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Introduction to Transportation Impact Analysis guidelines in City of Pasadena

1. INTRODUCTION

1.1. PURPOSE

The Department of Transportation is dedicated to ensuring the safe, efficient, and convenient movement of people and goods throughout Pasadena, while balancing land use and transportation to foster a livable community where reliance on cars is minimized. A community's ability to balance its transportation system components is essential for creating and maintaining a quality environment for living and business. The transportation system must facilitate the movement of all users, including pedestrians, bicyclists, transit users, and various vehicle traffic flows within and through the community. The Mobility Element of the City’s General Plan articulates goals and policies aimed at enhancing transportation in Pasadena, focusing on the needs of multimodal corridors and neighborhoods impacted by traffic. These guidelines aim to ensure a comprehensive transportation review that aligns with the City’s goals and state statutes for all proposed land use development projects. The objective is to identify necessary transportation system improvements to support new development while preserving community quality of life prior to project approval and construction. The guidelines detail the procedures, methodologies, and criteria for conducting transportation reviews of development projects, facilitating the preparation, review, and approval process by Pasadena’s Department of Transportation (DOT) staff. Analysis requirements for other project types will be determined in consultation with DOT staff. The DOT reserves the right to modify analysis requirements for specific development projects on a case-by-case basis when the transportation analysis begins, and the presented requirements may be revised at the discretion of the Director of Transportation to stay consistent with state law, city ordinances, and current best practices, as well as to further implement the City’s General Plan transportation objectives.

1.2. REGULATORY FRAMEWORK/BACKGROUND

On September 27, 2013, Governor Brown signed Senate Bill (SB) 743, which initiated a shift in how transportation impacts are analyzed under the California Environmental Quality Act (CEQA), codified in Public Resources Code (PRC) Section 21000 and following. SB 743 introduced PRC Section 21099, directing the Governor’s Office of Planning and Research (OPR) to establish criteria for assessing transportation impact significance, promoting the reduction of greenhouse gas emissions, development of multimodal transportation networks, and a diversity of land uses. After the certification of subsequent revisions to CEQA Guidelines, Section 21099 states that automobile delay, assessed solely through level of service (LOS) or similar measures, shall not be regarded as a significant environmental impact.

On December 30, 2013, OPR released a preliminary evaluation of alternative transportation analysis methods, advocating for project vehicle miles traveled (VMT) as opposed to impacts on intersection LOS. OPR provided additional draft documents in March 2015 and January 2016, recommending these revisions to CEQA Guidelines. Concurrently, OPR developed the Technical Advisory on Evaluating Transportation Impacts in CEQA, offering non-binding recommendations for VMT methodology implementation, which significantly influenced VMT analyses statewide. In November 2017, OPR submitted proposed amendments to CEQA Guidelines, including a new Section 15064.3 governing transportation impact analysis methods. Consistent with PRC Section 21099, CEQA Guidelines Section 15064.3 states that a project’s effects on automobile delay are not to be considered a significant environmental impact. The formal rulemaking process for these amendments began with a Notice of Rulemaking published by the Natural Resources Agency on January 26, 2018, and the California Office of Administrative Law adopted the amendments on December 28, 2018, formally implementing VMT as the metric for transportation analysis under CEQA, with compliance required by July 1, 2020.

Aligning with SB 743's intent, the City of Pasadena adopted VMT as the primary metric for assessing CEQA transportation impacts for development projects in 2015, with updates to the City’s CEQA impact thresholds approved by the Pasadena City Council in November 2020.

 

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