For Transportation Commission Meeting [November 3, 2021]
TO: Honorable Chairperson and Commission
APPROVAL: Michael Tahan, Interim Public works Director
FROM: Justin Schlaefli, Consultant Engineer, TKE Engineering
Title
Draft Vehicle Miles Traveled and Level of Service Guidelines (SB743)
(ACTION ITEM)
Body
BACKGROUND:
Senate Bill (SB) 743 changes how transportation impacts are measured under the California Environmental Quality Act (CEQA) from using vehicle Level of Service (LOS) to using Vehicle Miles Traveled (VMT). The new VMT metric for transportation analysis focuses on the overall miles traveled by vehicles within a region. This approach has an added inherent emphasis on reducing greenhouse gas emissions.
Historically, delay and congestion LOS were the metrics used when evaluating Transportation impacts. Adopting VMT thresholds do not however preclude the City from using LOS analysis to comply with Congestion Management Plan requirements or to conduct project specific transportation analysis.
The City of Rialto participated in the pathway implementation study led by San Bernardino County Transportation Authority (SBCTA) to assist its member agencies understand the specific questions that need to be addressed when making these determinations and to provide research, analysis, and other substantial evidence to support their final SB 743 implementation decisions.
Staff attended several regional meetings specific to the region and the City regarding SB743 and obtained consultant support resulting in the recommended guidelines.
The draft VMT and LOS Guidelines were previously provided to the Transportation and Planning Commission Joint Workshop on June 2, 2021 as an informational item.
Traffic Impact Analysis Guidelines for Vehicle Miles Traveled and Level of Service
Level of Service
The City adopted vehicle LOS policies that set standards for which local agency infrastructure will strive to maintain. These policies are contained in the General Plan and therefore apply to discretionary approvals of new land use and transportation projects. There is no update to this criteria with this approval.
Vehicle Miles Traveled (CEQA Compliance)
SB 743 represents a significant departure from the City’s previous transportation analysis practices, methodology, thresholds, and mitigation. The recommended methodology benchmark for the City will be the County regional average as its Baseline VMT performance for Project Generated VMT per service population or per household. This threshold option chosen for project generated VMT is consistent with RTP/SCS future year VMT projections and is better than general plan buildout/horizon year. VMT Mitigation measures can be found in the document and include regional specific traffic demand management (TDM) measures to implement and quantify VMT reductions.
The adoption of these benchmarks, methodology and threshold is consistent with the legislative intent of SB 743 promoting infill land development, active transportation and reducing greenhouse gas emissions.
ADDITIONAL CHANGES/UPDATES:
In addition to changes related to adopting VMT thresholds for CEQA, level of service (LOS) analysis will continue to be required. Compared to existing guidelines, the level of service assessment has been clarified and expanded. There are two (2) categories for level of service analysis as discussed below:
Focused (minor) Traffic Study (LOS)
A focused traffic study may be required for any Project that generates 1-49 trips during any peak hour without consideration of pass-by trips to the existing circulation system; or as directed by the City Engineer. The City of Rialto reserves the right to require that a TIA be prepared for any development, if there are safety concerns, operational issues, or if located in an area known to be impacted by traffic. At a minimum, the focused study shall assess the project’s points of access and adjacent intersections in the immediate vicinity of the project.
Full Study (major) Traffic Impact Analysis (LOS)
A major traffic study is required for any Project that generates 50 or more trips during any peak hour without consideration of pass-by trips.
At a minimum, the study area shall include any intersection of “Collector” to higher classification street, with “Collector” or higher classification, shown on the Rialto Circulation Element, at which the proposed project will add 50 or more A.M. or P.M. peak hour trips within five (5) miles of the Project. PCE factors apply to this threshold.
In addition to the criteria listed above for categorizing a study, General Plan Amendments or Specific Plan Amendments will require additional analysis to evaluate the proposed changes.
Buildout Analysis
A buildout analysis (long-term) will now be required for all major studies. This is a common practice throughout the State including agencies in both San Diego and Riverside counties. This analysis will follow the following criteria:
General Plan Traffic Conditions - Traffic projections for General Plan Buildout conditions shall utilize the City’s traffic model, growth projections to buildout of the General Plan or other approved model. The Engineer shall use the model projections as the basis for determining turning movement volumes for the required intersection analysis. A manual assignment of project traffic added to the General Plan Buildout traffic volumes may be used to determine total future traffic. This analysis will determine if the Circulation Element of the General Plan is adequate to accommodate projected traffic at the target LOS, or if additional delay reduction measures or fair-share contributions are necessary.
Conclusion
SB 743, signed by the Governor in 2013, changed the way transportation impacts are identified at a State level. Specifically, the legislation directed the Office of Planning and Research (OPR) to look at different metrics for identifying transportation as a CEQA impact. The Final OPR guidelines approved vehicle miles of travel (VMT) as the preferred metric moving forward. The Natural Resources Agency completed the rule to modify the CEQA guidelines in December of 2018.
The proposed Guidelines ensure the City’s compliance with the above requirements. In addition, continued Level of Service Assessment will be required consistent with the City’s General Plan and applicable policies. The updated Guidelines provide further clarity for applicants and outline the process in alignment with State Law and regional requirements. In some cases, common practices from other jurisdictions were incorporated to provide additional information and ensure deficiencies in the transportation system are identified and improved. Finally, the Guidelines provide a unified/updated document which incorporates common practice for the City of Rialto for the recent past.
RECOMMENDATIONS:
Staff requests that the Transportation Commission:
• Approve the revised guidlelines outlining Vehicle Miles Traveled thresholds for California Environmental Quality Act compliance related to transportation analysis consistent with the intent of SB743
• Recommend apporoval by City Council.