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HomeMy WebLinkAbout2025-11-05; Planning Commission; 01; Overview Vehicle Miles Traveled (VMT)Meeting Date: Nov. 5, 2025 Item 1 To: Planning Commission Staff Contact: Jason Geldert, 442-339-2758, Jason.Geldert@carlsbadca.gov Subject: Overview Vehicle Miles Traveled (VMT) Location: Citywide Case Numbers: n/a Applicant/Representative: City of Carlsbad Community Development Department Permit Type(s): ☐SDP ☐ CUP ☐ CDP ☐ TM/TPM ☐ GPA ☐ REZ ☐ LCPA☒Other: N/A CEQA Recommendation: ☒ Not a Project ☐ Exempt ☐ IS/ND or IS/MND ☐ EIR☐Other: Commission Action: ☐Decision ☐ Recommendation to City Council ☒ Informational (No Action) Recommended Action Receive a report and presentation of Vehicle Miles Traveled (VMT). Description In 2013, Senate Bill 743 (SB 743) changed how transportation impacts are evaluated under the California Environmental Quality Act (CEQA), shifting the focus from measuring vehicle delay (Level of Service, or LOS) to evaluating VMT, a metric that accounts for how much driving a project generates, as an indicator of environmental impacts related to greenhouse gas emissions, energy use, and roadway efficiency. As of July 2020, CEQA Guidelines Section 15064.3 identifies VMT as the primary metric for evaluating transportation impacts. To implement SB 743, the City Council adopted VMT thresholds of significance and screening criteria consistent with state guidance. The city’s VMT Analysis Guidelines (Exhibit 1) provides direction to city staff, consultants, and project applicants regarding how to evaluate transportation impacts pursuant to CEQA in the City of Carlsbad. In addition to the VMT Analysis Guidelines, a VMT Informational Bulletin (Exhibit 2) was published to provide the public with a high-level explanation of VMT. The purpose of this item is to provide the Planning Commission with an informational overview of VMT, summarize the city’s approach to VMT screening and analysis, and describe how VMT fits into the development review process. This information is intended to support the Planning Commission’s understanding of current CEQA transportation evaluation practices and provide context for future project decisions. This is an informational item only; no Commission action is required. Exhibits 1.VMT Analysis Guidelines Link: https://www.carlsbadca.gov/home/showpublisheddocument/312/638816039777155617 2.Informational Bulletin IB-160, Vehicle Miles Traveled Link: https://www.carlsbadca.gov/home/showpublisheddocument/10538/638816035273670000 Nov. 5, 2025 Item #1 1 of 83 VEHICLE MILES TRAVELED (VMT) ANALYSIS GUIDELINES May 31, 2023 April 25, 2025: Small Project and Transit Screening Criteria are not applicable per Cleveland National Forest Foundation v. County of San Diego (4th Appellate District). This version removes these screening criteria and provides additional justification for the other screening criteria in Appendix C. The removal of text is shown as strikeout and addition of text is underlined and highlighted. The City is in the process of updating the Carlsbad VMT Guidelines with these changes, and when available will replace the May 2023 VMT Guidelines. All other aspects of the May 2023 VMT Guidelines not modified herein remain in force. Exhibit 1 Nov. 5, 2025 Item #1 2 of 83 Vehicle Miles Traveled Analysis Guidelines | i TABLE OF CONTENTS 1 BACKGROUND ............................................................................................................................1 1.1 SB 743 Legislation and Updated CEQA Guidelines ....................................................................... 1 1.2 Governor’s Office of Planning and Research (OPR) Technical Advisory ....................................... 1 1.3 Consistency with City Goals and Policies ...................................................................................... 2 2 PURPOSE AND OBJECTIVE OF VMT ANALYSIS ..............................................................................2 2.1 Purpose of VMT Analysis Guidelines............................................................................................. 2 2.2 Coordination with Other Agencies ................................................................................................ 2 2.3 Necessary Qualifications of Individuals Preparing VMT Analyses ................................................ 2 3 LAND DEVELOPMENT PROJECTS ..................................................................................................3 3.1 Overview of Analysis ..................................................................................................................... 3 Figure 3.1: City of Carlsbad Residential VMT Map .............................................................................. 4 3.2 VMT Modeling Tools ..................................................................................................................... 5 VMT Efficiency Metric Definitions ........................................................................................ 6 Figure 3.2: VMT Analysis Process ........................................................................................................ 8 3.3 Screening Criteria .......................................................................................................................... 9 Small Projects ........................................................................................................................ 9 Projects Located Near Transit ............................................................................................... 9 Local-Serving Retail and Similar Land Uses ........................................................................... 9 Local-Serving Public Facilities ................................................................................................ 9 Affordable Housing Projects ................................................................................................. 9 Redevelopment Projects That Result in a Net Reduction of VMT ...................................... 10 3.4 Significance Thresholds ............................................................................................................... 10 3.5 Vehicle Miles Traveled Analysis .................................................................................................. 10 Single Land-Use Residential or Office Projects ................................................................... 11 Mixed-Use Projects ............................................................................................................. 11 Redevelopment Projects ..................................................................................................... 11 Regional Retail Projects ...................................................................................................... 12 Nov. 5, 2025 Item #1 3 of 83 Vehicle Miles Traveled Analysis Guidelines | ii Industrial Projects ............................................................................................................... 12 Regional Public Facility Projects .......................................................................................... 12 3.6 Mitigation .................................................................................................................................... 13 4 TRANSPORTATION PROJECTS .................................................................................................... 14 4.1 Screening Criteria ........................................................................................................................ 14 4.2 Vehicle Miles Traveled Analysis .................................................................................................. 15 4.3 Significance Thresholds ............................................................................................................... 16 4.4 Mitigation .................................................................................................................................... 16 5 ADDITIONAL RESOURCES FOR VEHICLE MILES TRAVELED ANALYSIS ........................................... 17 APPENDICES Appendix A – Vehicle Miles Traveled Report Templates Appendix B – Resolution No. 2020-114 Appendix C – Screening Criteria and Threshold Evidence Appendix D – Vehicle Miles Traveled Metric Calculation Documentation Appendix E – Land Use Designations Appendix F – Vehicle Miles Traveled Reduction Strategies and Effectiveness Calculations Nov. 5, 2025 Item #1 4 of 83 Vehicle Miles Traveled Analysis Guidelines | 1 1 BACKGROUND This chapter provides background information on Senate Bill 743 (SB 743) and the need to conduct vehicle miles traveled (VMT) analyses for CEQA transportation studies. 1.1 SB 743 Legislation and Updated CEQA Guidelines SB 743 was passed by the legislature and signed into law in the fall of 2013. This legislation led to a change in the way that transportation impacts are measured under the California Environmental Quality Act (CEQA). The California Natural Resources Agency updated the Guidelines for the Implementation of the California Environmental Quality Act (CEQA Guidelines) in December 2018. Per the CEQA Guidelines, starting on July 1, 2020, automobile delay and level of service (LOS) are no longer used as the performance measure to determine the transportation impacts of land development projects under CEQA. Instead, an alternative metric that supports the goals of the SB 743 legislation is necessary. CEQA Guidelines Section 15064.3 provides requirements for determining the significance of transportation impacts and states that, “This section describes specific considerations for evaluating a project’s transportation impacts. Generally, vehicle miles traveled is the most appropriate measure of transportation impacts.” Per the CEQA Guidelines, lead agencies have discretion to develop their own methodologies or guidelines for determining significant environmental impacts. SB 743 and the updated CEQA Guidelines also apply to transportation projects. The intent of SB 743 is to bring CEQA transportation analyses into closer alignment with other statewide policies regarding greenhouse gases, active transportation, and infill development. 1.2 Governor’s Office of Planning and Research (OPR) Technical Advisory The SB 743 legislation designated OPR to write guidelines for implementation. The process of writing guidelines started in January 2014 and concluded in 2018. OPR published the Technical Advisory on Evaluating Transportation Impacts in CEQA in December 2018 which represents the current statewide guidance for the implementation of SB 743. Under CEQA, lead agencies can determine their own methodologies and significance thresholds for CEQA technical analyses but are required to provide substantial evidence as a basis of their decisions, if challenged. In its Technical Advisory, OPR generally provides substantial evidence for its recommendation. However, even OPR’s recommendations are subject to challenge, and if an agency were to rely on the Technical Advisory recommendations, that agency would need to be prepared to defend the recommendations and produce the substantial evidence. OPR is not in a position to defend the Technical Advisory recommendations on behalf of agencies that choose to use it. While OPR provides recommendations on many aspects of conducting a CEQA transportation analysis using VMT, OPR’s guidance is not comprehensive, and some key decisions are left for lead agencies to determine. Nov. 5, 2025 Item #1 5 of 83 Vehicle Miles Traveled Analysis Guidelines | 2 1.3 Consistency with City Goals and Policies The intent of SB 743 is directly related to three of the city’s core values as stated in the General Plan: (1) Walking, Biking, Public Transportation, and Connectivity; (2) Sustainability; and (3) Neighborhood Revitalization, Community Design, and Livability. It is also consistent with many of the goals and policies included in the General Plan. 2 PURPOSE AND OBJECTIVE OF VMT ANALYSIS 2.1 Purpose of VMT Analysis Guidelines The VMT Analysis Guidelines provide direction to city staff, consultants, and project applicants regarding the methodologies and thresholds to be used for VMT analysis for evaluating transportation impacts pursuant to CEQA in the City of Carlsbad. The guidelines generally follow the state guidance provided in OPR’s Technical Advisory but add detail that is specific to the City of Carlsbad. Project applicants should refer to the VMT report templates in Appendix A to ensure compliance with the VMT Analysis Guidelines. Although these guidelines are intended to be comprehensive, not all aspects of VMT analysis can be addressed in a single document. City staff will need to use judgment in applying these guidelines to specific projects and situations. Exceptions and additions to the guidelines will need to occur on a case-by-case basis. 2.2 Coordination with Other Agencies Preparation of a VMT analysis may require coordination with other agencies as follows: •Caltrans will review and provide comments on certain VMT analyses, particularly if the project requires a Caltrans encroachment permit or if it is considered to have a substantial effect on state highway facilities. •Coordination with SANDAG may be needed if a model run of the SANDAG regional travel demand model is needed. •Coordination with the North County Transit District (NCTD) may be needed if project mitigation measures related to transit are proposed. •Detailed coordination with adjacent cities and the County of San Diego will not normally be required unless a proposed mitigation measure crosses jurisdictional boundaries. 2.3 Necessary Qualifications of Individuals Preparing VMT Analyses Simple screening/scoping assessments and VMT evaluation that uses the City’s screening maps may be performed by the applicant or non-engineering professionals. The applicant should contact City of Carlsbad staff to confirm that the VMT screening/scoping/evaluation is simple and can be performed by non-engineering professionals. Completing screening/scoping assessments and VMT evaluation of complex or multi-use projects that require VMT modeling should typically be prepared under the direction of an individual who is Nov. 5, 2025 Item #1 6 of 83 Vehicle Miles Traveled Analysis Guidelines | 3 a licensed Traffic Engineer in the State of California or who has equivalent knowledge and experience. Individuals who have equivalent level of knowledge and experience should contact City of Carlsbad staff for approval prior to preparing a VMT analysis. 3 LAND DEVELOPMENT PROJECTS This chapter provides guidance on conducting VMT analyses for land development projects, including single-use projects, mixed-use projects, and redevelopment projects. 3.1 Overview of Analysis The City of Carlsbad generally follows the VMT analysis methodology recommended in OPR’s Technical Advisory. OPR recommends analyzing VMT for most residential and office projects based on efficiency metrics. Projects evaluated in this way are analyzed using VMT/capita or VMT/employee rather than total VMT. City County Resolution Number 2020-114 approves the VMT thresholds of significance and screening criteria. A copy of the resolution is provided in Appendix B. Information regarding the selection of thresholds and screening criteria is provided in Appendix C. For large projects (usually over 2,400 average daily trips1), a model run of the regional travel demand model operated by the San Diego Association of Governments (SANDAG) is often used to determine the project’s VMT/capita or VMT/employee. For smaller projects (usually under 2,400 average daily trips – see footnote), VMT/capita and VMT/employee may also be based on the SANDAG regional travel demand model. However, rather than using an individual model run for each project, VMT/capita and VMT/employee may be determined from maps prepared by the City of Carlsbad using output from the base year SANDAG regional model. These maps, shown by the sample in Figure 3.1, provide an estimate of personal vehicle travel by residents and employees for each Traffic Analysis Zone (TAZ) within the city. TAZ’s are geographical areas of varying size set up in the SANDAG regional travel demand model. The maps display VMT/capita and VMT/employee compared to city-wide VMT average and regional VMT average, respectively. The coloring scheme for the VMT maps is as follows: •TAZs shown in brown represent a VMT/capita or VMT/employee of less than 85% of the city-wide or regional average, respectively, indicating a less than significant impact. •TAZs shown in red represent a VMT/capita or VMT/employee of between 85% and 100% of the city-wide or regional average, respectively, indicating a significant impact. •TAZs shown in grey represent a VMT/capita or VMT/employee of over 100% of the city- wide or regional average, indicating a significant impact. 1 2,400 daily trips is a historical “rule of thumb” number that may be updated periodically based on the travel demand model sensitivity. The 2,400 daily trips historical “rule of thumb” is based on congestion management program requirements from over a decade ago, and it may be updated based on current model considerations; however, at the time of this document publication it is the best available information. Applicants should coordinate with City staff to confirm the project size at which the SANDAG regional travel demand model maybe run. Nov. 5, 2025 Item #1 7 of 83 Vehicle Miles Traveled Analysis Guidelines | 4 Figure 3.1: City of Carlsbad Residential VMT Map The City of Carlsbad’s VMT maps are available online here: https://experience.arcgis.com/experience/43b530c57da9469387c665d96f11c5d6. To use the maps, simply select the map corresponding to the project’s land use (either residential or employment) to the right of the screen. It is important to note that only one land use should be selected at a time. Then select the TAZ in which the project is located. A pop-up will appear displaying the VMT data for that TAZ, including its percentage of the city-wide or regional average, which can then be used to assess the project’s impact. The assumption for smaller projects is that project VMT/capita or VMT/employee can be estimated based on the average VMT/capita or VMT/employee for the TAZ in which it is located. In some cases, TAZ’s do not have sufficient existing development to form the basis for VMT calculations. In these cases, the VMT is determined based on the census tract in which the TAZ is located. Census tracts are larger geographic areas that typically contain several TAZ’s. It may be acceptable for a project under 2,400 ADT to complete an individual VMT assessment using VMT modeling tools (such as the SANDAG regional travel demand model) if the project size and type are unique. Note that use of the SANDAG regional travel demand model should be considered carefully for smaller projects because often a project is too small for the regional model to be sensitive to; therefore, regional model results may not appropriately represent the project. Likewise, it may be possible for a project that is over 2,400 ADT to use other VMT modeling tools (other than the SANDAG regional model) that are more project specific or representative of the project conditions or the VMT maps if it is the same land use type/characteristics (such as density) as existing land use in the project TAZ. In either case, coordination with City staff is recommended. Nov. 5, 2025 Item #1 8 of 83 Vehicle Miles Traveled Analysis Guidelines | 5 Project trip generation should normally be determined using methodologies consistent with city transportation guidelines. Reductions for internal trips and pass-by trips (if appropriate) should be made prior to determination of project trip generation. 3.2 VMT Modeling Tools The SANDAG regional travel demand model is one tool for estimating VMT. Since the SANDAG model is a regional tool that provides high level planning estimates it is not appropriate for use for all project types or at a microscopic scale. There are other modeling methods/tools that may be more appropriate depending on the project characteristics, redevelopment conditions, or project location. As stated in the OPR Technical Advisory: Section 15064.3 explains that a “lead agency may use models to estimate a project’s vehicle miles traveled . . . .” CEQA generally defers to lead agencies on the choice of methodology to analyze impacts. (Santa Monica Baykeeper v. City of Malibu (2011) 193 Cal.App.4th 1538, 1546; see Laurel Heights Improvement Assn. v. Regents of University of California (1988) 47 Cal.3d 376, 409 [“the issue is not whether the studies are irrefutable or whether they could have been better” … rather, the “relevant issue is only whether the studies are sufficiently credible to be considered” as part of the lead agency’s overall evaluation].) (OPR Technical Advisory, Page 4) Travel demand models, sketch models, spreadsheet models, research, and data can all be used to calculate and estimate VMT… To the extent possible, lead agencies should choose models that have sensitivity to features of the project that affect VMT. Those tools and resources can also assist in establishing thresholds of significance and estimating VMT reduction attributable to mitigation measures and project alternatives. When using models and tools for those various purposes, agencies should use comparable data and methods, in order to set up an “apples-to-apples” comparison between thresholds, VMT estimates, and VMT mitigation estimates. (OPR Technical Advisory, Page 30) Coordination with City staff is necessary if a model other than the SANDAG regional model is proposed for a project analysis. The following provides an overview of the two categories of models available for estimating VMT: •Travel Forecasting Models: A travel forecasting model is a computer model used to estimate travel behavior for a specific base year or horizon year based on land use and transportation network supply inputs. VMT is one output of a travel forecasting model run. The SANDAG regional travel demand model is an example of a travel forecasting model. •Other models and tools: Use of a travel forecasting model is not always the most appropriate method for estimating VMT (or may not be available in some cases), VMT can also be estimated using sketch models or spreadsheet tools. Typically, these types of models/tools estimate VMT directly by multiplying the number of trips by an average trip length. Trips can be estimated using the results of local trip generation surveys or trip generation rate data published by the Institute of Transportation Engineers (ITE). Trip lengths can be extracted from models, from standardized averages, or travel pattern data from household travel surveys, big data, or other sources. These methodologies could also Nov. 5, 2025 Item #1 9 of 83 Vehicle Miles Traveled Analysis Guidelines | 6 be paired with a travel model and used between major model updates or to estimate project generated VMT for smaller projects that would “get lost” or be part of the “model noise” in a regional travel demand model. VMT Efficiency Metric Definitions The SANDAG regional travel demand model provides standard VMT efficiency metric outputs. The VMT/capita and VMT/employee metrics produced by the SANDAG model are defined as follows: •VMT/capita is established by summing up total daily VMT generated by residents of a geographic area and dividing by the population of that geographic area. Total daily VMT includes all trip tours made by residents: home-based and non-home-based trip tours (i.e. all VMT for a resident for the entire day regardless of trip purpose or origin/destination). To analyze the VMT/capita for a proposed project, total daily VMT generated by project residents is divided by the project resident population. The VMT/capita produced by the SANDAG model specifically includes VMT generated within the SANDAG region by residents of the SANDAG region. If a resident travels outside of the region, their VMT is only accounted for up to the SANDAG boundary. Since the OPR Technical Advisory specifically provides guidance on avoiding truncating VMT2, to account for VMT generated by residents of the SANDAG region making trips outside (and the back into) the region, the SANDAG model data must be manually appended with the external VMT from the California Statewide Travel Demand Model. The City of Carlsbad city average VMT/capita and VMT maps have refined VMT/capita data that includes the external VMT generated by SANDAG region residents. •VMT/employee, as produced by the SANDAG model, is established by summing the work related total daily VMT generated by resident employees3 of a geographic area and dividing by the number of resident employees of that geographic area. Total daily work related VMT includes all work tours made by employees (this includes an employee’s commute and any other work-related travel such as going to lunch or to a meeting). To analyze the VMT/employee for a proposed project, the total work tour daily VMT produced by the project’s employees is divided by the total number of employees. The SANDAG model only accounts for VMT generated within the SANDAG region by employees who are also residents of the SANDAG region. Therefore, external VMT from resident employees is not captured in the SANDAG model output. In addition, employees that live outside of the region and travel into the SANDAG region for work are not accounted for in the SANDAG output. 2 Lead agencies should not truncate any VMT analysis because of jurisdictional or other boundaries, for example, by failing to count the portion of a trip that falls outside the jurisdiction or by discounting the VMT from a trip that crosses a jurisdictional boundary. CEQA requires environmental analyses to reflect a “good faith effort at full disclosure.” (CEQA Guidelines, § 15151.) Thus, where methodologies exist that can estimate the full extent of vehicle travel from a project, the lead agency should apply them to do so. Where those VMT effects will grow over time, analyses should consider both a project’s short-term and long-term effects on VMT. (OPR Technical Advisory, Page 6) 3 Resident employees both live and work in the SANDAG region. Nov. 5, 2025 Item #1 10 of 83 Vehicle Miles Traveled Analysis Guidelines | 7 The City of Carlsbad regional VMT/employee average and VMT maps display refined data that accounts for the VMT associated with the commute trip for people who commute into the SANDAG region from another adjacent county. The data used to include the external VMT is derived from the “origin-destination” trip tables from the SANDAG model (which is a modeling step that is not part of the VMT calculations). The external VMT generated by people who live and work within the SANDAG region and travel outside the SANDAG region as part of their work tour is not included. For example, for someone who lives and works in the San Diego region and would occasionally travel to Orange County for a work conference, his or her VMT associated with that trip is not included in the refined work tour metric. Including this work related VMT is not possible because the SANDAG model does not contain trip purpose information for trips that exit and return to the region. One limitation that applies to all VMT data produced by the SANDAG regional travel model is that VMT generated within Mexico (for example, a San Diego region resident who travels to Mexico to go shopping) or by residents of Mexico (for example someone who lives in Mexico and works in the San Diego region) are not accounted for due to lack of information. Additional documentation for the VMT/capita and VMT/employee refined metrics is provided in Appendix D. Figure 3.2 shows a flow chart that summarizes the VMT analysis process. Nov. 5, 2025 Item #1 11 of 83 Start Identify VMT Metrics by Land Use Type Pr o j e c t Sc r e e n i n g Id e n t i f y V M T Me a s u r e VM T Th r e s h o l d As s e s s m e n t of I m p a c t Mi t i g a t i o n Me a s u r e s * Screening Criteria•Small Projects (110 or fewer net new daily trips)•Projects Located within a ½ Mile of a Major Transit Stop or a Stop on a High-Quality Transit Corridor•Local-Serving Retail Projects•Local-Serving Public Facilities•Affordable Housing Projects•Redevelopment Projects with Lower TotalVMT Screened* Residential Employment Retail, Recreational, Public Facilities Mixed-Use***Industrial Employment Other Project Types** VMT/Capita VMT/Employee Total VMT Figure 3.2: VMT Analysis ProcessThe following process depicts the typical steps for performing VMT analysis in the City of Carlsbad. Deviations from this process may be necessary for specific projects or unique situations as coordinated with City staff. Project presumed to cause less than significant impact. Provide a Technical Memorandum of the Screening Process End 15% Below Citywide Average (residential)ORRegional Average (employment)At or Below Regional Average No Net Increase in Total VMT Finding of Less than Significant ImpactFinding of Significant Impact Impact Fully Mitigated Yes Yes **Refer to Appendix C for a list of other project typesand to determine which land use category is appropriatefor VMT analysis purposes. ***Each project component should be evaluated based on land use type (e.g., residential, employment, and retail) and VMT metric. Yes Yes No No No Yes No Additional Analysis VMT/Employee End Identify Mitigation Measures End Id e n t i f y V M T Ca l c u l a t i o n Me t h o d o l o g y Smaller Project(Generally≤2,400 net new daily trips) Perform Project Specific Modeling Consult with City Staff VMT Maps to Determine VMT or May Perform Project Specific Modeling Residential Employment Retail, Recreational, Public Facilities Mixed-Use***Industrial Employment Larger Project(Generally>2,400 net new daily trips) Small Project and Transit Screening Criteriaare not applicable per Cleveland National Forest Foundation v. County of San Diego (4th Appellate District). Nov. 5, 2025 Item #1 12 of 83 Vehicle Miles Traveled Analysis Guidelines | 9 3.3 Screening Criteria The following is a description of projects that would be presumed to have a less than significant transportation impact due to project type or location unless substantial evidence would suggest otherwise. If a project meets at least one of the following screening criteria, it would not require a detailed VMT analysis. However, a discussion summarizing the applicability of relevant screening criteria is required. NOTE: Screening criteria are intended to quickly identify when a project would typically be expected to cause a less than significant impact without conducting a detailed study (OPR Technical Advisory, Page 12, December 2018). There may be circumstances where a project meets one of the screening criteria, but evidence suggests that the project may increase areawide VMT. For example, OPR describes replacing affordable housing with fewer moderate- or high-income units, resulting in less VMT generated by the site (qualifying for the redevelopment screening); however, the displaced residents’ VMT also needs to be considered because it may cause an overall increase in VMT as the residents move to farther away affordable housing. Thus, in this example, the project would not qualify for screening. Another example is redevelopment of core services (basic grocery shopping, general needs stores/services, etc.) that the existing population relies on. Removing these core services, without replacing them, may cause VMT to increase as existing residents travel farther to access these services. An analysis showing the project’s effect on VMT or an analysis showing how basic service access changes may be necessary. Further guidance on screening criteria can be found in OPR’s Technical Advisory. Small Projects Per OPR’s Technical Advisory, projects that generate less than 110 ADT would be presumed to have a less than significant transportation impact. Projects that can demonstrate that they would generate an ADT of less than 110 after applying trip-reduction strategies would be screened out from performing additional analysis. Projects Located Near Transit Per OPR’s Technical Advisory, residential, retail, office projects, or projects that have a mix of those uses whose project site boundaries are within one half mile of an existing major transit stop, planned major transit stop, or a stop/transit center along a high-quality transit corridor would normally be presumed to have a less than significant transportation impact. In the City of Carlsbad, this would apply to projects within one half mile of the Carlsbad Village or Carlsbad Poinsettia Coaster stations, as well as projects within one-half mile of the Plaza Camino Real transit center. Certain types of projects that are located near transit would not have a presumption of a less than significant transportation impact even if located near transit. This would include, for example, projects with low density or high levels of parking. OPR Technical Advisory includes additional detail on determining the status of projects located near transit. Small Project and Transit Screening Criteria are not applicable per Cleveland National Forest Foundation v. County of San Diego (4th Appellate District). Nov. 5, 2025 Item #1 13 of 83 Vehicle Miles Traveled Analysis Guidelines | 10 Local-Serving Retail and Similar Land Uses Per OPR’s Technical Advisory, local-serving retail uses are presumed to have a less than significant impact on VMT since they tend to attract trips from adjacent areas that would have otherwise been made to more distant retail locations. Local-Serving Public Facilities Similar to retail land uses, local-serving public facilities are presumed to have a less than significant impact on VMT. This would include government facilities intended to serve the local public, parks, public elementary schools, public middle schools, and public high schools. A study evaluating the user capture area may be required in order to demonstrate that a public facility is local-serving. Typically, private schools, charter schools, or public facilities with unique uses will be required to provide a user capture area study. Affordable Housing Projects OPR’s Technical Advisory allows for a less than significant finding for transportation impacts of residential projects that are 100% affordable housing located in infill areas. Affordable housing projects in the City of Carlsbad could use this recommendation if they demonstrate that they are located in infill areas based on urban planning considerations. Redevelopment Projects That Result in a Net Reduction of VMT Per CEQA, projects are considered to have a less than significant impact if they result in a net reduction in the relevant performance measure (in this case VMT). Therefore, redevelopment projects in the City of Carlsbad that generate less VMT than the existing project they are replacing would be considered to have a less than significant impact on VMT. Since VMT/capita and VMT/employee are efficiency metrics, a redevelopment project that would produce more VMT than the existing project it is replacing would need to conduct a VMT analysis assuming the proposed land use (with no credit taken for the existing land use) to determine whether the proposed project meets the applicable significance thresholds. 3.4 Significance Thresholds Significance thresholds for land development projects are summarized below. Additional discussion and substantial evidence can be found in Appendix C. •Residential Projects: A significant transportation impact occurs if the project VMT/capita exceeds a level 15% below the city average VMT/capita •Office Projects: A significant transportation impact occurs if the project VMT/employee exceeds a level 15% below the regional average VMT/employee •Regional Retail Projects: A significant transportation impact occurs if the project results in a net increase in VMT •Industrial Projects: A significant transportation impact occurs if the project VMT/employee exceeds the average regional VMT/employee Nov. 5, 2025 Item #1 14 of 83 Vehicle Miles Traveled Analysis Guidelines | 11 If the project is using data from the SANDAG regional travel demand model, the city average VMT/capita and regional average VMT/employee values are determined using the SANDAG regional travel demand model. If the project is performing a custom model run, the “no project” version of the model version being used for the analysis should be used to derive the regional average VMT/employee and VMT/capita values. Note that different model runs will produce slightly varied results because the model is a simulation model (results can’t be identically replicated). If a different VMT analysis tool is used for the analysis, the values for the VMT thresholds should be determined using the tool that is being used for the analysis. It is not appropriate to use one tool/method to determine the VMT threshold and a different tool/method to perform the analysis. 3.5 Vehicle Miles Traveled Analysis For projects that do not meet the screening criteria listed above, a detailed VMT analysis is needed. This section provides guidance on how a VMT analysis should be conducted for various types of land development projects. See Appendix E for land use designations or consult city staff for project types that are not listed. For projects that are inconsistent with the General Plan or are evaluated using net change in VMT, a cumulative VMT analysis may be required. Consultation with city staff should be conducted in these cases to determine the appropriate VMT analysis methodology. Single Land-Use Residential or Office Projects Typical residential or office single land-use projects generating less than 2,400 ADT4 would use the City of Carlsbad VMT/capita and VMT/employee analysis maps and would determine VMT/capita or VMT/employee for the traffic analysis zone in which the project is located. If the project VMT/capita or VMT/employee exceeds the corresponding threshold of significance, a significant impact would be indicated. Mitigation measures would then be considered. Typical single land-use residential or office projects generating more than 2,400 ADT would use a model run of the SANDAG regional travel demand model or other VMT estimation tool to determine the project’s VMT/capita or VMT/employee. If the resulting VMT/capita or VMT/employee exceeds the corresponding threshold of significance, a significant impact would be indicated. Mitigation measures would then be considered. Mixed-Use Projects Per OPR’s Technical Advisory, VMT analysis for mixed-use projects would be conducted by analyzing each individual land use independently and applying the significance threshold for each land use. It is appropriate to calculate a VMT reduction associated with “internal capture” that is applied to each land use. Internal capture accounts for the vehicle trip 4 2,400 daily trips is a historical “rule of thumb” number that may be updated periodically based on the travel demand model sensitivity. Applicants should coordinate with City staff to confirm the project size at which the travel demand model should be run. As described, a variety of considerations go into the selection of which VMT modeling tool should be used. Nov. 5, 2025 Item #1 15 of 83 Vehicle Miles Traveled Analysis Guidelines | 12 reduction due to interaction between land uses and is typically calculated as part of the trip generation analysis. Reducing vehicle trips results in reduced VMT; therefore, a reduction in VMT can be taken for mixed use projects that have internal capture. Note that if the SANDAG model is used to perform the VMT analysis for a mixed use project, it will typically account for the internal capture and further reductions are typically not necessary. Redevelopment Projects Redevelopment projects that do not meet the screening criteria above would need to conduct a VMT analysis to determine whether they meet the appropriate significance thresholds based on the project type. For analysis that uses efficiency metrics, it would be based solely on the characteristics of the new project to be developed without any consideration of the development that is being replaced. Regional Retail Projects All retail projects that do not meet the screening criteria above are considered regional retail projects and require a project specific evaluation of VMT using the SANDAG model or other model/method to assess the effect that the project has on affected area VMT. Note that the affected area should be developed in consultation with City staff and may include the City, Region, or another area as appropriate to the context of the project. Regional retail projects that result in a net increase in VMT compared to the no project condition would have a significant transportation impact. Industrial Projects For the purposes of VMT analysis, industrial projects include establishments whose primary purpose is the manufacture of goods. See Appendix E for types of industrial land uses. Typical industrial projects generating less than 2,400 ADT5 would use the City of Carlsbad VMT/employee analysis maps and would determine VMT/employee for the traffic analysis zone in which the project is located. If the project VMT/employee exceeds the regional average VMT/employee, a potentially significant impact would be indicated. Mitigation measures would then be considered. Typical industrial projects generating more than 2,400 ADT would use a model run of the SANDAG regional travel demand model or other model/method to determine VMT/employee. If the resulting VMT/employee exceeds the regional average VMT/employee, a potentially significant impact would be indicated. Mitigation measures would then be considered. It should be noted that goods movement is not subject to VMT analysis. Therefore, goods movement trips associated with an industrial project would not be included when determining VMT/employee. 5 2,400 daily trips is a historical “rule of thumb” number that may be updated periodically based on the travel demand model sensitivity. Applicants should coordinate with City staff to confirm the project size at which the travel demand model should be run. Nov. 5, 2025 Item #1 16 of 83 Vehicle Miles Traveled Analysis Guidelines | 13 Regional Public Facility Projects Regional public facilities that do not meet the screening criteria above are analyzed like a regional retail project and require a project specific evaluation of VMT using the SANDAG model or other model/method to assess the effect that the project has on affected area VMT. Note that the affected area should be developed in consultation with City staff and may include the City, Region, or another area as appropriate to the context of the project. Regional public facility projects that result in a net increase in VMT compared to the no project condition would have a significant transportation impact. Note that for regional public facilities that are entirely office space (for agency staff, not customer facing) it may be appropriate to use the office project methodology/metrics, coordination with City staff is required. 3.6 Mitigation Projects can apply VMT reductions to lower their calculated resident VMT/capita or employee VMT/employee below the significance threshold. Typically, VMT is reduced by implementing strategies that achieve one of the following: •Reducing the number of automobile trips generated by the project or by the residents or employees of the project. •Reducing the distance that people drive. Measures that reduce single occupant automobile trips or reduce travel distances are called Transportation Demand Management (TDM) strategies. Several TDM strategies applied in combination is referred to as a TDM plan or program. See Appendix F for additional information on mitigation measures for land development projects. Nov. 5, 2025 Item #1 17 of 83 Vehicle Miles Traveled Analysis Guidelines | 14 4 TRANSPORTATION PROJECTS SB 743 also applies to transportation projects, which are projects that improve transportation facilities for any mode of travel. Per revised CEQA Section 15064.3, lead agencies have the discretion to determine the appropriate measure of transportation impact consistent with CEQA and other applicable requirements. As recommended in OPR’s Technical Advisory, the City of Carlsbad uses VMT as the performance measure for transportation projects. 4.1 Screening Criteria Per OPR’s Technical Advisory, certain types of transportation projects are presumed to have a less than significant impact on transportation. These include the following: •Rehabilitation, maintenance, replacement, safety, and repair projects designed to improve the condition of existing transportation assets (e.g., highways; roadways; bridges; culverts; Transportation Management System field elements such as cameras, message signs, detection, or signals; tunnels; transit systems; and assets that serve bicycle and pedestrian facilities) and that do not add additional motor vehicle capacity •Roadside safety devices or hardware installation such as median barriers and guardrails •Roadway shoulder enhancements to provide “breakdown space,” dedicated space for use only by transit vehicles, to provide bicycle access, or to otherwise improve safety, but which will not be used as automobile vehicle travel lanes •Addition of an auxiliary lane of less than one mile in length designed to improve roadway safety •Installation, removal, or reconfiguration of traffic lanes that are not for through traffic, such as left, right, and U-turn pockets, two-way left turn lanes, or emergency breakdown lanes that are not utilized as through lanes •Addition of roadway capacity on local or collector streets provided the project also substantially improves conditions for pedestrians, cyclists, and, if applicable, transit •Conversion of existing general purpose lanes (including ramps) to managed lanes or transit lanes, or changing lane management in a manner that would not substantially increase vehicle travel •Addition of a new lane that is permanently restricted to use only by transit vehicles •Reduction in number of through lanes •Grade separation to separate vehicles from rail, transit, pedestrians or bicycles, or to replace a lane in order to separate preferential vehicles (e.g., HOV, HOT, or trucks) from general vehicles •Installation, removal, or reconfiguration of traffic control devices, including Transit Signal Priority (TSP) features Nov. 5, 2025 Item #1 18 of 83 Vehicle Miles Traveled Analysis Guidelines | 15 •Installation of traffic metering systems, detection systems, cameras, changeable message signs and other electronics designed to optimize vehicle, bicycle, or pedestrian flow •Timing of signals to optimize vehicle, bicycle, or pedestrian flow •Installation of roundabouts or traffic circles •Installation or reconfiguration of traffic calming devices •Adoption of or increase in tolls •Addition of tolled lanes, where tolls are sufficient to mitigate VMT increase •Initiation of new transit service •Conversion of streets from one-way to two-way operation with no net increase in number of traffic lanes •Removal or relocation of off-street or on-street parking spaces •Adoption or modification of on-street parking or loading restrictions (including meters, time limits, accessible spaces, and preferential/reserved parking permit programs) •Addition of traffic wayfinding signage •Rehabilitation and maintenance projects that do not add motor vehicle capacity •Addition of new or enhanced bike or pedestrian facilities on existing streets/highways or within existing public rights-of-way •Addition of Class I bike paths, trails, multi-use paths, or other off-road facilities that serve non- motorized travel •Installation of publicly available alternative fuel/charging infrastructure •Addition of passing lanes, truck climbing lanes, or truck brake-check lanes in rural areas that do not increase overall vehicle capacity along the corridor 4.2 Vehicle Miles Traveled Analysis For projects that do require VMT analysis and are large transportation infrastructure projects, the typical approach would be to use the SANDAG regional travel model (or other model/method) and compare a model run without the project to a model run with the project and determine the net change in total VMT. Any net increase in VMT would result in a significant impact. It is possible to manually calculate VMT for a small-scale transportation projects if the size of the project would be inappropriate for inclusion in a regional travel model because of model sensitivity. Generally, the change in daily trips on the project roadway (i.e. a new roadway) and roadways Nov. 5, 2025 Item #1 19 of 83 Vehicle Miles Traveled Analysis Guidelines | 16 within a reasonable distance of the project should be estimated. VMT can be manually calculated by multiplying the daily trips by the length of the roadway. For small-scale roadway projects that serve a small area, are a short distance, or add a short section of new travel lane, a qualitative analysis may be appropriate. If a project closes a gap (such as a bridge connection) where it can be shown to reduce the travel distance for roadway users, the project would likely reduce VMT and have a less than significant impact. 4.3 Significance Thresholds The significance thresholds for transportation projects is the following: •Transportation Projects: A significant transportation impact occurs if the project results in a net increase in VMT 4.4 Mitigation Guidance on mitigation measures for transportation projects may be found in OPR’s Technical Advisory. Nov. 5, 2025 Item #1 20 of 83 Vehicle Miles Traveled Analysis Guidelines | 17 5 ADDITIONAL RESOURCES FOR VEHICLE MILES TRAVELED ANALYSIS This chapter provides locations of websites that can be used to locate additional resources that may be useful in conducting VMT analyses in the City of Carlsbad: •Governor’s Office of Planning and Research (OPR): https://www.opr.ca.gov/ceqa/sb-743/ •California Air Pollution Control Officers Association (CAPCOA). This organization has provided one of the most widely used resources for VMT mitigation (Handbook for Analyzing Greenhouse Gas Emission Reductions, Assessing Climate Vulnerabilities, and Advancing Health and Equity). It can be found at the following website: https://www.airquality.org/ClimateChange/Documents/Final%20Handbook_AB434.pdf •Caltrans SB 743 Website: https://dot.ca.gov/programs/sustainability/sb-743 Nov. 5, 2025 Item #1 21 of 83 VEHICLE MILES TRAVELED ANALYSIS GUIDELINES APPENDIX A VEHICLE MILES TRAVELED REPORT TEMPLATES Nov. 5, 2025 Item #1 22 of 83 VMT Report Template for Land Development Projects – Screening Only City of Carlsbad 1200 Carlsbad Village Dr. Carlsbad, CA 92008 1 How to Use this Template: Land development projects are required to conduct a California Environmental Quality Act (CEQA) transportation analysis to evaluate the transportation impacts of the project. The City of Carlsbad’s VMT Analysis Guidelines provide direction to City staff, consultants, and project applicants regarding the methodologies and thresholds to be used for VMT analysis. The VMT analysis process as documented in the VMT Analysis Guidelines is: 1.Apply project screening criteria. If the project meets at least one of the screening criteria, the project is assumed to cause a less than significant impact and a detailed VMT analysis is not necessary. If the project does not meet any of the screening criteria, continue to Step 2. 2.Identify VMT calculation methodology. 3.Identify VMT metric. 4.Determine whether project falls within VMT threshold. 5.Assess transportation impact. 6.Propose mitigation measures, if necessary. Report Types Based on the VMT analysis process, a project will fall into one of three report types listed below: •Screening Only – Projects that have met at least one of the screening criteria and do not require a detailed VMT analysis. •VMT Analysis Using VMT Maps – Smaller projects (i.e., projects that generate 2,400 or less average daily trips or projects that do not require a separate modeling approach) that do not meet any of the screening criteria and require a detailed VMT analysis using the City of Carlsbad’s VMT maps to determine VMT. NOTE: This method only applies to residential and employment projects. •VMT Analysis Using a Custom Model/Method – Larger projects that do not meet any of the screening criteria and require a detailed VMT analysis using a project-specific model/method to determine VMT. This template applies to projects identified as Screening Only projects. For more detailed information, please refer to the Vehicle Miles Traveled (VMT) Analysis Guidelines. Note that for projects with multiple land uses, the land use with the most complex report should be followed. If components of the project meet the screening criteria, they should be documented in the Screening Assessment section of the document. Nov. 5, 2025 Item #1 23 of 83 VMT Report Template for Land Development Projects – Screening Only City of Carlsbad 1200 Carlsbad Village Dr. Carlsbad, CA 92008 2 VMT Analysis (Screening Only) Requirements Submission Date: SECTION I: Developer Profile Developer Name: Property Manager Name: Developer Mailing Address: Number Street Suite City State Zip CodePrimary Contact Name: Primary Contact Phone/Email: Phone:Email: Transportation Consultant Firm/ Representative Transportation Consultant Phone/Email: Phone:Email: SECTION II: Project Information Project Name: Permit Number: Project Address: Number Street Suite City State Zip Code Nov. 5, 2025 Item #1 24 of 83 VMT Report Template for Land Development Projects – Screening Only City of Carlsbad 1200 Carlsbad Village Dr. Carlsbad, CA 92008 3 SECTION III: Compliance Overview Checklist Complete the appropriate sections of the checklist below to ensure compliance with the City of Carlsbad’s VMT Analysis Guidelines. CEQA VMT Analysis (Screening Only) Compliance Checklist Satisfactory? (completed by City) YES NO Technical memorandum documenting screening analysis and conclusions, citing relevant information from VMT Analysis Guidelines Chapter 3.3 ☐☐ Which of the screening criteria does the project satisfy? Select all that apply. ☐Small project (less than 110 net new daily trips) ☐Local-serving public facility ☐Project located near transit ☐Affordable housing project ☐Local-serving retail project ☐Redevelopment project resulting in net reduction of VMT ☐ ☐ SECTION IV: Technical Memorandum Contents The following provides the required contents of a VMT Analysis (Screening Only) technical memorandum. Page # or Appendix: (completed by preparer) CEQA VMT Analysis (Screening Only) Required Content Satisfactory? (completed by City) YES NO Introduction, including: •Purpose of the VMT Analysis and identification of the type of VMT report being prepared •Regional vicinity map with project location ☐☐ Project Description, including: •Proposed project description (land use type, intensity, etc.) •Projected opening year •Site plan ☐☐ Nov. 5, 2025 Item #1 25 of 83 VMT Report Template for Land Development Projects – Screening Only City of Carlsbad 1200 Carlsbad Village Dr. Carlsbad, CA 92008 4 VMT Screening Assessment •Table that displays all screening criteria and identifies which screening criteria the project meets. •Justification for how the project meets the screening criteria listed in the screening criteria table. This information may include: o Daily project trip generation (total, without adjustments for existing land uses on the site). o A map showing proximity of the project to a major transit stop, planned major transit stop, or a stop/transit center along a high-quality transit corridor and the walking route from the project to the transit stop. Justify that the project does not exceed Carlsbad parking requirements and that the floor area ratio does not exceed 0.75. o Locally serving characteristics of the project. o Documentation of the project’s location within an infill area and designation as 100% affordable housing. o A total VMT analysis comparison for a redevelopment project demonstrating that the proposed project generates less total VMT than the existing land uses. ☐☐ Nov. 5, 2025 Item #1 26 of 83 VMT Report Template for Land Development Projects – VMT Analysis Using VMT Maps City of Carlsbad 1200 Carlsbad Village Dr. Carlsbad, CA 92008 1 How to Use this Template: Land development projects are required to conduct a California Environmental Quality Act (CEQA) transportation analysis to evaluate the transportation impacts of the project. The City of Carlsbad’s VMT Analysis Guidelines provide direction to City staff, consultants, and project applicants regarding the methodologies and thresholds to be used for VMT analysis. The VMT analysis process as documented in the VMT Analysis Guidelines is: 1.Apply project screening criteria. If the project meets at least one of the screening criteria, the project is assumed to cause a less than significant impact and a detailed VMT analysis is not necessary. If the project does not meet any of the screening criteria, continue to Step 2. 2.Identify VMT calculation methodology. 3.Identify VMT metric. 4.Determine whether project falls within VMT threshold. 5.Assess transportation impact. 6.Propose mitigation measures, if necessary. Report Types Based on the VMT analysis process, a project will fall into one of three report types listed below: •Screening Only – Projects that have met at least one of the screening criteria and do not require a detailed VMT analysis. •VMT Analysis Using VMT Maps – Smaller projects (i.e., projects that generate 2,400 or less average daily trips or projects that do not require a separate modeling approach) that do not meet any of the screening criteria and require a detailed VMT analysis using the City of Carlsbad’s VMT maps to determine VMT. NOTE: This method only applies to residential and employment projects. •VMT Analysis Using a Custom Model/Method – Larger projects that do not meet any of the screening criteria and require a detailed VMT analysis using a project-specific model/method to determine VMT. This template applies to projects identified as VMT Analysis Using VMT Maps projects. For more detailed information, please refer to the Vehicle Miles Traveled (VMT) Analysis Guidelines. Note that for projects with multiple land uses, the land use with the most complex report should be followed. If components of the project meet the screening criteria, they should be documented in the Screening Assessment section of the document. Nov. 5, 2025 Item #1 27 of 83 VMT Report Template for Land Development Projects – VMT Analysis Using VMT Maps City of Carlsbad 1200 Carlsbad Village Dr. Carlsbad, CA 92008 2 VMT Analysis Using VMT Maps Requirements Submission Date: SECTION I: Developer Profile Developer Name: Property Manager Name: Developer Mailing Address: Number Street Suite City State Zip Code Primary Contact Name: Primary Contact Phone/Email: Phone: Email: Transportation Consultant Firm/ Representative Transportation Consultant Phone/Email: Phone: Email: SECTION II: Project Information Project Name: Permit Number: Project Address: Number Street Suite City State Zip Code Nov. 5, 2025 Item #1 28 of 83 VMT Report Template for Land Development Projects – VMT Analysis Using VMT Maps City of Carlsbad 1200 Carlsbad Village Dr. Carlsbad, CA 92008 3 SECTION III: Compliance Overview Checklist Complete the appropriate sections of the checklist below to ensure compliance with the City of Carlsbad’s VMT Analysis Guidelines. CEQA VMT Analysis Using VMT Maps Compliance Checklist Satisfactory? (completed by City) YES NO VMT Report documenting VMT screening and VMT analysis ☐ ☐ VMT Analysis performed using VMT maps ☐ ☐ VMT Impact Conclusion (significant or less than significant impact) ☐ ☐ Mitigation Measure Identification and Analysis (for significant impacts) ☐ ☐ SECTION IV: VMT Report Contents The following provides the required contents of a VMT Analysis Using VMT Maps Report. Page # or Appendix: (completed by preparer) CEQA VMT Analysis Using VMT Maps Required Content Satisfactory? (completed by City) YES NO Executive Summary/Introduction: • Purpose of VMT analysis and identification of type of VMT report being prepared • Regional vicinity map with project location • Project screening results • VMT analysis method (Carlsbad VMT maps) • Significance of CEQA impacts • Mitigation measures and significance after mitigation ☐ ☐ Project Description, including: • Proposed project description (land use type, intensity, etc.) ☐ ☐ Nov. 5, 2025 Item #1 29 of 83 VMT Report Template for Land Development Projects – VMT Analysis Using VMT Maps City of Carlsbad 1200 Carlsbad Village Dr. Carlsbad, CA 92008 4 • VMT reduction measures that are part of the project description • Site plan VMT Screening Assessment • Table that displays all screening criteria and demonstrates that the project does not meet the criteria and a brief statement of why. To demonstrate why a project doesn’t meet any of the screening criteria, the following information may be necessary: o Daily project trip generation (total, without adjustments for existing land uses on the site). o A map showing the project’s lack of proximity to a major transit stop, planned major transit stop, or a stop/transit center along a high- quality transit corridor. o Statements that locally serving, affordable housing, and redevelopment criteria are not applicable. • For projects with multiple land uses, perform a screening assessment and create a screening assessment table for each land use. Document the conclusion of the screening assessment by land use. If one land use meets the screening criteria and one does not, only complete a VMT analysis for the component that does not meet the screening criteria. ☐ ☐ Identify VMT Calculation Methodology and VMT Metric • Provide screenshot(s) of Carlsbad VMT maps with project TAZ(s) highlighted and VMT data displayed (for each metric that is applicable). • For residential projects, VMT/Capita is applicable. • For employment projects, VMT/Employee is applicable. • The VMT Analysis Using VMT Maps Report type is only applicable to residential and employment projects. ☐ ☐ Nov. 5, 2025 Item #1 30 of 83 VMT Report Template for Land Development Projects – VMT Analysis Using VMT Maps City of Carlsbad 1200 Carlsbad Village Dr. Carlsbad, CA 92008 5 Identify VMT Thresholds and Perform VMT Impact Analysis •Refer to the Carlsbad VMT Analysis Guidelines to determine the appropriate impact threshold to apply to the analysis. Document the threshold and the numerical value that represents the threshold. For example, the threshold for residential projects is 15% below the city-wide average VMT/capita, or currently 20.4 miles per resident. •Determine the project’s VMT using the Carlsbad VMT maps, and if applicable, apply any VMT reduction measures that are part of the project description (refer to VMT Analysis Guidelines Appendix F for guidance on performing reduction calculations). •Compare the project’s VMT to the City threshold and document if the project has a significant or less than significant impact. Identify and Analyze Mitigation Measures (if the Impact is Significant) •If a significant impact is identified, refer to VMT Analysis Guidelines Appendix F to identify potential mitigation measures and analysis guidance. •Analyze how much VMT reduction is associated with the mitigation measures and determine if mitigation reduces the impact to less than significant. •If the impact is still significant after mitigation is applied, document that the project has a significant and unavoidable impact. Nov. 5, 2025 Item #1 31 of 83 VMT Report Template for Land Development Projects – VMT Analysis Using Custom Model/Method City of Carlsbad 1200 Carlsbad Village Dr. Carlsbad, CA 92008 1 How to Use this Template: Land development projects are required to conduct a California Environmental Quality Act (CEQA) transportation analysis to evaluate the transportation impacts of the project. The City of Carlsbad’s VMT Analysis Guidelines provide direction to City staff, consultants, and project applicants regarding the methodologies and thresholds to be used for VMT analysis. The VMT analysis process as documented in the VMT Analysis Guidelines is: 1.Apply project screening criteria. If the project meets at least one of the screening criteria, the project is assumed to cause a less than significant impact and a detailed VMT analysis is not necessary. If the project does not meet any of the screening criteria, continue to Step 2. 2.Identify VMT calculation methodology. 3.Identify VMT metric. 4.Determine whether project falls within VMT threshold. 5.Assess transportation impact. 6.Propose mitigation measures, if necessary. Report Types Based on the VMT analysis process, a project will fall into one of three report types listed below: •Screening Only – Projects that have met at least one of the screening criteria and do not require a detailed VMT analysis. •VMT Analysis Using VMT Maps – Smaller projects (i.e., projects that generate 2,400 or less average daily trips or projects that do not require a separate modeling approach) that do not meet any of the screening criteria and require a detailed VMT analysis using the City of Carlsbad’s VMT maps to determine VMT. NOTE: This method only applies to residential and employment projects. •VMT Analysis Using a Custom Model/Method – Larger projects that do not meet any of the screening criteria and require a detailed VMT analysis using a project-specific model/method to determine VMT. This template applies to projects identified as VMT Analysis Using a Custom Model/Method projects. For more detailed information, please refer to the Vehicle Miles Traveled (VMT) Analysis Guidelines. Note that for projects with multiple land uses, the land use with the most complex report should be followed. If components of the project meet the screening criteria, they should be documented in the Screening Assessment section of the document. Nov. 5, 2025 Item #1 32 of 83 VMT Report Template for Land Development Projects – VMT Analysis Using Custom Model/Method City of Carlsbad 1200 Carlsbad Village Dr. Carlsbad, CA 92008 2 VMT Analysis Using Custom Model/Method Requirements Submission Date: SECTION I: Developer Profile Developer Name: Property Manager Name: Developer Mailing Address: Number Street Suite City State Zip Code Primary Contact Name: Primary Contact Phone/Email: Phone: Email: Transportation Consultant Firm/ Representative Transportation Consultant Phone/Email: Phone: Email: SECTION II: Project Information Project Name: Permit Number: Project Address: Number Street Suite City State Zip Code Nov. 5, 2025 Item #1 33 of 83 VMT Report Template for Land Development Projects – VMT Analysis Using Custom Model/Method City of Carlsbad 1200 Carlsbad Village Dr. Carlsbad, CA 92008 3 SECTION III: Compliance Overview Checklist Complete the appropriate sections of the checklist below to ensure compliance with the City of Carlsbad’s VMT Analysis Guidelines. CEQA VMT Analysis Using Custom Model/Method Compliance Checklist Satisfactory? (completed by City) YES NO VMT Report documenting VMT screening and VMT analysis ☐ ☐ VMT Analysis performed using custom model/method ☐ ☐ VMT Impact Conclusion (significant or less than significant impact) ☐ ☐ Mitigation Measure Identification and Analysis (for significant impacts) ☐ ☐ SECTION IV: VMT Report Contents The following provides the required contents of a VMT Analysis Using Custom Model/Method Report. Page # or Appendix: (completed by preparer) CEQA VMT Analysis Using Custom Model/Method Required Content Satisfactory? (completed by City) YES NO Executive Summary/Introduction: • Purpose of VMT analysis and identification of type of VMT report being prepared • Regional vicinity map with project location • Project screening results • VMT analysis method • Significance of CEQA impacts • Mitigation measures and significance after mitigation ☐ ☐ Nov. 5, 2025 Item #1 34 of 83 VMT Report Template for Land Development Projects – VMT Analysis Using Custom Model/Method City of Carlsbad 1200 Carlsbad Village Dr. Carlsbad, CA 92008 4 Project Description, including: • Proposed project description (land use type, intensity, etc.) • VMT reduction measures that are part of the project description • Site plan ☐ ☐ VMT Screening Assessment • Table that displays all screening criteria and demonstrates that the project does not meet the criteria and a brief statement of why. To demonstrate why a project doesn’t meet any of the screening criteria, the following information may be necessary: o Daily project trip generation (total, without adjustments for existing land uses on the site). o A map showing the project’s lack of proximity to a major transit stop, planned major transit stop, or a stop/transit center along a high- quality transit corridor. o Statements that locally serving, affordable housing, and redevelopment criteria are not applicable. • For projects with multiple land uses, perform a screening assessment and create a screening assessment table for each land use. Document the conclusion of the screening assessment by land use. If one land use meets the screening criteria and one does not, only complete a VMT analysis for the component that does not meet the screening criteria. ☐ ☐ Identify VMT Calculation Methodology and VMT Metric • Provide a detailed description of the methodology that will be used to perform the analysis, including assumptions and substantial evidence for use of the method (i.e. data sources, research studies, etc.). • Identify the appropriate metrics for the project land use(s). Document how the metrics will be developed from the custom model/method. ☐ ☐ Nov. 5, 2025 Item #1 35 of 83 VMT Report Template for Land Development Projects – VMT Analysis Using Custom Model/Method City of Carlsbad 1200 Carlsbad Village Dr. Carlsbad, CA 92008 5 Identify VMT Thresholds and Perform VMT Impact Analysis •Refer to the Carlsbad VMT Guidelines to determine the appropriate impact threshold to apply to the analysis. Document the threshold and the numerical value that represents the threshold. Note that the same methodology must be used to determine the project VMT and the VMT threshold. For example, if a custom spreadsheet model using origin/destination GIS analysis is used, the threshold must also be determined using the same method. •Determine the project’s VMT using the custom model/method, and if applicable, apply any VMT reduction measures that are part of the project description (refer to VMT Analysis Guidelines Appendix F for guidance on performing reduction calculations). •Compare the project’s VMT to the City threshold and document if the project has a significant or less than significant impact. ☐ ☐ Identify and Analyze Mitigation Measures (if the Impact is Significant) •If a significant impact is identified, refer to VMT Analysis Guidelines Appendix F to identify potential mitigation measures and analysis guidance. •Analyze how much VMT reduction is associated with the mitigation measures and determine if mitigation reduces the impact to less than significant. •If the impact is still significant after mitigation is applied, document that the project has a significant and unavoidable impact. ☐☐ Nov. 5, 2025 Item #1 36 of 83 VEHICLE MILES TRAVELED ANALYSIS GUIDELINES APPENDIX B RESOLUTION NO. 2020-114 Nov. 5, 2025 Item #1 37 of 83 RESOLUTION NO. 2020-114 A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF CARLSBAD, CALIFORNIA, APPROVING VEHICLE MILES TRAVELED THRESHOLDS OF SIGNIFCANCE AND SCREENING CRITERIA FOR PUPRPOSES OF ANALYZING TRANSPORTATION IMPACTS UNDER THE CALIFORNIA ENVIRONMENTAL QUALITY ACT EXHIBIT 1 WHEREAS, the California Environmental Quality Act Guidelines ("CEQA Guidelines") encourage public agencies to develop and publish generally applicable "thresholds of significance" to be used in determining the significance of a project's environmental effects; and WHEREAS, CEQA Guidelines section 15064.7(a) defines a threshold of significance as "an identifiable quantitative, qualitative or performance level of a particular environmental effect, noncompliance with which means the effect will normally be determined to be significant by the agency and compliance with which means the effect normally will be determined to be less than significant"; and WHEREAS, screening criteria are applied to determine when a project should be expected to cause a less-than-significant impact without conducting a detailed study; and WHEREAS, CEQA Guidelines section 15064.7(b) requires that thresholds of significance must be adopted by ordinance, resolution, rule, or regulations, developed through a public review process, and be supported by substantial evidence; and WHEREAS, pursuant to CEQA Guidelines section 15064. 7(c), when adopting thresholds of significance, a public agency may consider thresholds of significance adopted or recommended by other public agencies provided that the decision of the agency is supported by substantial evidence; and WHEREAS, Senate Bill 743, enacted in 2013 and codified in Public Resources Code section 21099, required changes to the CEQA Guidelines regarding the criteria for determining the significance of transportation impacts of projects; and WHEREAS, in 2018, the Governor's Office of Planning and Research ("OPR") proposed, and the California Natural Resources Agency certified and adopted, new CEQA Guidelines section 15064.3 that identifies vehicle miles traveled ("VMT") -meaning the amount and distance of automobile travel attributable to a project -as the most appropriate metric to evaluate a project's transportation impacts; and June 16, 2020 Item #7 Page 9 of 221Nov. 5, 2025 Item #1 38 of 83 EXHIBIT 1 WHEREAS, as a result, automobile delay, as measured by "level of service" and other similar metrics, generally no longer constitutes a significant environmental effect under CEQA; and WHEREAS, CEQA Guidelines section 15064.3 goes into effect on July 1, 2020, though public agencies may elect to be governed by this section immediately; and WHEREAS, the City of Carlsbad, following internal study and a public review process consisting of staff a presentation before the Transportation and Mobility Commission, wishes to adopt VMT thresholds of significance for determining the significance of transportation impacts and screening criteria; and WHEREAS, on June 16, 2020, the City Council held a duly noticed public hearing to consider this Resolution, at which all persons interested were given an opportunity to be heard. NOW, THEREFORE, BE IT RESOLVED by the City Council of the City of Carlsbad, California, as follows: 1. That the above recitations are true and correct. 2. That the City of Carlsbad hereby adopts the VMT thresholds of significance and screening criteria for transportation impact analysis under CEQA that are included as Attachment A. These thresholds of significance and screening criteria have been developed through a public review process and are supported by substantial evidence, as required by CEQA Guidelines section 15064.7. 3. This Resolution shall take effect on July 1, 2020. PASSED, APPROVED AND ADOPTED at a Regular Meeting of the City Council of the City of Carlsbad on the 16th day of June 2020, by the following vote, to wit: AYES: NAYS: ABSENT: Hall, Blackburn, Bhat-Patel, Schumacher. None. None. MATT HALL, Mayor (SEAL) June 16, 2020 Item #7 Page 10 of 221Nov. 5, 2025 Item #1 39 of 83 VEHICLE MILES TRAVELED ANALYSIS GUIDELINES APPENDIX C SCREENING CRITERIA AND THRESHOLD EVIDENCE Nov. 5, 2025 Item #1 40 of 83 Vehicle Miles Traveled Analysis Guidelines (May 2023) | C-1 SCREENING CRITERIA AND THRESHOLD EVIDENCE This appendix provides context and evidence for the screening criteria and threshold evidence included in Chapters 3 for Land Development Projects and Chapter 4 for Transportation Projects. Screening Criteria Certain types of development projects are presumed to have less than significant impacts to the transportation system, and therefore would not be required to conduct a detailed VMT analysis, if any of the following criteria are established, based on substantial evidence. Small Projects Small projects that would generate less than 110 average daily vehicle trips (ADT), would also not result in significant transportation impacts on the transportation system: Evidence – The OPR Technical Advisory states that “projects that generate or attract fewer than 110 trips per day generally may be assumed to cause a less-than-significant impact.” This is supported by the fact that CEQA provides a categorical exemption for existing facilities, including additions to existing structures of up to 10,000 square feet, so long as the project is in an area where public infrastructure is available to allow for maximum planned development, and the project is not in an environmentally sensitive area. (CEQA Guidelines, § 15301(e)(2).) Typical project types for which trip generation increases relatively linearly with building footprint (e.g., general office building, single tenant office building, office park, or business park) generate or attract an additional 110- 124 trips per 10,000 square feet. Therefore, absent substantial evidence otherwise, it is reasonable to conclude that the addition of 110 or fewer trips could be considered not to lead to a significant impact. Projects Located Near Transit Per OPR’s Technical Advisory projects whose project site boundaries are within a half mile of an existing or planned major transit stop or a major stop along a high-quality transit corridor can be screened out of VMT analysis. Withing the City of Carlsbad, this would apply to projects within one half mile of the Carlsbad Village or Carlsbad Poinsettia Coaster stations, as well as projects within one-half mile of the Plaza Camino Real transit center. This presumption would not apply, however, if project-specific or location-specific information indicates that the project will still generate significant levels of VMT. Evidence – The OPR Technical Advisory states that “Proposed CEQA Guideline Section 15064.3, subdivision (b)(1), states that lead agencies generally should presume that certain projects (including residential, retail, and office projects, as well as projects that are a mix of these uses) proposed within ½ mile of an existing major transit stop or an existing stop along a high quality transit corridor will have a less-than-significant impact on VMT. This presumption would not apply, however, if project-specific or location-specific information indicates that the project will still generate significant levels of VMT.” Pub. Resources Code, § 21064.3 clarifies the definition of a major transit stop (“ ‘Major transit stop’ means a site containing an existing rail transit station, a ferry terminal served by either a bus or rail transit service, or the intersection of two or more major bus routes with a frequency of service interval of 15 minutes or less during the morning and afternoon peak commute periods.”). Pub. Resources Code, § 21155 clarifies the definition of a major transit stop (“For purposes of this section, a high-quality transit corridor means Nov. 5, 2025 Item #1 41 of 83 Vehicle Miles Traveled Analysis Guidelines (May 2023) | C-2 a corridor with fixed route bus service with service intervals no longer than 15 minutes during peak commute hours..”). Local-Serving Retail and Similar Uses Local-serving retail is defined in the City of Carlsbad as retail that is less than 50,000 square feet of total gross floor area or retail development that is greater than 50,000 square feet that has a market area study showing a market capture area that is primarily within Carlsbad and the adjacent cities of Oceanside, Vista, San Marcos, and Encinitas. Local-serving retail is typically characterized by retail and services that people access on a regular basis such as supermarkets, drug stores, discount store, restaurants, strip commercial, and other uses as identified in Appendix E. Evidence – The OPR Technical Advisory provides that “because New local-serving retail development new retail development typically redistributes shopping trips rather than creating new trips. The greater options and access to services that are nearby Carlsbad residential uses, the less likely it is for those residents to travel out of their way to obtain the service. For example, if an existing market is 3 miles away, and a new one is built 1 mile away, any resident that chooses the closer store would save 2 VMT, as shown in the graphic below. While some residents may still patronize the store that is 3 miles away, even if just one customer changes to the closer store, VMT is saved. It is reasonable to anticipate that a proportion of residents will choose the closer store, saving a significant amount of VMT. This concept applies to any retail/commercial that offers regular needs. A reduction in total VMT is considered a less than significant impact; therefore, since local-serving retail reduces VMT, it is presumed to have a less than significant impact. , estimating the total change in VMT (i.e., the difference in total VMT in the area affected with and without the project) is the best way to analyze a retail project’s transportation impacts.” Local serving retail generally shortens trips as longer trips from regional retail are redistributed to new local retail. The OPR Technical Advisory states that stores larger than 50,000 square feet may be considered regional-serving.Note that S since the type of retail influences whether it will be locally serving or retail servinglocal serving (for example grocery, drug stores, convenience stores, etc.) and the size of these facilities may be above 50,000 square feet, an applicant can provide a market surveydocumentation demonstrating that the project serves the local community if it is over 50,000 square feet. Nov. 5, 2025 Item #1 42 of 83 Vehicle Miles Traveled Analysis Guidelines (May 2023) | C-3 Local-Serving Public Facilities Local-serving public facilities are City or other public agency facilities that provide services or support to the community. Land uses such as libraries, public schools, fire stations, city buildings, and parks are all considered local-serving. A full list is provided in Appendix E. Similar to local-serving retail, local-serving public facilities serve the community and either produce very low VMT or divert existing trips from established local facilities. Evidence – Similar to local-serving retail, local-serving public facilities serve the community and providing additional access by constructing new public buildings/locations reduces VMT. For example, if an additional fire station were built in Carlsbad, the service call area of other nearby stations would decrease and the new station would provide closer and more efficient access to residents in need, reducing total VMT associated with emergency service calls. Similarly, if additional library or community recreation resources are provided closer than an existing facility residents may shift from driving to a more distant facility to use a closer facility as depicted in the graphic below. Even if just one resident chooses the closer option, VMT is reduced. It is reasonable to anticipate that a proportion of residents will choose to use the closer facility, saving a significant amount of VMT. A reduction in total VMT is considered a less than significant impact; therefore, since local-serving public facilities reduce total VMT, they are presumed to have a less than significant impact. Per CEQA, projects are considered to have a less than significant impact if they result in a net reduction in the relevant performance measure. Similar to local serving retail, local serving public facilities would redistribute trips and would not create new trips. Thus, similar to local serving retail, trips are generally shortened as longer trips from a regional facility are redistributed to the local serving public facility. The evidence from the OPR Technical Advisory described above also applies to local-serving public facilities. Affordable Housing Projects Affordable Housing is defined as multi-family housing that is below market rate, affordable for lower income families, and is deed restricted or otherwise permanently dedicated as affordable housing. The California Department of Housing and Community Development (2021) defines lower-income as 80 Nov. 5, 2025 Item #1 43 of 83 Vehicle Miles Traveled Analysis Guidelines (May 2023) | C-4 percent of the area median income or below, and affordable housing as costing 30 percent of the gross household income or less. Residents of affordable residential projects typically generate less VMT than residents in market rate residential projects. This pattern is particularly evident in affordable residential projects near transit. In recognition of this effect, and in accordance with the OPR Technical Advisory, deed- restricted affordable housing projects meet the City’s screening criteria and would not require a VMT analysis. Projects that provide affordable housing affordable to persons with a household income equal to or less than 50 percent of the area median income as defined by California Health and Safety Code Section 50093, housing for senior citizens (as defined in Section 143.0720(e)), housing for transitional foster youth, disabled veterans, or homeless persons (as defined in 143.0720(f)) are not required to complete a VMT analysis. Evidence –Affordable residential projects generate fewer trips than market rate residential projects. This supports the assumption that the rate of vehicle ownership is expected to be less for persons that qualify for affordable housing. Additionally, senior citizens, transitional foster youth, disabled veterans, and homeless individuals also have low vehicle ownership rates. The CAPCOA GHG Handbook (2024) provides the GHG percent reduction (which is equivalent to the VMT reduction) expected in affordable housing projects as compared to market rate projects. The CAPCOA GHG Handbook relies on the 11th Edition of the ITE Trip Generation Manual (2021) Land Use Category 221 – “Multifamily Housing (low-rise and not close to transit)” and ITE Land Use Category 223 – “Affordable Multifamily Housing.” It compares the daily trip generation rates for these two categories. The daily trip generation rate for Category 223 is 28.6% less than the rate for Category 221. While the ITE Trip Generation Manual is only focused on trip generation (not trip length or VMT) it is appropriate to apply because the equation for VMT is trip generation multiplied by average trip length. If the trip generation is 28.6% lower for an affordable housing project, and the trip length is unchanged for a project in a given location (which is an appropriate assumption, because trip length is a direct result of project location), it follows that the VMT would also be 28.6% lower. The City of Carlsbad’s VMT threshold for housing is 85% or below the citywide average VMT/capita. Carlsbad provides current citywide VMT/capita information by Traffic Analysis Zone (TAZ) based on the current SANDAG travel demand model. Based on analysis conducted using the current SANDAG Activity Based Model 2+, the TAZ that has the highest VMT/capita in Carlsbad has a VMT of 26.1 miles, which is 108.3% higher than the citywide average of 24.0. Therefore, an affordable housing project located in this TAZ would be expected to have a VMT that is 28.6% lower than the TAZ’s current VMT. This would result in 18.6 VMT/capita for the affordable housing project, which is 78% of the citywide average. 78% of the citywide average is better than the 85% of citywide average threshold, resulting in a less than significant impact. Since this analysis is conduced for the location in the City with the highest VMT/capita, affordable housing in all other locations of the City would have lower VMT/capita than this location and would also have a less than significant impact. Nov. 5, 2025 Item #1 44 of 83 Vehicle Miles Traveled Analysis Guidelines (May 2023) | C-5 Redevelopment Projects That Cause a Net Reduction in VMT A redevelopment project is a project that is demolishing an existing use (that has been in operation within two years of the initial project application submittal to the city) and replacing it with a new use. that demonstrates that the total project VMT is less than the existing land use’s total VMT is not required to complete a VMT analysis. Evidence – If analysis shows that the new proposed project would generate less total VMT than the project it is replacing the proposed project is reducing VMT. Consistent with the OPR Technical Advisory, “[w]here a project replaces existing VMT- generating land uses, if the replacement leads to a net overall decrease in VMT, the project would lead to a less-than-significant transportation impact. If the project leads to a net overall increase in VMT, then the thresholds described above should apply.” A reduction in total VMT is considered a less than significant impact; therefore, a redevelopment project that reduces total VMT has a less than significant impact. Per CEQA, projects are considered to have a less than significant impact if they result in a net reduction in the relevant performance measure. Thresholds If a project is required to complete a VMT analysis, the project’s impacts to the transportation system would be significant if the VMT would exceed any of the thresholds below. Residential Projects Threshold – 15% below city average household VMT/Capita. Evidence – The OPR Technical Advisory provides that “residential development that would generate vehicle travel that is 15 or more percent below the existing residential VMT/capita, measured against the region or city, may indicate a less-than-significant transportation impact.” Office/Employment Projects Threshold – 15% below regional average VMT/Employee. Evidence – The OPR Technical Advisory provides that “office projects that would generate vehicle travel exceeding 15 percent below existing VMT/employee for the region may indicate a significant transportation impact.” Industrial Projects Threshold – Above the regional average VMT/employee Evidence – The OPR Technical Advisory provides that “[o]f land use projects, residential, office, and retail projects tend to have the greatest influence on VMT. For that reason, OPR recommends the quantified thresholds described above for purposes of analysis and mitigation. Lead agencies, using more location- specific information, may develop their own more specific thresholds, which may include other land use types.” Purely industrial uses are desired to be located in locations that are less dense and not within urban areas which typically have higher VMT/employee. Industrial land uses are land intensive; therefore, placing industrial land uses in less urban areas characterized by having higher VMT/employee allows land in efficient VMT areas to be more effectively utilized as high density residential and commercial uses. This threshold is consistent with achieving an overall reduction in VMT. It recognizes that industrial uses, which Nov. 5, 2025 Item #1 45 of 83 Vehicle Miles Traveled Analysis Guidelines (May 2023) | C-6 generate relatively lower total VMT are most appropriate in areas that have a lower potential to reduce VMT. This allows more available land within areas with a high potential to achieve VMT reductions available for more dense development. Regional Retail Regional retail uses are retail uses that are larger than 50,000 square feet of total gross floor area and/or do not have a market study indicating that they are local-serving. Threshold – A net increase in total regional VMT Evidence – The OPR Technical Advisory provides that “because new rRetail development typically redistributes shopping trips rather than creating new trips, estimating the total change in VMT (i.e., the difference in total VMT in the area affected with and without the project) is the best way to analyze a retail project’s transportation impacts. …Therefore, since Rregional-serving retail development,… which can lead to substitution of longer trips for shorter ones, VMT analysis should be conducted to determine the change in the affected area’s total VMT.may tend to have a significant impact. Where such development decreases results in a decrease in affected area total VMT, lead agencies should consider the impact is to be less-than- significant.”. Transportation Project Screening Criteria This section provides a list of transportation projects that are presumed to have a less than significant impact, and therefore, would not be required to conduct VMT analysis. Project types that would not result in increased vehicle travel have a less than significant impact and can be screened out from performing VMT analysis. These types of projects include:  Rehabilitation/maintenance projects that do not add motor vehicle capacity  Addition of bicycle facilities  Intersection traffic signal improvements/turn-lane configuration changes  Additional capacity on local/collector streets if conditions are substantially improved for active transportation modes  Installation of roundabouts and traffic calming devices The following specific project types are presumed to have a less than significant impact to VMT:  Rehabilitation, maintenance, replacement, safety, and repair projects designed to improve the condition of existing transportation assets (e.g., highways; roadways; bridges; culverts; Transportation Management System field elements such as cameras, message signs, detection, or signals; tunnels; transit systems; and assets that serve bicycle and pedestrian facilities) and that do not add additional motor vehicle capacity  Roadside safety devices or hardware installation such as median barriers and guardrails Nov. 5, 2025 Item #1 46 of 83 Vehicle Miles Traveled Analysis Guidelines (May 2023) | C-7  Roadway shoulder enhancements to provide “breakdown space,” dedicated space for use only by transit vehicles, to provide bicycle access, or to otherwise improve safety, but which will not be used as automobile vehicle travel lanes  Addition of an auxiliary lane of less than one mile in length designed to improve roadway safety  Installation, removal, or reconfiguration of traffic lanes that are not for through traffic, such as left, right, and U-turn pockets, two-way left turn lanes, or emergency breakdown lanes that are not utilized as through lanes  Addition of roadway capacity on local or collector streets provided the project also substantially improves conditions for pedestrians, cyclists, and, if applicable, transit  Conversion of existing general purpose lanes (including ramps) to managed lanes or transit lanes, or changing lane management in a manner that would not substantially increase vehicle travel  Addition of a new lane that is permanently restricted to use only by transit vehicles  Reduction in number of through lanes  Grade separation to separate vehicles from rail, transit, pedestrians or bicycles, or to replace a lane in order to separate preferential vehicles (e.g., HOV, HOT, or trucks) from general vehicles  Installation, removal, or reconfiguration of traffic control devices, including Transit Signal Priority (TSP) features  Installation of traffic metering systems, detection systems, cameras, changeable message signs and other electronics designed to optimize vehicle, bicycle, or pedestrian flow  Timing of signals to optimize vehicle, bicycle, or pedestrian flow  Installation of roundabouts or traffic circles  Installation or reconfiguration of traffic calming devices  Adoption of or increase in tolls  Addition of tolled lanes, where tolls are sufficient to mitigate VMT increase  Initiation of new transit service  Conversion of streets from one-way to two-way operation with no net increase in number of traffic lanes  Removal or relocation of off-street or on-street parking spaces Nov. 5, 2025 Item #1 47 of 83 Vehicle Miles Traveled Analysis Guidelines (May 2023) | C-8  Adoption or modification of on-street parking or loading restrictions (including meters, time limits, accessible spaces, and preferential/reserved parking permit programs)  Addition of traffic wayfinding signage  Rehabilitation and maintenance projects that do not add motor vehicle capacity  Addition of new or enhanced bike or pedestrian facilities on existing streets/highways or within existing public rights-of-way  Addition of Class I bike paths, trails, multi-use paths, or other off-road facilities that serve non- motorized travel  Installation of publicly available alternative fuel/charging infrastructure  Addition of passing lanes, truck climbing lanes, or truck brake-check lanes in rural areas that do not increase overall vehicle capacity along the corridor Evidence – The list above contains transportation projects that would not change VMT, such as minor modifications to roadways and intersections and safety improvements or would reduce VMT, such as adding bicycle and pedestrian infrastructure. Since these projects would not change or reduce VMT, they are is consistent with recommendations in the OPR Technical Advisory that indicates projects that can be presumed to have a less than significant impact on VMT due to overall project characteristics. Threshold For transportation projects, significant impact occurs if the project results in a net increase in VMT. Evidence – Use of any net increase in the performance measure (in this case VMT) is considered to be the most conservative possible threshold possible under CEQA, assuming that any degradation in the performance measure cause a significant impact. In the OPR Technical Advisory, the determination of a performance measure for transportation projects is left to the discretion of the lead agency. Nov. 5, 2025 Item #1 48 of 83 VEHICLE MILES TRAVELED ANALYSIS GUIDELINES APPENDIX D VEHICLE MILES TRAVELED METRIC CALCULATION DOCUMENTATION Nov. 5, 2025 Item #1 49 of 83 Vehicle Miles Traveled Analysis Guidelines (May 2023) | D-1 VMT METRIC CALCULATION DOCUMENTATION ACCOUNTING FOR EXTERNAL VMT The City of Carlsbad uses refined VMT/capita and VMT/employee metrics instead of the metrics as produced directly from SANDAG and displayed on the SANDAG website/web-map application. The purpose of producing refined metrics is to provide more detailed estimates that are consistent with the recommendations from the OPR Technical Advisory on Evaluating Transportation Impacts in CEQA (December 2018). Specifically, refined metrics are responsive to the following quote from the OPR Technical Advisory: •Considerations for All Projects. Lead agencies should not truncate any VMT analysis because ofjurisdictional or other boundaries, for example, by failing to count the portion of a trip that falls outside the jurisdiction or by discounting the VMT from a trip that crosses a jurisdictional boundary. CEQA requires environmental analyses to reflect a “good faith effort at full disclosure.” (CEQAGuidelines, §15151.) Thus, where methodologies exist that can estimate the full extent of vehicle travel from a project, the lead agency should apply them to do so. Where those VMT effects will grow over time, analyses should consider both a project’s short-term and long-term effects on VMT (Page 6). If a SANDAG model run is used to evaluate a project’s VMT/capita or VMT/employee, an additional step is necessary to refine the results for impact analysis purposes. This step is to run a script that is available to the City and the step will be performed by City staff or affiliates. The script is available in two programming language formats; Python and R. The script utilizes SANDAG model files (some of the files are model outputs that will be generated after running the model and some are the model inputs) to calculate the employee and resident VMT based on new refined metrics. The following files should be requested from SANDAG/City in the CSV format to run the script: 1.Households (from SANDAG) – it provides information for every household in the SANDAG region. 2.Persons (from SANDAG) – it provides information for every person within a household in the SANDAG region. 3.wsLocResults_3 (from SANDAG) – it provides information about the work and school location. Only work location information is used for this script. 4.maz_xref (from SANDAG) – it provides information about Micro Analysis Zones (MAZ or MGRA); in what TAZ, Census Tract, City, or County they are located. 5.Ietrip (from SANDAG) – it provides information about internal-external trips. These trips are made by SANDAG residents who travel outside the region. Nov. 5, 2025 Item #1 50 of 83 Vehicle Miles Traveled Analysis Guidelines (May 2023) | D-2 6. Eitrip (from SANDAG) – it provides information about external-internal trips. These trips are made by people living outside the SANDAG region who travel to San Diego County. 7. Jointtrips (from SANDAG) – it provides information about trips made by SANDAG residents traveling in groups of more than one person per vehicle. 8. Indivtrips (from SANDAG) – it provides information about individual trips made by SANDAG residents. 9. jointTourData_3 (from SANDAG) – it provides information about tours made by SANDAG residents traveling in groups of more than one person per vehicle. 10. ieei (from the City) – it provides information about the average trip length outside the region for residents and non-residents where either end of their trips started in the SANDAG region. This file is based on the CSTDM and provides the calculated weighted average trip length outside of the region. Once the files are obtained, they can be loaded in the script. All necessary functions and libraries are included in the script to load and process the data. Outputs of the script will be generated in two CSV files for VMT/Capita and VMT/Employee. The CSV files will include all TAZs within the region. The user should look for the TAZ that they are interested in to find the associated VMT/Capita or VMT/Employee. The following sections explain how the refined metrics differ from the “off-the-shelf” metrics from SANDAG. VMT per Capita A limitation of the SANDAG-generated VMT/Capita is that it only includes VMT generated within the SANDAG region by residents of the SANDAG region. For example, if a resident of San Diego County shops in Riverside County, a part of his or her trip from the SANDAG border to the shopping mall would not be included in that resident’s VMT record. In addition, the Technical Advisory statement, mentioned above (CEQA Guidelines, § 15151), indicates that external trips – trips that originate or terminate outside of the transportation model area or outside of the agency – should be considered when calculating VMT. For the County of San Diego, this would entail incorporating VMT information from Riverside County, Imperial County, and Orange County. In addition, VMT associated with trips originating or terminating in Mexico should also be included; however, including these Mexico – US trips is extremely difficult because VMT data sources are extremely limited. To account for VMT generated by residents of the SANDAG region traveling outside of the region, the California Statewide Travel Demand Model (CSTDM) was used to calculate average trip lengths outside of San Diego County for each entry/exit point of San Diego County. These trip lengths were appended to trips made by residents of San Diego County to Riverside, Orange, or Imperial Counties and back to calculate VMT per Resident considering the entirety of a resident’s daily vehicle miles traveled both within and outside the County. Table D-1 displays the current base year (2012) weighted average distance beyond the SANDAG model boundary for trips passing through each model gateway using the CSTDM. Nov. 5, 2025 Item #1 51 of 83 Vehicle Miles Traveled Analysis Guidelines (May 2023) | D-3 TABLE D-1 - TRIP DISTANCES OUTSIDE SAN DIEGO COUNTY FOR ENTERING AND EXITING TRIPS Gateway Distance Outside San Diego County (miles) Route County IX Trips XI Trips I-8 Imperial 70.16 69.20 SR-78 Imperial 54.07 58.90 SR-79 Riverside 71.71 62.54 Pechanga Pkwy Riverside 35.89 30.91 I-15 Riverside 24.86 24.81 I-5 Orange County 60.54 62.81 VMT per Employee A limitation of the SANDAG VMT/Employee is that it does not include employee trips from people living outside of San Diego County. For example, someone who commutes to San Diego from Riverside County would not be included in the calculation. In addition, the VMT/Employee metric only includes VMT generated within the SANDAG region by employees who live and work in the SANDAG region; therefore if an employee lives and works in Carlsbad, but travels regularly to meetings in Orange County, the VMT associated with the meeting travel is not included. The Carlsbad refined work-tour VMT/Employee metric includes all work-related trips (work-tour) for employees and is assigned to their work location TAZ. To account for work-related VMT generated by people living outside of the San Diego region, one of SANDAG’s model output files (“eitrip” file) was used to calculate the work-related VMT for trips originating outside the SANDAG region and terminating in the SANDAG region. For example, if a resident of Orange County works in the City of Carlsbad, his or her commute VMT is included in the employee VMT record. There is a limitation with inclusion of non- resident commute VMT, which is that if that employee makes other work-related trips during the day (for example going to lunch or to a meeting), the VMT associated with those trips is not included. One other limitation of the refined metric is that external to/from internal work-related VMT generated by people who live and work within the SANDAG region and travel outside the SANDAG region as part of their work tour is not included. For example, for someone who lives and works in the San Diego region and occasionally travels to Orange County for a work conference, his or her VMT associated with the Orange County trips is not included in the refined work tour metrics. Including this work related VMT is not possible because the SANDAG model does not provide trip type/purpose for resident’s trips that are leaving and re-entering the SANDAG model boundary; therefore, it is not possible to conclude which internal to/from external trips are work related. APPLYING COMMUTE RELATED TDM MEASURES TO THE VMT/CAPITA METRIC Residential projects, as part of their travel demand management program, will sometimes provide on- site travel demand management measures and amenities that reduce commute/work related trips. Example work based measures that may be incorporated into residential projects are rideshare programs, vanpool programs, and business centers. Since these measures apply specifically to work Nov. 5, 2025 Item #1 52 of 83 Vehicle Miles Traveled Analysis Guidelines (May 2023) | D-4 related travel, VMT reductions associated with them should only be applied to the portion of VMT generated by the project that is commute/work related. Therefore, it is necessary to determine the portion of the VMT/capita metric that is work related. The SANDAG ABM 2+ model output was used to determine the portion of the VMT/Capita metric that is work related. The calculation was specifically performed for Carlsbad VMT/Capita, the percentage would be slightly different in other areas of the region. The portion of City of Carlsbad VMT/Capita that is work related is approximately 44% of the total VMT/Capita. Table D-2 shows the calculation for determining the percent of VMT/capita that is work related for the City of Carlsbad. TABLE D-2 – PERCENT OF VMT/CAPITA THAT IS WORK RELATED TRACT Within the City Total Resident VMT Commute Tour VMT 17109 169,512.32 71,571.76 17801 171,803.75 75,181.49 17808 155,168.22 64,574.99 17809 54,413.80 23,800.48 17810 123,174.56 52,491.84 17811 153,235.52 67,175.34 17813 110,467.06 44,286.25 17900 162,556.71 79,133.40 18000 89,582.07 42,555.98 19803 103,112.99 46,054.21 19804 110,746.43 45,678.20 19806 269,038.40 106,520.49 20013 317,174.47 145,442.50 20014 196,150.14 86,916.59 20015 135,581.04 64,107.30 20016 220,858.50 98,741.53 22100 225,085.81 88,839.17 Total 2,767,661.80 1,203,071.52 Portion of City of Carlsbad Resident VMT that is work related 44% Source: SANDAG Model ABM 2+ Output To determine the effectiveness of TDM measure(s) or commute trip reduction program(s) that are part of a residential project’s travel demand management program, the following steps are taken: 1. Determine the project’s VMT/Capita 2. Identify the work based TDM measure and calculate the percent reduction in work-related VMT due to implementing the measures/program. Nov. 5, 2025 Item #1 53 of 83 Vehicle Miles Traveled Analysis Guidelines (May 2023) | D-5 3. The effectiveness of the work based TDM measure is multiplied by 44% to get the resulting effectiveness. If multiple work based TDM measures are identified, the procedure outlined in Appendix F would be followed to combine them together. If TDM measures that would reduce all VMT are also included, the same dampening process for combining measures would apply (Appendix F). The resulting work effectiveness would be combined with the other measures’ effectiveness using the dampening equations. 4. The percent reduction calculated in Step 3 is applied to the VMT/Capita from Step 1 to arrive at “reduced” VMT/Capita. 5. The “reduced” VMT/Capita is compared to the significance threshold to assess whether there is a significant impact. Nov. 5, 2025 Item #1 54 of 83 VEHICLE MILES TRAVELED ANALYSIS GUIDELINES APPENDIX E LAND USE DESIGNATIONS Nov. 5, 2025 Item #1 55 of 83 Vehicle Miles Traveled Analysis Guidelines (May 2023) | E-1 LAND USE DESIGNATIONS Table E-1 provides guidance on how specific land use designations fit within the overall land use VMT analysis categories: residential, office, industrial, retail (typically size determines if it is locally serving or regional), and public facilities. Land use designation will be determined in consultation with City staff. TABLE E-1: LAND USE DESIGNATIONS LAND USE Residential Mobile Home Multiple Dwelling Unit (all sizes) Senior Housing (not Assisted Living) Single Family Detached Office/Employment Assisted Living/Nursing Facility Hospital Industrial/Business Park Scientific Research and Development Hotel (including with and without convention facilities/restaurant) Motel Resort Hotel (could be considered retail, coordination with City Staff required) Office Medical Office Government Offices (Use is Primarily Office with Employees; not Providing In-Person Customer Service) Industrial Employment Manufacturing/Assembly Warehousing (including high-cube warehouses, parcel hubs, fulfillment centers, and cold storage warehouses) Data Center Agriculture Nov. 5, 2025 Item #1 56 of 83 Vehicle Miles Traveled Analysis Guidelines (May 2023) | E-2 Regional Public Facilities/Services: Presumed to be Not Locally Serving Airport University Community College Regional Education Facilities Regional House of Worship Regional Park Public Facilities/Services: Presumed to be Locally Serving Cemetery Cellular Communications Towers/Facilities and other Utility Facilities Local-Serving Educational Facilities Day Care Center/Child Care Center Fire Stations Library Department of Motor Vehicles Government Offices (Providing Primarily In-Person Customer Service) Post Office Park & Ride Lot Neighborhood House of Worship Transit Station Park Waste-water Treatment Facilities Regional Retail: Presumed to be Not Locally Serving Shopping Center Greater than 50,000 square feet (unless a market study demonstrates otherwise) Stand Alone Convention Centers/Event Venues Theme Parks Nov. 5, 2025 Item #1 57 of 83 Vehicle Miles Traveled Analysis Guidelines (May 2023) | E-3 Retail: Presumed to be Locally Serving (Less than 50,000 square feet or a market study). If multiple retail land uses are provided as one development, the sizes for all retail uses must be summed and considered together as a shopping center to determine whether the project qualifies for screening. Automobile Services Convenience Market Chain Discount Store/Discount Club Drugstore Fitness Center/Sports Facility (indoor or outdoor) Furniture Store Lumber/Home Improvement Store Nursery Restaurant/Winery Neighborhood Shopping Center Specialty Retail Center/Strip Commercial Supermarket Financial Institution (Bank or Credit Union) Bowling Center Movie Theater Nov. 5, 2025 Item #1 58 of 83 VEHICLE MILES TRAVELED ANALYSIS GUIDELINES APPENDIX F VEHICLE MILES TRAVELED REDUCTION STRATEGIES AND EFFECTIVENESS CALCULATIONS Nov. 5, 2025 Item #1 59 of 83 Vehicle Miles Traveled Analysis Guidelines (May 2023) | F-1 VMT REDUCTION STRATEGIES AND EFFECTIVENESS CALCULATIONS VMT REDUCTION STRATEGIES UNDER CEQA Projects can apply VMT reduction strategies to lower their calculated VMT below the significance threshold. Typically, VMT is reduced by implementing strategies that achieve one of the following: • Reducing the number of automobile trips generated by the project or by the residents or employees of the project; or • Reducing the distance that people drive. Measures that reduce single occupant automobile trips or travel distances are called Transportation Demand Management (TDM) strategies. QUANTIFYING TDM EFFECTIVENESS To be effective mitigation measures, TDM strategies must be supported by sufficient evidence to quantify the level of VMT reduction that they could achieve for a given project site. In general, the TDM strategies can be quantified using the methodologies described in the Handbook for Analyzing Greenhouse Gas Emission Reductions, Assessing Climate Vulnerabilities, and Advancing Health and Equity (California Air Pollution Control Officers Association (CAPCOA), 2021, referred to herein as “GHG Handbook”). The 2021 GHG Handbook supersedes the 2010 CAPCOA Quantifying Greenhouse Gas Mitigation Measures handbook (referred to herein as the “CAPCOA report”). Projects must use the current available information, and as such, should rely on data and procedures contained in the 2021 GHG Handbook and not the 2010 CAPCOA report. The GHG Handbook contains updated data, calculations, and procedures used in calculating TDM measure effectiveness at reducing VMT. Table F-1 identifies TDM measures that are included in the GHG Handbook. This table provides a description of each measure with information about the land use types that they are applicable to, maximum effectiveness (if available), and guidance for the application of each measure for VMT reduction. Calculating TDM Program Effectiveness As explained below, there are some important considerations for calculating the effectiveness of TDM strategy mitigation measures. Alternative methodologies may be used to quantify VMT reductions, provided there is substantial evidence to justify the calculated reduction. All assumptions regarding participation, eligibility, and other variables should be clearly documented for each proposed TDM strategy. Some TDM strategies can be combined with others to increase the effectiveness of VMT mitigation; however, the interaction between the various strategies is complex and sometimes counterintuitive. Strategies apply to either the Project scale or the Community/City scale; therefore, VMT reductions at these scales must be calculated separately. This limits project scale strategies to employer commute Nov. 5, 2025 Item #1 60 of 83 Vehicle Miles Traveled Analysis Guidelines (May 2023) | F-2 programs, land use strategies (increased density, mixed-use development, and transit-oriented development), and parking (unbundled parking, parking cash-out, and pricing). While individual projects may contribute to the cost of community-serving infrastructure improvements (for example, pedestrian network and bicycle facility improvements), percentage VMT reductions from community-scale strategies should be calculated separately from percentage VMT reductions due to project-focused strategies. These percentage reductions can then be applied to total VMT generated at the project or community levels. At the City’s discretion, community-scale VMT reductions can be applied to offset project-generated VMT impacts. As described in the GHG Handbook, strategy effectiveness levels are not directly additive, and when determining the overall VMT reduction, the VMT reduction separately calculated for each individual strategy (within their overall TDM strategy category) should be dampened, or diminished, according to a multiplicative formula to account for the fact that some of the strategies may be redundant or applicable to the same populations. Ultimately, the intent of this dampening is to provide a mechanism for minimizing the possibility of overstating VMT reduction effectiveness. To quantify the VMT reduction that results from combining strategies, the formula below can be applied absent additional knowledge or information: 𝑇𝑇𝑇𝑇𝑇𝑇𝑇𝑇𝑇𝑇 𝑉𝑉𝑉𝑉𝑇𝑇 𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑇𝑇𝑅𝑅𝑇𝑇𝑅𝑅 = 1-[(1 − 𝑃𝑃a) ∗ (1 – 𝑃𝑃b) ∗ (1 – 𝑃𝑃c) ∗ …] Where: 𝑃𝑃x = percent reduction of each VMT reduction strategy For example, if two strategies were proposed with corresponding VMT reductions of 20 percent and 10 percent, the equation would be [1-(1-20%)*(1-10%)] or [1-(80%*90%)], which equates to a 28 percent reduction rather than the 30 percent reduction that would otherwise result from a direct sum. This adjustment methodology is simply a mathematical approach to dampening the potential effectiveness and is not supported by research related to the actual effectiveness of combined strategies. As noted above, this approach minimizes possibility of overstating VMT reduction effectiveness. When calculating the effects of different groups of strategies, this formula should be applied when combining individual strategies in a group and again when combining groups of strategies in a single program. When calculating the VMT reduction of a combination of strategies, the effectiveness of each strategy should be calculated using the same method consistently. Per the GHG Handbook, subcategory-specific maximum reasonable VMT reductions are identified to prevent double-counting of reductions from measures that affect travel behavior in similar ways. For example, the GHG Handbook indicates that the combination of any group of trip reduction strategies would have a maximum effect. Maximums are provided for each subcategory of measures. Within Carlsbad, the combination of all measures is expected to have a maximum feasible overall reduction of 15 percent. Nov. 5, 2025 Item #1 61 of 83 Vehicle Miles Traveled Analysis Guidelines (May 2023) | F-3 TABLE F-1: VMT REDUCTION STRATEGIES AND EFFECTIVENESS CALCULATIONS GHG Handbook # Measure1 Measures shown in green may be applied to individual development projects in Carlsbad– Must Follow procedures in GHG Handbook, this Appendix, and Calculation Notes shown in this Table. Measures shown in orange are not quantified in the GHG Handbook but may be quantifiable with appropriate evidence/information. Coordination with City staff required. Measures shown in yellow are not quantifiable but should be considered if a project has a significant and unavoidable impact to provide mitigation to the extent feasible. Measures shown in gray are not quantifiable, are not appropriate at the project scale, are not applicable in Carlsbad, or are already accounted for in the VMT modeling and may not be considered as mitigation measures. Scale of Application P/S – Project/Site P/C – Plan/Community Locational Context U – Urban (Village) S – Suburban (Outside of Village) Applicable Land Use Types Maximum Percent Reduction in VMT2 Measure Description/GHG Handbook Calculation Notes The calculation notes provide guidance on selecting values for the variables in the GHG Handbook VMT reduction equations. If a variable does not have stated guidance below, the user should apply the value provided in the GHG Handbook. Additionally, data sources are periodically updated; therefore, the user should confirm and use the most current data source for any given variable. Land Use Measures T-1 Increase Residential Density (from existing neighborhood conditions) P/S U, S Residential 30% Typically, this measure is accounted for in the SANDAG Model if a model run is performed for a project. If a model run is not required for the project, this measure may be applicable. To be applicable, the project density must exceed 9.1 dwelling units per acre (the typical US residential unit density). If the existing residential density of the transportation analysis zone/census tract is greater than 9.1 dwelling units per acre, the existing residential unit density (variable “C” in the GHG Handbook equation) should be derived from the relevant transportation analysis zone or census tract instead of the value for a typical development in the calculation. T-2 Increase Job Density (from existing neighborhood conditions) P/S U, S Retail Office Industrial 30% Typically, this measure is accounted for in the SANDAG Model if a model run is performed for a project. If a model run is not required for the project, this measure may be applicable. To be applicable, the employment density must exceed 145 employees per acre (the typical US employment density). If the existing employment density is greater than 145 employees per acre, the existing employment density (variable “C” in the GHG Handbook equation) should be derived from the relevant transportation analysis zone (or census tract) instead of the value for a typical development in the calculation. T-3 Provide Transit-Oriented Development P/S U, S Residential Retail Office Industrial 31% This measure is accounted for in the SANDAG model. T-4 Integrate Affordable and Below Market Rate Housing P/S U, S Residential 26.8% This measure is applicable to a project (or a portion of a project) that is defined as below market rate affordable housing, defined as 80-percent of area median income or below. T-17 Improve Street Connectivity P/S U, S N/A 30% This measure accounts for the VMT reduction achieved by a project that is designed with a higher density of vehicle intersections compared to the average intersection density in the U.S. This is not applicable at a project scale. T-31-A Locate Project in Area with High Destination Activity P/S U, S Residential Retail Office Industrial Not Quantified This measure is accounted for in the SANDAG model. The measure requires development in an area with high accessibility to destinations. Destination accessibility is measured in terms of the number of jobs or other attractions (e.g., schools, supermarkets, and health care services) that are reachable within a given travel time or travel distance, and tends to be highest at central locations and lowest at peripheral ones. Nov. 5, 2025 Item #1 62 of 83 Vehicle Miles Traveled Analysis Guidelines (May 2023) | F-4 TABLE F-1: VMT REDUCTION STRATEGIES AND EFFECTIVENESS CALCULATIONS GHG Handbook # Measure1 Measures shown in green may be applied to individual development projects in Carlsbad– Must Follow procedures in GHG Handbook, this Appendix, and Calculation Notes shown in this Table. Measures shown in orange are not quantified in the GHG Handbook but may be quantifiable with appropriate evidence/information. Coordination with City staff required. Measures shown in yellow are not quantifiable but should be considered if a project has a significant and unavoidable impact to provide mitigation to the extent feasible. Measures shown in gray are not quantifiable, are not appropriate at the project scale, are not applicable in Carlsbad, or are already accounted for in the VMT modeling and may not be considered as mitigation measures. Scale of Application P/S – Project/Site P/C – Plan/Community Locational Context U – Urban (Village) S – Suburban (Outside of Village) Applicable Land Use Types Maximum Percent Reduction in VMT2 Measure Description/GHG Handbook Calculation Notes The calculation notes provide guidance on selecting values for the variables in the GHG Handbook VMT reduction equations. If a variable does not have stated guidance below, the user should apply the value provided in the GHG Handbook. Additionally, data sources are periodically updated; therefore, the user should confirm and use the most current data source for any given variable. T-31-B Increase Destination Accessibility in Underserved Areas P/C U, S Retail Office Industrial Not Quantified This measure accounts for the VMT reduction that would be achieved by constructing job centers or other attractions (e.g., schools, supermarkets, and health care services) for residents in underserved areas (e.g., food deserts). T-32 Orient Project Toward Non-Auto Corridor P/S U, S Residential Retail Office Industrial Not Quantified Not applicable/captured by other measures. T-33 Locate Project near Bike Path/Bike Lane P/C U, S Residential Retail Office Industrial Not Quantified Not applicable/captured by other measures. Trip Reduction Programs T-5 Implement Commute Trip Reduction Program (Voluntary) P/S U, S Retail Office Industrial 4% A multi-strategy program implemented by employers on a voluntary basis. The program must include: • Employer-provided services, infrastructure, and incentives for alternative modes such as ridesharing (Measure T-8), discounted transit (Measure T-9), bicycling end of trip facilities (Measure T-10), vanpool (Measure T-11), and guaranteed ride home. • Information, coordination, and marketing for said services, infrastructure, and incentives (Measure T-7). T-6 Implement Commute Trip Reduction Program (Mandatory Implementation and Monitoring) P/S U, S Retail Office Industrial 26% Participation in the program by employees is required and the GHG Handbook requires specific strategies are implemented as part of the program. A reduction goal is specified, and ongoing monitoring and reporting to assess the program’s effectiveness is required. Given the mandatory trip reduction requirements and associated penalties, this measure would not typically be applicable. Coordination with Carlsbad staff is required if this measure is selected. Nov. 5, 2025 Item #1 63 of 83 Vehicle Miles Traveled Analysis Guidelines (May 2023) | F-5 TABLE F-1: VMT REDUCTION STRATEGIES AND EFFECTIVENESS CALCULATIONS GHG Handbook # Measure1 Measures shown in green may be applied to individual development projects in Carlsbad– Must Follow procedures in GHG Handbook, this Appendix, and Calculation Notes shown in this Table. Measures shown in orange are not quantified in the GHG Handbook but may be quantifiable with appropriate evidence/information. Coordination with City staff required. Measures shown in yellow are not quantifiable but should be considered if a project has a significant and unavoidable impact to provide mitigation to the extent feasible. Measures shown in gray are not quantifiable, are not appropriate at the project scale, are not applicable in Carlsbad, or are already accounted for in the VMT modeling and may not be considered as mitigation measures. Scale of Application P/S – Project/Site P/C – Plan/Community Locational Context U – Urban (Village) S – Suburban (Outside of Village) Applicable Land Use Types Maximum Percent Reduction in VMT2 Measure Description/GHG Handbook Calculation Notes The calculation notes provide guidance on selecting values for the variables in the GHG Handbook VMT reduction equations. If a variable does not have stated guidance below, the user should apply the value provided in the GHG Handbook. Additionally, data sources are periodically updated; therefore, the user should confirm and use the most current data source for any given variable. T-7 Implement Commute Trip Reduction Marketing P/S U, S Residential Retail Office Industrial 4% Promote and advertise various transportation options, including promoting information and resources regarding Carlsbad’s Citywide TDM Plan as well as SANDAG’s iCommute program, which provides support to commuters through a variety of TDM measures such as carpool matching services, vanpool, and other services. As resources are available through Carlsbad’s Citywide TDM Program, those should be advertised and applied as well. Marketing should be for services that are appropriate and available to employees/residents. Viable transportation alternatives should be marketed, for example, it is not appropriate to market transit options if there are no transit options near the project site. For residential projects, the VMT reduction is only applicable to the portion of the VMT associated with the commute trips. The “eligible employees” should be a maximum of 50% to indicate that not all residents will have work locations or schedules that are compatible with available options. For ABM2+, the portion of the Carlsbad citywide average VMT/capita that is commute/work related is 44% (see Appendix D for additional information). T-8 Provide Ridesharing Program P/S U, S Residential Retail Office Industrial 8% This strategy focuses on encouraging carpooling by project site/building tenants. Existing ride-share companies could also be leveraged by providing subsidies for shared ride purchases (e.g., Waze Carpool or equivalent). The program must be specify the platform(s) that will be promoted and identify the subsidy that will be provided to incentive use. Must use GHG Handbook, Table T-8.1 to determine variable “C.” For Suburban context the value is -4%, for Urban context the value is -8%. For residential projects, the VMT reduction is only applicable to the portion of the VMT associated with the commute trips and the “eligible employees” should be a maximum of 25% to indicate that it is more difficult to match employees for ridesharing in a residential project where people work in various geographic areas and have various work schedules. For ABM2+, the portion of the Carlsbad citywide average VMT/capita that is commute/work related is 44% (see Appendix D for additional information). Nov. 5, 2025 Item #1 64 of 83 Vehicle Miles Traveled Analysis Guidelines (May 2023) | F-6 T-9 Implement Subsidized or Discounted Transit Program P/S U, S Residential Retail Office Industrial 5.5% Subsidized or discounted public transit passes are provided to employees and/or residents. Example applications include subsidized, discounted, or free out-of-pocket costs for daily or monthly public transit passes. Reducing the out-of-pocket cost for choosing transit improves the competitiveness of transit against driving, increasing the total number of transit trips and decreasing vehicle trips. The project should be accessible either within 1 mile of high-quality transit service (rail or bus with headways of less than 15minutes), 0.5 mile of local or less frequent transit service, or along a designated shuttle route providing last-mile connections to rail service. If a well-established bikeshare service (Measure T-22-A) is available, the site may be located up to 2 miles from a high-quality transit service. If this measure is selected, the user may not also take credit for either Measure T-5 or T-6. Calculating the effectiveness of this measure requires inputting several variables. Guidance for selecting variables is described below: Variable B/C – Average transit fare without subsidy and subsidy amount. These variables can be presented as either the fare per ride or cost of a monthly pass. The variables should be input based on how the program will be administered. If the program will subsidize individual rides, the fare per ride should be used. If the program will provide monthly passes, the cost of a monthly pass should be used. Variable D – The percentage of employees/residents associated with the site who have access to the subsidy. If it is an employment project – all employees (accounting for contract, part-time, etc. who may not be eligible) should be included in the percentage. If the subsidy doesn’t fully cover the cost of transit, or if a limited number of subsidized passes would be available, Variable D must be adjusted. Variable E – The percentage of project-generated VMT from employees/residents is used to adjust the percent reduction in GHG emissions from the scale of employee and/or resident-generated VMT to project-generated VMT. Since the VMT metrics are VMT/employee or VMT/resident and the VMT associated with these metrics is already scaled to the individual, the value is 100%. Variable F – The existing transit mode share for work trips (employment projects) or all trips (residential projects) should be based on the project location. The GHG Handbook indicates that if a local survey is not available, the California Household Travel Survey is the preferred data source for determining the transit mode shares. Based on the most recent California Household Travel Survey (2012) the values are 0.6% for all trip transit mode share based on the City of Carlsbad data (to be applied to residential projects) and 1.6% for work trips transit mode share (based on the combined transit mode share for North County coastal cities: Del Mar, Solana Beach, Encinitas, Carlsbad, and Oceanside). The North County coastal cities were combined to provide a bigger sample size of work trips in the California Household Travel survey data. Variable H – Use given value of 50% unless a project specific value is available. T-10 Provide End-of-Trip Bicycle Facilities P/S U, S Retail Office Industrial 4.4% This measure will install and maintain end-of-trip facilities for employee use. End-of-trip facilities include bike parking, bike lockers, showers, and personal lockers. If this measure is selected, the user may not also take credit for either Measure T-5 or T-6. See the City of Carlsbad TDM Handbook for amenity design requirements. Guidance for selecting variables is described below: Variable B: If only bicycle racks/lockers are provided the value is 1.78. If bicycle racks/lockers, personal storage lockers, and showers are provided the value is 4.86. Variable C/D – The bicycle and vehicle average trip length should be based on the project location. The GHG Handbook indicates that if a local survey is not available, the California Household Travel Survey is the preferred data source for determining the average trip lengths. Based on the most recent California Household Travel Survey Nov. 5, 2025 Item #1 65 of 83 Vehicle Miles Traveled Analysis Guidelines (May 2023) | F-7 TABLE F-1: VMT REDUCTION STRATEGIES AND EFFECTIVENESS CALCULATIONS GHG Handbook # Measure1 Measures shown in green may be applied to individual development projects in Carlsbad– Must Follow procedures in GHG Handbook, this Appendix, and Calculation Notes shown in this Table. Measures shown in orange are not quantified in the GHG Handbook but may be quantifiable with appropriate evidence/information. Coordination with City staff required. Measures shown in yellow are not quantifiable but should be considered if a project has a significant and unavoidable impact to provide mitigation to the extent feasible. Measures shown in gray are not quantifiable, are not appropriate at the project scale, are not applicable in Carlsbad, or are already accounted for in the VMT modeling and may not be considered as mitigation measures. Scale of Application P/S – Project/Site P/C – Plan/Community Locational Context U – Urban (Village) S – Suburban (Outside of Village) Applicable Land Use Types Maximum Percent Reduction in VMT2 Measure Description/GHG Handbook Calculation Notes The calculation notes provide guidance on selecting values for the variables in the GHG Handbook VMT reduction equations. If a variable does not have stated guidance below, the user should apply the value provided in the GHG Handbook. Additionally, data sources are periodically updated; therefore, the user should confirm and use the most current data source for any given variable. (2012) the average bicycle trip length for Carlsbad is 5.0 miles and the average vehicle trip length is 7.9 miles. The applicant may also provide SANDAG model data specific to the City of Carlsbad for these values as an alternative. Variable E/F - The existing bicycle and vehicle mode shares for work trips (employment projects) should be based on the project location. The GHG Handbook indicates that if a local survey is not available, the California Household Travel Survey is the preferred data source for determining the bicycle and vehicle mode shares. Based on the most recent California Household Travel Survey (2012) the values are 1.2% for work trips bicycle mode share (based on the combined bicycle mode share for North County coastal cities: Del Mar, Solana Beach, Encinitas, Carlsbad, and Oceanside). The work trip vehicle mode share for the North County coastal cities is 95.0%. The North County coastal cities were combined to provide a bigger sample size of work trips in the California Household Travel survey data. The applicant may also provide SANDAG model data specific to the City of Carlsbad for these values as an alternative. T-11 Provide Employer Sponsored Vanpool P/S U, S Retail Office Industrial 20.4% This measure will implement an employer-sponsored vanpool service or subsidy for iCommute vanpool program. Vanpooling is a flexible form of public transportation that provides groups of 5 to 15 people with a cost-effective and convenient rideshare option for commuting. If this measure is selected, the user may not also take credit for either Measure T-5 or T-6. Guidance for selecting variables is described below: Variable B, D, and E – Since the GHG Handbook values are derived from San Diego data, use GHG Handbook suggestions. Variable C - The work trip vehicle average trip length should be based on the project location. The GHG Handbook indicates that if a local survey is not available, the California Household Travel Survey is the preferred data source for determining the average trip lengths. Based on the most recent California Household Travel Survey (2012) the average work vehicle trip length is 11.9 miles. The applicant may also provide SANDAG model data specific to the City of Carlsbad for as an alternative. Nov. 5, 2025 Item #1 66 of 83 Vehicle Miles Traveled Analysis Guidelines (May 2023) | F-8 TABLE F-1: VMT REDUCTION STRATEGIES AND EFFECTIVENESS CALCULATIONS GHG Handbook # Measure1 Measures shown in green may be applied to individual development projects in Carlsbad– Must Follow procedures in GHG Handbook, this Appendix, and Calculation Notes shown in this Table. Measures shown in orange are not quantified in the GHG Handbook but may be quantifiable with appropriate evidence/information. Coordination with City staff required. Measures shown in yellow are not quantifiable but should be considered if a project has a significant and unavoidable impact to provide mitigation to the extent feasible. Measures shown in gray are not quantifiable, are not appropriate at the project scale, are not applicable in Carlsbad, or are already accounted for in the VMT modeling and may not be considered as mitigation measures. Scale of Application P/S – Project/Site P/C – Plan/Community Locational Context U – Urban (Village) S – Suburban (Outside of Village) Applicable Land Use Types Maximum Percent Reduction in VMT2 Measure Description/GHG Handbook Calculation Notes The calculation notes provide guidance on selecting values for the variables in the GHG Handbook VMT reduction equations. If a variable does not have stated guidance below, the user should apply the value provided in the GHG Handbook. Additionally, data sources are periodically updated; therefore, the user should confirm and use the most current data source for any given variable. T-12 Price Workplace Parking P/S U, S Retail Office Industrial 20% This measure will price onsite parking at workplaces. Because free employee parking is a common benefit, charging employees to park onsite increases the cost of choosing to drive to work. On-street public parking must be restricted near (within ¾ miles) the project to reduce the opportunity for employees to avoid charges for parking at the workplace while still driving to work. Given the context of the City of Carlsbad, this measure would not typically be applicable and use of it requires coordination with City staff. Guidance for selecting variables is described below: Variable C: If baseline parking price is $0 (that is, if parking is typically free), set C = ¼ B, allowing for the maximum 50 percent increase in price. Alternatively, for locations that are located within 0.5 mile of transit service, set C = average transit fare to/from the location. T-13 Implement Employee Parking Cash-Out P/S U, S Retail Office Industrial 12% This measure will require project employers to offer employee parking cash-out. Cash-out is when employers provide employees with a choice of forgoing their current subsidized/free parking for a cash payment equivalent to or greater than the cost of the parking space. This measure also requires that employee parking is managed and enforced via a permit system (or other monitoring system) and free parking is not available within ¾ miles of the project site (reducing the incidence of employees receiving parking cash out, but still driving and parking within walking distance). T-23 Provide Community-Based Travel Planning P/C U, S Residential 2.3% This measure will target residences in the plan/community with community-based travel planning (CBTP). CBTP is a residential based approach to outreach that provides households with customized information, incentives, and support to encourage the use of transportation alternatives in place of single occupancy vehicles, thereby reducing household VMT and associated GHG emissions. This measure requires a staffed position that is responsible for providing outreach. T-38 Provide First and Last Mile TNC Incentives P/C U, S N/A Not Quantified This measure requires a first-last mile partnership between a municipality/transit agency and a transportation network company (TNC) for subsidized, shared TNC rides to or from the local transit station within a specific geographic area. This measure encourages a shift to transit mode for longer trips. Consider providing inclusive mechanisms so people without bank accounts, credit cards, or smart phones can access the incentives. Nov. 5, 2025 Item #1 67 of 83 Vehicle Miles Traveled Analysis Guidelines (May 2023) | F-9 TABLE F-1: VMT REDUCTION STRATEGIES AND EFFECTIVENESS CALCULATIONS GHG Handbook # Measure1 Measures shown in green may be applied to individual development projects in Carlsbad– Must Follow procedures in GHG Handbook, this Appendix, and Calculation Notes shown in this Table. Measures shown in orange are not quantified in the GHG Handbook but may be quantifiable with appropriate evidence/information. Coordination with City staff required. Measures shown in yellow are not quantifiable but should be considered if a project has a significant and unavoidable impact to provide mitigation to the extent feasible. Measures shown in gray are not quantifiable, are not appropriate at the project scale, are not applicable in Carlsbad, or are already accounted for in the VMT modeling and may not be considered as mitigation measures. Scale of Application P/S – Project/Site P/C – Plan/Community Locational Context U – Urban (Village) S – Suburban (Outside of Village) Applicable Land Use Types Maximum Percent Reduction in VMT2 Measure Description/GHG Handbook Calculation Notes The calculation notes provide guidance on selecting values for the variables in the GHG Handbook VMT reduction equations. If a variable does not have stated guidance below, the user should apply the value provided in the GHG Handbook. Additionally, data sources are periodically updated; therefore, the user should confirm and use the most current data source for any given variable. T-39 Implement Preferential Parking Permit Program (Carpoolers) P/S U, S Residential Retail Office Industrial Not Quantified This measure requires projects provide preferential parking in terms of free or reduced parking fees, priority parking, or reserved parking in convenient locations (such as near public transportation or building entrances) for commuters who carpool, vanpool, ride-share or use sustainably fueled vehicles. T-40 Implement School Bus Program P/S U, S Residential Not Quantified This measure will provide school bus service transporting students to a school project. A school bus service can reduce the number of private vehicle trips to drop-off or pick-up students, thereby reducing VMT and associated GHG emissions, as well as onsite air pollution emissions, especially if the bus is zero emissions. If a residential project includes a school and the type, enrollment, and school bus commitment is known, it may be possible to quantify the VMT reduction associated with school busing. The reduction would only apply to school related VMT. Coordination with Carlsbad staff is required if this measure is selected. T-41 Implement School Pool Program P/S U, S Residential Not Quantified This measure requires projects create a ridesharing program for school children. If a residential project includes a school and the type, enrollment, and school pool commitment is known, it may be possible to quantify the VMT reduction associated with a school pool program. The reduction would only apply to school related VMT. Coordination with Carlsbad staff is required if this measure is selected. T-42 Implement Telecommute and/or Alternative Work Schedule Program P/S U, S Retail Office Industrial Not Quantified This measure requires projects to permit employee telecommuting and/or alternative work schedules and monitor employee involvement to ensure forecasted participation matches observed participation. This measure is not quantified because recent research has suggested that while commute VMT is reduced, overall VMT of teleworkers may not be reduced. Since commute VMT is reduced and can be directly applicable to VMT/Employee, teleworking may be appropriate to include VMT reduction for. The program must ensure that more than 15% of the employees will telecommute (15% is assumed in the SANDAG model; therefore, is already accounted for in the VMT calculations). Information on employee participation and methods for monitoring the program are necessary. Coordination with Carlsbad staff is required if this measure is selected. Nov. 5, 2025 Item #1 68 of 83 Vehicle Miles Traveled Analysis Guidelines (May 2023) | F-10 TABLE F-1: VMT REDUCTION STRATEGIES AND EFFECTIVENESS CALCULATIONS GHG Handbook # Measure1 Measures shown in green may be applied to individual development projects in Carlsbad– Must Follow procedures in GHG Handbook, this Appendix, and Calculation Notes shown in this Table. Measures shown in orange are not quantified in the GHG Handbook but may be quantifiable with appropriate evidence/information. Coordination with City staff required. Measures shown in yellow are not quantifiable but should be considered if a project has a significant and unavoidable impact to provide mitigation to the extent feasible. Measures shown in gray are not quantifiable, are not appropriate at the project scale, are not applicable in Carlsbad, or are already accounted for in the VMT modeling and may not be considered as mitigation measures. Scale of Application P/S – Project/Site P/C – Plan/Community Locational Context U – Urban (Village) S – Suburban (Outside of Village) Applicable Land Use Types Maximum Percent Reduction in VMT2 Measure Description/GHG Handbook Calculation Notes The calculation notes provide guidance on selecting values for the variables in the GHG Handbook VMT reduction equations. If a variable does not have stated guidance below, the user should apply the value provided in the GHG Handbook. Additionally, data sources are periodically updated; therefore, the user should confirm and use the most current data source for any given variable. Parking or Road Pricing/Management T-14 Provide Electric Vehicle Charging Infrastructure P/S U, S Residential Retail Office Industrial 0% Install onsite electric vehicle chargers in an amount beyond what is required by the 2019 California Green Building Standards (CALGreen) at buildings with designated parking areas (e.g., commercial, educational, retail, multifamily). This measure does not result in VMT reduction but does reduce GHG. T-15 Limit Residential Parking Supply P/S U, S Residential 13.7% This measure will reduce the total parking supply available at a residential project or site as compared to the residential parking demand in an effort to reduce access to automobiles and reduce driving. Since the majority of Carlsbad is car dependent, this measure is not applicable at this time. T-16 Unbundle Residential Parking Costs from Property Cost P/S U, S Residential 15.7% This measure will unbundle, or separate, a residential project’s parking costs from property costs, requiring those who wish to purchase parking spaces to do so at an additional cost. To be effective, this parking cost must be passed through to the vehicle owners/drivers utilizing the parking spaces. In addition. on-street public parking must be restricted within ¾ miles of the project to reduce the opportunity for residents to avoid parking costs. If this measure is selected, a discussion of the implications of reductions in car ownership is necessary. For example, for much of the City it would be unreasonable to conclude that residential units would have no vehicles; however, it may be feasible that the number of units that have two vehicles is reduced through this measure. The values provided in the GHG Handbook should be used in the VMT reduction equation. T-24 Implement Market Rate Public Parking (On-Street) P/C U, S N/A 30% This measure will price all on-street parking in a given community, with a focus on parking near central business districts, employment centers, and retail centers. T-48 Implement Area or Cordon Pricing P/C U N/A Not Quantified This measure requires projects implement a cordon pricing scheme. The pricing scheme will set a cordon (boundary) around a specified area to charge a toll to enter the area by vehicle. The cordon location is usually the boundary of a central business district or urban center but could also apply to substantial development projects with limited points of access. This is not applicable at a project scale. Nov. 5, 2025 Item #1 69 of 83 Vehicle Miles Traveled Analysis Guidelines (May 2023) | F-11 TABLE F-1: VMT REDUCTION STRATEGIES AND EFFECTIVENESS CALCULATIONS GHG Handbook # Measure1 Measures shown in green may be applied to individual development projects in Carlsbad– Must Follow procedures in GHG Handbook, this Appendix, and Calculation Notes shown in this Table. Measures shown in orange are not quantified in the GHG Handbook but may be quantifiable with appropriate evidence/information. Coordination with City staff required. Measures shown in yellow are not quantifiable but should be considered if a project has a significant and unavoidable impact to provide mitigation to the extent feasible. Measures shown in gray are not quantifiable, are not appropriate at the project scale, are not applicable in Carlsbad, or are already accounted for in the VMT modeling and may not be considered as mitigation measures. Scale of Application P/S – Project/Site P/C – Plan/Community Locational Context U – Urban (Village) S – Suburban (Outside of Village) Applicable Land Use Types Maximum Percent Reduction in VMT2 Measure Description/GHG Handbook Calculation Notes The calculation notes provide guidance on selecting values for the variables in the GHG Handbook VMT reduction equations. If a variable does not have stated guidance below, the user should apply the value provided in the GHG Handbook. Additionally, data sources are periodically updated; therefore, the user should confirm and use the most current data source for any given variable. T-49 Replace Traffic Controls with Roundabout P/C U, S N/A Not Quantified This measure requires projects install a roundabout as a traffic control device to smooth traffic flow, reduce idling, eliminate bottlenecks, and manage speed. In some cases, roundabouts can improve traffic flow and reduce emissions. The emission reduction depends heavily on what the roundabout is compared to (e.g., uncontrolled intersection, stop sign, traffic signal). This is not applicable at a project scale. T-50 Required Project Contributions to Transportation Infrastructure Improvement P/C U, S N/A Not Quantified This measure requires projects contribute to traffic-flow improvements or other multi-modal infrastructure projects that reduce emissions and are not considered as substantially growth inducing. This may be applicable when/if Carlsbad develops a program to facilitate contributions to VMT reducing infrastructure. If that program determines the citywide VMT reduction associated with implementation, credit to the project VMT may be warranted. T-51 Install Park-and-Ride Lots P/C U,S N/A Not Quantified This measure requires projects install park-and-ride lots near transit stops and high occupancy vehicle lanes. This is not applicable at a project scale. T-52 Designate Zero Emissions Delivery Zones P/C U N/A Not Quantified This measure requires the municipality to designate certain curbside locations as commercial loading zones exclusively available for zero-emission commercial delivery vehicles. This is not applicable at a project scale. Neighborhood Design T-18 Provide Pedestrian Network Improvement P/C U, S Residential Retail Office Industrial 6.4% This measure will increase the sidewalk coverage to improve pedestrian access. Reduction is calculated for all household trips in the surrounding neighborhood, offsetting VMT impacts arising from the project. VMT reduction is associated with expansion of sidewalk coverage, which includes building of new sidewalks and improving degraded or substandard sidewalk. Sidewalk measurements should be collected on both sides of the street. A reasonableness check should be performed using an average walk trip length of 0.5 miles to determine how many new walk trips result from this measure. If the VMT reduced divided by 0.5 miles results in a 200% increase or higher on a particular sidewalk segment, the VMT reduction may need to be adjusted. Note that percentage VMT reductions from Project-Level and Community-Level measures must be calculated separately. To apply the VMT reduction as a credit to the project VMT, the total residential tour based VMT should be calculated by multiplying the VMT/resident by the total number of residents. The VMT reduction is subtracted from the total residential tour based VMT value. Nov. 5, 2025 Item #1 70 of 83 Vehicle Miles Traveled Analysis Guidelines (May 2023) | F-12 TABLE F-1: VMT REDUCTION STRATEGIES AND EFFECTIVENESS CALCULATIONS GHG Handbook # Measure1 Measures shown in green may be applied to individual development projects in Carlsbad– Must Follow procedures in GHG Handbook, this Appendix, and Calculation Notes shown in this Table. Measures shown in orange are not quantified in the GHG Handbook but may be quantifiable with appropriate evidence/information. Coordination with City staff required. Measures shown in yellow are not quantifiable but should be considered if a project has a significant and unavoidable impact to provide mitigation to the extent feasible. Measures shown in gray are not quantifiable, are not appropriate at the project scale, are not applicable in Carlsbad, or are already accounted for in the VMT modeling and may not be considered as mitigation measures. Scale of Application P/S – Project/Site P/C – Plan/Community Locational Context U – Urban (Village) S – Suburban (Outside of Village) Applicable Land Use Types Maximum Percent Reduction in VMT2 Measure Description/GHG Handbook Calculation Notes The calculation notes provide guidance on selecting values for the variables in the GHG Handbook VMT reduction equations. If a variable does not have stated guidance below, the user should apply the value provided in the GHG Handbook. Additionally, data sources are periodically updated; therefore, the user should confirm and use the most current data source for any given variable. T-19-A Construct or Improve a Bike Facility P/C U, S Residential Retail Office Industrial 0.8% of adjacent roadway VMT This measure will construct or improve a single bicycle lane facility (only Class I, II, or IV) that connects to a larger existing bikeway network. This measure reduces VMT on the roadway segment parallel to the bicycle facility (i.e., the corridor). Therefore, to calculate the VMT reduced it is necessary to know the VMT on the corridor. This is calculated by multiplying the daily vehicle volume by the length of the corridor. The corridor length should be the full length of the roadway that includes the bicycle facility or the full length of the roadway within Carlsbad if the bicycle facility is present on the entire corridor. A reasonableness check should be performed using an average bike trip length of 5 miles to determine how many new bike trips result from this measure. If the VMT reduced divided by 5 miles results in 200% or larger increase in daily bike trips, the VMT reduction may need to be adjusted. Note that percentage VMT reductions from Project-Level and Community-Level measures must be calculated separately. To apply the VMT reduction as a credit to the project VMT, the total residential tour based VMT should be calculated by multiplying the VMT/resident by the total number of residents. The VMT reduction is subtracted from the total residential tour based VMT value. Guidance for selecting variables is described below: Variables B, C, D, E, F, and I should be applied from the GHG Handbook. Variable G/H: The bicycle and vehicle average trip length should be based on the project location. The GHG Handbook indicates that if a local survey is not available, the California Household Travel Survey is the preferred data source for determining the average trip lengths. Based on the most recent California Household Travel Survey (2012) the average bicycle trip length for Carlsbad is 5.0 miles and the average vehicle trip length is 7.9 miles. The applicant may also provide SANDAG model data specific to the City of Carlsbad for these values as an alternative. Nov. 5, 2025 Item #1 71 of 83 Vehicle Miles Traveled Analysis Guidelines (May 2023) | F-13 We T-19-B Construct or Improve Bike Boulevard P/C U, S Residential Retail Office Industrial 0.2% of corridor VMT Construct or improve a single bicycle boulevard that connects to a larger existing bikeway network. Bicycle boulevards are a designation within Class III Bikeway that create safe, low-stress connections for people biking and walking on streets. See GHG Handbook for specific design requirements. This measure reduces VMT on the roadway segment parallel to the bicycle facility (i.e., the corridor). Therefore, to calculate the VMT reduced it is necessary to know the VMT on the corridor. This is calculated by multiplying the daily vehicle volume by the length of the corridor. The corridor length should be the full length of the roadway that includes the bicycle facility or the full length of the roadway within Carlsbad if the bicycle facility is present on the entire corridor. A reasonableness check should be performed using an average bike trip length of 5 miles to determine how many new bike trips result from this measure. If the VMT reduced divided by 5 miles results in 200% or larger increase in daily bike trips, the VMT reduction may need to be adjusted. Guidance for selecting variables is described below: Variables B and C should be applied from the GHG Handbook. Variable D/E: The bicycle and vehicle average trip length should be based on the project location. The GHG Handbook indicates that if a local survey is not available, the California Household Travel Survey is the preferred data source for determining the average trip lengths. Based on the most recent California Household Travel Survey (2012) the average bicycle trip length for Carlsbad is 5.0 miles and the average vehicle trip length is 7.9 miles. The applicant may also provide SANDAG model data specific to the City of Carlsbad for these values as an alternative. Variable F/G: The existing bicycle and vehicle mode shares for work trips (employment projects) should be based on the project location. The GHG Handbook indicates that if a local survey is not available, the California Household Travel Survey is the preferred data source for determining the bicycle and vehicle mode shares. Based on the most recent California Household Travel Survey (2012) the values are 1.2% for work trips bicycle mode share (based on the combined bicycle mode share for North County coastal cities: Del Mar, Solana Beach, Encinitas, Carlsbad, and Oceanside). The work trip vehicle mode share for the North County coastal cities is 95.0%. The North County coastal cities were combined to provide a bigger sample size of work trips in the California Household Travel survey data. OR The “San Diego-Carlsbad” values from GHG Handbook Appendix C Table T-10.2 (which are based on the National Household Travel Survey) should be used (unless more current local survey data is available) for bicycle and vehicle work trip mode share. Based on the December 2021 GHG Handbook the values are 1.3% for work trips bicycle mode share and 91.8% for work trips vehicle mode share. T-20 Expand Bikeway Network P/C U, S N/A 0.5% This measure will increase the length of a city or community bikeway network. A bicycle network is an interconnected system of bike lanes, bike paths, bike routes, and cycle tracks. This is not applicable at a project scale, see T-19A/B for options that could be available to individual projects. T-21-A Implement Conventional Carshare Program P/C U, S Residential Retail Office Industrial 0.15% This measure will increase carshare access in the user’s community by deploying conventional carshare vehicles. Carsharing offers people convenient access to a vehicle for personal or commuting purposes. This research associated with this measure was conducted for large scale carshare programs (with fleets of 400 vehicles or more); therefore, applying this measure at a small scale will result in minimal reductions. An applicant may coordinate with the City of Carlsbad to determine if VMT reduction associated with this measure is appropriate. Guidance for selecting variables is described below: Variable B, D, and E should be applied from the GHG Handbook. Nov. 5, 2025 Item #1 72 of 83 Vehicle Miles Traveled Analysis Guidelines (May 2023) | F-14 TABLE F-1: VMT REDUCTION STRATEGIES AND EFFECTIVENESS CALCULATIONS GHG Handbook # Measure1 Measures shown in green may be applied to individual development projects in Carlsbad– Must Follow procedures in GHG Handbook, this Appendix, and Calculation Notes shown in this Table. Measures shown in orange are not quantified in the GHG Handbook but may be quantifiable with appropriate evidence/information. Coordination with City staff required. Measures shown in yellow are not quantifiable but should be considered if a project has a significant and unavoidable impact to provide mitigation to the extent feasible. Measures shown in gray are not quantifiable, are not appropriate at the project scale, are not applicable in Carlsbad, or are already accounted for in the VMT modeling and may not be considered as mitigation measures. Scale of Application P/S – Project/Site P/C – Plan/Community Locational Context U – Urban (Village) S – Suburban (Outside of Village) Applicable Land Use Types Maximum Percent Reduction in VMT2 Measure Description/GHG Handbook Calculation Notes The calculation notes provide guidance on selecting values for the variables in the GHG Handbook VMT reduction equations. If a variable does not have stated guidance below, the user should apply the value provided in the GHG Handbook. Additionally, data sources are periodically updated; therefore, the user should confirm and use the most current data source for any given variable. Variable C: Total VMT in plan/community without carshare should be calculated using the total tour VMT calculated by multiplying the VMT/resident or VMT/employee by the total residents or employees. T-21-B Implement Electric Carshare Program P/C U, S Residential Retail Office Industrial 0.15% This measure will increase electric vehicle carshare access in the user’s community by deploying electric carshare vehicles. Carsharing offers people convenient access to a vehicle for personal or commuting purposes. This research associated with this measure was conducted for large scale carshare programs (with fleets of 400 vehicles or more); therefore, applying this measure at a small scale will result in minimal reductions. An applicant may coordinate with the City of Carlsbad to determine if VMT reduction associated with this measure is appropriate. Guidance for selecting variables is described below: Variable B, D, and E should be applied from the GHG Handbook. Variable C: Total VMT in plan/community without carshare should be calculated using the total tour VMT calculated by multiplying the VMT/resident or VMT/employee by the total residents or employees. The VMT reduction is calculated using the simplified equation for Variable O in the GHG Handbook. T-22-A Implement Pedal (non-Electric) Bikeshare Program P/C U, S N/A 0.02% This measure will establish a bikeshare program. Bikeshare programs provide users with on-demand access to bikes for short-term rentals. Minimal reductions are calculated for this measure. The research associated with this measure is for citywide bikeshare programs and is not applicable to individual development projects. T-22-B Implement Electric Bikeshare Program P/C U, S N/A 0.06% This measure will establish an electric bikeshare program. Electric bikeshare programs provide users with on-demand access to electric pedal assist bikes for short-term rentals. Minimal reductions are calculated for this measure. The research associated with this measure is for citywide bikeshare programs and is not applicable to individual development projects. Nov. 5, 2025 Item #1 73 of 83 Vehicle Miles Traveled Analysis Guidelines (May 2023) | F-15 TABLE F-1: VMT REDUCTION STRATEGIES AND EFFECTIVENESS CALCULATIONS GHG Handbook # Measure1 Measures shown in green may be applied to individual development projects in Carlsbad– Must Follow procedures in GHG Handbook, this Appendix, and Calculation Notes shown in this Table. Measures shown in orange are not quantified in the GHG Handbook but may be quantifiable with appropriate evidence/information. Coordination with City staff required. Measures shown in yellow are not quantifiable but should be considered if a project has a significant and unavoidable impact to provide mitigation to the extent feasible. Measures shown in gray are not quantifiable, are not appropriate at the project scale, are not applicable in Carlsbad, or are already accounted for in the VMT modeling and may not be considered as mitigation measures. Scale of Application P/S – Project/Site P/C – Plan/Community Locational Context U – Urban (Village) S – Suburban (Outside of Village) Applicable Land Use Types Maximum Percent Reduction in VMT2 Measure Description/GHG Handbook Calculation Notes The calculation notes provide guidance on selecting values for the variables in the GHG Handbook VMT reduction equations. If a variable does not have stated guidance below, the user should apply the value provided in the GHG Handbook. Additionally, data sources are periodically updated; therefore, the user should confirm and use the most current data source for any given variable. T-22-C Implement Scootershare Program P/C U, S N/A 0.07% This measure will establish a scootershare program. Scootershare programs provide users with on-demand access to electric scooters for short-term rentals. Minimal reductions are calculated for this measure. The research associated with this measure is for citywide scootershare programs and is not applicable to individual development projects. T-34 Provide Bike Parking All U, S Residential Not Quantified This measure requires projects provide short-term and long-term bicycle parking facilities to meet peak season maximum demand. Parking can be provided in designated areas or added within rights-of-way, including by replacing parking spaces with bike parking corrals. Ensure that bike parking can be accessed by all, not just project employees or residents. This measure is a component of measure T-10. T-35 Provide Traffic Calming Measures All U, S Residential Retail Office Industrial Not Quantified This measure requires projects to include pedestrian/bicycle safety and traffic calming measures above jurisdictional requirements. Roadways should also be designed to reduce motor vehicle speeds and encourage pedestrian and bicycle trips with traffic calming features. T-36 Create Urban Non-Motorized Zones P/C U Residential Retail Office Industrial Not Quantified The measure requires projects to convert a percentage of its roadway miles to transit malls, linear parks, or other non-motorized zones. T-37 Dedicate Land for Bike Trails All? U, S Residential Retail Office Industrial Not Quantified This measure requires projects to provide for, contribute to, or dedicate land for the provision of off-site bicycle trails linking the project to designated bicycle commuting routes in accordance with an adopted citywide bikeway plan. Transit T-25 Extend Transit Network Coverage or Hours P/C U, S N/A 4.6% This measure will expand the local transit network by either adding or modifying existing transit service or extending the operation hours to enhance the service near the plan/community area. This is not applicable at a project scale since transit service is managed and operated by North County Transit District (NCTD) and is not within the control of an individual project to change. Nov. 5, 2025 Item #1 74 of 83 Vehicle Miles Traveled Analysis Guidelines (May 2023) | F-16 TABLE F-1: VMT REDUCTION STRATEGIES AND EFFECTIVENESS CALCULATIONS GHG Handbook # Measure1 Measures shown in green may be applied to individual development projects in Carlsbad– Must Follow procedures in GHG Handbook, this Appendix, and Calculation Notes shown in this Table. Measures shown in orange are not quantified in the GHG Handbook but may be quantifiable with appropriate evidence/information. Coordination with City staff required. Measures shown in yellow are not quantifiable but should be considered if a project has a significant and unavoidable impact to provide mitigation to the extent feasible. Measures shown in gray are not quantifiable, are not appropriate at the project scale, are not applicable in Carlsbad, or are already accounted for in the VMT modeling and may not be considered as mitigation measures. Scale of Application P/S – Project/Site P/C – Plan/Community Locational Context U – Urban (Village) S – Suburban (Outside of Village) Applicable Land Use Types Maximum Percent Reduction in VMT2 Measure Description/GHG Handbook Calculation Notes The calculation notes provide guidance on selecting values for the variables in the GHG Handbook VMT reduction equations. If a variable does not have stated guidance below, the user should apply the value provided in the GHG Handbook. Additionally, data sources are periodically updated; therefore, the user should confirm and use the most current data source for any given variable. T-26 Increase Transit Service Frequency/Speed P/C U, S N/A 11.3% This measure will increase transit frequency on one or more transit lines serving the plan/community. This is not applicable at a project scale since transit service is managed and operated by NCTD and is not within the control of an individual project to change. T-27 Implement Transit-Supportive Roadway Treatments P/C U, S N/A 0.6% This measure will implement transit-supportive treatments on the transit routes serving the plan/community. Treatments can include transit signal priority, bus-only signal phases, queue jumps, curb extensions to speed passenger loading, and dedicated bus lanes. This is not applicable at a project scale since transit service is managed and operated by NCTD and is not within the control of an individual project to change. T-28 Provide Bus Rapid Transit P/C U, S N/A 13.8% This measure will convert an existing bus route to a bus rapid transit (BRT) system. BRT includes the following additional components, compared to traditional bus service: exclusive right-of-way (e.g., busways, queue jumping lanes) at congested intersections, increased limited-stop service (e.g., express service), intelligent transportation technology (e.g., transit signal priority, automatic vehicle location systems), advanced technology vehicles (e.g., articulated buses, low-floor buses), enhanced station design, efficient fare-payment smart cards or smartphone apps, branding of the system, and use of vehicle guidance systems. This is not applicable at a project scale since transit service is managed and operated by NCTD and is not within the control of an individual project to change. T-29 Reduce Transit Fares P/C U, S N/A 1.2% This measure will reduce transit fares on the transit lines serving the plan/community. This is not applicable at a project scale since transit service is managed and operated by NCTD and is not within the control of an individual project to change. T-43 Provide Real-Time Transit Information P/C U, S N/A Not Quantified This measure requires projects provide real-time bus/train/ferry arrival time, travel time, alternative routings, or other transit information via electronic message signs, dedicated monitor or interactive electronic displays, websites, or mobile apps. This is not applicable at a project scale since transit service is managed and operated by NCTD and is not within the control of an individual project to change. Nov. 5, 2025 Item #1 75 of 83 Vehicle Miles Traveled Analysis Guidelines (May 2023) | F-17 TABLE F-1: VMT REDUCTION STRATEGIES AND EFFECTIVENESS CALCULATIONS GHG Handbook # Measure1 Measures shown in green may be applied to individual development projects in Carlsbad– Must Follow procedures in GHG Handbook, this Appendix, and Calculation Notes shown in this Table. Measures shown in orange are not quantified in the GHG Handbook but may be quantifiable with appropriate evidence/information. Coordination with City staff required. Measures shown in yellow are not quantifiable but should be considered if a project has a significant and unavoidable impact to provide mitigation to the extent feasible. Measures shown in gray are not quantifiable, are not appropriate at the project scale, are not applicable in Carlsbad, or are already accounted for in the VMT modeling and may not be considered as mitigation measures. Scale of Application P/S – Project/Site P/C – Plan/Community Locational Context U – Urban (Village) S – Suburban (Outside of Village) Applicable Land Use Types Maximum Percent Reduction in VMT2 Measure Description/GHG Handbook Calculation Notes The calculation notes provide guidance on selecting values for the variables in the GHG Handbook VMT reduction equations. If a variable does not have stated guidance below, the user should apply the value provided in the GHG Handbook. Additionally, data sources are periodically updated; therefore, the user should confirm and use the most current data source for any given variable. T-44 Provide Shuttles (Gas or Electric) All U, S Residential Office Industrial Not Quantified This measure will provide local shuttle service through coordination with the local transit operator or private contractor. The shuttles will provide service to and from commercial centers to nearby transit centers to help with first and last mile connectivity, thereby incentivizing a shift from private vehicles to transit, reducing associated GHG emissions. Note that this measure can also be implemented at the Project/Site scale by a large employer as part of a Trip Reduction Program. Quantification of VMT reduction associated with this measure may be possible if the applicant can provide details about the shuttle service such as vehicle type, routes, schedule, and ridership estimates. An applicant may coordinate with the City of Carlsbad to determine if VMT reduction associated with this measure is appropriate. T-45 Provide On-Demand Microtransit All U, S Office Industrial Not Quantified This measure will provide small-scale, on-demand public transit services that can offer fixed routes and schedules or flexible routes and on-demand scheduling through coordination with the local transit operator or private contractor. Note that this measure may also be applicable at the Project/Site scale for a large employer (e.g., Google’s Via2G pilot) as part of a Trip Reduction Program. Typically, this is not applicable at a project scale since transit service is managed and operated by NCTD and is not within the control of an individual project to change. An applicant may coordinate with the City of Carlsbad to determine if VMT reduction associated with this measure is appropriate. T-46 Improve Transit Access, Safety, and Comfort All U, S Residential Retail Office Industrial Not Quantified This measure requires projects improve transit access and safety through sidewalk/crosswalk safety enhancements, bus shelter improvements, improved lighting, and other features. Projects should evaluate access to transit stops within one-half mile of the project site to determine if additional features are needed to meet NCTD’s Bus Stop Development Handbook, March 2018 or the city’s multimodal level of service standards. T-47 Provide Bike Parking Near Transit -All U, S Residential Retail Office Industrial Not Quantified This measure requires the project to provide short-term and long-term bicycle parking near rail stations, transit stops, and freeway access points where there are commuter or rapid bus lines. Source: GHG Handbook (2021), Fehr & Peers, 2022. 1 Refer to updated information contained in the 2021 GHG Handbook. CAPCOA (2021) Each measure is numbered alphanumerically with the first letter of the emissions sector serving as the letter code (e.g., T=Transportation). 2 Effectiveness is based on the 2021 GHG Handbook unless otherwise specified. Measures that are “not quantified” are those that did not have sufficient research to support determination of individual effectiveness. Nov. 5, 2025 Item #1 76 of 83 Community Development Department | 1635 Faraday Ave. | Carlsbad, CA 92008 | www.carlsbadca.gov Vehicle Miles Traveled IB-160 This info-bulletin generalizes the process of analyzing and mitigating transportation impacts resulting from development projects using the Vehicle Miles Traveled (VMT) methodology, as required under the California Environmental Quality Act (CEQA). The intent of this bulletin is to provide the general public with a high-level understanding of VMT; it is not intended to act as a technical guide. For that level of detail, please refer to the links and documents referenced in this bulletin. SENATE BILL 743 SB 743 (Public Resources Code §21099) was passed by the state legislature and signed into law in the fall of 2013 and led to a significant change in the way transportation impacts are measured under CEQA (Refer to IB-150 for more information on CEQA and its role in the development process). SB 743 mandates that jurisdictions can no longer use automobile delay –commonly measured by Level of Service (LOS) – as the performance measure to determine the transportation impacts of land development projects pursuant to CEQA. SB 743 helps reduce transportation impacts on the environment by measuring the overall amount that people drive. While a replacement performance measure was not specified, SB 743 required that the replacement metric needed to bring CEQA transportation analyses into closer alignment with other statewide policies regarding greenhouse gas reductions, smart growth, and improved and expanded multimodal transportation networks (i.e., more complete streets to serve a variety of roadway users including pedestrians and bicyclists). GOV. OFFICE OF PLANNING & RESEARCH The SB 743 legislation designated the Governor’s Office of Planning and Research (OPR) to develop detailed implementation guidelines consistent with SB 743 that jurisdictions can use for CEQA transportation analysis. While the bill does not prevent jurisdictions from developing their own methodologies or guidelines, the city, along with virtually every other jurisdiction in the state, opted to follow OPRs chosen methodology. OPR develops technical advice on various issues that broadly affect CEQA practice and land use planning. These “advisories” provide general advice and recommendations, which agencies, the public, and other entities may use at their discretion. When developing a replacement for LOS, OPR looked towards an alternative transportation impact metric that more closely approximates the true environmental impacts of driving --- how much actual auto travel (additional miles driven) a proposed project would create on regional and local roads. If the project adds excessive car travel onto our roads, the project may cause a significant transportation impact that requires mitigation under CEQA. The process of writing guidelines started in January 2014 and concluded in 2018, when OPR released their guidance document entitled Technical Advisory on Evaluating Transportation Impacts in CEQA (OPR Advisory), which cities can, and have used to develop their own VMT guidelines. The OPR Advisory contains technical recommendations regarding assessment of VMT, thresholds of significance, screening criteria, and mitigation guidance. More on this below. Documents Referenced Senate Bill 743; PRC §21099 OPR Technical Advisory; OPR Advisory California Air Pollution Control Officers Association (CAPCOA) Guidance Document; GHG Handbook Carlsbad VMT Analysis Guidelines; VMT Guidelines Transportation Demand Management; TDM CEQA Informational Bulletin; IB-150 Exhibit 2 Nov. 5, 2025 Item #1 77 of 83 Page 2 of 7 IB-160_Vehicle Miles Traveled_April 2025 CALIFORNIA NATURAL RESOURCES AGENCY The mission of the California Natural Resources Agency (Resources Agency) is to restore, protect and manage the state’s natural, historical, and cultural resources. Among other duties, the Resources Agency is tasked with updating the state’s CEQA Guidelines, which are state administrative regulations that public agencies follow in order to show compliance with CEQA statute, applicable court decisions, and practical planning considerations. Relative to VMT, the Resources Agency on Dec. 28, 2018 adopted revisions to CEQA Guidelines §15064.3 stating that VMT is the most appropriate measure of transportation impacts under CEQA. This is the official action taken by the state that replaced LOS with VMT. Following this action, and the release of the OPR Advisory, jurisdictions throughout the state had until July 1, 2020, to adopt local VMT analysis guidelines for CEQA analysis. CALIFORNIA ENVIRONMENTAL QUALITY ACT Before we can discuss the components of the city’s VMT Analysis Guidelines, which were largely based on the OPR Advisory, it is important to define certain CEQA terms such as “thresholds of significance” and “screening criteria” to better understand their roles and functions when reviewing VMT impacts. Simply put, CEQA requires government agencies to inform decision-makers and the public about the potential environmental impacts of proposed projects, and to reduce those environmental impacts to the extent feasible. In practice, however, CEQA is a complex piece of legislation with complicated processes and procedures that projects must follow. The sections below provide a brief description of the aforementioned terms, and how they relate to VMT. For additional information on how CEQA works, please refer to our Info-Bulletin on CEQA (IB-150). CEQA Thresholds of Significance To assist in determining whether a specific impact is “significant” under CEQA, public agencies are encouraged to develop administrative guidance often referred to as significance thresholds. For VMT analysis, significance thresholds are based on the use of land, because land use conditions directly affect transportation activity. For residential projects, OPR recommends that a project’s VMT per capita be compared to the citywide average. For office and industrial projects, a project’s VMT per employee is compared to the regional average. For retail and other projects that evaluate VMT, the threshold is based on the change in VMT in the affected area. CEQA Screening Criteria In another method similar to creating significance thresholds, public agencies are encouraged to develop “screening criteria” to help quickly and easily screen out projects that are likely not to cause significant environmental impacts. For VMT, OPR recommends that a project may be presumed to not have a significant impact resulting from VMT if it is near public transit, comprised entirely of affordable housing, or considered a small project. Nov. 5, 2025 Item #1 78 of 83 IB-160_Vehicle Miles Traveled_April 2025 Page 3 of 7 CARLSBAD VMT ANALYSIS GUIDELINES Transportation impacts and their potential need for mitigation are important for any community to consider when contemplating proposed new developments, expansion of existing developments, or implementation of transportation projects. Carlsbad residents, businesses, other community members, and permit decision-makers all have a stake in understanding and responding to additional demands on the transportation system. To help analyze project related transportation impacts, the city developed VMT Analysis Guidelines (VMT Guidelines), which include procedures to promote consistency in VMT analysis and assist with the evaluation of discretionary projects under CEQA. In preparing and implementing the VMT Guidelines, the city relied on the OPR Advisory and recent court rulings. The city’s VMT screening criteria and thresholds were adopted by the City Council on June 16, 2020. Any changes to the thresholds and criteria will require City Council action, following recommendations by the Traffic & Mobility Commission. Due to a recent court ruling, the city’s “small project” and “transit proximate” thresholds may no longer be utilized to review the environmental impacts of proposed projects, so they are no longer referenced in the bulletin. The rest of the VMT Guidelines are for informational purposes only to assist applicants and their consultants when preparing traffic impact analyses. As such, the VMT Guidelines themselves may be administratively updated as new information becomes available. VMT Screening Criteria Below are the city’s adopted VMT screening criteria, which coincide with the VMT screening criteria in the OPR Advisory with the exception of one (discussed further below). It is presumed that projects meeting any one of the criteria listed below will not cause a significant impact on transportation services. As such, no further VMT analysis or mitigation is required. VMT SCREENING CRITERIA Residential projects made up of entirely affordable housing Redevelopment projects that result in a net overall decrease in VMT for the site Locally serving public facilities (i.e., public schools, parks, fire/police stations, libraries, other facilities intended to serve the local public) All screening criteria listed in OPR’s Advisory for transportation projects “Locally serving public facilities” are not specifically defined in the OPR Advisory. However, like “locally serving retail uses,” locally serving public facilities redistribute trips rather than create new ones. For example, the construction of a new community park or library actually shortens trips for nearby residents because users do not need to travel as far to receive the same public service or benefit. As such, these facilities are screened out and determined not to have a significant impact on transportation. It should be noted, however, that if a proposed public facility includes a use that has the potential of generating trips from outside the region, such as an amphitheater or a public golf course, a study evaluating where users are coming from may be required to demonstrate that a public facility is locally serving and still eligible to be screened out under these criteria. Nov. 5, 2025 Item #1 79 of 83 Page 4 of 7 IB-160_Vehicle Miles Traveled_April 2025 VMT Significance Thresholds A threshold of significance for a given environmental impact defines the level of effect above which the city will normally consider impacts to be significant, and below which it will normally consider impacts to be less than significant. The table below reflects the City Council adopted VMT Thresholds of Significance, which are used to determine whether a project, which did not meet the screening criteria, will create a significant transportation impact. The thresholds and specific VMT metrics used to measure VMT are described by land use type below. These thresholds are consistent with OPR Advisory recommendations. How these thresholds are applied in practice is discussed later in the bulletin. PROJECT TYPE THRESHOLD OF SIGNIFICANCE Residential A significant transportation impact occurs if the project VMT/capita exceeds a level 15% below the city average VMT/capita. Office A significant transportation impact occurs if the project VMT per employee exceeds a level 15% below the regional average VMT/employee. Retail A significant transportation impact occurs if the project results in a net increase in VMT. Industrial A significant transportation impact occurs if the project VMT/employee exceeds the average regional VMT/employee. Transportation A significant transportation impact occurs if the project creates a net VMT increase in the affected area. VMT Analysis The OPR Advisory advises that a city/county may use transportation modeling to estimate a project’s VMT. And CEQA requires that jurisdictions must use the best available data when assessing project impacts. As such, jurisdictions, including Carlsbad, typically use the most current regional travel demand model available, which is developed and maintained by the San Diego Association of Governments (SANDAG). The value of travel forecasting using SANDAG’s activity-based modeling comes from its capacity to provide a full range of quantitative dimensions to estimate travel-inducing activities and choices. The model simulates daily activities and travel patterns in the region, as affected by the transportation level of service, and it simulates the effects of transportation and land development patterns and policies on the quality (time and cost) and quantity (traffic volume, congestion, and VMT) of travel by different modes (walk, bike, transit, and auto). However, the VMT data that is provided by SANDAG does not account for interregional trips. Put another way, SANDAG’s data does not reflect the miles that are traveled beyond the county border or those trips originating from outside the county. As such, the city takes the SANDAG travel demand model data and combines it with the regional transportation model data that is collected by Caltrans. This combined data is then used to create local VMT maps that better forecast a full accounting of VMT, not limited by regional boundaries, as recommended by the OPR Technical Advisory. Residential, office, and industrial projects generating under 2,400 Average Daily Trips (ADT) can utilize these VMT Maps. Projects that generate over 2,400 ADT, or retail projects that do not meet screening criteria discussed earlier in this bulletin, must perform project-specific modeling consistent with OPR guidelines. The 2,400 threshold comes from the document entitled “Guidelines for Transportation Impact Studies in the San Diego Region,” as prepared by a SB 743 subcommittee led by the Institute of Transportation Engineers. Staff from SANDAG and Caltrans were on this subcommittee along with transportation engineers from the region. Nov. 5, 2025 Item #1 80 of 83 IB-160_Vehicle Miles Traveled_April 2025 Page 5 of 7 Sometimes showing the math helps folks better understand how the analysis works. This is one way of calculating VMT impacts. THEORETICAL PROJECT A law firm is locating in Carlsbad and proposing to construct a new two-story office complex on a vacant lot located near the corner of Carlsbad Village and Pio Pico Drive. The size of the office building is anticipated to generate an ADT of 1,500 trips. Per city VMT maps, the regional mean is shown as 20.6 VMT/employee and the office project will have a VMT/employee of 18.71, which is 90.8 % of the regional average (18.7 divided by 20.6). Per the city’s significance threshold, a significant transportation impact occurs when an office project exceeds a level of 15% below the regional average, or another way of stating this is the project exceeds 85% of the regional average. 85% of the regional average is 17.5 VMT/employee. As such, in this theoretical example, the percentage of project VMT that must be reduced is 6.4% (1-(17.5/18.7)). It is important to note that travel demand modeling is very sensitive to input changes. As growth and transportation system development occurs in the region, which is inconsistent with the assumptions used in the model, SANDAG will adjust the model to keep the analysis current and reliable for CEQA review. The city defaults to the most recent version of SANDAG’s model when analyzing VMT but accepts other modeling strategies that are consistent with the OPR Advisory (see “Common VMT Questions” for additional information). VMT Mitigation Under CEQA, projects resulting in a significant impact requires that mitigation measures be applied in an effort to reduce VMT impacts to the extent feasible. There are two ways to do this. • Reduce the number of automobile trips generated by the project; and/or, • Reduce the distance people drive. A project can accomplish this by incorporating Transportation Demand Management (TDM) strategies or actions into the development. Some examples include rideshare programs, trip reduction marketing, charging to use parking, employer paid transit expenses, end-of-trip bicycle facilities, and improvements to existing infrastructure such as bike paths and sidewalks. TDM strategies can be quantified using the methodologies described in the ”Handbook for Analyzing Greenhouse Gas Emission Reductions, Assessing Climate Vulnerabilities, and Advancing Health and Equity” (GHG Handbook). As mentioned above, CEQA requires that cities use the most reliable information available --- this document meets this requirement and is currently used by virtually all state jurisdictions when developing VMT mitigation. The resource document provides a description of each TDM measure with examples, notes on which measures must be grouped with others to be effective, a range of effectiveness (how much VMT reduction will be achieved), and guidance on how the measure should be implemented. Some of the TDM measures can be combined with others to increase the effectiveness of VMT mitigation; however, the interaction between the various strategies is complex and the effectiveness levels are not directly additive --- simply adding together the maximum VMT reduction values of multiple TDM measures will not provide a true representation of the total VMT expected to be reduced. This is because some TDM measures, when combined with others, may become redundant. Per the GHG Handbook, maximum VMT reductions are dependent upon the category of TDM measures implemented, which are defined as subsectors. Subsector maximums are intended to ensure that emissions are not double counted when measures within a given subsector are combined. For example, the subsector maximum for “Trip Reduction Programs” is 45% of a project’s commute VMT. For a TDM program consisting of many measures, care must be taken to verify that the calculated VMT reductions are dampened (diminished) according to a multiplicative formula to account for the above- mentioned redundancies. This formula can be found on page C-2 of the city’s guidelines but let’s use the sample project above to show how a TDM program made up of multiple measures is discounted. Nov. 5, 2025 Item #1 81 of 83 Page 6 of 7 IB-160_Vehicle Miles Traveled_April 2025 THEORETICAL PROJECT, CONTINUED… As shown previously, the office project requires a 6.4% reduction in VMT to have a transportation impact that is less than significant under CEQA. As such, the applicant proposes two TDM measures from the GHG Handbook to mitigate this impact. • Rideshare Program (3.2% VMT reduction) • Commute Trip Marketing (4.0% VMT reduction) To address anticipated redundancies when applying multiple TDM measures, the following GHG Handbook dampening equation must be applied. 1 - [(1-Pa) X (1-Pb) X (1-Pc)] = Total VMT Reduction (where Px is percent reduction of a TDM measure) After applying this dampening equation to the proposed TDM measures for the theoretical office project, the anticipated VMT reduction for the project is adjusted to 7.1%. 1 - [(1 -3.2%) X (1-4.0%)] = 7.1% Since 7.1% is more than the minimum 6.4% reduction needed, the proposed TDM measures, which will be added as conditions to the project permit, will adequately reduce the project’s transportation impacts to a level of less than significant. COMMON VMT QUESTIONS VMT analysis is new and evolving, which has resulted in a lot of confusion and questions in its appropriateness and effectiveness. This info-bulletin is intended to explain to the reader the value, aptness, and usefulness of measuring and mitigating transportation impacts through the reduction of VMT. However, given its technical nature, there are some common questions that warrant discussion. Why are new projects only required to implement minimum TDM measures? This question comes up a lot during the review of new development projects --- particularly in areas where traffic congestion is already an issue or existing infrastructure (e.g., bus stop) is lacking or deficient. CEQA Guidelines §15126.4(a) requires lead agencies (city) to consider and require feasible mitigation measures to avoid or substantially reduce a proposed project's significant environmental impacts. The key word here is the project’s impacts. The city cannot legally require a project to make improvements to resolve transportation deficiencies that existed prior to the project being developed; the city can only require mitigation that addresses the direct and cumulative impacts generated by the proposed development. The due process clause of the Fifth Amendment of the US Constitution further addresses this point. Pursuant to the US Constitution, local governments can exact property, or something of value from a property owner (developer), without having to provide compensation, provided two tests are met: • “Nexus” • “Rough Proportionality” Nexus means the exaction (TDM mitigation) must have a rational connection (nexus) to the burden the government seeks to avoid (increased VMT). The nexus requirement derives from the court case Nollan v. California Coastal Commission, 483 U.S. 825, 107 S. Ct. 3141 (1987). Rough proportionality means that the amount of the exaction (TDM mitigation) must roughly correspond to the burden placed on the government/public (increased VMT), resulting from the proposed development. This test derives from court case Dolan v. City of Tigard, 512 U.S. 374, 114 S. Ct. 2309 (‘94). Using the theoretical project example, since the rideshare and commute trip reduction marketing programs address the VMT impacts of the office project to a level of less than significant, the city cannot require that the same project also improve a nearby transit stop or add a turn lane to an existing intersection to improve existing traffic flows as a mitigation requirement under CEQA. To do so would violate both tests. That said, there may be other city policies that require multimodal improvements and transportation demand management strategies. The city may impose additional project requirements in order to satisfy these mobility policies IF the city finds that the VMT mitigation does not adequately address them. In other words, VMT CEQA mitigation can also be used to satisfy other city mobility policies. Nov. 5, 2025 Item #1 82 of 83 IB-160_Vehicle Miles Traveled_April 2025 Page 7 of 7 Why are applicants allowed to use customized VMT models? While the SANDAG model is the city’s default model to analyze project level VMT impacts, it is not without its limitations. The SANDAG model makes certain general assumptions on how land will be develop/redeveloped. However, proposed development projects, or the surrounding development area, may be a particular size or contain certain features that were not or could not be accounted for in the SANDAG model. Recognizing this, the OPR Advisory, and in turn the city, allows applicants to develop customized models using varying model strategies. Travel demand models, sketch models, spreadsheet models, research, and data can all be used to calculate and estimate VMT. Models can also work together. For example, an applicant can use travel demand models or survey data to estimate existing trip lengths and input those into sketch models to achieve more accurate results. When using alternative models and tools, however, the city requires consultants to use comparable data and methods in order to set up an “apples-to-apples” comparison between thresholds, VMT estimates, and VMT mitigation estimates. Why do some TDM measures work for some projects, but don’t work for others? There are some limits to overall VMT reduction effectiveness depending on a project’s land use context --- Developable area, proposed land use mix, surrounding development patterns, and availability of transit resources can vary significantly from project to project. Similarly, so can the effectiveness of TDM measures. For this reason, VMT mitigation measures must be reviewed on a case-by-case basis to ensure that they are site appropriate, justified, and can be reasonably incorporated in the proposed project. Why does the city use traffic analysis zones for VMT analysis? Daily activities and travel patterns in any city is greatly influenced by existing land use patterns and transportation networks. To maximize the effectiveness of a predictive model, it is important to assess VMT impacts in smaller, more focused geographic areas. SANDAG provides transportation model data in two different ways: Census Tracts and Traffic Analysis Zones (TAZ). Some people may be familiar with Census Tracts (image right), which are small geographical subdivisions of a county that help present different statistical data points (i.e., average age, ethnicity, household income, household size), with each tract representing a population size between 1,200 and 8,000 people. A TAZ is a similar geographical area, but typically much smaller than a census tract and most commonly used in transportation models. Use of either geographic area is perfectly acceptable for VMT analysis. However, the city prefers to use TAZ data because the TAZ offers a more refined area around the project. The data tends to be a better representation of the VMT in the area of the project as opposed to the census tract where the VMT is averaged across larger areas. YOUR OPTIONS FOR SERVICE To learn more, please contact one of our staff in Land Development Engineering at 760-602-2750 or via email at LandDev@CarlsbadCA.gov. Nov. 5, 2025 Item #1 83 of 83 Overview of Vehicle Miles Traveled (VMT) Jason Geldert, P.E. Engineering Manager, Land Development Engineering Katy Cole, P.E. Fehr & Peers/City of Carlsbad VMT Reviews November 5, 2025 2 TODAY’S PRESENTATION •VMT Overview (Jason) •VMT Thresholds and Screening Criteria (Katy) •Measuring VMT (Katy) •Mitigating VMT (Katy) •Sample Project (Katy & Jason) •Q&A Overview of the VMT Guidelines VMT? (VEHICLE MILES TRAVELED) 3 Amount of driving generated by a project OLD WAY OF MEASURING TRANSPORTATION IMPACTS 4 Level of Service (LOS) 5 •Metric: Vehicle delay (congestion) •Goal: Reduce congestion •Mitigation: Bigger roads, lower density LEVEL OF SERVICE (LOS) 6 •Sprawl •Reduced infill development •Induced Demand OUTCOMES OF LOS LOS is not a measure of environmental impacts 7 •Metric: Amount of driving •Goal: Reduce emissions, promote sustainable land use •Mitigation: transit, bike and pedestrian improvements, infill development VMT 8 •Increased infill development •Less sprawl •Focus on travel options OUTCOMES OF VMT 9 CARLSBAD’S REGULATIONS Overview of the VMT Guidelines •Resolution No. 2020-114 approved on June 16, 2020 •Adopted VMT thresholds of significance and screening criteria •VMT Analysis Guidelines were provided with the staff report for context 10 •Miles/resident/day •Miles/employee/day •Total miles/day VMT METRIC majority of projects 11 VMT THRESHOLDS Overview of the VMT Guidelines Residential Projects A significant transportation impact occurs if the project VMT/capita exceeds a level 15% below the city average VMT/capita. Office/Employment Projects A significant transportation impact occurs if the project VMT/employee exceeds a level 15% below the regional average VMT/employee. Regional Retail/Recreational Projects A significant transportation impact occurs if the project results in a net increase in VMT. Industrial Projects A significant transportation impact occurs if the project VMT/employee exceeds the average regional VMT/employee. Transportation Projects A significant transportation impact occurs if the project results in a net increase in VMT in the affected area. 12 VMT SCREENING CRITERIA Overview of the VMT Guidelines Projects that generate less than 110 ADT (no longer legally valid, an applicant can provide evidence to support other “small project” screening) Residential, office, or retail uses located withing one-half mile of a major transit stop or stop along a high- quality transit corridor that can demonstrate that existing VMT meets the VMT threholds Locally serving retail uses Affordable housing (all units) Redevelopment projects that result in a net overall decrease in VMT for the project site Locally serving public facility Transportation projects that don’t increase vehicle capacity (as listed in the Office of Land Use and Climate Innovation’s (LCI, formally OPR) Technical Advisory 13 Overview of the VMT Guidelines MEASURING VMT •No Universal Tool •Common Tools in Carlsbad: •City VMT Maps •SANDAG Travel Demand Model •Travel Survey Data (using a project’s trip generation and average trip length. •Custom spreadsheet tools •Use of “big data” to understand existing VMT. 14 REDUCING VMT Overview of the VMT Guidelines VMT > Vehicle Trips x Average Trip Length •Affordable Housing •Rideshare Program •Subsidize Transit •Bicycle Facilities •Pedestrian Facilities •Price Parking •Compact Land Use •Infill Locations •Mixed Use Projects 15 REDUCING VMT Overview of the VMT Guidelines VMT > Vehicle Trips x Average Trip Length •Affordable Housing •Rideshare Program •Subsidize Transit •Bicycle Facilities •Pedestrian Facilities •Price Parking •Compact Land Use •Infill Locations •Mixed Use Projects 16 SAMPLE PROJECT - DESCRIPTION Pretend Project: Location: Rotary Park Land Uses: Residential and Office 17 SAMPLE PROJECT – ANALYSIS REQUIREMENTS 18 SAMPLE PROJECT – VMT/RESIDENT 19 SAMPLE PROJECT – VMT/EMPLOYEE 20 SAMPLE PROJECT – IMPACT CONCLUSION Residential Component = Less Than Significant (82% of City Average) No Mitigation Required Office Component = Significant Impact (92% of Regional Average) Mitigation Required Mitigation could include transit pass subsidies, carpool program, end of trip bicycle facilities, etc. 21 QUESTIONS & COMMENTS Overview of the VMT Guidelines 22 Measuring VMT Overview of the VMT Guidelines 23 VMT 201 Overview of the VMT Guidelines