The City of Pomona’s Transportation Study (TS) Guidelines outline the requirements for transportation analysis in land development, roadway projects, and specific plans. These guidelines are designed to evaluate a project's transportation impacts and ensure compliance with local and state regulations, particularly under the California Environmental Quality Act (CEQA). With the passage of Senate Bill 743 (SB 743), which was signed into law in 2013, the way transportation impacts are assessed under CEQA has undergone a fundamental shift. The key change mandated by SB 743 is the replacement of Level of Service (LOS) as the metric for transportation impact analysis with Vehicle Miles Traveled (VMT). By July 2020, all lead agencies in California were required to adopt VMT as the primary measure for evaluating the transportation impacts of land use and transportation projects under CEQA.
In response to SB 743, the San Gabriel Valley Council of Governments (SGVCOG) initiated the SB 743 Implementation Study to help its member agencies, including the City of Pomona, adapt to the new CEQA guidelines. This study explored key aspects of VMT analysis, such as determining significance thresholds, identifying mitigation strategies, and developing tools for VMT screening and mitigation. As part of this effort, the City of Pomona adopted new methodologies and significance thresholds to align its transportation studies with the updated CEQA requirements.
Background and Purpose of the Guidelines
The primary goal of Pomona’s TS Guidelines is to provide guidance for the preparation of transportation studies in the city, ensuring compliance with both local and state-level regulations. This includes the need to evaluate environmental transportation impacts and assess effects on the local transportation system. The guidelines are aimed at ensuring consistency with SB 743, which shifted the focus of CEQA transportation analysis from vehicle delay and traffic congestion (LOS) to the broader metric of VMT, in line with the state’s goals of reducing greenhouse gas emissions, encouraging infill development, and promoting active transportation.
CEQA Changes and SB 743 Implementation
Prior to SB 743, transportation impact analysis under CEQA relied heavily on LOS, which measured vehicle delays at intersections and along roadway segments. Projects were evaluated based on their potential to increase traffic congestion and reduce roadway efficiency. However, SB 743 eliminated LOS as a CEQA metric, stating that measures of vehicle delay are no longer sufficient to determine significant environmental impacts under CEQA. Instead, the new guidelines emphasize reducing the number of vehicle miles traveled, thus promoting more sustainable forms of development that align with the state’s environmental and public health goals.
The Office of Planning and Research (OPR) played a key role in developing the new CEQA guidelines, which officially recognized VMT as the preferred metric for assessing transportation impacts. While LOS is no longer required under CEQA, cities and counties are still allowed to use it for other planning purposes, such as in general plans, congestion management programs, and traffic fee calculations.
The new guidelines introduced by SB 743 require cities to adopt thresholds of significance for VMT that are based on evidence and developed through a public review process. In Pomona’s case, the SGVCOG Implementation Study provided the foundational framework for identifying suitable VMT thresholds and methodologies. These include strategies for assessing a project's transportation impact and proposing effective mitigation measures when necessary.
Application of VMT in Pomona’s Transportation Study Guidelines
Pomona’s TS Guidelines require the preparation of a transportation study when a proposed project has the potential to affect the local transportation network, especially in terms of VMT. Projects that exceed specific thresholds of significance for VMT may be required to implement mitigation measures, such as transportation demand management (TDM) programs, to reduce their overall VMT impact.
To determine whether a VMT analysis is needed for a specific project, the guidelines include screening criteria. Projects that meet one or more of the following criteria may be exempt from VMT analysis:
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Transit Priority Areas Screening: Projects located within transit priority areas may be excluded from VMT analysis if they are likely to generate low VMT due to their proximity to high-quality public transit services.
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Low VMT-Generating Areas Screening: Projects located in areas with established low VMT rates may also be exempt from further VMT analysis, as they are unlikely to contribute significantly to vehicle travel.
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Project Type Screening: Certain project types, such as small developments or affordable housing projects, may be excluded from VMT analysis if they are not expected to significantly increase vehicle travel in the area.
If a project does not meet any of the screening criteria, a detailed VMT analysis is required to assess its potential transportation impacts. The analysis must consider factors such as the project's location, land use, and expected trip generation rates. If the project is found to have a significant VMT impact, mitigation measures may be necessary to reduce its transportation-related environmental effects.
VMT Mitigation and Level of Service (LOS) Policy
Although VMT is now the primary metric for evaluating transportation impacts under CEQA, the City of Pomona continues to use LOS for certain planning purposes, such as ensuring that local roadways maintain an acceptable level of service. The TS Guidelines still require a LOS analysis for projects expected to generate more than 50 vehicle trips during peak hours. This ensures that even if a project passes the VMT screening criteria, it still complies with the city's broader transportation goals, including congestion management and roadway efficiency.
For projects that trigger both VMT and LOS analyses, the transportation study must address both metrics. If a project exceeds the city’s LOS thresholds, it may need to implement improvements to the roadway network, such as traffic signal upgrades or lane expansions, to mitigate its impact on traffic flow.
CEQA-Based and Non-CEQA Based Requirements
The City of Pomona's TS Guidelines distinguish between CEQA-based and non-CEQA-based requirements for transportation studies. While CEQA-based requirements focus on evaluating a project’s environmental impacts (primarily using the VMT metric), non-CEQA-based requirements focus on maintaining local transportation standards, such as LOS and roadway capacity. These dual requirements ensure that projects not only meet the state’s environmental goals but also align with the city’s infrastructure and transportation planning objectives.
Summary of the Transportation Study Process
The transportation study process in Pomona involves several key steps, including:
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Project Screening: City staff reviews the project to determine if a transportation study is necessary and whether it requires VMT or LOS analysis (or both).
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Transportation Study Preparation: If required, the transportation study must include a detailed analysis of the project’s transportation impacts, including VMT and LOS assessments, depending on the project’s scope and location.
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Mitigation Measures: If the project is found to have significant transportation impacts, the study must propose mitigation measures to reduce those impacts, particularly in terms of VMT. Potential mitigation strategies may include improvements to public transit, pedestrian and bicycle infrastructure, or TDM programs designed to reduce vehicle travel.
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Approval and Compliance: Once the transportation study is complete, it is submitted to the City for review. If the project complies with both CEQA and non-CEQA transportation requirements, it may proceed to the approval stage.
Conclusion
The City of Pomona’s Transportation Study Guidelines reflect the shift in transportation planning priorities following the passage of SB 743 and the adoption of VMT as the primary CEQA metric for transportation impact analysis. These guidelines provide a clear framework for evaluating the transportation effects of development projects and ensuring that they align with both state and local goals, including the reduction of greenhouse gas emissions and the promotion of sustainable transportation options. While VMT now serves as the cornerstone of CEQA transportation analysis, the city’s continued use of LOS for non-CEQA purposes ensures that local traffic conditions remain manageable and that roadway infrastructure is maintained to accommodate growth.
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