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Traffic Impact Analysis Under CEQA: Methodology, Screening, Assessment, and Mitigation for the project in city of Lake Elsinore

Traffic Impact Analysis – CEQA Analysis

5.1 Required Methodology

The passage of Senate Bill 743 (SB 743) in 2013 marked a significant shift in the way transportation impacts are assessed under the California Environmental Quality Act (CEQA). Under this legislation, automobile delay and Level of Service (LOS) are no longer considered primary determinants of transportation impacts. Instead, projects must be evaluated based on Vehicle Miles Traveled (VMT). A VMT analysis is required for land use projects as deemed necessary by the City of Lake Elsinore. This applies to projects that could potentially increase the average VMT per service population (which includes both residents and employees) compared to the City's established baseline threshold. The goal of this metric is to determine whether a project will contribute to increased VMT and, if so, to identify necessary mitigation measures.

The methodology for VMT assessment follows the guidelines established in the Western Riverside Council of Governments (WRCOG) Implementation Pathway Study (March 2019). This study provides a standardized approach for evaluating VMT impacts and establishes screening methodologies. Additionally, a separate in-depth analysis has been conducted to determine the maximum project sizes that would result in less-than-significant VMT impacts. This study is based on a screening threshold of 3,000 metric tons (MT) of CO2e emissions per year, utilizing the RIVCOM model and CalEEMod.

5.2 Project Screening

To streamline the VMT assessment process, three primary screening criteria have been established for determining whether a project requires a full VMT analysis:

  1. Transit Priority Area (TPA) Screening
    A Transit Priority Area (TPA) is defined as a half-mile radius around a major transit stop or a stop along a high-quality transit corridor. A major transit stop includes rail, ferry, or bus terminals with frequent service (15-minute intervals or less during peak periods). Projects within a TPA are generally presumed to have a less-than-significant VMT impact unless substantial evidence suggests otherwise. The following factors may disqualify a project from TPA screening:

    • A Floor Area Ratio (FAR) of less than 0.75.

    • Excessive parking beyond jurisdictional requirements.

    • Inconsistencies with the applicable Sustainable Communities Strategy.

    • A reduction in affordable residential units in favor of market-rate housing.

  2. Low VMT Area Screening
    Residential and office projects in low VMT-generating areas may be presumed to have a less-than-significant impact. These areas are identified using the RIVTAM travel-forecasting model, which estimates VMT per service population at the Traffic Analysis Zone (TAZ) level. A project qualifies for this screening if it is consistent with existing land use in the low VMT area and does not alter the built environment in a way that increases vehicle trip lengths or rates.

  3. Project Type Screening
    Certain project types are inherently local-serving and therefore presumed to have a less-than-significant VMT impact. These include:

    • Local-serving K-12 schools

    • Local parks

    • Daycare centers

    • Local-serving gas stations

    • Local-serving banks

    • Non-destination hotels

    • Student housing projects

    • Police, fire, and emergency services

    • Government offices (e.g., libraries, community centers)

    • Local-serving community colleges

    • Projects generating fewer than 110 daily vehicle trips per CEQA guidelines

Additionally, based on Exhibit G, specific land use project sizes are also presumed to have a less-than-significant impact:

  • Single-family residential: 148 dwelling units

  • Multi-family low-rise: 200 dwelling units

  • Multi-family mid-rise: 266 dwelling units

  • General office: 224,000 square feet

  • Retail: 91,000 square feet

  • Warehousing: 258,000 square feet

  • Light industrial: 149,000 square feet

  • Projects emitting less than 3,000 MT of CO2e annually

5.3 VMT Assessment for Non-Screened Projects

Projects that do not qualify for screening must complete a detailed VMT analysis using the RIVCOM travel demand model. This involves assessing project-generated VMT and the project’s overall effect on regional VMT under the following conditions:

  • Baseline Conditions: Current VMT levels in the project area.

  • Baseline Plus Project: A model scenario incorporating the project’s expected VMT impact.

  • Cumulative No Project: Future VMT projections without the proposed project.

  • Cumulative Plus Project: Future VMT projections with the proposed project included.

The model outputs should include total VMT and VMT per service population. Additionally, projects must evaluate their impact on public transit, bicycle, and pedestrian facilities, ensuring consistency with adopted policies and plans.

5.4 VMT Impact Thresholds

A project is considered to have a significant VMT impact if:

  • Project-generated VMT per service population exceeds the City’s baseline VMT per service population.

  • Cumulative project-generated VMT per service population exceeds the City’s baseline.

Additionally, a project’s effect on VMT is significant if:

  • The baseline link-level boundary VMT per service population increases compared to the no-project condition.

  • The cumulative link-level boundary VMT per service population increases under the plus-project condition compared to the no-project condition.

5.5 VMT Mitigation Measures

If a project is found to have a significant VMT impact, mitigation measures must be implemented. These can include:

  1. Modifying the built environment to reduce VMT (e.g., increasing density, reducing parking, or enhancing walkability).

  2. Implementing Transportation Demand Management (TDM) strategies (e.g., providing transit incentives, carpool programs, bike infrastructure).

  3. Participating in VMT mitigation banking or fee programs (if available).

A list of effective TDM strategies can be found in WRCOG’s TDM Strategies Evaluation Memorandum.

5.6 CEQA Findings and Overriding Considerations

Under CEQA, the City Council may approve projects with significant VMT impacts if overriding benefits exist. Such benefits may include:

  • Job creation in underserved areas

  • Critical transportation infrastructure improvements

  • Habitat conservation efforts

  • Non-motorized transportation enhancements

  • Other unique community benefits

Projects with significant traffic impacts requiring an overriding consideration will need to prepare an Environmental Impact Report (EIR). The necessity of an EIR will be determined through consultation between the City’s Engineering and Planning Departments and the City Attorney

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