INTRODUCTION
State and federal laws mandate a direct correlation between the Land Use Element building intensities outlined in a General Plan and the capacity of the Circulation Element. To ensure this alignment, the City of Anaheim requires a Traffic Impact Analysis (TIA) to assess the effects of proposed land use developments on the current and future transportation infrastructure. The TIA process is designed to ensure compliance with the California Environmental Quality Act (CEQA) and Congestion Management Program (CMP) laws and guidelines.
These TIA requirements provide a comprehensive framework for developers or project proponents seeking approval for developments within Anaheim. The guidelines should be used in conjunction with CEQA guidelines and the Anaheim Municipal Code to streamline the project review process and ensure regulatory compliance.
For decades, TIA preparation has been closely integrated with the CEQA process. Traditionally, TIAs have been used to evaluate a project's transportation impacts under CEQA. However, the passage of Senate Bill 743 (SB 743) has necessitated changes to the TIA process. Under SB 743, TIAs may now serve as standalone documents, independent of the CEQA review, to provide decision-makers with additional information beyond what is required for environmental impact assessment.
The purpose of the TIA Guidelines is to establish clear instructions for analyzing the transportation impacts of proposed developments. These guidelines outline the recommended methodologies, analysis formats, and steps necessary to prepare TIAs for CEQA compliance and broader project approval purposes.
BACKGROUND INFORMATION
SB 743, signed into law in 2013, has fundamentally changed how transportation impacts are identified under CEQA. Specifically, the legislation directed the Governor's Office of Planning and Research (OPR) to evaluate alternative metrics for measuring transportation impacts. By December 2018, OPR finalized its guidelines and identified Vehicle Miles Traveled (VMT) as the preferred metric for evaluating transportation impacts moving forward. Subsequently, the Natural Resources Agency updated the CEQA guidelines to reflect this change, and as of July 2020, all lead agencies are required to use VMT as the transportation metric for CEQA purposes.
CEQA Guidelines Section 15064.7(b) encourages public agencies to formally adopt their significance thresholds, which play a critical role in implementing SB 743. The section states:
"Each public agency is encouraged to develop and publish thresholds of significance that the agency uses in the determination of the significance of environmental effects. Thresholds of significance to be adopted for general use as part of the lead agency’s environmental review process must be adopted by ordinance, resolution, rule, or regulation, and developed through a public review process and be supported by substantial evidence. Lead agencies may also use thresholds on a case-by-case basis as provided in Section 15064(b)(2)."
To ensure compliance with SB 743, the City of Anaheim has developed these TIA Guidelines. These guidelines provide a detailed framework for conducting VMT analyses and ensuring consistency with CEQA requirements. As CEQA requirements are subject to periodic updates and legal interpretations, the City of Anaheim will continuously review these guidelines to maintain their applicability. Consultants are encouraged to contact the City to confirm they are using the most current guidelines when conducting project impact assessments.
LEVEL OF SERVICE (LOS) STANDARDS AND GENERAL PLAN CONSISTENCY
The City of Anaheim has adopted Level of Service (LOS) standards to maintain the performance of local infrastructure. These standards are documented in the City’s General Plan and apply to discretionary approvals of new land use and transportation projects. Consequently, LOS analyses may still be required to ensure consistency with General Plan policies, even though SB 743 has shifted the primary focus to VMT for CEQA purposes.
The City Traffic Engineer retains the authority to require LOS analyses, VMT analyses, or both, depending on the nature of the proposed project. Site-specific traffic studies that evaluate site access and LOS must adhere to the City’s most recent Criteria for Preparation of Traffic Impact Studies. All studies must be scoped with the City Traffic Engineer to determine specific requirements.
CEQA CHANGES
SB 743 introduced significant changes to how transportation impacts are analyzed under CEQA. Most notably, the legislation eliminates auto delay, LOS, and similar measures of vehicular capacity or traffic congestion as bases for determining significant impacts under CEQA. This shift aims to balance congestion management needs with statewide goals, including promoting infill development, enhancing public health through active transportation, and reducing greenhouse gas emissions.
The following key changes have resulted from SB 743:
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Elimination of LOS as a CEQA Metric: LOS and measures of traffic congestion are no longer considered valid criteria for identifying significant transportation impacts under CEQA. This change is intended to prioritize sustainable transportation planning and reduce reliance on automobile-centric metrics.
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Adoption of VMT as the Preferred Metric: OPR has identified VMT as the most appropriate metric for evaluating transportation impacts of land use projects and plans under CEQA. VMT measures the total vehicle miles traveled generated by a project and its impact on regional transportation systems.
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Flexibility for Transportation Projects: For transportation-related projects, lead agencies may select their preferred metric but must provide substantial evidence to support their decision in compliance with CEQA expectations.
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Optional LOS Analysis Outside CEQA: SB 743 permits cities and counties to continue analyzing LOS or delay outside of the CEQA review process. These analyses may be used for general plans, impact fee programs, corridor studies, congestion mitigation, or ongoing network monitoring. However, LOS or delay metrics may no longer serve as the sole basis for identifying significant CEQA impacts.
The City of Anaheim’s TIA Guidelines reflect these changes and ensure compliance with SB 743. While VMT is now the primary metric for CEQA analysis, LOS analyses may still be required to address consistency with the City’s General Plan and other planning initiatives.
IMPLEMENTATION OF SB 743 AND VMT ANALYSIS
Under SB 743, VMT has replaced LOS as the primary metric for evaluating transportation impacts under CEQA. The implementation of this metric supports California’s broader objectives of reducing greenhouse gas emissions and encouraging sustainable development patterns. The City of Anaheim has incorporated VMT into its TIA Guidelines to comply with state requirements and facilitate the transition to this new evaluation framework.
Key aspects of VMT analysis under the City’s guidelines include:
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Thresholds of Significance: The City of Anaheim has established thresholds of significance for VMT analysis, which are periodically reviewed and updated to align with CEQA guidelines and legal precedents. Projects that exceed these thresholds may require mitigation measures to reduce their VMT impacts.
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Screening Criteria: Certain projects may qualify for VMT screening, exempting them from detailed VMT analysis. For example, small-scale developments, affordable housing projects, or projects in transit-priority areas may meet screening criteria, provided they meet specific conditions outlined in the guidelines.
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Mitigation Measures: Projects that generate significant VMT impacts may be required to implement mitigation measures. These may include transportation demand management (TDM) strategies, improvements to active transportation infrastructure, or other measures designed to reduce vehicle travel.
The adoption of SB 743 has marked a significant shift in transportation impact analysis under CEQA, emphasizing sustainable metrics like VMT over traditional measures like LOS. The City of Anaheim’s TIA Guidelines provide a comprehensive framework for developers to assess and mitigate transportation impacts while ensuring compliance with state and local regulations. By adopting these guidelines, the City aims to promote sustainable development, reduce greenhouse gas emissions, and support broader state goals related to transportation and environmental planning.
Project proponents are encouraged to engage with the City early in the development process to ensure their proposals align with these guidelines and meet all regulatory requirements. As CEQA requirements and best practices evolve, the City will continue to update its TIA Guidelines to reflect the latest standards and provide clear, effective guidance for transportation impact analysis
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