CEQA Transportation Analysis
This section outlines the requirements for conducting transportation analyses for projects subject to the California Environmental Quality Act (CEQA), in alignment with the provisions of Senate Bill (SB) 743. Under CEQA, lead agencies are empowered to establish their own significance thresholds and methodologies for technical analyses, reflecting local development patterns, policy objectives, and unique contexts. These decisions must be grounded in substantial evidence to ensure legal and analytical robustness.
Appendix G of the CEQA Guidelines identifies four key questions to assess transportation impacts:
a) Would the project conflict with a program, plan, ordinance, or policy addressing the circulation system, including transit, roadway, bicycle, and pedestrian facilities?
b) Would the project conflict with or be inconsistent with CEQA Guidelines section 15064.3, subdivision (b), which mandates the use of vehicle miles traveled (VMT) as the metric for transportation impact analysis?
c) Would the project substantially increase hazards due to a geometric design feature (e.g., sharp curves or dangerous intersections) or incompatible uses?
d) Would the project result in inadequate emergency access?
Consistent with CEQA Guidelines Section 15064.3, the City of Dublin has established VMT-based thresholds of significance to evaluate when a project’s transportation impacts would be considered significant. Additionally, the City employs specific screening criteria to streamline analyses for qualifying projects, a process referred to as project screening.
Figure 1 illustrates the VMT-based development project analysis process, providing a step-by-step approach to determine if detailed analysis is necessary.
4.1. Consistency with Adopted Plans
The City of Dublin’s adopted plans provide a framework for transportation planning and must be referenced to ensure project consistency with the City’s vision for a safe and efficient transportation system. Major plans include:
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General Plan Land Use and Circulation Element (General Plan)
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Bicycle and Pedestrian Master Plan (Bike and Pedestrian Plan)
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Downtown Dublin Specific Plan (Downtown Dublin Plan)
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Dublin Village Historic Area Specific Plan (Village Historic Plan)
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Eastern Dublin Specific Plan (Eastern Dublin Plan)
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Dublin Crossing Specific Plan (Dublin Crossing Plan)
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Downtown Dublin Streetscape Plan (Streetscape Plan)
All projects must be reviewed against these plans to confirm whether they align with Dublin’s transportation objectives or create conflicts.
4.2. VMT Screening Criteria
The City of Dublin has established five screening criteria to identify projects that are presumed to have less than significant transportation impacts. Projects meeting any one of these criteria do not require a detailed VMT analysis. These criteria are:
4.2.1. Small Projects
Projects generating fewer than 110 vehicle trips per day are presumed to have a less than significant impact on transportation. Table 2 provides examples of small projects that typically meet this threshold:
| Land Use Type | Units/Square Feet | Daily Trips |
|---|---|---|
| Single Family Residential | 10 Dwelling Units | 110 |
| Multi-Family Residential | 11 Dwelling Units | 104 |
| Office | 11,000 SF | 107 |
(Trip estimates are based on the ITE Trip Generation Manual, 10th Edition.)
4.2.2. Affordable Housing
Projects consisting of 100% deed-restricted affordable housing are presumed to have less than significant transportation impacts. If a project includes a mix of affordable and market-rate units, only the affordable portion can be screened out of a detailed VMT analysis.
4.2.3. Local-Serving Retail and Public Services
Retail projects that primarily serve local needs are presumed to have a less than significant VMT impact. Examples include grocery stores, pharmacies, casual dining, fitness centers, and beauty services. To qualify, projects must document their local-serving nature and may require an economic market analysis. Public services such as fire stations, public schools, and neighborhood parks are generally presumed to have less than significant impacts, except for uses like charter schools, which typically attract visitors from a larger geographic area.
4.2.4. High-Quality Transit Areas (HQTAs)
Projects located within ½ mile of major transit stops or high-quality transit corridors are presumed to have less than significant VMT impacts. Major transit stops in Dublin include the West Dublin and Dublin/Pleasanton BART stations. Projects in HQTAs must meet additional criteria, including a minimum floor area ratio (FAR) of 0.75 and parking restrictions, to qualify for screening.
4.2.5. Low VMT Areas
Projects located in traffic analysis zones (TAZs) with VMT per capita or per employee below the City’s adopted thresholds are presumed to have less than significant transportation impacts. This presumption applies to projects with similar land uses to the surrounding area. If a proposed project differs substantially from the surrounding land uses, a detailed VMT analysis may be required.
4.3. Consistency with RTP/SCS
Projects must align with the Metropolitan Transportation Commission’s (MTC) Regional Transportation Plan (RTP) and Sustainable Communities Strategy (SCS). Projects inconsistent with the RTP/SCS may be subject to detailed VMT analysis to determine potential significant impacts.
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