the citywide network.

  • Cumulative No Project: Use OCTAM’s cumulative no project data.

  • Cumulative Plus Project: Add project land uses to the cumulative scenario and reallocate land uses across other TAZs as necessary.

The project’s impact is determined by comparing generated VMT and effects on citywide VMT to established thresholds of significance.

CEQA VMT Impact Thresholds

A project would result in a significant VMT impact if:

  1. Baseline or cumulative project-generated VMT per service population exceeds the City’s General Plan Build-Out average VMT per service population.

  2. The cumulative citywide VMT per service population increases with the project compared to the no project condition.

Projects consistent with the Regional Transportation Plan/Sustainable Communities Strategy (RTP/SCS) are generally considered to have less-than-significant cumulative impacts.

VMT Mitigation Measures

If a project results in significant VMT impacts, mitigation options include:

  1. Modifying the project’s built environment to reduce VMT.

  2. Implementing Transportation Demand Management (TDM) measures.

  3. Participating in a VMT fee or mitigation banking program.

Transportation Demand Management (TDM)

Key TDM measures include:

  • Encouraging active transportation (e.g., bike lanes, sidewalks).

  • Improving access to transit.

  • Providing shared mobility options.

The effectiveness of TDM measures must be demonstrated using industry-accepted methodologies, with a maximum assumed VMT reduction of 10%. Monitoring and enforcement may be required to ensure compliance.

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