CEQA Transportation Assessment - VMT Analysis: City of Pomona
Introduction
The California Environmental Quality Act (CEQA) mandates that transportation impacts from land development projects be analyzed to evaluate their effects on environmental and transportation systems. With the adoption of Senate Bill (SB) 743, the state of California moved from focusing on automobile delay to evaluating transportation efficiency through Vehicle Miles Traveled (VMT) as a metric for assessing transportation impacts under CEQA. The City of Pomona, as part of its compliance with SB 743, has implemented VMT analysis methodologies, project screening criteria, and thresholds of significance to ensure sustainable transportation development within the city.
This assessment provides guidelines for analyzing VMT impacts for new projects in Pomona, ensuring consistency with the latest CEQA requirements. The objective is to promote more sustainable transportation by reducing the generation of VMT, which aligns with state and regional efforts to reduce greenhouse gas (GHG) emissions and air pollution.
VMT Analysis Methodology
The VMT analysis applies to land use projects that could potentially increase baseline VMT per service population (i.e., the sum of residents and employees). Normalizing VMT by service population provides a transportation efficiency metric used for determining the environmental impacts of the project. All assumptions and methodologies must be reviewed and approved by the City Traffic Engineer.
The City of Pomona has developed a web-based tool to assist with VMT assessments and mitigation recommendations. This tool, accompanied by a user guide, facilitates project screening and analysis. Key steps in the VMT analysis process are outlined below and include screening procedures to determine whether a detailed project-level VMT analysis is required.
Project Screening
Screening procedures are used to identify projects that may be exempt from detailed VMT analysis. There are three types of screening applicable:
1. Transit Priority Area (TPA) Screening
Projects located within a designated TPA, which includes areas within a half-mile of major transit stops or high-quality transit corridors, may be presumed to have a less-than-significant impact on VMT. However, there are exceptions to this presumption. Projects may not qualify for this screening if:
- The Floor Area Ratio (FAR) is less than 0.75.
- The project provides more parking than required by the City.
- The project is inconsistent with the regional Sustainable Communities Strategy (SCS).
- The project replaces affordable housing with fewer moderate- or high-income units.
To confirm eligibility for TPA screening, analysts must verify the project’s location within a TPA using maps provided by the San Gabriel Valley Council of Governments (SGVCOG) VMT assessment tool. Additionally, the availability and frequency of transit services must be checked with local providers to account for any recent changes.
2. Low VMT Area Screening
Residential and office projects located within a low VMT-generating area can be presumed to have a less-than-significant VMT impact. Mixed-use projects may also qualify if the project’s VMT generation is expected to match existing land uses in the area.
The SCAG travel forecasting model is used to evaluate VMT performance for specific traffic analysis zones (TAZs). Projects in low VMT areas should not alter the built environment in ways that increase vehicle trip rates or distances. The SGVCOG VMT Evaluation Tool helps identify whether a project is within a low VMT area. Two metrics can be used for screening:
- Total VMT per Service Population.
- Home-Based VMT per capita or Home-Based Work VMT per employee.
3. Project Type Screening
Certain local-serving projects are assumed to generate minimal VMT and can be screened from detailed analysis. These include:
- Local-serving schools, parks, daycare centers, and libraries.
- Retail projects under 50,000 square feet.
- Affordable and senior housing, assisted living, and transitional housing.
- Local-serving hotels, restaurants, and medical services.
- Projects generating fewer than 110 daily vehicle trips, such as small housing or office developments.
Local-serving retail projects, in particular, are presumed to reduce overall VMT by shortening travel distances for existing residents. These projects must demonstrate that they serve the existing community rather than generate new demand.
VMT Assessment for Non-Screened Development
Projects not exempt through screening must undergo a full VMT analysis. This includes modeling project-generated VMT using the SCAG model or a sub-area model approved by the City Traffic Engineer. The analysis involves evaluating both project-generated VMT and the project’s effect on VMT across a larger network.
Analysis Scenarios
Several scenarios are modeled to evaluate VMT impacts:
- Baseline Conditions: Represents existing travel patterns and VMT levels at the time of the Notice of Preparation (NOP).
- Baseline Plus Project: Adds the proposed project’s land use to the baseline model and evaluates how it changes VMT levels.
- Cumulative No Project: Represents future travel patterns without the proposed project.
- Cumulative Plus Project: Evaluates the impact of the proposed project on future VMT, considering the regional growth and development.
The model outputs include total VMT for all trips and trip purposes, as well as VMT per service population, which is used to assess transportation efficiency. For projects that do not result in significant baseline VMT increases, cumulative analysis may not be necessary.
VMT Forecasting
Project-generated VMT is extracted from the model using origin-destination trip matrices and assignment skims. The project's effect on VMT is estimated by analyzing changes in VMT at the network level. In some cases, for retail or office projects, it may be necessary to isolate Home-Based Work (HBW) VMT to focus on commute-related impacts.
CEQA VMT Impact Thresholds
The City of Pomona has established VMT impact thresholds based on CEQA requirements and state guidelines. A project is considered to have a significant VMT impact if:
- The project-generated VMT per service population exceeds 15% below the baseline VMT for the SGVCOG Southeast Subarea.
- For residential projects, if the home-based VMT per capita exceeds the threshold.
- For office and employment-generating projects, if the home-based work VMT per employee exceeds the threshold.
The analysis compares project-generated VMT to these benchmarks to determine whether the project’s VMT impacts are significant.
Mitigation Measures
For projects with significant VMT impacts, mitigation measures must be developed. These may include:
- Enhancing pedestrian, bicycle, or transit infrastructure to reduce reliance on vehicles.
- Implementing transportation demand management (TDM) strategies, such as carpool programs or telecommuting incentives.
- Modifying the project’s land use to reduce VMT generation, such as reducing parking availability or increasing density.
The effectiveness of mitigation measures must be quantified to ensure they sufficiently reduce VMT to below the significance threshold.
Conclusion
The VMT analysis for the City of Pomona under CEQA ensures that new development projects align with state and regional transportation goals. By focusing on VMT as a transportation efficiency metric, the City can promote more sustainable growth, reduce greenhouse gas emissions, and improve the overall quality of life for residents and workers. This assessment framework helps identify projects that may have significant transportation impacts and provides pathways for mitigating those impacts through thoughtful planning and design.
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