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Detailed VMT Analysis for development projects in the City of Dublin

4.3 Detailed VMT Analysis

Projects that do not meet the City of Dublin’s Vehicle Miles Traveled (VMT) screening criteria are required to undergo a comprehensive evaluation of the VMT generated by the project. The assessment of a project’s impact on VMT involves comparing its generated VMT to the VMT thresholds established by the City. This section outlines the methodologies, thresholds, and considerations for conducting a detailed VMT analysis for various project types, ensuring compliance with the California Environmental Quality Act (CEQA) guidelines and the City’s adopted standards.

VMT Metrics and Their Applications

The City of Dublin has identified three key VMT metrics to assess transportation impacts for development projects:

  1. VMT per Capita: This metric applies to residential projects and includes all home-based trips made by residents, including trips made while residents are away from home. Trips visiting residences, such as delivery van trips, are excluded.

  2. VMT per Employee: This metric is used for projects providing employment in non-retail settings. It includes trips made by employees to and from their workplaces, as well as trips to and from points other than the employees’ homes. Visitors to employment sites are not included.

  3. Total VMT: This metric evaluates retail and similar projects by estimating the change in the overall VMT for the region with and without the project.

4.3.1 Efficiency Metrics: VMT per Capita and VMT per Employee

For residential and employment land uses where VMT per capita or VMT per employee metrics are applied, the following analysis methods are recommended:

  • Use of Screening Maps: The VMT per capita or VMT per employee can be determined using the City’s latest screening maps and the Transportation Analysis Zone (TAZ) containing the project site. This method is applicable when the project’s land use is similar to surrounding land uses.

  • TAZ Data Adjustments: If the TAZ value is zero due to a lack of land use data for the existing condition, the City may permit the VMT per capita or VMT per employee to be based on an average of surrounding TAZs, provided the land uses are similar to the proposed project.

  • Direct Calculation: Alternatively, the VMT per capita or VMT per employee can be directly calculated using data about the number of residents or employees, mode share, and average trip length.

4.3.2 Total VMT

For projects assessed using total VMT (e.g., retail projects), the following methods are used:

  • Smaller Projects: Total VMT can be calculated by multiplying the total daily vehicle trip generation (based on references such as the Institute of Transportation Engineers Trip Generation Manual) by an average trip length derived from the travel demand model or a market research analysis.

  • Larger Projects: For larger projects that significantly affect the balance of residential and non-residential land uses in the area, it is recommended to rerun the travel demand model to include the proposed project. The total regional VMT with and without the project is then compared.

4.3.3 Exclusion of Truck VMT

Under SB 743, the VMT associated with goods movement (trucks) is not required to be analyzed or mitigated for transportation impacts. CEQA Guidelines Section 15064.3 defines transportation impacts based on the “amount and distance of automobile travel.” However, projects generating substantial truck traffic also create associated automobile trips, which are subject to VMT analysis and mitigation. Additionally, truck-related VMT is calculated for other environmental analyses, including air quality, greenhouse gas emissions, noise, and energy impacts.

4.3.4 Thresholds of Significance

The City of Dublin has established the following thresholds to determine the significance of VMT impacts for various development projects:

  • Residential Projects: A project’s VMT per capita must be at least 15% below the existing Planning Area 4 average to avoid significant impacts.

  • Office Projects: A project’s VMT per employee must be at least 15% below the existing Planning Area 4 average to avoid significant impacts.

  • Retail Projects: A significant impact occurs if a project causes a net increase in total VMT. The net change in total VMT is determined by comparing total VMT for Planning Area 4 with and without the project.

  • Other Development Projects: For other types of development, the applicable thresholds are determined on a case-by-case basis, based on the land use type, project description, and setting.

    • For example, student housing and senior housing are typically analyzed as residential projects, while research and development, industrial, medical offices, and hospital projects are evaluated as office projects using the VMT per employee metric. Projects such as hotels, private schools, religious institutions, and regional parks are analyzed using the total VMT metric.

  • Mixed-Use Projects: For mixed-use developments, each component is evaluated independently using the applicable thresholds for each land use type. Alternatively, if a dominant use generates at least 80% of the project’s total daily trips, the evaluation may apply to the dominant use only.

4.3.5 Redevelopment Projects

Redevelopment projects are analyzed as follows:

  • If the project replaces existing uses and results in a similar or reduced overall VMT, it is presumed to have a less than significant impact.

  • If the project replaces existing uses and leads to a net increase in VMT compared to the previous uses, thresholds for the new land use type apply. For example, a residential project replacing an office use would be evaluated using the VMT per capita metric for residential projects. For mixed-use redevelopment projects, the recommended mixed-use methodology applies.

4.3.6 Land Use Plans

For land use plans, such as specific plans, community plans, or general plan updates, the analysis must compare existing VMT metrics (e.g., VMT per capita or VMT per employee) to the projected metrics for the plan’s horizon year. If the plan results in a net increase in VMT metrics, it may have a potentially significant impact. The most current travel demand model—either the Alameda Countywide or City of Dublin model—must be used to calculate the VMT.

4.3.7 Cumulative Impacts

CEQA Guidelines Section 15064(h)(1) states that cumulative impacts should be assessed based on whether a project’s contribution to a cumulative impact is “cumulatively considerable.” The cumulative analysis considers the following:

4.3.7.1 VMT per Capita or VMT per Employee

For projects evaluated using efficiency metrics (VMT per capita or VMT per employee), a project that falls below the threshold under existing conditions is presumed to have less than significant cumulative impacts. Such projects are not considered to contribute additional cumulative impacts distinct from their individual impacts.

4.3.7.2 Total VMT

For projects analyzed using total VMT, a cumulative VMT analysis must account for future travel patterns and total VMT trends. A cumulative impact occurs if the project causes an increase in total VMT for the region under future conditions, similar to the evaluation of existing conditions.

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