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CEQA Assessment - VMT Analysis for City of Buena Park Traffic Impact Analysis Guidelines for Vehicle Miles Traveled and Level of Service Assessment

CEQA Guidelines and VMT Analysis for Project Transportation Impacts

The California Environmental Quality Act (CEQA) no longer considers Level of Service (LOS) as the sole measure for assessing transportation impacts. The updated CEQA Guidelines, released in December 2018, recommend Vehicle Miles Traveled (VMT) as the most appropriate measure of transportation-related impacts. However, Senate Bill (SB) 743 does not prevent local jurisdictions from continuing to analyze LOS for general planning, transportation studies, or monitoring purposes.

VMT Analysis Methodology

For compliance with SB 743, the City of Buena Park requires a VMT analysis for land use projects that could potentially increase the baseline VMT per service population (population plus employment). This measure provides a transportation efficiency metric for analysis.

The NOCC+ tool is available to assess project eligibility for screening. This tool helps determine if a parcel is in a Transit Priority Area (TPA) or a low VMT-generating area. The tool also identifies project type-based screening eligibility. Analysts must apply professional judgment to ensure proper screening classification.

Project Screening Criteria

Projects may be screened from project-level VMT assessment through three primary methods:

1. Transit Priority Area (TPA) Screening

Projects in a TPA are generally presumed to have a less-than-significant impact unless substantial evidence suggests otherwise. However, the presumption does not apply if the project:

  • Has a Floor Area Ratio (FAR) lower than 0.75.

  • Exceeds the City's parking requirements.

  • Conflicts with the Sustainable Communities Strategy (SCS) as determined by the Southern California Association of Governments (SCAG).

  • Replaces affordable housing units with fewer moderate- or high-income units.

A TPA is defined as a half-mile radius around an existing major transit stop or a high-quality transit corridor, with fixed-route bus service and intervals of 15 minutes or less during peak hours. To verify TPA status, analysts should consult the NOCC+ tool and confirm with local transit providers regarding any recent service changes.

2. Low VMT Area Screening

Residential and office projects in low VMT-generating areas are presumed to have a less-than-significant impact unless substantial evidence indicates otherwise. Mixed-use and employment-based projects may also qualify if they generate VMT levels comparable to surrounding land uses.

OCTAM travel forecasting data estimates VMT per service population at the Traffic Analysis Zone (TAZ) level. Projects should align with existing built environments to avoid increasing trip rates or travel distances. The NOCC+ tool assists in identifying low VMT areas, but analysts must ensure project compatibility with surrounding land use and verify that no unique conditions misrepresent the model results.

3. Project Type Screening

Certain local-serving projects are presumed to have a less-than-significant impact on VMT:

  • Local-serving K-12 public schools

  • Public parks

  • Daycare centers

  • Local-serving retail (under 50,000 sq. ft.), including gas stations, banks, restaurants, and shopping centers

  • Local-serving hotels

  • Student housing adjacent to college campuses

  • Public assembly spaces (places of worship, community organizations)

  • Public institutions (libraries, fire stations, local government buildings)

  • Affordable, supportive, or transitional housing

  • Assisted living and senior housing (as defined by HUD)

  • Projects generating fewer than 836 daily VMT

Retail projects under 50,000 square feet typically reduce VMT by improving local access to goods and services. Analysts can use the NOCC+ tool to confirm whether a project meets the 836 daily VMT threshold.

VMT Analysis for Non-Screened Projects

Projects that do not qualify for screening must undergo a full VMT analysis using the OCTAM model. This includes:

  1. Project-Generated VMT – Compares site-specific VMT to the CEQA significance threshold.

  2. Project Effect on VMT – Evaluates how the project alters VMT across the citywide transportation network.

Analysis scenarios include:

  • Baseline Conditions: Using data from OCTAM and the NOCC+ tool.

  • Baseline Plus Project: Adds project land use to the TAZ and evaluates changes in VMT. If impacts are not significant, further cumulative analysis may not be required.

  • Cumulative No Project: Uses OCTAM projections.

  • Cumulative Plus Project: Assesses future conditions with the project included, considering possible reallocation of land uses from other TAZs.

The model outputs should include total VMT (by speed bin) for air quality, greenhouse gas (GHG), and energy impact analysis. Additionally, VMT per service population should be analyzed to assess transportation impacts.

For some projects, extracting VMT using the production-attraction trip matrix may be necessary, particularly for office and retail projects where home-based work (HBW) trips need isolation. The City should determine the most appropriate methodology based on project land use.

CEQA VMT Impact Thresholds

A project is considered to have a significant transportation impact if:

  • The baseline project-generated VMT per service population exceeds the County of Orange General Plan Buildout VMT per service population.

  • The cumulative project-generated VMT per service population exceeds the County of Orange General Plan Buildout VMT per service population.

A project’s effect on VMT is considered significant if:

  • The citywide VMT per service population increases under the plus project condition compared to the no project condition.

  • The cumulative citywide VMT per service population increases under the plus project condition compared to the no project condition.

If a project aligns with the SCAG Regional Transportation Plan/Sustainable Communities Strategy (RTP/SCS), then cumulative project effects are generally considered less than significant, subject to additional evidence.

VMT Mitigation Strategies

Projects with significant VMT impacts must implement mitigation measures, which may include:

  1. Modifying Project Design – Adjusting land use and site design to reduce VMT.

  2. Implementing Transportation Demand Management (TDM) Strategies – Encouraging alternatives to driving.

  3. Participating in a VMT Fee or Banking Program – Offsetting VMT impacts by funding regional mitigation efforts.

The North Orange County Cities Implementation Study outlines appropriate TDM measures, detailed in Attachment B of the TDM Strategies Evaluation Memorandum. The NOCC+ tool can be used to assess which mitigation strategies will achieve necessary reductions.

TDM strategies should be evaluated using best-practice methodologies, recognizing that many rely on ongoing tenant participation. Monitoring may be required to ensure effectiveness.

Transportation Demand Management (TDM) Plans

Projects with significant VMT impacts must prepare a TDM plan demonstrating how peak-hour and total vehicle trips will be reduced. The plan must include:

  1. Detailed Description – How the TDM plan will be implemented and maintained.

  2. Supporting Evidence – Case studies or empirical data showing expected traffic reductions.

  3. Traffic Impact Calculations – Volume/Capacity ratio calculations illustrating circulation benefits.

  4. Monitoring and Enforcement Measures – Strategies for compliance.

  5. Regulatory Compliance – Alignment with South Coast Air Quality Management District (SCAQMD) regulations.

By implementing these measures, the City of Buena Park aims to reduce VMT impacts, promote sustainable transportation, and align with state environmental goals.

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