Title
Consideration of Text Amendments to the Transportation Element of the General Plan to Replace Level of Service (LOS) with Vehicle Miles Traveled (VMT) as the Criteria to be used for Transportation Analysis under the California Environmental Quality Act (CEQA), in Compliance with Senate Bill (SB) 743 and CEQA Guidelines Section 15064.3
Staffreport
SUMMARY
Senate Bill (SB) 743, signed into law in 2013, required a shift in the focus of transportation analysis under the California Environmental Quality Act (CEQA) to better align with the State’s sustainability and greenhouse gas (GHG) emissions reduction goals. SB 743 required lead agencies, starting on July 1, 2020, to change the primary metric utilized to evaluate a project’s transportation impacts from Level of Service (LOS), as measured by roadway capacity and vehicle delay, to Vehicle Miles Traveled (VMT), which is an estimate of the amount and distance people drive by vehicle to reach a destination.
Staff is proposing text amendments to the Transportation Element of the General Plan to formalize the replacement of LOS with VMT as the criteria to be used for transportation analysis under CEQA and to establish the appropriate context for LOS-based analyses outside of the CEQA process.
BACKGROUND
CEQA requires public agencies to identify, disclose, and mitigate environmental impacts of projects by comparing potential impacts against adopted significance thresholds. Historically, lead agencies have used LOS to identify significant transportation impacts under CEQA. LOS prioritizes moving the largest number of cars as fast as possible and does not account for impacts to other travel modes. Rather than moving automobiles faster, the focus on LOS has often created traffic congestion over large areas and encouraged sprawling development patterns.
Senate Bill 743, codified in Public Resources Code Section 21099, prohibited the use of LOS as a CEQA threshold of significance after July 1, 2020 and directed the Governor’s Office of Planning and Research (OPR) to amend the CEQA Guidelines to better align transportation impact criteria with State environmental, economic, and public health goals. SB 743 allows cities to continue to use LOS within the local development review process to inform site access and traffic operations decisions, but does not allow LOS be used to evaluate CEQA impacts or mitigations.
The City of San Leandro implemented SB 743 locally by shifting to VMT-based transportation analysis for CEQA documentation after July 1, 2020. The 2035 General Plan Transportation Element envisioned the transition from LOS to VMT. The proposed General Plan Text Amendments would formalize the replacement of LOS with VMT as the criteria to be used for transportation analysis under CEQA.
ANALYSIS
Engineering & Transportation and Planning staff worked with a transportation consultant, Fehr and Peers, to develop administrative guidelines (Attachment 3) for staff to use in evaluating VMT-based transportation impacts in the City of San Leandro. Fehr and Peers utilized technical guidance from OPR, as well as their experience in implementing VMT-based analysis in other cities, to support the development of the guidelines, which include recommended thresholds of significance, project screening criteria, and standardized mitigation. The proposed amendments to the General Plan Transportation Element are intended to provide policy support for the use of these administrative guidelines.
Thresholds of Significance
OPR’s technical guidance suggests that a per capita or per employee VMT that is fifteen percent below that of existing development may be a reasonable threshold of significance. Although the CEQA Guidelines allow cities to establish different thresholds based on substantial evidence, staff believes the State guidance is generally appropriate for San Leandro. A deviation from state guidance was recommended by Fehr and Peers for industrial and warehouse projects due to the unique characteristics of those uses. The recommended thresholds are below:
• Residential (and similar) projects: Project VMT exceeds the level that is 15 percent below existing home-based VMT per resident for the Central Planning Area.
• Employment generating/office (and similar) projects: Project VMT exceeds the level that is 15 percent below existing home-work VMT per worker for the Central Planning Area.
• Employment generating/industrial and warehouse (and similar) projects: Project VMT exceeds the level that is below existing home-work VMT per employee for the Central Planning Area. Areas appropriately zoned for these uses are typically clustered together, have low development densities, and may not be well served by transit or non-motorized infrastructure. As a result, these areas tend to have higher VMT. This threshold, which has been analyzed and adopted by other cities, including San Jose and Fremont, acknowledges that industrial and warehouse development typically cannot relocate to areas with a greater mix of uses or better transit or non-motorized connectivity that would have low VMT.
• Mixed-use projects: Each land use component of the project would be analyzed independently, applying the appropriate threshold of significance from above to each land use type included in the project.
• Other land use and regional-serving project types: Net increase in total VMT in the region (that is, the difference in total VMT in the region with and without the project), an appropriate per capita metric, or as determined by the City’s Planning and Engineering staff.
• Road projects: Net increase in total VMT in the region.
Mitigation of VMT Impacts
Mitigations are used to reduce or eliminate the potential impacts of a project pursuant to CEQA. Mitigating a VMT impact involves different types of actions than mitigating an LOS impact. Mitigating a project’s LOS impact typically entails roadway or intersection improvements that would reduce vehicle delay while reducing VMT impact entails reducing the number and/or the length of vehicle trips generated by the project. This could include modifying the characteristics of a project or implementing transportation demand management (TDM) measures.
Staff has identified the Alameda CTC VMT Reduction Calculator Tool, a research-based tool that accounts for the location of a development project and estimates the percentage reduction in VMT by various standalone strategies or a combination of strategies, as the main resource for developing mitigation measures for VMT impacts.
Screening
In conducting transportation analysis under CEQA, many cities use “screens” to quickly identify when a project should be expected to cause a less-than significant impact without the need to prepare a detailed study. Based on OPR’s technical guidance and analysis from Fehr and Peers, the following types of projects have been determined to be appropriate to be “screened out” from detailed analysis:
• Projects that are subject to and exempt from CEQA.
• Small projects generating fewer than 110 daily trips.
• Local serving retail/public facilities (e.g., grocery store, dry cleaners, gym, etc.) not exceeding 50,000 square feet.
• 100% affordable housing developments.
• Projects in Transit Priority Areas (TPA) (areas generally within a 0.5-mile of a BART or bus rapid transit stops).
• Projects in Low-VMT Areas (areas where existing VMT per capita meets the VMT thresholds.
• Infill residential developments with a minimum density of 30 dwelling units per acre in certain identified areas in the City.
PROPOSED GENERAL PLAN AMENDMENTS
Staff is recommending text amendments to the General Plan Transportation Element to serve the following purposes:
• Memorialize the switch from LOS-based analysis to VMT-based analysis.
• Direct staff to develop, maintain and periodically update administrative guidelines to support VMT-based transportation impact analysis including thresholds of significance, project screening criteria, and standardized mitigation. The administrative guidelines would consist of the information contained in Attachment 3.
• Support the use of LOS outside of CEQA to address a project’s effect on traffic operations at nearby intersections, access and circulation for various travel modes, and parking.
The proposed amendments are described below:
• Action T-1.3.B: Revised to allow staff to require a Local Transportation Impact Analysis (LTIA) based on LOS for development projects that may potentially affect access and circulation.
• Policy T-5.2: Revised to identify VMT as the metric for evaluating transportation impacts in CEQA documents.
• Action T-5.2.A: Added to direct staff to develop, maintain and periodically update local administrative guidelines supporting VMT-based transportation impact analysis.
• Action T-5.2.B: Revised to clarify that LOS will no longer be used for evaluating and mitigating transportation impacts.
GENERAL PLAN CONFORMANCE
The following are the specific General Plan policies that support the proposed text amendments to the General Plan:
Policy LU-6.5. Reducing VMT Through Land Use Choices. Provide a mix of land uses, site planning and design practices, and circulation improvements in the BART Station area that maximize transit ridership and the potential to reduce vehicle miles traveled (VMT)
Policy OSC-7.9. Reducing Greenhouse Gases Through Land Use and Transportation Choices. Locate and design new development in a manner which maximizes the ability to use transit, walk, or bicycle for most trips, reduce dependence on fossil fuel powered vehicles, and reduce vehicle miles traveled.
Policy T-1.1. Decision Making. Ensure that future land use and development decisions are in balance with the capacity of the City’s transportation system and consistent with the City's goal of reducing greenhouse gas emissions.
Policy T-1.4. Transit Oriented Development. Ensure that properties adjacent to the City’s BART stations and along heavily used public transit routes are developed in a way that maximizes the potential for transit use and reduces dependence on single-occupancy vehicles. Such development should be of particularly high quality, include open space and other amenities, and respect the scale and character of nearby neighborhoods.
Policy T-1.5. Land Use Strategies. Promote land use concepts that reduce the necessity of driving, encourage public transit use, and reduce trip lengths. These concepts include live-work development, mixed use development, higher densities along public transit corridors, and the provision of commercial services close to residential areas and employment centers.
ENVIRONMENTAL REVIEW
The proposed text amendments are exempt from the requirements of the California Environmental Quality Act in accordance with, each on a separate and independent basis, CEQA Guidelines Section 15061(b)(3) because the text amendments do not have the potential to cause a significant effect on the environment and CEQA Guidelines Section 15268(a) because the proposed amendments are ministerial actions that are exempt from CEQA.
RECOMMENDATION
Staff recommends the Planning Commission adopt a resolution recommending the City Council adopt text amendments to the Transportation Element of the General Plan to formalize the replacement of LOS with VMT as the criteria to be used for transportation analysis under CEQA in the City of San Leandro and to establish the appropriate context for LOS-based analyses.
ATTACHMENTS
Attachment 1 - Draft Planning Commission Resolution
Attachment 1 Exhibit A - Amended Transportation Element (excerpted clean version)
Attachment 2 - Amended Transportation Element (excerpted redlined version)
Attachment 3 - Administrative Guidelines Memo