Introduction to CEQA Analysis Requirements for Development Projects in the City of Inglewood

Since the updated CEQA Guidelines were certified and adopted by the California Natural Resources Agency, the Public Works Department recognizes the need to provide information on the assessment of vehicle miles traveled (VMT), thresholds of significance, and mitigation measures for development projects and land use plans. This information should be in accordance with the amended Appendix G question below:

• For a development project, would the project conflict or be inconsistent with CEQA Guidelines section 15064.3, subdivision (b)(1)?

The intent of this question is to assess whether a proposed project or plan adequately reduces total VMT. The following guidance regarding screening and impact criteria to address this question is provided. The following screening and impact criteria are only meant to serve as guidance for projects to determine whether a Traffic Impact Analysis (TIA) is needed, and the criteria to determine if a project generates a significant transportation impact. The criteria shall be determined on a project-by-project basis as approved by the Public Works Department.

3.2.1. Project Screening

Non-Retail Project Trip Generation Screening Criteria

Estimate the development project's daily trip generation using the latest edition of the Institute of Transportation Engineers (ITE) Trip Generation Manual. If the project proposed land use is not listed in the ITE Trip Generation Manual, a trip generation study should be prepared and submitted to the Public Works Department for review and approval.

If the answer to the question "Does the development project generate a net increase of 250 or more daily vehicle trips?" is no, then further analysis is not required, and a less than significant impact determination can be made.

Retail Project Site Plan Screening Criteria

If the answer to the question "Does the project contain retail uses that exceed 50,000 square feet of gross floor area?" is no, then no further analysis is required, and a less than significant impact determination can be made. However, if the retail project is part of a mixed-use project, then the remaining portion of the project may be subject to further analysis in accordance with other screening criteria in this Section. Projects that include retail uses in excess of the Retail Project Site Plan Screening Criteria need to evaluate the entirety of the project's VMT.

Residential Land Use Based Screening Criteria

Independent of the screening criteria for non-retail and retail projects, certain projects that further the State's affordable housing goals are presumed to have a less than significant impact on VMT. If the project requires a discretionary action and the answer is yes to the question "Are 100% of the units, excluding manager's units, set aside for lower-income households?" further analysis is not required, and a less than significant determination can be made.

Additionally, for unique development uses, if the development project results in a net daily trip generation of less than 250 trips, no further analysis is required, and a less than significant impact determination can be made.

3.2.2. VMT Estimating Tools

The recommended VMT estimating tools for land use projects in the City of Inglewood are outlined below:

• The SCAG RTP/SCS Regional Travel Demand Model: The project applicant may utilize the SCAG's RTP/SCS travel demand model working with the City of Inglewood and/or its on-call modeling consultant to estimate VMT efficiency metrics specific to a project as well as the total Citywide VMT. Updates to the socio-economic and demographic data input to the model should be coordinated with the City and/or its on-call modeling consultant and potential updates relative to computation of VMT metrics may be required.
• City of Inglewood VMT Tool: The City's VMT estimating tool can be utilized to estimate VMT efficiency metrics for land use projects. Projects can be located using the assessor's parcel number (APN).

In determining the appropriate VMT estimating tool(s), it should be noted that the VMT tool cannot be used for the purposes listed below, which require conducting a full Inglewood Model run:

• Estimating net changes in VMT and evaluating VMT impacts of regional-serving retail projects, entertainment projects, or event centers
• Estimating changes in cumulative citywide VMT

Project applicants should consult with City staff before utilizing one of these VMT estimating tools.

3.2.3. VMT Methodology & Evaluation; Metrics and Significant Impact Thresholds

VMT Methodology

Utilizing the appropriate tool described in Section 3.2.2, the project VMT should be estimated. The project VMT per capita (household VMT per capita; work VMT per employee) should then be compared with the respective values presented in Table 3.2.3.1 derived from baseline metrics to determine the significance of project impacts.

Evaluation

For the following types of development projects, screening and impact evaluation should be conducted:

• Non-Retail Land Uses:

  • Residential Land Uses:
    • Single-Family dwelling units
    • Multi-Family dwelling units
    • Affordable Housing (for lower-income households)
  • Office, Manufacturing, or Institutional Land Uses:
    • General office
    • Medical office
    • Light industrial
    • Manufacturing
    • Warehousing / self-storage
    • K-12 schools
    • College/university
    • Trade Schools
    • Hotel/motel
    • Hospital
    • Day Care

• Retail Land Uses:

  • General retail
  • Furniture store
  • Gas station/gas station with convenience store
  • Car wash/car wash with convenience store
  • Pharmacy/drugstore
  • Supermarket
  • Restaurant
  • Fast food
  • Bank
  • Health club
  • Auto repair
  • Home improvement superstore
  • Discount store
  • Movie theater

The various land uses described above are not inclusive of every development project type that is reviewed by the Public Works Department and Planning Division, and subject to CEQA. For all other land uses, the appropriate screening criteria and impact evaluation shall be determined on a case-by-case basis by the Public Works Department.

Project Impact Metrics

• Residential Projects: Estimate the daily vehicle trips, daily VMT and daily residential VMT per capita using the VMT estimating tools noted in Section 3.2.2. Any project design features including Transportation Demand Management (TDM) strategies should be accounted for in the estimation of a project's daily vehicle trips and VMT.
• Office Projects: Estimate the daily vehicle trips, daily VMT and daily work VMT per employee using the VMT estimating tools noted in Section 3.2.2. Any project design features including TDM strategies should be accounted for in the estimation of a project's daily vehicle trips and VMT.
• Regional Retail Projects: Local-serving retail projects tend to shorten trips and reduce VMT, whereas regional-serving retail projects tend to lengthen net effective trip lengths potentially increasing VMTs. The Public Works Department will advise the applicant during the preparation of the Scoping Document as to the use of the following methods for impact determination:
  • A market-study prepared by the applicant shall be submitted to the Public Works Department. This study shall demonstrate that the project area is underserved for the proposed retail use and that the project will shorten existing shopping trips by virtue of creating an intervening location between trip origins and current retail destinations.
  • Utilize the appropriate VMT estimating tools specified in Section 3.2.2, as advised by the Public Works Department during the process of preparation of the Scoping Document for the with and without project conditions. Since all these tools use the concept that the overall number of trips in the model is based on the home-based trips and is balanced to home-trip productions, the total number of trips will not be influenced by the introduction of additional retail space. The model will redistribute home-shopping trips from other retail destinations to the proposed retail project destination.

For mixed-use projects with more than 50,000 square feet of retail, the same steps described above should be followed. For the "without" project scenario, include the rest of the proposed land uses and run the model, and then create socio-economic data including the retail component and run the model for the "with" project scenario. Compute the difference in net daily VMTs between the "with" and "without" retail project scenarios.

Event Centers and Regional-Serving Entertainment Venue projects should be evaluated to determine whether the project would result in a net increase in total VMT. Analysis prepared for these uses should follow a special generator (event-based) model methodology to be customized by the applicant and approved by the Public Works Department.

Cumulative Impact Metrics

All development projects should consider short-term and long-term effects on VMT. Short-term effects are evaluated in the detailed project-level VMT analysis. Cumulative effects that are long-term are determined through consistency with the SCAG RTP/SCS. Since the RTP/SCS demonstrates compliance with air quality conformity requirements and GHG reduction targets, projects that are consistent with this regional plan in terms of development location, density, and intensity would be part of the regional solution for meeting air pollution and GHG goals and therefore, would have a less than significant cumulative impact on VMT.

Development projects that are located where the RTP/SCS does not specify any development or lesser density or intensity may indicate a significant impact on transportation. However, if these projects do not demonstrate a significant impact in the project-level analysis, a less than significant impact in the cumulative impact analysis can also be determined. Projects and land use plans that fall under the City's efficiency-based impact thresholds are already shown to align with the long-term VMT and GHG reduction goals of SCAG's RTP/SCS.

Development projects that (1) demonstrate a project impact after applying an efficiency-based VMT threshold and (2) are not deemed to be consistent with the SCAG RTP/SCS could have a significant cumulative impact on VMT. Therefore, further analysis and evaluation would be necessary to determine whether the project's cumulative impact on VMT is significant.

Utilizing the specified tools for estimating VMT in Section 3.2.2, and as advised by the Public Works Department, the analysis of future RTP/SCS cumulative conditions for the with and without project conditions should be conducted. Appropriate socio-economic and demographic data input to the modeling tool for the cumulative without project conditions representing the adopted RTP/SCS cumulative year conditions and for the cumulative with project conditions including adjustments to reflect reallocation of the population and/or employment growth based on the land supply changes associated with the proposed project should be prepared and the model runs should be conducted. Citywide VMT, household VMT per capita, work VMT per employee, or VMT per service population (depending on project type) would be calculated for both scenarios, and any increase in VMT, household VMT per capita, work VMT per employee, or VMT per service population (depending on project type) above that which was forecast in the adopted RTP/SCS would constitute a significant impact because it could jeopardize regional air quality conformity or GHG reduction findings.

For evaluating the VMT impacts of regional-serving retail, entertainment projects, and/or event centers, the cumulative analysis would include additional steps to that described above to compare a cumulative "plus project" scenario with the cumulative "no project" scenario representing the adopted RTP/SCS cumulative year conditions (as incorporated into the suggested VMT estimation models). This could involve the following additional steps:

• Convert the project land uses into the appropriate employment categories utilized in the adopted RTP/SCS horizon year model. Adjust the socioeconomic parameters in the TAZ appropriately to reflect the removal of the existing land uses and addition of the project.
• Run the four-step model process for the model cumulative "no project" for the four-time periods in the model (AM peak period, midday period, PM peak period, nighttime period) for the base cumulative "no project" scenario and for the cumulative "plus project" scenario.
• Calculate total VMT on the model network for each time period and sum to determine daily VMT for each scenario. Subtract the daily VMT for the base cumulative "no project" scenario from the daily VMT for the cumulative "plus project" scenario to determine the net change in daily VMT.

Significant Impact Criteria

A project's potentially significant VMT impact shall be determined if one or more of the criteria listed below are met. These impact criteria are based on guidance published by OPR and CARB but their specific applicability to a project shall be justified with substantial evidence and is not presumed to be appropriate. The impact criteria below are considered as potential options that may be selected as thresholds for determining significance.

• Residential Projects: The project's residential VMT per capita would not be over 15% below the existing residential VMT per capita for the Baseline Area in which the project is located or > 9.66
• Office Projects: The project's employment VMT per employee would not be equal to or over 15% below the existing employment VMT per employee for the Baseline Area in which the project is located or > 14.46
• Event Centers and Regional Serving Retail Projects: The project would result in a net increase in total VMT (citywide)

The Baseline VMT applied in the Transportation Impact Analysis should be consistent with the year that the transportation study begins as defined in the Scoping Document.

3.2.4. Mitigations

The potential mitigation measures to alleviate VMT impacts of development projects include the following:

• Transportation Demand Management (TDM) Strategies in addition to those included as project design features. The TDM effectiveness in reducing VMT impacts has to be substantiated to the Public Works Department to support the claimed mitigation. The table below provides the categories and a brief listing of the specific measures:

• Additional TDM measures beyond those listed above, to reduce project VMTs for development projects, with substantial evidence provided to the Public Works Department to support the claimed mitigation effectiveness. This could include enhanced bicycle facilities.
• Enhancements to the public transit system (or contribution towards implementation and operations of the transit system)
• For a single-use project, introducing compatible additional land uses to allow for internalization of trips
• For a mixed-use project, modifying the project's land use mix to increase internalization of trips, reduce external trip generation, and serve the local community

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