CEQA Transportation Analysis Requirements VMT – Land Use Projects for the Culver City
CEQA Threshold
Would the project conflict or be inconsistent with CEQA Guideline Section 15064.3(b)(1)?
Screening Criteria
A development project can be cleared from conducting a Vehicle Miles Traveled (VMT) impact analysis if it meets any of the following thresholds, which suggest a less than significant impact:
- Small Projects: Projects resulting in less than 250 daily or 25 peak-hour trips.
- Proximity to Key Transit Priority Areas (TPAs): Projects within a ½ mile from the Metro E (Expo) Line Culver City Station, Metro E (Expo) Line La Cienega Station, Westfield-Culver City Transit Center, or Sepulveda/Venice Boulevard intersection. This threshold may be updated as TPAs change.
- Affordable Housing in TPAs: Projects located within any TPA where at least 15% of on-site residential units are affordable.
- 100% Affordable Housing Projects: Projects where all dwelling units are affordable.
- Local Serving Retail Projects: Retail projects with less than 50,000 square feet in size at a single store.
For mixed-use projects, only the specific land use components meeting these criteria may be screened, while other components must still undergo VMT impact analysis.
Impact Analysis
VMT thresholds for land use projects in Culver City are outlined in Table 2:
| Use | Metric | Threshold |
|---|---|---|
| Residential | Daily home-based VMT/capita | 15% below existing levels |
| Work | Daily home-based-work VMT/employee | 15% below existing levels |
| Regional Retail | Total VMT | Any net positive change in citywide VMT |
If a project’s VMT per capita or per employee is less than 15% below the threshold, it is considered to have a significant impact. For regional-serving retail, any net increase in VMT is considered significant.
Methodology
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Residential VMT per Capita: Calculated using the Culver City VMT Evaluation Tool and User Guide, which determines daily trips generated and VMT per capita for the project. Travel demand management (TDM) measures should be included in the analysis.
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Work VMT per Employee: Calculated using the Culver City VMT tool, which assesses daily trips generated and VMT per employee. Any TDM measures should be incorporated.
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Regional Serving Retail VMT: Assessed for their impact on vehicle trip length and VMT using the Culver City Travel Demand Forecast Model (TDFM) with a four-step process. Local serving retail projects (less than 50,000 square feet) are screened out from the VMT analysis.
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Mixed-Use Projects: Components of a mixed-use project are evaluated independently using the appropriate thresholds for each land use type. Internalization of trips must be accounted for to accurately assess VMT. All components should be included in the tool for analysis.
Mitigation Measures
To mitigate VMT impacts for land use projects, the focus is on reducing the number of people driving alone to the project site through a Transportation Demand Management (TDM) program. Effective TDM measures may include:
- Carpooling and vanpooling incentives.
- Pricing parking and reducing parking supply.
- Pedestrian-oriented design.
- Commute marketing programs promoting non-driving options.
- Incentives for using transit or alternative modes of transportation, like transit vouchers or bike-share memberships.
- Financial contributions towards enhancing transit frequency or providing shuttle services.
TDM measures are particularly applicable to larger developments (non-residential projects >25,000 gross square feet). Only TDM measures listed in the VMT evaluation tool, backed by research, are deemed effective for mitigating VMT impacts. Other measures may be considered if sufficient evidence is provided and accepted by the City of Culver.
TDM Program Monitoring and Reporting
For certain projects, the City of Culver may require:
- Annual Monitoring and Reporting: Collection of trip data to evaluate the TDM program's effectiveness.
- Conditions of Approval: Implementation of TDM measures to reduce vehicle trips, with specific monitoring methods and potential penalties.
- Enforcement Measures: If conditions are not met, the City may utilize penalty charges or other financial measures to enhance TDM efforts.
The Culver City monitoring program includes evaluating the effectiveness of the TDM measures and making necessary adjustments based on the results.
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