CEQA ASSESSMENT - VMT ANALYSIS
Introduction
A key element of SB 743, signed in 2013, is the elimination of automobile delay and Level of Service (LOS) as the sole basis for determining CEQA impacts. The most recent CEQA guidelines, released in December 2018, recommend Vehicle Miles Traveled (VMT) as the most appropriate measure of project transportation impacts. However, SB 743 does not prevent a city or county from continuing to analyze delay or LOS as part of other plans, such as the general plan, studies, or ongoing network monitoring.
Recommendations for Determining VMT Impact Thresholds and Mitigation Requirements
12.1 Analysis Methodology
For SB 743 compliance, a VMT analysis should be conducted for land use projects as deemed necessary by the Traffic Division. This applies to projects with the potential to increase the average VMT per service population (e.g., population plus employment) compared to the County’s boundary. Normalizing VMT per service population provides a transportation efficiency metric that forms the basis of the analysis. Using this efficiency metric allows the user to compare the project to the remainder of the unincorporated area to identify transportation impacts.
These guidelines are based on the SBCTA SB 743 Implementation Study, which provides options for both methodologies and VMT screening. The methodologies and significance thresholds presented below are based on SBCTA recommendations from the Implementation Study.
12.2 Project Screening
There are four types of screening that lead agencies can apply to effectively screen projects from project-level assessment:
Step 1: Transit Priority Area (TPA) Screening Projects located within a TPA may be presumed to have a less than significant impact, absent substantial evidence to the contrary. This presumption may not be appropriate if the project:
- Has a Floor Area Ratio (FAR) of less than 0.75.
- Includes more parking than required by the City requirements.
- Is inconsistent with the applicable Sustainable Communities Strategy.
- Replaces affordable residential units with a smaller number of moderate or high-income residential units.
Step 2: Low VMT Area Screening Residential and office projects located within a low VMT-generating area may be presumed to have a less than significant impact, absent substantial evidence to the contrary. Other employment-related and mixed-use land use projects may qualify for this screening if the project can reasonably be expected to generate VMT per resident, per worker, or per service population similar to the existing land uses in the low VMT area.
For this screening in the SBCTA area, the SBTAM travel forecasting model measures VMT performance for the City of Fontana and individual traffic analysis zones (TAZs). This presumption may not be appropriate if the project land uses would alter the existing built environment in such a way as to increase the rate or length of vehicle trips. Analysts should review the SBCTA screening tool to apply the appropriate threshold and ensure project consistency with existing land use.
Step 3: Low Project Type Screening Local serving retail projects less than 50,000 square feet may be presumed to have a less than significant impact, absent substantial evidence to the contrary. Local serving retail generally improves shopping convenience close to home and reduces vehicle travel. Local serving retail includes supermarkets, restaurants, cafes, coffee shops, dry cleaners, barbershops, salons, walk-in medical clinics, urgent care, auto repair shops, gyms, and dance/yoga studios. Other local serving uses include K-12 schools, parks, day care centers, gas stations, banks, hotels, student housing, places of worship, community institutions, community colleges, affordable housing, assisted living facilities, and senior housing.
Step 4: Projects with Net Daily Trips Less Than 500 ADT Projects generating fewer than 500 average daily trips (ADT) are presumed to have a less than significant impact on VMT. Appendix B, City of Fontana SB 743 Small Project Testing, discusses the application of the 500 ADT screening criteria within the CEQA context. The latest ITE Trip Generation Manual is preferred for calculating trip generation in the City of Fontana. Other sources must be approved by the Engineering Department. The screening criteria trip limit is based on net trip generation after considering pass-by, internal capture, affordable housing, and/or existing land use trips.
12.3 VMT Assessment for Non-Screened Development
Projects not screened through the steps above should complete VMT analysis and forecasting through the SBTAM model to determine if they have a significant VMT impact. This analysis should include 'project generated VMT' and 'project effect on VMT' estimates for the project TAZ (or TAZs) under the following scenarios:
- Baseline conditions.
- Baseline plus project.
- Cumulative no project.
- Cumulative plus project.
The model output should include total VMT and VMT per service population. Total VMT (by speed bin) is needed for air quality, greenhouse gas (GHG), and energy impact analysis, while total VMT per service population is recommended for transportation impact analysis.
Both "plus project" scenarios should summarize two types of VMT:
- Project generated VMT per service population compared to the appropriate benchmark noted in the thresholds of significance.
- Project effect on VMT, comparing how the project changes VMT on the network looking at Citywide or sub-regional VMT per service population compared to the no project condition.
Project-generated VMT should be extracted from the travel demand forecasting model using the origin-destination trip matrix and multiplied by the final assignment skims. The project-effect on VMT should be estimated using a sub-regional boundary and extracting the total link-level VMT for both the no project and with project condition.
In some cases, it may be appropriate to extract the Project-generated VMT using the production-attraction trip matrix, particularly when the project is entirely composed of retail or office uses. This approach helps isolate home-based work (HBW) VMT for commute VMT purposes. The City should evaluate the appropriate methodology based on project land use types and context.
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