HomeMy WebLinkAbout2020-05-04; Traffic and Mobility Commission; ; ADOPTION OF VEHICLE MILES TRAVELED THRESHOLDS AND SCREENING CRITERIItem 7
Meeting Date: May 4, 2020
To: Traffic and Mobility Commission
From: Jason Geldert, City Engineer
jason.geldert@carlsbadca.gov, 760-602-2758
Subject: Adoption of Vehicle Miles Traveled thresholds and screening criteria
Recommended Action
Staff recommends that the Traffic and Mobility Commission recommend to the City Council
adoption of a resolution approving citywide Vehicle Miles Traveled thresholds and screening
criteria pursuant to Senate Bill 743.
Executive Summary
California Senate Bill 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 will be measured under the California
Environmental Quality Act (CEQA). Starting on July 1, 2020, automobile delay and level of service (LOS)
may no longer be used as the performance measure to determine the transportation impacts of projects
under CEQA. Instead, an alternative metric that supports the goals of the SB 743 legislation will be
required. Although there is no requirement to use any specific metric in the law, the use of vehicle
miles traveled (VMT) as a metric is recommended by the Governor’s Office of Planning and Research
(OPR).
Each public agency is encouraged to develop and publish thresholds of significance that the agency uses
in the determination of the significance of environmental effects. Thresholds of significance to be
adopted for general use as part of the lead agency's environmental review process must be adopted by
ordinance, resolution, rule, or regulation, and developed through a public review process and be
supported by substantial evidence. Staff has developed and is proposing new screening criteria and
thresholds of significance for transportation impacts for adoption by resolution. The proposed VMT
thresholds and guidelines largely follow OPRs guidelines with minor deviations as explained in this staff
report.
Discussion
• Policy Background
California Senate Bill (SB) 743, signed into law in November 2013, initiated a significant
departure from past policy and national practice regarding analysis of transportation impacts. SB
743 was a response to state emissions targets established in various senate bills and executive
orders, such as Senate Bill 32 and Executive Order B-30-15. These legislative mandates set
aggressive greenhouse gas emissions reduction targets, and they established unique emissions
benchmarks for various years in the future.
SB 743 directed the Office of Planning and Research (OPR) to develop criteria for determining
the significance of transportation impacts of projects to align with statewide emission reduction
goals. Specifically, the criteria, as stated in the Bill, shall promote the reduction of greenhouse
gas emissions, the development of multimodal transportation networks, and a diversity of land
uses. Measures of vehicular capacity or traffic congestion (Level of Service or LOS) is no longer
to be considered a significant impact on the environment, according to the Bill.
OPR identified the use of vehicle miles traveled (VMT) as the most appropriate metric to
evaluate a project’s transportation impact that aligns with the goals of Senate Bill 743. VMT
refers to the amount and distance of automobile travel attributable to a project or a
geographical region over a given period of time. The California Natural Resources Agency
certified and adopted revisions to the CEQA Guidelines based on OPR’s recommendations in
December 2018. According to the adopted guidelines, the use of VMT to determine
transportation impacts will begin no later than July 1, 2020.
• What are the CEQA Guidelines
The California Environmental Quality Act (CEQA) generally requires state and local 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. The CEQA
Guidelines are administrative regulations governing implementation of the California
Environmental Quality Act (Public Resources Code section 21000 and following). The CEQA
Guidelines reflect the requirements set forth in the Public Resources Code, as well as court
decisions interpreting the statute and practical planning considerations. Among other things,
the CEQA Guidelines explain how to determine whether an activity is subject to environmental
review, what steps are involved in the environmental review process, and the required content
of environmental documents. The CEQA Guidelines apply to public agencies throughout the
state, including local governments, special districts, and state agencies.
• What is a Threshold of Significance
A threshold of significance for a given environmental impact defines the level of effect above
which the impacts are significant, and below which impacts are less than significant. Thresholds
of significance may be defined either as quantitative or qualitative standards, or sets of criteria,
whichever is most applicable to each specific type of environmental impact. For example,
quantitative criteria are often applied to traffic, air quality, and noise impacts, while aesthetics
impacts are typically evaluated using qualitative thresholds. Screening criteria may also be used
to determine a project’s environmental impact. Screening criteria are certain project
characteristics that, if exhibited by a proposed project, allow presumption of no significant
impact without having to perform a detailed analysis.
Lead Agencies, such as Carlsbad, have discretion to formulate their own significance thresholds
including screening criteria. Setting thresholds requires the Lead Agency to make a judgment
about how to distinguish significant impacts from less-than-significant impacts based on
substantial evidence. Substantial evidence means that a fair argument, based on enough
relevant information and reasonable inferences, can be made to support a conclusion, even
though other conclusions might also be reached.
• How is VMT evaluated
Evaluation of vehicle miles traveled can be completed using various methods. To achieve the
state’s long-term goals, the recommended methodology for evaluating residential and office
projects is through the efficiency metrics of VMT per capita and VMT per employee. For
residential projects, VMT per capita represents the average VMT per resident associated with a
project. For office projects, VMT per employee represents the average VMT per employee
associated with a project. These metrics are independent of project size and an indication of
how efficient a project’s VMT characteristics are. Alternatively, the recommended methodology
for evaluating retail and other types of projects is the change in total VMT on the roadway
network.
Screening criteria may be applied to projects evaluating VMT. For example, a project may be
presumed to not have a significant impact if it is near transit, comprised entirely of affordable
housing, or can be considered a small project. Any project that does not meet screening criteria
is subject to completing a detailed VMT analysis and must compare its project VMT to the
appropriate threshold of significance.
For VMT analyses, thresholds of significance are based on the type of VMT evaluation. For
residential and office projects, a project’s VMT per capita or VMT per employee must be
compared to the corresponding average for a larger geographical area. For retail and other
projects that evaluate VMT on the roadway network, the threshold is based on the change in
VMT in the affected area.
If a project is determined to have a significant transportation impact, projects can apply VMT
reduction measures, also known as mitigation measures, to lower their calculated VMT values.
Typically, VMT is reduced by implementing strategies that reduce the number of automobile
trips generated or reducing the distance that people drive. Measures that reduce single
occupant automobile trips are called Transportation Demand Management (TDM) strategies.
TDM strategies may include such measures as ride-sharing programs, transit passes, and
telecommuting.
• OPR’s Technical Advisory on Evaluating Transportation Impacts in CEQA
OPR’s Technical Advisory on Evaluating Transportation Impacts in CEQA (Exhibit 1) contains
recommendations regarding evaluation of VMT, thresholds of significance, and mitigation
measures, and it also provides substantial evidence for its recommendations. Screening criteria
included in OPR’s Technical Advisory include projects generating less than 110 average daily
traffic (ADT), projects located in VMT-efficient areas, projects located near transit, projects
containing 100% affordable housing, and redevelopment projects that lead to a net decrease in
overall VMT.
OPR recommends that a per capita or per employee VMT that is fifteen percent below that of
existing development may be a reasonable threshold. For residential projects, a proposed
project exceeding a level of 15 percent below existing regional or city VMT per capita may
indicate a significant transportation impact. For office projects, a proposed project exceeding a
level of 15 percent below existing regional VMT per employee may indicate a significant
transportation impact. Retail projects may have a significant transportation impact if there is a
net increase in total VMT in the affected area.
The Technical Advisory lists examples of potential mitigation measures and alternatives to
reducing VMT, but selection of particular measures is left to the discretion of the agency and no
recommendations are provided regarding calculation of the VMT reductions associated with
particular measures.
The Technical Advisory is provided as a resource for lead agencies to use at their discretion, and
it is intended to assist lead agencies in selecting a threshold of significance for particular
projects. However, lead agencies may consider alternative thresholds of significance provided
they are supported by substantial evidence.
• OPR’s Transportation Projects
OPR’s Technical Advisory also contains guidance on the analysis of transportation projects, and
it states that for roadway capacity projects lead agencies have discretion to choose which metric
to use to evaluate transportation impacts. However, as required by SB 743, criteria for
determining the significance of transportation impacts must promote the reduction of
greenhouse gas emissions, the development of multimodal transportation networks, and a
diversity of land uses. Transit, bicycle, pedestrian, and maintenance projects can generally be
presumed to have a less than significant impact, and the OPR Technical Advisory contains a list
of project types that may be screened out from completing a VMT analysis.
The effect of a project on vehicle travel should be estimated based on total change in VMT over
the region where driving patterns are expected to change, and it should account for a project’s
growth-inducing impacts such as induced travel. OPR’s Technical Advisory states that a
threshold of significance for transportation projects should be based on the three main goals of
SB 743 stated above. It also requires the analysis to address direct, indirect, and cumulative
effects of the project, and near-term and long-term effects of the project. It suggests that GHG
emissions targets may be used to develop thresholds but does not include any specific
recommendations for thresholds of significance.
• City of Carlsbad’s Proposed VMT Screening Criteria and Guidelines
City staff have developed city specific VMT screening criteria and analysis guidelines (Exhibit 2),
which comply with CEQA recommendations for thresholds of significance, to encourage
consistency in VMT analysis across projects, and to balance recommendations presented in OPR
with City of Carlsbad values. The guidelines are based largely on recommendations presented in
OPR’s Technical Advisory, with some refinements to reflect regional and local conditions. The
guidelines contain background on the use of VMT to evaluate transportation impacts, screening
criteria, methodologies for evaluating VMT for individual projects, thresholds of significance,
and guidance on VMT mitigation.
For large projects (over 2,400 average daily trips), a model run of the regional travel demand
model operated by the San Diego Association of Governments (SANDAG) is used to determine
the project’s VMT/capita or VMT/employee. For small projects (under 2,400 average daily trips),
VMT/capita and VMT/employee are also based on the regional travel demand model. However,
rather than using an individual model run for each project, VMT/capita and VMT/employee are
determined from maps prepared by the City of Carlsbad using output from the model. The VMT
analysis maps show VMT/capita and VMT/employee for each traffic analysis zone (TAZ) in the
city. TAZ’s are geographical areas of varying size set up in the regional travel demand model. The
assumption for small 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. The
analysis maps will be available through a city GIS web page. Exhibits 3 and 4 are general
representations of the GIS data. Exhibit 3 represents VMT/Capita and Exhibit 4 represents
VMT/Employee. The TAZ boundaries are indicated by the gray lines.
The document contains guidance on methods for calculating VMT reductions for mitigation
measures, as well as appropriate applications of each mitigation measure. Generally, projects
may choose to use methodologies described in Quantifying Greenhouse Gas Mitigation
Measures (California Air Pollution Control Officers Association (CAPCOA), 2010) or the SANDAG
Mobility Management Guidebook/VMT Reduction Calculator Tool. Other methodologies may be
used to quantify VMT reductions provided there is substantial evidence to justify the calculated
reduction.
Tables 1 and 2, below, summarize the screening criteria and CEQA thresholds proposed in the
document. As you will see, most of the guidelines come directly from OPR; an explanation for
those areas that deviate are identified. Additional support and explanation is provided in the
document.
Table 1: Proposed Screening Criteria
Screening Criteria Substantial Evidence
Projects that generate less than 110 ADT OPR recommendation
Residential, office or retail uses located within
one-half mile of a major transit stop or a stop
along a high-quality transit corridor
OPR recommendation
Locally serving retail uses OPR recommendation
Residential projects made up of entirely
affordable housing
OPR recommendation
Redevelopment projects that result in a net
overall decrease in VMT for the site
OPR recommendation
Locally serving public-facility Adopted by City of San Diego, locally serving
public-facilities will have similar effect as locally
serving retail
All screening criteria listed in OPR’s Technical
Advisory (Exhibit 1) for transportation projects
OPR recommendation
Table 2: Proposed Thresholds of Significance
Threshold of Significance Substantial Evidence
Residential Projects: A significant transportation
impact occurs if the project VMT per capita
exceeds a level 15% below the city average VMT
per capita
OPR recommendation
Office Projects: A significant transportation
impact occurs if the project VMT per employee
exceeds a level 15% below the city average VMT
per employee
OPR recommends VMT per employee compared
to a regional average. Due to the large size of the
San Diego region and the VMT characteristics of
the city, VMT per employee compared to the
regional average would produce a jobs/housing
imbalance. This will increase VMT for residents by
discouraging employment in Carlsbad. From the
overall VMT point of view, a more favorable
result is to locate future employment in VMT-
efficient areas of the city. A diversity of land uses
is consistent with the primary goals of SB 743.
Regional Retail Projects: A significant
transportation impact occurs if the project results
in a net increase in VMT
OPR recommendation
Industrial Projects: A significant transportation
impact occurs if the project VMT per employee
exceeds the average city VMT per employee
Adopted by City of San Diego, Industrial uses tend
to be more land intensive and generate lower
amounts of VMT. Therefore, locating industrial
uses in less VMT-efficient areas results in greater
opportunity for more dense infill development to
achieve VMT reductions in low VMT areas
Transportation Projects: A significant
transportation impact occurs if the project
creates a net VMT increase in the affected area
Guidelines for Transportation Impact Studies
in the San Diego Region (Exhibit 5); OPR did not
give a specific recommendation
Next Steps
This item is tentatively scheduled for a City Council Hearing on June 9, 2020
Environmental Evaluation (CEQA)
State CEQA Guidelines Section 15064.7(b) requires “thresholds of significance to be adopted for
general use as part of the lead agency’s environmental review process by ordinance, resolution,
rule or regulation, and developed through a public review process and supported by substantial
evidence.” The courts have clarified that Section 15064.7(b) does not additionally require CEQA
review as a prerequisite for adopting thresholds of significance. Requiring the preparation of a
CEQA document would be redundant with the public review process and substantial evidence
standard already set forth in Section 15064.7. The city is meeting the requirement for public
review by providing notice of the City Council public hearing through publication in the
newspaper in accordance with CMC Chapter 21.54. Additionally, the city is providing another
opportunity for public review and input at the Traffic and Mobility Commission meeting the
meeting was noticed as described in the following section. Lastly, city staff have shared the
proposed thresholds and screening criteria with stakeholders including development project
applicants, traffic consultants along with a public posting to the city’s website. The city’s
thresholds of significance and screening criteria are supported by substantial evidence as
described in this report. Therefore, the city planner has determined that adoption of the
thresholds and screening criteria is not a project under State CEQA Guidelines section
15378(b)(5) because the city is complying with the requirements of State CEQA Guidelines
Section 15064.7(b) and no CEQA review is required.
Public Notification
This item was noticed in accordance with the Ralph M. Brown Act and was available for public
viewing and review at least 72 hours prior to the scheduled meeting date.
Exhibits
1. Office of Planning and Research Technical Advisory on Evaluating Transportation Impact in
CEQA
2. Draft City of Carlsbad VMT Analysis Guidelines
3. VMT/Capita Analysis Map
4. VMT/Employee Analysis Map
5. Guidelines for Transportation Impact Studies in the San Diego Region
ON EVALUATING TRANSPORTATION
IMPACTS IN CEQA
TECHNICAL ADVISORY
December 2018
Contents
A. Introduction ...................................................................................................................................... 1
B. Background ....................................................................................................................................... 2
C. Technical Considerations in Assessing Vehicle Miles Traveled ......................................................... 4
1. Recommendations Regarding Methodology ................................................................................ 4
D. General Principles to Guide Consideration of VMT .......................................................................... 7
E. Recommendations Regarding Significance Thresholds .................................................................... 8
1. Screening Thresholds for Land Use Projects ............................................................................... 12
2. Recommended Numeric Thresholds for Residential, Office, and Retail Projects ....................... 15
3. Recommendations Regarding Land Use Plans ............................................................................ 18
4. Other Considerations .................................................................................................................. 19
F. Considering the Effects of Transportation Projects on Vehicle Travel ........................................... 19
1. Recommended Significance Threshold for Transportation Projects .......................................... 22
2. Estimating VMT Impacts from Transportation Projects ............................................................. 23
G. Analyzing Other Impacts Related to Transportation ...................................................................... 25
H. VMT Mitigation and Alternatives .................................................................................................... 26
Appendix 1. Considerations About Which VMT to Count ....................................................................... 29
Appendix 2. Induced Travel: Mechanisms, Research, and Additional Assessment Approaches ............ 32
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December 2018
A. Introduction
This technical advisory is one in a series of advisories provided by the Governor’s Office of Planning and
Research (OPR) as a service to professional planners, land use officials, and CEQA practitioners. OPR
issues technical assistance on issues that broadly affect the practice of land use planning and the
California Environmental Quality Act (CEQA) (Pub. Resources Code, § 21000 et seq.). (Gov. Code, §
65040, subds. (g), (l), (m).) The purpose of this document is to provide advice and recommendations,
which agencies and other entities may use at their discretion. This document does not alter lead agency
discretion in preparing environmental documents subject to CEQA. This document should not be
construed as legal advice.
Senate Bill 743 (Steinberg, 2013), which was codified in Public Resources Code section 21099, required
changes to the guidelines implementing CEQA (CEQA Guidelines) (Cal. Code Regs., Title 14, Div. 6, Ch. 3,
§ 15000 et seq.) regarding the analysis of transportation impacts. As one appellate court recently
explained: “During the last 10 years, the Legislature has charted a course of long-term sustainability
based on denser infill development, reduced reliance on individual vehicles and improved mass transit,
all with the goal of reducing greenhouse gas emissions. Section 21099 is part of that strategy . . . .”
(Covina Residents for Responsible Development v. City of Covina (2018) 21 Cal.App.5th 712, 729.)
Pursuant to Section 21099, the criteria for determining the significance of transportation impacts must
“promote the reduction of greenhouse gas emissions, the development of multimodal transportation
networks, and a diversity of land uses.” (Id., subd. (b)(1); see generally, adopted CEQA Guidelines, §
15064.3, subd. (b) [Criteria for Analyzing Transportation Impacts].) To that end, in developing the
criteria, OPR has proposed, and the California Natural Resources Agency (Agency) has certified and
adopted, changes to the CEQA Guidelines that identify vehicle miles traveled (VMT) as the most
appropriate metric to evaluate a project’s transportation impacts. With the California Natural Resources
Agency’s certification and adoption of the changes to the CEQA Guidelines, automobile delay, as
measured by “level of service” and other similar metrics, generally no longer constitutes a significant
environmental effect under CEQA. (Pub. Resources Code, § 21099, subd. (b)(3).)
This advisory contains technical recommendations regarding assessment of VMT, thresholds of
significance, and mitigation measures. Again, OPR provides this Technical Advisory as a resource for the
public to use at their discretion. OPR is not enforcing or attempting to enforce any part of the
recommendations contained herein. (Gov. Code, § 65035 [“It is not the intent of the Legislature to vest
in the Office of Planning and Research any direct operating or regulatory powers over land use, public
works, or other state, regional, or local projects or programs.”].)
This December 2018 technical advisory is an update to the advisory it published in April 2018. OPR will
continue to monitor implementation of these new provisions and may update or supplement this
advisory in response to new information and advancements in modeling and methods.
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December 2018
B. Background
VMT and Greenhouse Gas Emissions Reduction. Senate Bill 32 (Pavley, 2016) requires California to
reduce greenhouse gas (GHG) emissions 40 percent below 1990 levels by 2030, and Executive Order B-
16-12 provides a target of 80 percent below 1990 emissions levels for the transportation sector by 2050.
The transportation sector has three major means of reducing GHG emissions: increasing vehicle
efficiency, reducing fuel carbon content, and reducing the amount of vehicle travel. The California Air
Resources Board (CARB) has provided a path forward for achieving these emissions reductions from the
transportation sector in its 2016 Mobile Source Strategy. CARB determined that it will not be possible to
achieve the State’s 2030 and post-2030 emissions goals without reducing VMT growth. Further, in its
2018 Progress Report on California’s Sustainable Communities and Climate Protection Act, CARB found
that despite the State meeting its 2020 climate goals, “emissions from statewide passenger vehicle
travel per capita [have been] increasing and going in the wrong direction,” and “California cannot meet
its [long-term] climate goals without curbing growth in single-occupancy vehicle activity.”1 CARB also
found that “[w]ith emissions from the transportation sector continuing to rise despite increases in fuel
efficiency and decreases in the carbon content of fuel, California will not achieve the necessary
greenhouse gas emissions reductions to meet mandates for 2030 and beyond without significant
changes to how communities and transportation systems are planned, funded, and built.”2
Thus, to achieve the State’s long-term climate goals, California needs to reduce per capita VMT. This can
occur under CEQA through VMT mitigation. Half of California’s GHG emissions come from the
transportation sector3, therefore, reducing VMT is an effective climate strategy, which can also result in
co-benefits.4 Furthermore, without early VMT mitigation, the state may follow a path that meets GHG
targets in the early years, but finds itself poorly positioned to meet more stringent targets later. For
example, in absence of VMT analysis and mitigation in CEQA, lead agencies might rely upon verifiable
offsets for GHG mitigation, ignoring the longer-term climate change impacts resulting from land use
development and infrastructure investment decisions. As stated in CARB’s 2017 Scoping Plan:
“California’s future climate strategy will require increased focus on integrated land use planning
to support livable, transit-connected communities, and conservation of agricultural and other
lands. Accommodating population and economic growth through travel- and energy-efficient
land use provides GHG-efficient growth, reducing GHGs from both transportation and building
energy use. GHGs can be further reduced at the project level through implementing energy-
efficient construction and travel demand management approaches.”5 (Id. at p. 102.)
1 California Air Resources Board (Nov. 2018) 2018 Progress Report on California’s Sustainable
Communities and Climate Protection Act, pp. 4, 5, available at
https://ww2.arb.ca.gov/sites/default/files/2018-11/Final2018Report_SB150_112618_02_Report.pdf.
2 Id., p. 28.
3 See https://ca50million.ca.gov/transportation/
4 Fang et al. (2017) Cutting Greenhouse Gas Emissions Is Only the Beginning: A Literature Review of the
Co-Benefits of Reducing Vehicle Miles Traveled.
5 California Air Resources Board (Nov. 2017) California’s 2017 Climate Change Scoping Plan, p. 102,
available at https://www.arb.ca.gov/cc/scopingplan/scoping_plan_2017.pdf.
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December 2018
In light of this, the 2017 Scoping Plan describes and quantifies VMT reductions needed to achieve our
long-term GHG emissions reduction goals, and specifically points to the need for statewide deployment
of the VMT metric in CEQA:
“Employing VMT as the metric of transportation impact statewide will help to ensure GHG
reductions planned under SB 375 will be achieved through on-the-ground development, and will
also play an important role in creating the additional GHG reductions needed beyond SB 375
across the State. Implementation of this change will rely, in part, on local land use decisions to
reduce GHG emissions associated with the transportation sector, both at the project level, and
in long-term plans (including general plans, climate action plans, specific plans, and
transportation plans) and supporting sustainable community strategies developed under SB
375.”6
VMT and Other Impacts to Health and Environment. VMT mitigation also creates substantial benefits
(sometimes characterized as “co-benefits” to GHG reduction) in both in the near-term and the long-
term. Beyond GHG emissions, increases in VMT also impact human health and the natural environment.
Human health is impacted as increases in vehicle travel lead to more vehicle crashes, poorer air quality,
increases in chronic diseases associated with reduced physical activity, and worse mental health.
Increases in vehicle travel also negatively affect other road users, including pedestrians, cyclists, other
motorists, and many transit users. The natural environment is impacted as higher VMT leads to more
collisions with wildlife and fragments habitat. Additionally, development that leads to more vehicle
travel also tends to consume more energy, water, and open space (including farmland and sensitive
habitat). This increase in impermeable surfaces raises the flood risk and pollutant transport into
waterways.7
VMT and Economic Growth. While it was previously believed that VMT growth was a necessary
component of economic growth, data from the past two decades shows that economic growth is
possible without a concomitant increase in VMT. (Figure 1.) Recent research shows that requiring
development projects to mitigate LOS may actually reduce accessibility to destinations and impede
economic growth.8,9
6 Id. at p. 76.
7 Fang et al. (2017) Cutting Greenhouse Gas Emissions Is Only the Beginning: A Literature Review of the
Co-Benefits of Reducing Vehicle Miles Traveled, available at https://ncst.ucdavis.edu/wp-
content/uploads/2017/03/NCST-VMT-Co-Benefits-White-Paper_Fang_March-2017.pdf.
8 Haynes et al. (Sept. 2015) Congested Development: A Study of Traffic Delays, Access, and Economic
Activity in Metropolitan Los Angeles, available at http://www.its.ucla.edu/wp-
content/uploads/sites/6/2015/11/Haynes_Congested-Development_1-Oct-2015_final.pdf.
9 Osman et al. (Mar. 2016) Not So Fast: A Study of Traffic Delays, Access, and Economic Activity in the
San Francisco Bay Area, available at http://www.its.ucla.edu/wp-
content/uploads/sites/6/2016/08/Taylor-Not-so-Fast-04-01-2016_final.pdf.
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December 2018
Figure 1. Kooshian and Winkelman (2011) VMT and Gross Domestic Product (GDP), 1960-2010.
C. Technical Considerations in Assessing Vehicle Miles Traveled
Many practitioners are familiar with accounting for VMT in connection with long-range planning, or as
part of the CEQA analysis of a project’s greenhouse gas emissions or energy impacts. This document
provides technical information on how to assess VMT as part of a transportation impacts analysis under
CEQA. Appendix 1 provides a description of which VMT to count and options on how to count it.
Appendix 2 provides information on induced travel resulting from roadway capacity projects, including
the mechanisms giving rise to induced travel, the research quantifying it, and information on additional
approaches for assessing it.
1. Recommendations Regarding Methodology
Proposed 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].) This section provides suggestions to lead agencies regarding methodologies to
analyze VMT associated with a project.
Vehicle Types. Proposed Section 15064.3, subdivision (a), states, “For the purposes of this section,
‘vehicle miles traveled’ refers to the amount and distance of automobile travel attributable to a
project.” Here, the term “automobile” refers to on-road passenger vehicles, specifically cars and light
trucks. Heavy-duty truck VMT could be included for modeling convenience and ease of calculation (for
example, where models or data provide combined auto and heavy truck VMT). For an apples-to-apples
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comparison, vehicle types considered should be consistent across project assessment, significance
thresholds, and mitigation.
Residential and Office Projects. Tour- and trip-based approaches10 offer the best methods for assessing
VMT from residential/office projects and for comparing those assessments to VMT thresholds. These
approaches also offer the most straightforward methods for assessing VMT reductions from mitigation
measures for residential/office projects. When available, tour-based assessment is ideal because it
captures travel behavior more comprehensively. But where tour-based tools or data are not available
for all components of an analysis, a trip-based assessment of VMT serves as a reasonable proxy.
Models and methodologies used to calculate thresholds, estimate project VMT, and estimate VMT
reduction due to mitigation should be comparable. For example:
• A tour-based assessment of project VMT should be compared to a tour-based threshold, or a
trip-based assessment to a trip-based VMT threshold.
• Where a travel demand model is used to determine thresholds, the same model should also be
used to provide trip lengths as part of assessing project VMT.
• Where only trip-based estimates of VMT reduction from mitigation are available, a trip-based
threshold should be used, and project VMT should be assessed in a trip-based manner.
When a trip-based method is used to analyze a residential project, the focus can be on home-based
trips. Similarly, when a trip-based method is used to analyze an office project, the focus can be on
home-based work trips.
When tour-based models are used to analyze an office project, either employee work tour VMT or VMT
from all employee tours may be attributed to the project. This is because workplace location influences
overall travel. For consistency, the significance threshold should be based on the same metric: either
employee work tour VMT or VMT from all employee tours.
For office projects that feature a customer component, such as a government office that serves the
public, a lead agency can analyze the customer VMT component of the project using the methodology
for retail development (see below).
Retail Projects. Generally, lead agencies should analyze the effects of a retail project by assessing the
change in total VMT11 because retail projects typically re-route travel from other retail destinations. A
retail project might lead to increases or decreases in VMT, depending on previously existing retail travel
patterns.
10 See Appendix 1, Considerations About Which VMT to Count, for a description of these approaches.
11 See Appendix 1, Considerations About Which VMT to Count, “Assessing Change in Total VMT” section,
for a description of this approach.
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December 2018
Considerations for All Projects. 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.
Combining land uses for VMT analysis is not recommended. Different land uses generate different
amounts of VMT, so the outcome of such an analysis could depend more on the mix of uses than on
their travel efficiency. As a result, it could be difficult or impossible for a lead agency to connect a
significance threshold with an environmental policy objective (such as a target set by law), inhibiting the
CEQA imperative of identifying a project’s significant impacts and providing mitigation where feasible.
Combining land uses for a VMT analysis could streamline certain mixes of uses in a manner disconnected
from policy objectives or environmental outcomes. Instead, OPR recommends analyzing each use
separately, or simply focusing analysis on the dominant use, and comparing each result to the
appropriate threshold. Recommendations for methods of analysis and thresholds are provided below.
In the analysis of each use, a mixed-use project should take credit for internal capture.
Any project that includes in its geographic bounds a portion of an existing or planned Transit Priority
Area (i.e., the project is within a ½ mile of an existing or planned major transit stop or an existing stop
along a high quality transit corridor) may employ VMT as its primary metric of transportation impact for
the entire project. (See Pub. Resources Code, § 21099, subds. (a)(7), (b)(1).)
Cumulative Impacts. A project’s cumulative impacts are based on an assessment of whether the
“incremental effects of an individual project are considerable when viewed in connection with the
effects of past projects, the effects of other current projects, and the effects of probable future
projects.” (Pub. Resources Code, § 21083, subd. (b)(2); see CEQA Guidelines, § 15064, subd. (h)(1).)
When using an absolute VMT metric, i.e., total VMT (as recommended below for retail and
transportation projects), analyzing the combined impacts for a cumulative impacts analysis may be
appropriate. However, metrics such as VMT per capita or VMT per employee, i.e., metrics framed in
terms of efficiency (as recommended below for use on residential and office projects), cannot be
summed because they employ a denominator. A project that falls below an efficiency-based threshold
that is aligned with long-term environmental goals and relevant plans would have no cumulative impact
distinct from the project impact. Accordingly, a finding of a less-than-significant project impact would
imply a less than significant cumulative impact, and vice versa. This is similar to the analysis typically
conducted for greenhouse gas emissions, air quality impacts, and impacts that utilize plan compliance as
a threshold of significance. (See Center for Biological Diversity v. Department of Fish & Wildlife (2015) 62
Cal.4th 204, 219, 223; CEQA Guidelines, § 15064, subd. (h)(3).)
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D. General Principles to Guide Consideration of VMT
SB 743 directs OPR to establish specific “criteria for determining the significance of transportation
impacts of projects[.]” (Pub. Resources Code, § 21099, subd. (b)(1).) In establishing this criterion, OPR
was guided by the general principles contained within CEQA, the CEQA Guidelines, and applicable case
law.
To assist in the determination of significance, many lead agencies rely on “thresholds of significance.”
The CEQA Guidelines define a “threshold of significance” to mean “an identifiable quantitative,
qualitative12 or performance level of a particular environmental effect, non-compliance 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.” (CEQA Guidelines, §
15064.7, subd. (a) (emphasis added).) Lead agencies have discretion to develop and adopt their own, or
rely on thresholds recommended by other agencies, “provided the decision of the lead agency to adopt
such thresholds is supported by substantial evidence.” (Id. at subd. (c); Save Cuyama Valley v. County of
Santa Barbara (2013) 213 Cal.App.4th 1059, 1068.) Substantial evidence means “enough relevant
information and reasonable inferences from this information that a fair argument can be made to
support a conclusion, even though other conclusions might also be reached.” (Id. at § 15384 (emphasis
added); Protect the Historic Amador Waterways v. Amador Water Agency (2004) 116 Cal.App.4th 1099,
1108-1109.)
Additionally, the analysis leading to the determination of significance need not be perfect. The CEQA
Guidelines describe the standard for adequacy of environmental analyses:
An EIR should be prepared with a sufficient degree of analysis to provide decision makers
with information which enables them to make a decision which intelligently takes
account of environmental consequences. An evaluation of the environmental effects of
a proposed project need not be exhaustive, but the sufficiency of an EIR is to be reviewed
in the light of what is reasonably feasible. Disagreement among experts does not make
an EIR inadequate, but the EIR should summarize the main points of disagreement among
the experts. The courts have looked not for perfection but for adequacy, completeness,
and a good faith effort at full disclosure.
(CEQA Guidelines, § 15151 (emphasis added).)
These general principles guide OPR’s recommendations regarding thresholds of significance for VMT set
forth below.
12 Generally, qualitative analyses should only be conducted when methods do not exist for undertaking a
quantitative analysis.
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December 2018
E.Recommendations Regarding Significance Thresholds
As noted above, lead agencies have the discretion to set or apply their own thresholds of significance.
(Center for Biological Diversity v. California Dept. of Fish & Wildlife (2015) 62 Cal.4th 204, 218-223 [lead
agency had discretion to use compliance with AB 32’s emissions goals as a significance threshold]; Save
Cuyama Valley v. County of Santa Barbara (2013) 213 Cal.App.4th at p. 1068.) However, Section 21099
of the Public Resources Code states that the criteria for determining the significance of transportation
impacts must promote: (1) reduction of greenhouse gas emissions; (2) development of multimodal
transportation networks; and (3) a diversity of land uses. It further directed OPR to prepare and develop
criteria for determining significance. (Pub. Resources Code, § 21099, subd. (b)(1).) This section provides
OPR’s suggested thresholds, as well as considerations for lead agencies that choose to adopt their own
thresholds.
The VMT metric can support the three statutory goals: “the reduction of greenhouse gas emissions, the
development of multimodal transportation networks, and a diversity of land uses.” (Pub. Resources
Code, § 21099, subd. (b)(1), emphasis added.) However, in order for it to promote and support all three,
lead agencies should select a significance threshold that aligns with state law on all three. State law
concerning the development of multimodal transportation networks and diversity of land uses requires
planning for and prioritizing increases in complete streets and infill development, but does not mandate
a particular depth of implementation that could translate into a particular threshold of significance.
Meanwhile, the State has clear quantitative targets for GHG emissions reduction set forth in law and
based on scientific consensus, and the depth of VMT reduction needed to achieve those targets has
been quantified. Tying VMT thresholds to GHG reduction also supports the two other statutory goals.
Therefore, to ensure adequate analysis of transportation impacts, OPR recommends using quantitative
VMT thresholds linked to GHG reduction targets when methods exist to do so.
Various legislative mandates and state policies establish quantitative greenhouse gas emissions
reduction targets. For example:
•Assembly Bill 32 (2006) requires statewide GHG emissions reductions to 1990 levels by 2020 and
continued reductions beyond 2020.
•Senate Bill 32 (2016) requires at least a 40 percent reduction in GHG emissions from 1990 levels
by 2030.
•Pursuant to Senate Bill 375 (2008), the California Air Resources Board GHG emissions reduction
targets for metropolitan planning organizations (MPOs) to achieve based on land use patterns
and transportation systems specified in Regional Transportation Plans and Sustainable
Community Strategies (RTP/SCS). Current targets for the State’s largest MPOs call for a 19
percent reduction in GHG emissions from cars and light trucks from 2005 emissions levels by
2035.
•Executive Order B-30-15 (2015) sets a GHG emissions reduction target of 40 percent below 1990
levels by 2030.
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December 2018
• Executive Order S-3-05 (2005) sets a GHG emissions reduction target of 80 percent below 1990
levels by 2050.
• Executive Order B-16-12 (2012) specifies a GHG emissions reduction target of 80 percent below
1990 levels by 2050 specifically for transportation.
• Executive Order B-55-18 (2018) established an additional statewide goal of achieving carbon
neutrality as soon as possible, but no later than 2045, and maintaining net negative emissions
thereafter. It states, “The California Air Resources Board shall work with relevant state agencies
to develop a framework for implementation and accounting that tracks progress toward this
goal.”
• Senate Bill 391 requires the California Transportation Plan to support 80 percent reduction in
GHGs below 1990 levels by 2050.
• The California Air Resources Board Mobile Source Strategy (2016) describes California’s strategy
for containing air pollutant emissions from vehicles, and quantifies VMT growth compatible with
achieving state targets.
• The California Air Resources Board’s 2017 Climate Change Scoping Plan Update: The Strategy for
Achieving California’s 2030 Greenhouse Gas Target describes California’s strategy for containing
GHG emissions from vehicles, and quantifies VMT growth compatible with achieving state
targets.
Considering these various targets, the California Supreme Court observed:
Meeting our statewide reduction goals does not preclude all new development. Rather,
the Scoping Plan … assumes continued growth and depends on increased efficiency and
conservation in land use and transportation from all Californians.
(Center for Biological Diversity v. California Dept. of Fish & Wildlife, supra, 62 Cal.4th at p. 220.) Indeed,
the Court noted that when a lead agency uses consistency with climate goals as a way to determine
significance, particularly for long-term projects, the lead agency must consider the project’s effect on
meeting long-term reduction goals. (Ibid.) And more recently, the Supreme Court stated that “CEQA
requires public agencies . . . to ensure that such analysis stay in step with evolving scientific knowledge
and state regulatory schemes.” (Cleveland National Forest Foundation v. San Diego Assn. of
Governments (2017) 3 Cal.5th 497, 504.)
Meeting the targets described above will require substantial reductions in existing VMT per capita to
curb GHG emissions and other pollutants. But targets for overall GHG emissions reduction do not
translate directly into VMT thresholds for individual projects for many reasons, including:
• Some, but not all, of the emissions reductions needed to achieve those targets could be
accomplished by other measures, including increased vehicle efficiency and decreased fuel
carbon content. The CARB’s First Update to the Climate Change Scoping Plan explains:
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December 2018
“Achieving California’s long-term criteria pollutant and GHG emissions goals will require four
strategies to be employed: (1) improve vehicle efficiency and develop zero emission
technologies, (2) reduce the carbon content of fuels and provide market support to get these
lower-carbon fuels into the marketplace, (3) plan and build communities to reduce vehicular
GHG emissions and provide more transportation options, and (4) improve the efficiency and
throughput of existing transportation systems.”13 CARB’s 2018 Progress Report on California’s
Sustainable Communities and Climate Protection Act states on page 28 that “California cannot
meet its climate goals without curbing growth in single-occupancy vehicle activity.” In other
words, vehicle efficiency and better fuels are necessary, but insufficient, to address the GHG
emissions from the transportation system. Land use patterns and transportation options also
will need to change to support reductions in vehicle travel/VMT.
• New land use projects alone will not sufficiently reduce per-capita VMT to achieve those targets,
nor are they expected to be the sole source of VMT reduction.
• Interactions between land use projects, and also between land use and transportation projects,
existing and future, together affect VMT.
• Because location within the region is the most important determinant of VMT, in some cases,
streamlining CEQA review of projects in travel efficient locations may be the most effective
means of reducing VMT.
• When assessing climate impacts of some types of land use projects, use of an efficiency metric
(e.g., per capita, per employee) may provide a better measure of impact than an absolute
numeric threshold. (Center for Biological Diversity, supra.)
Public Resources Code section 21099 directs OPR to propose criteria for determining the significance of
transportation impacts. In this Technical Advisory, OPR provides its recommendations to assist lead
agencies in selecting a significance threshold that may be appropriate for their particular projects. While
OPR’s Technical Advisory is not binding on public agencies, CEQA allows lead agencies to “consider
thresholds of significance . . . recommended by other public agencies, provided the decision to adopt
those thresholds is supported by substantial evidence.” (CEQA Guidelines, § 15064.7, subd. (c).) Based
on OPR’s extensive review of the applicable research, and in light of an assessment by the California Air
Resources Board quantifying the need for VMT reduction in order to meet the State’s long-term climate
goals, OPR recommends that a per capita or per employee VMT that is fifteen percent below that of
existing development may be a reasonable threshold.
Fifteen percent reductions in VMT are achievable at the project level in a variety of place types.14
Moreover, a fifteen percent reduction is consistent with SB 743’s direction to OPR to select a threshold
that will help the State achieve its climate goals. As described above, section 21099 states that the
13 California Air Resources Board (May 2014) First Update to the Climate Change Scoping Plan, p. 46
(emphasis added).
14 CAPCOA (2010) Quantifying Greenhouse Gas Mitigation Measures, p. 55, available at
http://www.capcoa.org/wp-content/uploads/2010/11/CAPCOA-Quantification-Report-9-14-Final.pdf.
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criteria for determining significance must “promote the reduction in greenhouse gas emissions.” In its
document California Air Resources Board 2017 Scoping Plan-Identified VMT Reductions and Relationship
to State Climate Goals15, CARB assesses VMT reduction per capita consistent with its evidence-based
modeling scenario that would achieve State climate goals of 40 percent GHG emissions reduction from
1990 levels by 2030 and 80 percent GHG emissions reduction levels from 1990 by 2050. Applying
California Department of Finance population forecasts, CARB finds per-capita light-duty vehicle travel
would need to be approximately 16.8 percent lower than existing, and overall per-capita vehicle travel
would need to be approximately 14.3 percent lower than existing levels under that scenario. Below
these levels, a project could be considered low VMT and would, on that metric, be consistent with 2017
Scoping Plan Update assumptions that achieve climate state climate goals.
CARB finds per capita vehicle travel would need to be kept below what today’s policies and plans would
achieve.
CARB’s assessment is based on data in the 2017 Scoping Plan Update and 2016 Mobile Source Strategy.
In those documents, CARB previously examined the relationship between VMT and the state’s GHG
emissions reduction targets. The Scoping Plan finds:
“While the State can do more to accelerate and incentivize these local decisions, local actions
that reduce VMT are also necessary to meet transportation sector-specific goals and achieve the
2030 target under SB 32. Through developing the Scoping Plan, CARB staff is more convinced
than ever that, in addition to achieving GHG reductions from cleaner fuels and vehicles,
California must also reduce VMT. Stronger SB 375 GHG reduction targets will enable the State to
make significant progress toward needed reductions, but alone will not provide the VMT growth
reductions needed; there is a gap between what SB 375 can provide and what is needed to meet
the State’s 2030 and 2050 goals.”16
Note that, at present, consistency with RTP/SCSs does not necessarily lead to a less-than-significant VMT
impact.17 As the Final 2017 Scoping Plan Update states,
VMT reductions are necessary to achieve the 2030 target and must be part of any strategy
evaluated in this Plan. Stronger SB 375 GHG reduction targets will enable the State to make
significant progress toward this goal, but alone will not provide all of the VMT growth reductions
that will be needed. There is a gap between what SB 375 can provide and what is needed to
meet the State’s 2030 and 2050 goals.”18
15 California Air Resources Board (Jan. 2019) California Air Resources Board 2017 Scoping Plan-Identified
VMT Reductions and Relationship to State Climate Goals, available at
https://ww2.arb.ca.gov/resources/documents/carb-2017-scoping-plan-identified-vmt-reductions-and-
relationship-state-climate.
16 California Air Resources Board (Nov. 2017) California’s 2017 Climate Change Scoping Plan, p. 101.
17 California Air Resources Board (Feb. 2018) Updated Final Staff Report: Proposed Update to the SB 375
Greenhouse Gas Emission Reduction Targets, Figure 3, p. 35, available at
https://www.arb.ca.gov/cc/sb375/sb375_target_update_final_staff_report_feb2018.pdf.
18 California Air Resources Board (Nov. 2017) California’s 2017 Climate Change Scoping Plan, p. 75.
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Also, in order to capture the full effects of induced travel resulting from roadway capacity projects, an
RTP/SCS would need to include an assessment of land use effects of those projects, and the effects of
those land uses on VMT. (See section titled “Estimating VMT Impacts from Transportation Projects”
below.) RTP/SCSs typically model VMT using a collaboratively-developed land use “vision” for the
region’s land use, rather than studying the effects on land use of the proposed transportation
investments.
In summary, achieving 15 percent lower per capita (residential) or per employee (office) VMT than
existing development is both generally achievable and is supported by evidence that connects this level
of reduction to the State’s emissions goals.
1. Screening Thresholds for Land Use Projects
Many agencies use “screening thresholds” to quickly identify when a project should be expected to
cause a less-than-significant impact without conducting a detailed study. (See e.g., CEQA Guidelines, §§
15063(c)(3)(C), 15128, and Appendix G.) As explained below, this technical advisory suggests that lead
agencies may screen out VMT impacts using project size, maps, transit availability, and provision of
affordable housing.
Screening Threshold for Small Projects
Many local agencies have developed screening thresholds to indicate when detailed analysis is needed.
Absent substantial evidence indicating that a project would generate a potentially significant level of
VMT, or inconsistency with a Sustainable Communities Strategy (SCS) or general plan, projects that
generate or attract fewer than 110 trips per day19 generally may be assumed to cause a less-than-
significant transportation impact.
Map-Based Screening for Residential and Office Projects
Residential and office projects that locate in areas with low VMT, and that incorporate similar features
(i.e., density, mix of uses, transit accessibility), will tend to exhibit similarly low VMT. Maps created with
VMT data, for example from a travel survey or a travel demand model, can illustrate areas that are
19 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, subd. (e)(2).) Typical project types for which trip generation increases
relatively linearly with building footprint (i.e., general office building, single tenant office building, office
park, and 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.
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December 2018
currently below threshold VMT (see recommendations below). Because new development in such
locations would likely result in a similar level of VMT, such maps can be used to screen out residential
and office projects from needing to prepare a detailed VMT analysis.
Figure 2. Example map of household VMT that could be used to
delineate areas eligible to receive streamlining for VMT analysis.
(Source: City of San José, Department of Transportation, draft output of
City Transportation Model.)
Presumption of Less Than Significant Impact Near Transit Stations
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 stop20 or an existing stop
20 Pub. Resources Code, § 21064.3 (“‘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.”).
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along a high quality transit corridor21 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. For example, the presumption might not be appropriate if
the project:
● Has a Floor Area Ratio (FAR) of less than 0.75
● Includes more parking for use by residents, customers, or employees of the project than
required by the jurisdiction (if the jurisdiction requires the project to supply parking)
● Is inconsistent with the applicable Sustainable Communities Strategy (as determined by the lead
agency, with input from the Metropolitan Planning Organization)
● Replaces affordable residential units with a smaller number of moderate- or high-income
residential units
A project or plan near transit which replaces affordable residential units22 with a smaller number of
moderate- or high-income residential units may increase overall VMT because the increase in VMT of
displaced residents could overwhelm the improvements in travel efficiency enjoyed by new residents.23
If any of these exceptions to the presumption might apply, the lead agency should conduct a detailed
VMT analysis to determine whether the project would exceed VMT thresholds (see below).
Presumption of Less Than Significant Impact for Affordable Residential Development
Adding affordable housing to infill locations generally improves jobs-housing match, in turn shortening
commutes and reducing VMT.24,25 Further, “… low-wage workers in particular would be more likely to
choose a residential location close to their workplace, if one is available.”26 In areas where existing jobs-
housing match is closer to optimal, low income housing nevertheless generates less VMT than market-
21 Pub. Resources Code, § 21155 (“For purposes of this section, a high-quality transit corridor means a
corridor with fixed route bus service with service intervals no longer than 15 minutes during peak
commute hours.”).
22 Including naturally-occurring affordable residential units.
23 Chapple et al. (2017) Developing a New Methodology for Analyzing Potential Displacement, Chapter 4,
pp. 159-160, available at https://www.arb.ca.gov/research/apr/past/13-310.pdf.
24 Karner and Benner (2016) The convergence of social equity and environmental sustainability: Jobs-
housing fit and commute distance (“[P]olicies that advance a more equitable distribution of jobs and
housing by linking the affordability of locally available housing with local wage levels are likely to be
associated with reduced commuting distances”).
25 Karner and Benner (2015) Low-wage jobs-housing fit: identifying locations of affordable housing
shortages.
26 Karner and Benner (2015) Low-wage jobs-housing fit: identifying locations of affordable housing
shortages.
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rate housing.27,28 Therefore, a project consisting of a high percentage of affordable housing may be a
basis for the lead agency to find a less-than-significant impact on VMT. Evidence supports a
presumption of less than significant impact for a 100 percent affordable residential development (or the
residential component of a mixed-use development) in infill locations. Lead agencies may develop their
own presumption of less than significant impact for residential projects (or residential portions of mixed
use projects) containing a particular amount of affordable housing, based on local circumstances and
evidence. Furthermore, a project which includes any affordable residential units may factor the effect
of the affordability on VMT into the assessment of VMT generated by those units.
2.Recommended Numeric Thresholds for Residential, Office, and Retail
Projects
Recommended threshold for residential projects: A proposed project exceeding a level of 15
percent below existing VMT per capita may indicate a significant transportation impact. Existing
VMT per capita may be measured as regional VMT per capita or as city VMT per capita. Proposed
development referencing a threshold based on city VMT per capita (rather than regional VMT per
capita) should not cumulatively exceed the number of units specified in the SCS for that city, and
should be consistent with the SCS.
Residential development that would generate vehicle travel that is 15 or more percent below the
existing residential VMT per capita, measured against the region or city, may indicate a less-than-
significant transportation impact. In MPO areas, development measured against city VMT per capita
(rather than regional VMT per capita) should not cumulatively exceed the population or number of units
specified in the SCS for that city because greater-than-planned amounts of development in areas above
the region-based threshold would undermine the VMT containment needed to achieve regional targets
under SB 375.
For residential projects in unincorporated county areas, the local agency can compare a residential
project’s VMT to (1) the region’s VMT per capita, or (2) the aggregate population-weighted VMT per
capita of all cities in the region. In MPO areas, development in unincorporated areas measured against
aggregate city VMT per capita (rather than regional VMT per capita) should not cumulatively exceed the
population or number of units specified in the SCS for that city because greater-than-planned amounts
of development in areas above the regional threshold would undermine achievement of regional targets
under SB 375.
27 Chapple et al. (2017) Developing a New Methodology for Analyzing Potential Displacement, available
at https://www.arb.ca.gov/research/apr/past/13-310.pdf.
28 CAPCOA (2010) Quantifying Greenhouse Gas Mitigation Measures, pp. 176-178, available at
http://www.capcoa.org/wp-content/uploads/2010/11/CAPCOA-Quantification-Report-9-14-Final.pdf.
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These thresholds can be applied to either household (i.e., tour-based) VMT or home-based (i.e., trip-
based) VMT assessments.29 It is critical, however, that the agency be consistent in its VMT measurement
approach throughout the analysis to maintain an “apples-to-apples” comparison. For example, if the
agency uses a home-based VMT for the threshold, it should also be use home-based VMT for calculating
project VMT and VMT reduction due to mitigation measures.
Because new retail development typically redistributes shopping trips rather than creating new trips,30
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.
By adding retail opportunities into the urban fabric and thereby improving retail destination proximity,
local-serving retail development tends to shorten trips and reduce VMT. Thus, lead agencies generally
may presume such development creates a less-than-significant transportation impact. Regional-serving
retail development, on the other hand, which can lead to substitution of longer trips for shorter ones,
may tend to have a significant impact. Where such development decreases VMT, lead agencies should
consider the impact to be less-than-significant.
Many cities and counties define local-serving and regional-serving retail in their zoning codes. Lead
agencies may refer to those local definitions when available, but should also consider any project-
29 See Appendix 1 for a description of these approaches.
30 Lovejoy, et al. (2013) Measuring the impacts of local land-use policies on vehicle miles of travel:
The case of the first big-box store in Davis, California, The Journal of Transport and Land Use.
Recommended threshold for retail projects: A net increase in total VMT may indicate a significant
transportation impact.
Office projects that would generate vehicle travel exceeding 15 percent below existing VMT per
employee for the region may indicate a significant transportation impact. In cases where the region is
substantially larger than the geography over which most workers would be expected to live, it might be
appropriate to refer to a smaller geography, such as the county, that includes the area over which nearly
all workers would be expected to live.
Office VMT screening maps can be developed using tour-based data, considering either total employee
VMT or employee work tour VMT. Similarly, tour-based analysis of office project VMT could consider
either total employee VMT or employee work tour VMT. Where tour-based information is unavailable
for threshold determination, project assessment, or assessment of mitigation, home-based work trip
VMT should be used throughout all steps of the analysis to maintain an “apples-to-apples” comparison.
Recommended threshold for office projects: A proposed project exceeding a level of 15 percent
below existing regional VMT per employee may indicate a significant transportation impact.
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specific information, such as market studies or economic impacts analyses that might bear on
customers’ travel behavior. Because lead agencies will best understand their own communities and the
likely travel behaviors of future project users, they are likely in the best position to decide when a
project will likely be local-serving. Generally, however, retail development including stores larger than
50,000 square feet might be considered regional-serving, and so lead agencies should undertake an
analysis to determine whether the project might increase or decrease VMT.
Mixed-Use Projects
Lead agencies can evaluate each component of a mixed-use project independently and apply the
significance threshold for each project type included (e.g., residential and retail). Alternatively, a lead
agency may consider only the project’s dominant use. In the analysis of each use, a project should take
credit for internal capture. Combining different land uses and applying one threshold to those land uses
may result in an inaccurate impact assessment.
Other Project Types
Of 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. In developing thresholds for other project
types, or thresholds different from those recommended here, lead agencies should consider the
purposes described in section 21099 of the Public Resources Code and regulations in the CEQA
Guidelines on the development of thresholds of significance (e.g., CEQA Guidelines, § 15064.7).
Strategies and projects that decrease local VMT but increase total VMT should be avoided. Agencies
should consider whether their actions encourage development in a less travel-efficient location by
limiting development in travel-efficient locations.
Redevelopment Projects
Where 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.
As described above, a project or plan near transit which replaces affordable31 residential units with a
smaller number of moderate- or high-income residential units may increase overall VMT, because
31 Including naturally-occurring affordable residential units.
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displaced residents’ VMT may increase.32 A lead agency should analyze VMT for such a project even if it
otherwise would have been presumed less than significant. The assessment should incorporate an
estimate of the aggregate VMT increase experienced by displaced residents. That additional VMT
should be included in the numerator of the VMT per capita assessed for the project.
If a residential or office project leads to a net increase in VMT, then the project’s VMT per capita
(residential) or per employee (office) should be compared to thresholds recommended above. Per
capita and per employee VMT are efficiency metrics, and, as such, apply only to the existing project
without regard to the VMT generated by the previously existing land use.
If the project leads to a net increase in provision of locally-serving retail, transportation impacts from
the retail portion of the development should be presumed to be less than significant. If the project
consists of regionally-serving retail, and increases overall VMT compared to with existing uses, then the
project would lead to a significant transportation impact.
RTP/SCS Consistency (All Land Use Projects)
Section 15125, subdivision (d), of the CEQA Guidelines provides that lead agencies should analyze
impacts resulting from inconsistencies with regional plans, including regional transportation plans. For
this reason, if a project is inconsistent with the Regional Transportation Plan and Sustainable
Communities Strategy (RTP/SCS), the lead agency should evaluate whether that inconsistency indicates
a significant impact on transportation. For example, a development may be inconsistent with an
RTP/SCS if the development is outside the footprint of development or within an area specified as open
space as shown in the SCS.
3. Recommendations Regarding Land Use Plans
As with projects, agencies should analyze VMT outcomes of land use plans across the full area over
which the plan may substantively affect travel patterns, including beyond the boundary of the plan or
jurisdiction’s geography. And as with projects, VMT should be counted in full rather than split between
origin and destination. (Emissions inventories have sometimes spit cross-boundary trips in order to sum
to a regional total, but CEQA requires accounting for the full impact without truncation or discounting).
Analysis of specific plans may employ the same thresholds described above for projects. A general plan,
area plan, or community plan may have a significant impact on transportation if proposed new
residential, office, or retail land uses would in aggregate exceed the respective thresholds
recommended above. Where the lead agency tiers from a general plan EIR pursuant to CEQA Guidelines
sections 15152 and 15166, the lead agency generally focuses on the environmental impacts that are
specific to the later project and were not analyzed as significant impacts in the prior EIR. (Pub. Resources
Code, § 21068.5; Guidelines, § 15152, subd. (a).) Thus, in analyzing the later project, the lead agency
32 Chapple et al. (2017) Developing a New Methodology for Analyzing Potential Displacement, Chapter 4,
pp. 159-160, available at https://www.arb.ca.gov/research/apr/past/13-310.pdf.
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would focus on the VMT impacts that were not adequately addressed in the prior EIR. In the tiered
document, the lead agency should continue to apply the thresholds recommended above.
Thresholds for plans in non-MPO areas may be determined on a case-by-case basis.
4. Other Considerations
Rural Projects Outside of MPOs
In rural areas of non-MPO counties (i.e., areas not near established or incorporated cities or towns),
fewer options may be available for reducing VMT, and significance thresholds may be best determined
on a case-by-case basis. Note, however, that clustered small towns and small town main streets may
have substantial VMT benefits compared to isolated rural development, similar to the transit oriented
development described above.
Impacts to Transit
Because criteria for determining the significance of transportation impacts must promote “the
development of multimodal transportation networks” pursuant to Public Resources Code section 21099,
subd. (b)(1), lead agencies should consider project impacts to transit systems and bicycle and pedestrian
networks. For example, a project that blocks access to a transit stop or blocks a transit route itself may
interfere with transit functions. Lead agencies should consult with transit agencies as early as possible in
the development process, particularly for projects that are located within one half mile of transit stops.
When evaluating impacts to multimodal transportation networks, lead agencies generally should not
treat the addition of new transit users as an adverse impact. An infill development may add riders to
transit systems and the additional boarding and alighting may slow transit vehicles, but it also adds
destinations, improving proximity and accessibility. Such development also improves regional vehicle
flow by adding less vehicle travel onto the regional network.
Increased demand throughout a region may, however, cause a cumulative impact by requiring new or
additional transit infrastructure. Such impacts may be adequately addressed through a fee program that
fairly allocates the cost of improvements not just to projects that happen to locate near transit, but
rather across a region to all projects that impose burdens on the entire transportation system, since
transit can broadly improve the function of the transportation system.
F. Considering the Effects of Transportation Projects on Vehicle Travel
Many transportation projects change travel patterns. A transportation project which leads to additional
vehicle travel on the roadway network, commonly referred to as “induced vehicle travel,” would need to
quantify the amount of additional vehicle travel in order to assess air quality impacts, greenhouse gas
emissions impacts, energy impacts, and noise impacts. Transportation projects also are required to
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examine induced growth impacts under CEQA. (See generally, Pub. Resources Code, §§ 21065 [defining
“project” under CEQA as an activity as causing either a direct or reasonably foreseeable indirect physical
change], 21065.3 [defining “project-specific effect” to mean all direct or indirect environmental effects],
21100, subd. (b) [required contents of an EIR].) For any project that increases vehicle travel, explicit
assessment and quantitative reporting of the amount of additional vehicle travel should not be omitted
from the document; such information may be useful and necessary for a full understanding of a project’s
environmental impacts. (See Pub. Resources Code, §§ 21000, 21001, 21001.1, 21002, 21002.1
[discussing the policies of CEQA].) A lead agency that uses the VMT metric to assess the transportation
impacts of a transportation project may simply report that change in VMT as the impact. When the lead
agency uses another metric to analyze the transportation impacts of a roadway project, changes in
amount of vehicle travel added to the roadway network should still be analyzed and reported.33
While CEQA does not require perfection, it is important to make a reasonably accurate estimate of
transportation projects’ effects on vehicle travel in order to make reasonably accurate estimates of GHG
emissions, air quality emissions, energy impacts, and noise impacts. (See, e.g., California Clean Energy
Com. v. City of Woodland (2014) 225 Cal.App.4th 173, 210 [EIR failed to consider project’s
transportation energy impacts]; Ukiah Citizens for Safety First v. City of Ukiah (2016) 248 Cal.App.4th
256, 266.) Appendix 2 describes in detail the causes of induced vehicle travel, the robust empirical
evidence of induced vehicle travel, and how models and research can be used in conjunction to
quantitatively assess induced vehicle travel with reasonable accuracy.
If a project would likely lead to a measurable and substantial increase in vehicle travel, the lead agency
should conduct an analysis assessing the amount of vehicle travel the project will induce. Project types
that would likely lead to a measurable and substantial increase in vehicle travel generally include:
• Addition of through lanes on existing or new highways, including general purpose lanes, HOV
lanes, peak period lanes, auxiliary lanes, or lanes through grade-separated interchanges
Projects that would not likely lead to a substantial or measurable increase in vehicle travel, and
therefore generally should not require an induced travel analysis, include:
• 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
33 See, e.g., California Department of Transportation (2006) Guidance for Preparers of Growth-related,
Indirect Impact Analyses, available at http://www.dot.ca.gov/ser/Growth-
related_IndirectImpactAnalysis/GRI_guidance06May_files/gri_guidance.pdf.
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• 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
• 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
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1. Recommended Significance Threshold for Transportation Projects
As noted in Section 15064.3 of the CEQA Guidelines, lead agencies for roadway capacity projects have
discretion, consistent with CEQA and planning requirements, to choose which metric to use to evaluate
transportation impacts. This section recommends considerations for evaluating impacts using vehicle
miles traveled. Lead agencies have discretion to choose a threshold of significance for transportation
projects as they do for other types of projects. As explained above, Public Resources Code section
21099, subdivision (b)(1), provides that criteria for determining the significance of transportation
impacts must promote the reduction of greenhouse gas emissions, the development of multimodal
transportation networks, and a diversity of land uses. (Id.; see generally, adopted CEQA Guidelines, §
15064.3, subd. (b) [Criteria for Analyzing Transportation Impacts].) With those goals in mind, OPR
prepared and the Agency adopted an appropriate transportation metric.
Whether adopting a threshold of significance, or evaluating transportation impacts on a case-by-case
basis, a lead agency should ensure that the analysis addresses:
• Direct, indirect and cumulative effects of the transportation project (CEQA Guidelines, § 15064,
subds. (d), (h))
• Near-term and long-term effects of the transportation project (CEQA Guidelines, §§ 15063,
subd. (a)(1), 15126.2, subd. (a))
• The transportation project’s consistency with state greenhouse gas reduction goals (Pub.
Resources Code, § 21099)34
• The impact of the transportation project on the development of multimodal transportation
networks (Pub. Resources Code, § 21099)
• The impact of the transportation project on the development of a diversity of land uses (Pub.
Resources Code, § 21099)
The CARB Scoping Plan and the CARB Mobile Source Strategy delineate VMT levels required to achieve
legally mandated GHG emissions reduction targets. A lead agency should develop a project-level
threshold based on those VMT levels, and may apply the following approach:
1. Propose a fair-share allocation of those budgets to their jurisdiction (e.g., by population);
34 The California Air Resources Board has ascertained the limits of VMT growth compatible with
California containing greenhouse gas emissions to levels research shows would allow for climate
stabilization. (See The 2017 Climate Change Scoping Plan: The Strategy for Achieving California’s 2030
Greenhouse Gas Target (p. 78, p. 101); Mobile Source Strategy (p. 37).) CARB’s Updated Final Staff
Report on Proposed Update to the SB 375 Greenhouse Gas Emission Reduction Targets illustrates that
the current Regional Transportation Plans and Sustainable Communities Strategies will fall short of
achieving the necessary on-road transportation-related GHG emissions reductions called for in the 2017
Scoping Plan (Figure 3, p. 35). Accordingly, OPR recommends not basing GHG emissions or
transportation impact analysis for a transportation project solely on consistency with an RTP/SCS.
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2. Determine the amount of VMT growth likely to result from background population growth, and
subtract that from their “budget”;
3. Allocate their jurisdiction’s share between their various VMT-increasing transportation projects,
using whatever criteria the lead agency prefers.
2. Estimating VMT Impacts from Transportation Projects
CEQA requires analysis of a project’s potential growth-inducing impacts. (Pub. Resources Code, § 21100,
subd. (b)(5); CEQA Guidelines, § 15126.2, subd. (d).) Many agencies are familiar with the analysis of
growth inducing impacts associated with water, sewer, and other infrastructure. This technical advisory
addresses growth that may be expected from roadway expansion projects.
Because a roadway expansion project can induce substantial VMT, incorporating quantitative estimates
of induced VMT is critical to calculating both transportation and other impacts of these projects.
Induced travel also has the potential to reduce or eliminate congestion relief benefits. An accurate
estimate of induced travel is needed to accurately weigh costs and benefits of a highway capacity
expansion project.
The effect of a transportation project on vehicle travel should be estimated using the “change in total
VMT” method described in Appendix 1. This means that an assessment of total VMT without the project
and an assessment with the project should be made; the difference between the two is the amount of
VMT attributable to the project. The assessment should cover the full area in which driving patterns are
expected to change. As with other types of projects, the VMT estimation should not be truncated at a
modeling or jurisdictional boundary for convenience of analysis when travel behavior is substantially
affected beyond that boundary.
Transit and Active Transportation Projects
Transit and active transportation projects generally reduce VMT and therefore are presumed to cause a
less-than-significant impact on transportation. This presumption may apply to all passenger rail projects,
bus and bus rapid transit projects, and bicycle and pedestrian infrastructure projects. Streamlining
transit and active transportation projects aligns with each of the three statutory goals contained in SB
743 by reducing GHG emissions, increasing multimodal transportation networks, and facilitating mixed
use development.
Roadway Projects
Reducing roadway capacity (for example, by removing or repurposing motor vehicle travel lanes) will
generally reduce VMT and therefore is presumed to cause a less-than-significant impact on
transportation. Generally, no transportation analysis is needed for such projects.
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Building new roadways, adding roadway capacity in congested areas, or adding roadway capacity to
areas where congestion is expected in the future, typically induces additional vehicle travel. For the
types of projects previously indicated as likely to lead to additional vehicle travel, an estimate should be
made of the change in vehicle travel resulting from the project.
For projects that increase roadway capacity, lead agencies can evaluate induced travel quantitatively by
applying the results of existing studies that examine the magnitude of the increase of VMT resulting
from a given increase in lane miles. These studies estimate the percent change in VMT for every percent
change in miles to the roadway system (i.e., “elasticity”).35 Given that lead agencies have discretion in
choosing their methodology, and the studies on induced travel reveal a range of elasticities, lead
agencies may appropriately apply professional judgment in studying the transportation effects of a
particular project. The most recent major study, estimates an elasticity of 1.0, meaning that every
percent change in lane miles results in a one percent increase in VMT.36
To estimate VMT impacts from roadway expansion projects:
1. Determine the total lane-miles over an area that fully captures travel behavior changes
resulting from the project (generally the region, but for projects affecting interregional travel
look at all affected regions).
2. Determine the percent change in total lane miles that will result from the project.
3. Determine the total existing VMT over that same area.
4. Multiply the percent increase in lane miles by the existing VMT, and then multiply that by the
elasticity from the induced travel literature:
[% increase in lane miles] x [existing VMT] x [elasticity] = [VMT resulting from the project]
A National Center for Sustainable Transportation tool can be used to apply this method:
https://ncst.ucdavis.edu/research/tools
This method would not be suitable for rural (non-MPO) locations in the state which are neither
congested nor projected to become congested. It also may not be suitable for a new road that provides
new connectivity across a barrier (e.g., a bridge across a river) if it would be expected to substantially
35 See U.C. Davis, Institute for Transportation Studies (Oct. 2015) Increasing Highway Capacity Unlikely
to Relieve Traffic Congestion; Boarnet and Handy (Sept. 2014) Impact of Highway Capacity and Induced
Travel on Passenger Vehicle Use and Greenhouse Gas Emissions, California Air Resources Board Policy
Brief, available at https://www.arb.ca.gov/cc/sb375/policies/hwycapacity/highway_capacity_brief.pdf.
36 See Duranton and Turner (2011) The Fundamental Law of Road Congestion: Evidence from US cities,
available at http://www.nber.org/papers/w15376.
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shorten existing trips. If it is likely to be substantial, the trips-shortening effect should be examined
explicitly.
The effects of roadway capacity on vehicle travel can also be applied at a programmatic level. For
example, in a regional planning process the lead agency can use that program-level analysis to
streamline later project-level analysis. (See CEQA Guidelines, § 15168.) A program-level analysis of VMT
should include effects of the program on land use patterns, and the VMT that results from those land
use effects. In order for a program-level document to adequately analyze potential induced demand
from a project or program of roadway capacity expansion, lead agencies cannot assume a fixed land use
pattern (i.e., a land use pattern that does not vary in response to the provision of roadway capacity). A
proper analysis should account for land use investment and development pattern changes that react in a
reasonable manner to changes in accessibility created by transportation infrastructure investments
(whether at the project or program level).
Mitigation and Alternatives
Induced VMT has the potential to reduce or eliminate congestion relief benefits, increase VMT, and
increase other environmental impacts that result from vehicle travel.37 If those effects are significant,
the lead agency will need to consider mitigation or alternatives. In the context of increased travel that is
induced by capacity increases, appropriate mitigation and alternatives that a lead agency might consider
include the following:
• Tolling new lanes to encourage carpools and fund transit improvements
• Converting existing general purpose lanes to HOV or HOT lanes
• Implementing or funding off-site travel demand management
• Implementing Intelligent Transportation Systems (ITS) strategies to improve passenger
throughput on existing lanes
Tolling and other management strategies can have the additional benefit of preventing congestion and
maintaining free-flow conditions, conferring substantial benefits to road users as discussed above.
G. Analyzing Other Impacts Related to Transportation
While requiring a change in the methodology of assessing transportation impacts, Public Resources
Code section 21099 notes that this change “does not relieve a public agency of the requirement to
analyze a project’s potentially significant transportation impacts related to air quality, noise, safety, or
any other impact associated with transportation.” OPR expects that lead agencies will continue to
37 See National Center for Sustainable Transportation (Oct. 2015) Increasing Highway Capacity Unlikely
to Relieve Traffic Congestion, available at
http://www.dot.ca.gov/newtech/researchreports/reports/2015/10-12-2015-
NCST_Brief_InducedTravel_CS6_v3.pdf; see Duranton and Turner (2011) The Fundamental Law of Road
Congestion: Evidence from US cities, available at http://www.nber.org/papers/w15376.
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address mobile source emissions in the air quality and noise sections of an environmental document and
the corresponding studies that support the analysis in those sections. Lead agencies should continue to
address environmental impacts of a proposed project pursuant to CEQA’s requirements, using a format
that is appropriate for their particular project.
Because safety concerns result from many different factors, they are best addressed at a programmatic
level (i.e., in a general plan or regional transportation plan) in cooperation with local governments,
metropolitan planning organizations, and, where the state highway system is involved, the California
Department of Transportation. In most cases, such an analysis would not be appropriate on a project-
by-project basis. Increases in traffic volumes at a particular location resulting from a project typically
cannot be estimated with sufficient accuracy or precision to provide useful information for an analysis of
safety concerns. Moreover, an array of factors affect travel demand (e.g., strength of the local economy,
price of gasoline), causing substantial additional uncertainty. Appendix B of OPR’s General Plan
Guidelines summarizes research which could be used to guide a programmatic analysis under CEQA.
Lead agencies should note that automobile congestion or delay does not constitute a significant
environmental impact (Pub. Resources Code, §21099(b)(2)), and safety should not be used as a proxy for
road capacity.
H. VMT Mitigation and Alternatives
When a lead agency identifies a significant impact, it must identify feasible mitigation measures that
could avoid or substantially reduce that impact. (Pub. Resources Code, § 21002.1, subd. (a).)
Additionally, CEQA requires that an environmental impact report identify feasible alternatives that could
avoid or substantially reduce a project’s significant environmental impacts.
Indeed, the California Court of Appeal recently held that a long-term regional transportation plan was
deficient for failing to discuss an alternative which could significantly reduce total vehicle miles traveled.
In Cleveland National Forest Foundation v. San Diego Association of Governments, et al. (2017) 17
Cal.App.5th 413, the court found that omission “inexplicable” given the lead agency’s “acknowledgment
in its Climate Action Strategy that the state’s efforts to reduce greenhouse gas emissions from on-road
transportation will not succeed if the amount of driving, or vehicle miles traveled, is not significantly
reduced.” (Cleveland National Forest Foundation, supra, 17 Cal.App.5th at p. 436.) Additionally, the
court noted that the project alternatives focused primarily on congestion relief even though “the
[regional] transportation plan is a long-term and congestion relief is not necessarily an effective long-
term strategy.” (Id. at p. 437.) The court concluded its discussion of the alternatives analysis by stating:
“Given the acknowledged long-term drawbacks of congestion relief alternatives, there is not substantial
evidence to support the EIR’s exclusion of an alternative focused primarily on significantly reducing
vehicle trips.” (Ibid.)
Several examples of potential mitigation measures and alternatives to reduce VMT are described below.
However, the selection of particular mitigation measures and alternatives are left to the discretion of
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the lead agency, and mitigation measures may vary, depending on the proposed project and significant
impacts, if any. Further, OPR expects that agencies will continue to innovate and find new ways to
reduce vehicular travel.
Potential measures to reduce vehicle miles traveled include, but are not limited to:
• Improve or increase access to transit.
• Increase access to common goods and services, such as groceries, schools, and daycare.
• Incorporate affordable housing into the project.
• Incorporate neighborhood electric vehicle network.
• Orient the project toward transit, bicycle and pedestrian facilities.
• Improve pedestrian or bicycle networks, or transit service.
• Provide traffic calming.
• Provide bicycle parking.
• Limit or eliminate parking supply.
• Unbundle parking costs.
• Provide parking cash-out programs.
• Implement roadway pricing.
• Implement or provide access to a commute reduction program.
• Provide car-sharing, bike sharing, and ride-sharing programs.
• Provide transit passes.
• Shifting single occupancy vehicle trips to carpooling or vanpooling, for example providing ride-
matching services.
• Providing telework options.
• Providing incentives or subsidies that increase the use of modes other than single-occupancy
vehicle.
• Providing on-site amenities at places of work, such as priority parking for carpools and vanpools,
secure bike parking, and showers and locker rooms.
• Providing employee transportation coordinators at employment sites.
• Providing a guaranteed ride home service to users of non-auto modes.
Notably, because VMT is largely a regional impact, regional VMT-reduction programs may be an
appropriate form of mitigation. In lieu fees have been found to be valid mitigation where there is both a
commitment to pay fees and evidence that mitigation will actually occur. (Save Our Peninsula
Committee v. Monterey County Bd. of Supervisors (2001) 87 Cal.App.4th 99, 140-141; Gentry v. City of
Murrieta (1995) 36 Cal.App.4th 1359; Kings County Farm Bureau v. City of Hanford (1990) 221
Cal.App.3d 692, 727–728.) Fee programs are particularly useful to address cumulative impacts. (CEQA
Guidelines, § 15130, subd. (a)(3) [a “project’s incremental contribution is less than cumulatively
considerable if the project is required to implement or fund its fair share of a mitigation measure or
measures designed to alleviate the cumulative impact”].) The mitigation program must undergo CEQA
evaluation, either on the program as a whole, or the in-lieu fees or other mitigation must be evaluated
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on a project-specific basis. (California Native Plant Society v. County of El Dorado (2009) 170 Cal.App.4th
1026.) That CEQA evaluation could be part of a larger program, such as a regional transportation plan,
analyzed in a Program EIR. (CEQA Guidelines, § 15168.)
Examples of project alternatives that may reduce vehicle miles traveled include, but are not limited to:
• Locate the project in an area of the region that already exhibits low VMT.
• Locate the project near transit.
• Increase project density.
• Increase the mix of uses within the project or within the project’s surroundings.
• Increase connectivity and/or intersection density on the project site.
• Deploy management strategies (e.g., pricing, vehicle occupancy requirements) on roadways or
roadway lanes.
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Appendix 1. Considerations About Which VMT to Count
Consistent with the obligation to make a good faith effort to disclose the environmental consequences
of a project, lead agencies have discretion to choose the most appropriate methodology to evaluate
project impacts.38 A lead agency can evaluate a project’s effect on VMT in numerous ways. The purpose
of this document is to provide technical considerations in determining which methodology may be most
useful for various project types.
Background on Estimating Vehicle Miles Traveled
Before discussing specific methodological recommendations, this section provides a brief overview of
modeling and counting VMT, including some key terminology.
Here is an illustrative example of some methods of estimating vehicle miles traveled. Consider the
following hypothetical travel day (all by automobile):
1. Residence to Coffee Shop
2. Coffee Shop to Work
3. Work to Sandwich Shop
4. Sandwich Shop to Work
5. Work to Residence
6. Residence to Store
7. Store to Residence
Trip-based assessment of a project’s effect on travel behavior counts VMT from individual trips to and
from the project. It is the most basic, and traditionally the most common, method of counting VMT. A
trip-based VMT assessment of the residence in the above example would consider segments 1, 5, 6 and
7. For residential projects, the sum of home-based trips is called home-based VMT.
A tour-based assessment counts the entire home-back-to-home tour that includes the project. A tour-
based VMT assessment of the residence in the above example would consider segments 1, 2, 3, 4, and 5
in one tour, and 6 and 7 in a second tour. A tour-based assessment of the workplace would include
segments 1, 2, 3, 4, and 5. Together, all tours comprise household VMT.
38 The California Supreme Court has explained that when an agency has prepared an environmental
impact report:
[T]he issue is not whether the [lead agency’s] studies are irrefutable or whether they
could have been better. The relevant issue is only whether the studies are sufficiently
credible to be considered as part of the total evidence that supports the [lead agency’s]
finding[.]
(Laurel Heights Improvement Assn. v. Regents of the University of California (1988) 47 Cal.3d 376, 409;
see also Eureka Citizens for Responsible Gov’t v. City of Eureka (2007) 147 Cal.App.4th 357, 372.)
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Both trip- and tour-based assessments can be used as measures of transportation efficiency, using
denominators such as per capita, per employee, or per person-trip.
Trip- and Tour-based Assessment of VMT
As illustrated above, a tour-based assessment of VMT is a more complete characterization of a project’s
effect on VMT. In many cases, a project affects travel behavior beyond the first destination. The location
and characteristics of the home and workplace will often be the main drivers of VMT. For example, a
residential or office development located near high quality transit will likely lead to some commute trips
utilizing transit, affecting mode choice on the rest of the tour.
Characteristics of an office project can also affect an employee’s VMT beyond the work tour. For
example, a workplace located at the urban periphery, far from transit, can require an employee to own
a car, which in turn affects the entirety of an employee’s travel behavior and VMT. For this reason, when
estimating the effect of an office development on VMT, it may be appropriate to consider total
employee VMT if data and tools, such as tour-based models, are available. This is consistent with CEQA’s
requirement to evaluate both direct and indirect effects of a project. (See CEQA Guidelines, § 15064,
subd. (d)(2).)
Assessing Change in Total VMT
A third method, estimating the change in total VMT with and without the project, can evaluate whether
a project is likely to divert existing trips, and what the effect of those diversions will be on total VMT.
This method answers the question, “What is the net effect of the project on area VMT?” As an
illustration, assessing the total change in VMT for a grocery store built in a food desert that diverts trips
from more distant stores could reveal a net VMT reduction. The analysis should address the full area
over which the project affects travel behavior, even if the effect on travel behavior crosses political
boundaries.
Using Models to Estimate VMT
Travel demand models, sketch models, spreadsheet models, research, and data can all be used to
calculate and estimate VMT (see Appendix F of the preliminary discussion draft). 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.
Models can work together. For example, agencies can use travel demand models or survey data to
estimate existing trip lengths and input those into sketch models such as CalEEMod to achieve more
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accurate results. Whenever possible, agencies should input localized trip lengths into a sketch model to
tailor the analysis to the project location. However, in doing so, agencies should be careful to avoid
double counting if the sketch model includes other inputs or toggles that are proxies for trip length (e.g.,
distance to city center). Generally, if an agency changes any sketch model defaults, it should record and
report those changes for transparency of analysis. Again, trip length data should come from the same
source as data used to calculate thresholds to be sure of an “apples-to-apples” comparison.
Additional background information regarding travel demand models is available in the California
Transportation Commission’s “2010 Regional Transportation Plan Guidelines,” beginning at page 35.
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Appendix 2. Induced Travel: Mechanisms, Research, and Additional Assessment Approaches
Induced travel occurs where roadway capacity is expanded in an area of present or projected future
congestion. The effect typically manifests over several years. Lower travel times make the modified
facility more attractive to travelers, resulting in the following trip-making changes:
● Longer trips. The ability to travel a long distance in a shorter time increases the attractiveness of
destinations that are farther away, increasing trip length and vehicle travel.
● Changes in mode choice. When transportation investments are devoted to reducing automobile
travel time, travelers tend to shift toward automobile use from other modes, which increases
vehicle travel.
● Route changes. Faster travel times on a route attract more drivers to that route from other
routes, which can increase or decrease vehicle travel depending on whether it shortens or
lengthens trips.
● Newly generated trips. Increasing travel speeds can induce additional trips, which increases
vehicle travel. For example, an individual who previously telecommuted or purchased goods on
the internet might choose to accomplish those tasks via automobile trips as a result of increased
speeds.
● Land Use Changes. Faster travel times along a corridor lead to land development farther along
that corridor; that new development generates and attracts longer trips, which increases vehicle
travel. Over several years, this induced growth component of induced vehicle travel can be
substantial, making it critical to include in analyses.
Each of these effects has implications for the total amount of vehicle travel. These effects operate over
different time scales. For example, changes in mode choice might occur immediately, while land use
changes typically take a few years or longer. CEQA requires lead agencies to analyze both short-term
and long-term effects.
Evidence of Induced Vehicle Travel. A large number of peer reviewed studies39 have demonstrated a
causal link between highway capacity increases and VMT increases. Many provide quantitative
estimates of the magnitude of the induced VMT phenomenon. Collectively, they provide high quality
evidence of the existence and magnitude of the induced travel effect.
39 See, e.g., Boarnet and Handy (Sept. 2014) Impact of Highway Capacity and Induced Travel on
Passenger Vehicle Use and Greenhouse Gas Emissions, California Air Resources Board Policy Brief,
available at https://www.arb.ca.gov/cc/sb375/policies/hwycapacity/highway_capacity_brief.pdf;
National Center for Sustainable Transportation (Oct. 2015) Increasing Highway Capacity Unlikely to
Relieve Traffic Congestion, available at
http://www.dot.ca.gov/research/researchreports/reports/2015/10-12-2015-
NCST_Brief_InducedTravel_CS6_v3.pdf.
33 | Page
December 2018
Most of these studies express the amount of induced vehicle travel as an “elasticity,” which is a
multiplier that describes the additional vehicle travel resulting from an additional lane mile of roadway
capacity added. For example, an elasticity of 0.6 would signify an 0.6 percent increase in vehicle travel
for every 1.0 percent increase in lane miles. Many of these studies distinguish “short run elasticity”
(increase in vehicle travel in the first few years) from “long run elasticity” (increase in vehicle travel
beyond the first few years). Long run elasticity is larger than short run elasticity, because as time passes,
more of the components of induced vehicle travel materialize. Generally, short run elasticity can be
thought of as excluding the effects of land use change, while long run elasticity includes them. Most
studies find a long run elasticity between 0.6 and just over 1.0,40 meaning that every increase in lanes
miles of one percent leads to an increase in vehicle travel of 0.6 to 1.0 percent. The most recent major
study finds the elasticity of vehicle travel by lanes miles added to be 1.03; in other words, each percent
increase in lane miles results in a 1.03 percent increase in vehicle travel.41 (An elasticity greater than 1.0
can occur because new lanes induce vehicle travel that spills beyond the project location.) In CEQA
analysis, the long-run elasticity should be used, as it captures the full effect of the project rather than
just the early-stage effect.
Quantifying Induced Vehicle Travel Using Models. Lead agencies can generally achieve the most accurate
assessment of induced vehicle travel resulting from roadway capacity increasing projects by applying
elasticities from the academic literature, because those estimates include vehicle travel resulting from
induced land use. If a lead agency chooses to use a travel demand model, additional analysis would be
needed to account for induced land use. This section describes some approaches to undertaking that
additional analysis.
Proper use of a travel demand model can capture the following components of induced VMT:
• Trip length (generally increases VMT)
• Mode shift (generally shifts from other modes toward automobile use, increasing VMT)
• Route changes (can act to increase or decrease VMT)
• Newly generated trips (generally increases VMT)
o Note that not all travel demand models have sensitivity to this factor, so an off-model
estimate may be necessary if this effect could be substantial.
However, estimating long-run induced VMT also requires an estimate of the project’s effects on land
use. This component of the analysis is important because it has the potential to be a large component of
40 See Boarnet and Handy (Sept. 2014) Impact of Highway Capacity and Induced Travel on Passenger
Vehicle Use and Greenhouse Gas Emissions, California Air Resources Board Policy Brief, p. 2, available at
https://www.arb.ca.gov/cc/sb375/policies/hwycapacity/highway_capacity_brief.pdf.
41 Duranton and Turner (2011) The Fundamental Law of Road Congestion: Evidence from US cities,
available at http://www.nber.org/papers/w15376.
34 | Page
December 2018
the overall induced travel effect. Options for estimating and incorporating the VMT effects that are
caused by the subsequent land use changes include:
1. Employ an expert panel. An expert panel could assess changes to land use development that
would likely result from the project. This assessment could then be analyzed by the travel
demand model to assess effects on vehicle travel. Induced vehicle travel assessed via this
approach should be verified using elasticities found in the academic literature.
2. Adjust model results to align with the empirical research. If the travel demand model analysis is
performed without incorporating projected land use changes resulting from the project, the
assessed vehicle travel should be adjusted upward to account for those land use changes. The
assessed VMT after adjustment should fall within the range found in the academic literature.
3. Employ a land use model, running it iteratively with a travel demand model. A land use model
can be used to estimate the land use effects of a roadway capacity increase, and the traffic
patterns that result from the land use change can then be fed back into the travel demand
model. The land use model and travel demand model can be iterated to produce an accurate
result.
A project which provides new connectivity across a barrier, such as a new bridge across a river, may
provide a shortened path between existing origins and destinations, thereby shortening existing trips. In
rare cases, this trip-shortening effect might be substantial enough to reduce the amount of vehicle
travel resulting from the project below the range found in the elasticities in the academic literature, or
even lead a net reduction in vehicle travel overall. In such cases, the trip-shortening effect could be
examined explicitly.
Whenever employing a travel demand model to assess induced vehicle travel, any limitation or known
lack of sensitivity in the analysis that might cause substantial errors in the VMT estimate (for example,
model insensitivity to one of the components of induced VMT described above) should be disclosed and
characterized, and a description should be provided on how it could influence the analysis results. A
discussion of the potential error or bias should be carried into analyses that rely on the VMT analysis,
such as greenhouse gas emissions, air quality, energy, and noise.
GUIDELINES FOR TRANSPORTATION IMPACT STUDIES
IN THE SAN DIEGO REGION
May 2019
Guidelines for Transportation Impact Studies in the San Diego Region Page i
ACKNOWLEDGEMENTS
This technical paper was prepared by members of the Institute of Transportation Engineers, San
Diego Section, Transportation Capacity and Mobility Task Force, SB 743 Subcommittee.
PRINCIPAL AUTHORS
Erik Ruehr, VRPA Technologies (Subcommittee Chair)
Katy Cole, Fehr and Peers
Mychal Loomis, Kimley-Horn and Associates
KC Yellapu, Linscott, Law & Greeenspan, Engineers
Justin Rasas, LOS Engineering
ADDITIONAL SB 743 SUBCOMMITTEE MEMBERS
Andrew Martin, Ascent Environmental Jacob Armstrong, San Diego County
Alyssa Begley, Caltrans Kimberly Dodson, Caltrans
Roger Sanchez-Rangel, Caltrans Monique Chen, Chen Ryan Associates
Phuong Nguyen, Chen Ryan Associates Craig Williams, City of Carlsbad
Scott Barker, City of Chula Vista Claudia Brizuela, City of San Diego
Meghan Cedeno, City of San Diego Maureen Gardiner, City of San Diego
George Ghossain, City of San Diego Ann Gonsalves, City of San Diego
Samir Hajjiri, City of San Diego Nic Abboud, City of San Marcos
Minjie Mei, City of Santee Meghan Macias, EPD Solutions
Sarah Brandenberg, Fehr and Peers Amy Jackson, Kimley- Horn and Associates
Larry Hofreiter, Port of San Diego Cara Hilgesen, Linscott, Law & Greenspan, Engineers
Mike Calandra, SANDAG Walter Musial, Linscott, Law & Greenspan, Engineers
Keith Greer, SANDAG Dawn Wilson, Michael Baker International
Sandipan Bhattacharjee, Translutions David Wong-Toi
Guidelines for Transportation Impact Studies in the San Diego Region Page ii
TABLE OF CONTENTS
SECTION PAGE
1.0 Background ........................................................................................................................................... 1-1
2.0 Purpose of Guidelines .......................................................................................................................... 2-1
3.0 Project Coordination and Staff Consultation ..................................................................................... 3-1
PART I – CEQA TRANSPORTATION ANALYSIS
4.0 Individual Land Development Projects and Specific Plans ............................................................... 4-1
5.0 Community Plans and General Plans ................................................................................................. 5-1
6.0 Transportation Projects ....................................................................................................................... 6-1
PART II – LOCAL TRANSPORTATION ANALYSIS
7.0 Roadway ................................................................................................................................................ 7-1
8.0 Transit .................................................................................................................................................... 8-1
9.0 Bicycle .................................................................................................................................................. 9-1
10.0 Pedestrian ........................................................................................................................................... 10-1
APPENDICES
APPENDIX
A. Local Transportation Analysis Screen Check
B. Ramp Meter Analysis
C. Level of Service (LOS) Definitions
Guidelines for Transportation Impact Studies in the San Diego Region Page iii
LIST OF FIGURES
SECTION—FIGURE # PAGE
Figure 4–1 Transportation Impact Study Flow Chart – Individual Projects and Specific Plans ................... 4-2
Figure 6–1 Transportation Impact Study Flow Chart – Transportation Projects .......................................... 6-2
Figure 7–1 Flow Chart for LTA Roadway Analysis ..................................................................................... 7-2
LIST OF TABLES
SECTION—TABLE # PAGE
Table 7–1 Thresholds for Roadway Improvements ................................................................................... 7-6
Table 7–2 Roadway Classifications, Level of Service, and Average Daily Traffic...................................... 7-7
Guidelines for Transportation Impact Studies in the San Diego Region
Page 1-1
GUIDELINES FOR TRANSPORTATION IMPACT STUDIES (TIS)
IN THE SAN DIEGO REGION
1.0 BACKGROUND
The original Guidelines for Traffic Impact Studies in the San Diego Region (ITE/SANTEC, 2000) have been
in use for over 19 years. They were developed by a group of volunteers from the San Diego Section of the
Institute of Transportation Engineers (ITE) and the San Diego Traffic Engineers Council (SANTEC). The
guidelines were later incorporated into the region’s Congestion Management Program (CMP) prepared by
the San Diego Association of Governments (SANDAG, 2008). Although inclusion in the Congestion
Management Program (CMP) increased the visibility of the guidelines for a period of time, SANDAG has
since opted out of the CMP process.
The intent in preparing the year 2000 guidelines was to promote consistency in the methodology for traffic
impact studies used by different agencies in the San Diego region. While these guidelines were not
intended to be used as a standard or a requirement, they provided a methodology for traffic impact studies
that was similar to the methodology used by most agencies within the region. Some agencies in the region
have “adopted” the guidelines by specifying that traffic impact studies follow the procedures recommended
by the guidelines. Other agencies, including San Diego County and the City of San Diego, prepared their
own guidelines, which included some elements in common with the regional guidelines.
The impetus to develop a revised set of regional transportation impact study guidelines is primarily related
to the passage of Senate Bill 743 (SB 743) 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). Starting
on July 1, 2020, automobile delay and level of service (LOS) may no longer be 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 will be required. Although there is no
requirement to use any particular metric, the use of vehicle miles traveled (VMT) has been recommended
by the Governor’s Office of Planning and Research (OPR). This requirement does not modify the discretion
lead agencies have to develop their own methodologies or guidelines, or to analyze impacts to other
components of the transportation system, such as walking, bicycling, transit, and safety. SB 743 also
applies to transportation projects, although agencies were given flexibility in the determination of the
performance measure for these types of projects.
The intent of SB 743 is to bring CEQA transportation analyses into closer alignment with other statewide
policies regarding greenhouse gases, complete streets, and smart growth. Using VMT as a performance
measure instead of LOS is intended to discourage suburban sprawl, reduce greenhouse gas emissions,
and encourage the development of smart growth, complete streets, and multimodal transportation
networks.
Guidelines for Transportation Impact Studies in the San Diego Region
Page 2-1
2.0 PURPOSE OF GUIDELINES
The guidelines described in this report were prepared to provide methodologies for transportation
engineers and planners to conduct CEQA transportation analyses for land development and transportation
projects in compliance with SB 743. Lead agencies may opt-in to using VMT at any time but will be required
to use it for analysis of transportation impacts of land development projects starting July 1, 2020. In
addition, methodologies are provided to evaluate automobile delay and LOS outside of the CEQA process.
Although no longer incorporated in CEQA (starting July 1, 2020), automobile delay and LOS continue to be
of interest to transportation engineers and planners who plan, design, operate, and maintain the roadway
system. In addition, delay experienced due to traffic congestion is a concern to drivers and passengers of
vehicles using the roadway system.
Given the need to prepare VMT-based CEQA transportation impact analyses to satisfy the requirements of
SB 743 as well as the need to evaluate the performance of the roadway system based on delay and LOS,
these guidelines are divided into separate parts. Part I is focused on CEQA transportation impact analyses,
while Part II is focused on the more traditional LOS-based transportation analyses, called local
transportation analysis for the purpose of these guidelines. Local transportation analysis includes
evaluation of any multimodal transportation improvements (transit, bicycle, pedestrian) that are
recommended to support a land development project but may or may not be required as mitigation
measures for a project’s significant VMT impacts. Background information for each is provided below with
more detail included in the sections that follow.
CEQA TRANSPORTATION IMPACT ANALYSIS
The SB 743 legislation specified that the Governor’s Office of Planning and Research (OPR) prepare
guidelines for the implementation of SB 743. During the period from the passage of SB 743 in 2013 to the
fall of 2018, OPR prepared various sets of guidelines and sought public comments from stakeholders. At
the time of preparation of these transportation impact study guidelines, guidance regarding the changes to
CEQA initiated by SB 743 were contained in the following documents:
CEQA Guidelines Revisions: Revisions to the CEQA Guidelines were adopted into CEQA in
December 2018 through a formal process conducted by the Natural Resources Agency. Additional
changes can only be made through a future CEQA update process.
Technical Advisory on Evaluating Transportation Impacts in CEQA (Technical Advisory): The
technical advisory provides recommendations for the preparation of transportation impact analyses
under SB 743. It is not formally included in CEQA and can be revised by OPR at any time without
going through a formal process. Updated versions of the technical advisory are expected to be
issued by OPR as new information becomes available and as California agencies gain experience
in applying SB 743 to actual projects. As of the time of preparation of these transportation impact
study guidelines, the current version of the technical advisory was dated December 2018.
In addition to the differences described above, the CEQA Guidelines revisions and the technical advisory
also differ in the extent to which they must be followed by local agencies. The CEQA Guidelines revisions
are rules that must be followed in order to prepare an adequate CEQA document. In contrast, the technical
Guidelines for Transportation Impact Studies in the San Diego Region
Page 2-2
advisory provides statewide guidance based on evidence collected by OPR that can be refined or modified
by local agencies with appropriate justification and substantial evidence. (Refer to CEQA Guidelines
Section 15384 for a definition of substantial evidence). As an example, the CEQA Guidelines revisions
specify that a land development project’s effect on automobile delay does not cause a significant
environmental impact. The use of VMT is suggested as a performance metric, but there is no indication of
what level of VMT increase would cause a significant environmental impact. The technical advisory
suggests various thresholds for the significance of VMT impacts but does not require the use of a particular
threshold. Therefore, lead agencies would be prohibited from using automobile delay to determine
significant transportation impacts and would be required to use VMT instead. Lead agencies have
discretion to select their preferred significance thresholds and could choose to use the thresholds
suggested in the technical advisory or develop alternative thresholds. Either decision should be supported
by substantial evidence that considers the legislative intent objectives of SB 743 and the specific direction
the statute provides regarding setting thresholds (per the excerpts below):
SB 743 Statute - Legislative Intent – Senate Bill No. 743, Section (b)(2)
More appropriately balance the needs of congestion management with statewide goals related to
infill development, promotion of public health through active transportation, and reduction of
greenhouse gas emissions.
SB 743 Statute – Section 21099(b)(1)
Those criteria shall promote the reduction of greenhouse gas emissions, the development of
multimodal transportation networks, and a diversity of land uses.
Regardless of the changes described above, SB 743 is clear in its intent that CEQA documents continue to
address noise, air quality, and safety (per the excerpt below):
SB 743 Statute – Section 21099(b)(3)
This subdivision does not relieve a public agency of the requirement to analyze a project’s
potentially significant transportation impacts related to air quality, noise, safety, or any other impact
associated with transportation. The methodology established by these guidelines shall not create a
presumption that a project will not result in significant impacts related to air quality, noise, safety, or
any other impact associated with transportation.
Although State CEQA Guidelines section 15064.3 states that generally vehicle miles traveled is the most
appropriate measure of transportation impacts, other relevant considerations may include the project’s
impact on transit and non-motorized travel. A complete environmental review will generally consider how
projects effect VMT in addition to effects on walking, bicycling, transit, and safety.
The CEQA transportation impact analysis described in these transportation impact study guidelines is
based on the technical advisory prepared by OPR, but refinements and clarifications have been added to
reflect local conditions. For any subsequent revisions of the SB 743 technical advisory prepared by OPR, it
would need to be determined whether the new information would suggest a change in the methodologies
for conducting CEQA transportation impact studies in the San Diego region.
LOCAL TRANSPORTATION ANALYSIS
As stated above, localized traffic congestion remains a concern to transportation engineers and planners as
well as the traveling public. It is recommended that consideration be given to preparation of a local
Guidelines for Transportation Impact Studies in the San Diego Region
Page 2-3
transportation analysis for all land development and transportation projects which evaluate a project’s
access and circulation within and nearby the project site. The local transportation analysis would provide
analysis of roadway conditions where there is the potential that substantial worsening of traffic congestion
would result due to implementation of the project. In addition, it would analyze the need for multimodal
improvements in cases where there is the potential for the project to cause a substantial worsening of
conditions for multimodal travel. Since any increases in traffic congestion or vehicular delay would not
constitute a significant environmental impact, the local transportation analysis could be included in the
project’s CEQA document for information only or it could be provided in a separate document. The
purposes of the local transportation analysis may include, but are not limited to the following:
Recommendations for any roadway improvements that should be built/implemented by the project
(or should be built/implemented by the project in coordination with other nearby land development
projects) based on the project’s expected effect on vehicular delay and LOS.
Recommendations for any multimodal transportation improvements (transit, bicycle, pedestrian)
that should be built/implemented by the project (or should be built/implemented by the project in
coordination with other nearby land development projects). Recommended multimodal
transportation improvements may be required as mitigation measures for transportation impacts
related to VMT increases or they may be recommended for other reasons.
Transportation analysis needed to determine the appropriate level of fees for multimodal
transportation improvements if the local jurisdiction has a fee program in place.
Documentation of the project’s expected effect on vehicular delay and level of service in the nearby
transportation system.
The roadway analysis methodologies recommended for conducting local transportation analysis, as
detailed in Part II of these guidelines, are based on the previous regional traffic impact study guidelines,
with changes to reflect evolution in the practice that has occurred. Users of these guidelines should note
that transportation analysis advances occur each year as documented through key conferences, including
the Transportation Research Board (TRB) Annual Meeting. Further, new data vendors, and new mobility
options continue to evolve. As such, the recommended methodologies in this document may require
ongoing updates and refinements. The recommended methodologies for multimodal transportation analysis
generally reflect new procedures that were not included in the previous guidelines.
The intent of these guidelines is that agencies in the San Diego region be encouraged to implement Part I –
CEQA guidelines to promote consistency in methodology and the pursuit of VMT reductions to meet
regional and state goals. It is recognized that agencies may wish to make specific exceptions to these
guidelines to account for local conditions. Agencies may also desire to have additional analyses conducted
outside of the CEQA analyses to help inform staff and decision makers in reviewing a project. To that end,
Part II – Local Transportation Analyses reflects an update to the previous regional Traffic Impact Study
Guidelines.
Guidelines for Transportation Impact Studies in the San Diego Region
Page 3-1
3.0 PROJECT COORDINATION AND STAFF CONSULTATION
TIS preparers are encouraged to discuss the project with the lead agency’s staff at an early stage in the
planning process. An understanding of the level of detail and the assumptions required for the analysis
should be reached. While a pre-submittal conference is highly encouraged, it may not be a requirement.
For straightforward studies prepared by consultants familiar with these TIS procedures, a telephone call or
email, followed by a verification of key assumptions, may suffice. Transportation impact studies should be
prepared by a qualified transportation professional. Lead agencies should consider requiring that all
transportation impact studies be prepared by or reviewed under the supervision of a licensed traffic
engineer.
Guidelines for Transportation Impact Studies in the San Diego Region
PART I – CEQA TRANSPORTATION ANALYSIS
Guidelines for Transportation Impact Studies in the San Diego Region
Page 4-1
4.0 INDIVIDUAL LAND DEVELOPMENT PROJECTS AND SPECIFIC PLANS
The recommended methodology for conducting a VMT analysis is based on guidance prepared by the
California Governor’s Office of Planning and Research (OPR) as provided in the published Technical
Advisory on Evaluating Transportation Impacts in CEQA. At the time of writing of these guidelines, the
current version of OPR’s technical advisory was dated December 2018. The guidance recommended by
OPR has been modified to be better suited to local conditions in the San Diego region. These modifications
are noted in the details described later in this chapter.
The basic process is to compare a project’s estimated VMT/capita or VMT/employee to average values on
a regional, citywide, or community basis. The target is to achieve a project VMT/capita or VMT/employee
that is 85% or less of the appropriate average based on suggestions in these guidelines. Note that lead
agencies have discretion for choosing a VMT metric and threshold. The selection should represent how
VMT reduction is balanced against other objectives of the lead agency and be supported by substantial
evidence.
The methodology for determining VMT/capita or VMT/employee is related to the project’s expected daily
trip generation. The process for determining appropriate methodology to be used for conducting a VMT
analysis for individual land development projects and specific plans is summarized in Figure 4-1.
The remainder of this section of the guidelines is divided into individual components that describe different
aspects of the methodology. Other methodologies for VMT analysis could be considered at the discretion of
the lead agency. However, it is recommended that any VMT methodologies within a particular analysis use
consistent methodologies and that VMT analysis consider the differences between trip-based VMT analysis
methodologies and tour-based VMT methodologies, as described in OPR’s technical advisory.
MINIMUM PROJECT SIZE
It is recommended that lead agencies determine a minimum project size, below which VMT impacts are
presumed to be less than significant. Two alternative approaches for determining minimum project size are
described below.
Alternative 1 – Minimum Project Size Based on Previous TIS Guidelines
Under this alternative, projects would be subjected to different levels of VMT analysis, depending on the
size of the project and whether the project is consistent with the local jurisdiction’s General Plan or
Community Plan. Projects that are consistent with the General Plan or Community Plan are also
considered to be consistent with the Regional Transportation Plan/Sustainable Communities Strategy
(RTP/SCS).
The determination of minimum project size for VMT analysis described below differs from the statewide
guidance provided by OPR. It is based on regional standards for transportation analyses that were
documented in the Guidelines for Traffic Impact Studies in the San Diego Region (ITE/SANTEC, 2000) and
have been in use for over 19 years.
The following level of VMT analysis is recommended based on project size (expressed in terms of Average
Daily Trips generated by the project; also known as ADT) and zoning:
Level of Significance and MitigationsDaily Project TripsVMT Analysis MethodologyFigure 4‐1VMT Analysis for Individual Land Development Projects1Run SANDAG model with and without ProjectLess than Significant ImpactMitigate to Below Threshold?Less Than Significant ImpactSignificant ImpactYESNOUse SANDAG VMT Calculation Tool0 ‐Minimum VMT Threshold2Minimum VMT Threshold2‐2400 ADTBelow ThresholdExceeds ThresholdLess than Significant Impact>2400 ADTFootnotes:1. VMT impacts presumed to be less than significant for certain local‐serving retail projects, affordable housing projects, and projects within transit priority areas. See text.2. Minimum VMT threshold to be determined by lead agency.I -. j ~ -. ' '. I -. I -. -! !
Guidelines for Transportation Impact Studies in the San Diego Region
Page 4-3
Projects Inconsistent with General Plan or Community Plan
ADT Level of Analysis
0 – 500 VMT Analysis Not Needed/VMT Impacts Presumed Less Than Significant
500 and Greater VMT Analysis Recommended
Projects Consistent with General Plan or Community Plan
ADT Level of Analysis
0 – 1,000 VMT Analysis Not Needed/VMT Impacts Presumed Less Than Significant
1,000 and Greater VMT Analysis Recommended
The advantage of this alternative for determining minimum project size is that it is based on the engineering
judgment of professionals who are experts in determining the effect of projects on the transportation
system. It has been used successfully for over 19 years in the San Diego region and has received wide
acceptance from the transportation profession, decision makers, and the public. Transportation engineers
and planners who support this alternative for determining minimum project size consider it to be equally
valid for the current LOS-based transportation analyses as well as the new VMT-based analyses taking
effect on July 1, 2020.
Alternative 2 – Minimum Project Size Based on Statewide Guidance
Under this alternative, the minimum project size for VMT analysis would be based on statewide guidance
provided by OPR. In OPR’s technical advisory, the minimum project size is based a categorical exemption
in CEQA that allows expansion of existing structures under certain circumstances. On page 12 of the
December 2018 technical advisory, footnote 19, the following language describes the situation: “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, subd. (e)(2).]”
OPR uses a general office building as the appropriate project type for the determination of minimum project
size based on the exemption described above. Typical ITE trip generation rates are then applied to a
10,000 square-foot general office building which yields a minimum project size based on 110 daily trips.
If this alternative is used in the San Diego region, it is recommended that the use of regional or local trip
generation rates be considered in addition to the typical trip generation rate used by OPR. For example,
using the SANDAG trip generation manual (Brief Guide of Vehicular Traffic Generation Rates for the San
Diego Region, April 2002), a standard commercial office would generate 20 daily trips per 1,000 square
feet. Therefore, a 10,000 square-foot office would be expected to generate 200 daily trips and projects that
generate less than 200 daily trips would not require a VMT analysis and would be presumed to have less
than significant VMT impacts.
One advantage of this alternative is that it is based on statewide guidance with a reference to CEQA
provisions. A second advantage is that it was developed in consideration of VMT as the performance
measure for the determination of the transportation impacts of land development projects.
Guidelines for Transportation Impact Studies in the San Diego Region
Page 4-4
PROJECTS LOCATED NEAR TRANSIT STATIONS
OPR’s technical advisory contains the following guidance regarding projects located near transit stations:
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.
An existing major transit stop is defined as “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.”
For the purposes of these guidelines, the distance between the project site and the transit station is
typically based on direct walking distance without missing sidewalks or physical barriers.
Typically, a major transit stop would be considered to be applicable for this purpose if the transit stop were
assumed to be in place in SANDAG’s RTIP scenario (see Methodology for VMT analysis for further
discussion of this scenario).
METHODOLOGY FOR VMT ANALYSIS
As mentioned above, it is recommended that VMT thresholds for SB 743 analysis will be developed by
comparisons to average VMT/capita (for residential projects) or VMT/employee (for employment projects).
The analysis can be conducted by comparing either the project VMT/capita or VMT/employee to both the
San Diego regional average and the average for the city or community in which the project is located. It is
recommended that if the project average is lower than either 85% of the regional average or 85% of the
average for the city or community in which the project is located, the VMT impacts of the project can be
presumed to be less than significant. Since this is the basis for the presumption of “less than significance,”
it will be up to each city in the San Diego region and the County to adopt this recommended presumption
and either define its jurisdiction as a single community for the purposes of determining VMT thresholds or
subdivide its jurisdiction into smaller communities for the purpose of SB 743 analysis.
It should be noted that OPR’s technical advisory includes special considerations for affordable housing and
these considerations are also recommended for use in the San Diego area. Projects that include 100%
affordable housing in infill locations can be presumed to have a less than significant VMT impact. Infill
locations will typically have better than average access to transit and/or greater opportunities for walking
and bicycling trips. The exact definition of infill locations will need to be determined based on local
conditions.
The VMT methodology recommended above differs from the statewide guidance recommended by OPR in
the following ways:
OPR recommends that VMT/capita comparisons for residential projects be made both on a
regional and citywide basis. These guidelines recommend that a city may choose to do
Guidelines for Transportation Impact Studies in the San Diego Region
Page 4-5
comparisons at a community level rather than at the citywide level. This recommendation applies
to all cities within San Diego County and provides the lead agencies flexibility and discretion for
selecting the threshold that is appropriate for their agency, based on their values and substantial
evidence. Many communities within cities in the San Diego Region have a size and population that
is comparable to a typical city on a statewide basis. The unincorporated area of San Diego County
also has a governing structure in place for its communities, and the choice to do VMT/capita
comparisons at a community level is also recommended to be extended to the unincorporated area
of the County. The Cities of Encinitas and Chula Vista are also examples of cities that have distinct
communities which have been treated differently for various historical planning considerations.
OPR recommends that VMT/employee comparisons for employment projects be conducted at a
regional basis only, as compared to VMT/capita comparisons that are made both at a regional and
citywide basis. These guidelines recommend that VMT/employee comparisons be made at both
the regional and at the citywide level (or community level as described above). The San Diego
Region is the third largest region in California (after the Los Angeles Area and the San Francisco
Bay Area). While some employment trips are made across the region (or even outside the region),
there is a large incentive to live and work within a relatively short distance, even within the same
city or community, to avoid the relatively long commute distances that can be experienced by
traveling across the region during peak commute hours.
OPR recommends that the VMT/capita comparisons for projects in unincorporated county areas be
based on the region’s VMT/capita or the average VMT/capita of all cities within the county. These
guidelines recommend that VMT/capita and VMT/employee comparisons for projects in the
unincorporated area of San Diego County be made to the overall average VMT/capita and
VMT/employee for the unincorporated area of the county (or for individual communities if the
County decides to use individual communities rather than the entire unincorporated area for VMT
comparisons). San Diego County is one of the largest counties in California in terms of geography
and also one of the most diverse in terms of topography and climate. While the VMT/capita
comparison recommended by OPR may make sense for some counties in California, the
comparisons between unincorporated areas and averages of the cities make less sense in San
Diego County, where there are great differences in terms of distance and other factors between
rural and urban areas of the county.
It is recommended that once the SB 743 analysis communities have been defined by local jurisdictions,
SANDAG should then calculate the average VMT/capita (for residential projects) and the average
VMT/employee (for employment projects) for each city or community. This calculation can be based on the
Regional Transportation Improvement Plan (RTIP) scenario for future land use and transportation network,
which includes expected growth through the end of the RTIP scenario and transportation network
improvements that are considered to be funded through the RTIP. It is recommended that the RTIP
scenario used for VMT analysis purposes will be held constant once it is created and will only be changed
with each update of the Regional Transportation Plan/Sustainable Communities Strategy (RTP/SCS),
typically every four years. It is recommended that the SANDAG online VMT analysis tool (described below)
also be held constant and be updated on the same schedule as the RTP is updated and a new regional
model is produced by SANDAG. If an online VMT analysis tool is not available for the RTIP scenario, it is
recommended that analysts use the online VMT analysis tool published by SANDAG that most closely
approximates the RTIP scenario.
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Retail development falls into a category which is neither considered to be residential nor employment-
based. For retail projects, these guidelines are based on the methodology recommended by OPR for retail
projects. It is recommended that local-serving retail projects be presumed to have less than significant VMT
impacts and regional-serving retail projects be presumed to have significant VMT impacts if they increase
VMT above the level that would occur for conditions without the project. OPR’s technical advisory
recommends that lead agencies determine which retail projects are local-serving, but it does include a
general guideline that retail projects larger than 50,000 square feet might be considered regional-serving
rather than local-serving.
For some land development projects, it may not be immediately obvious whether the project is a residential
project or an employment project. For these projects, the preferred methodology is to analyze the trip-
making characteristics of the project and then use either the residential or employment methodology. For
example, a hotel may be considered to have trip-making characteristics closer to an employment project,
and therefore the employment methodology could be used for this land use category.
The recommended methodology for calculation of VMT depends on the size of the project as determined
by the project’s trip generation calculated in terms of ADT. The project’s trip generation should be
calculated using standard practice. For projects with a trip generation of less than 2,400 ADT, the
recommended VMT analysis methodology is the SANDAG VMT calculation tool. SANDAG has prepared an
online tool that calculates average VMT/capita and VMT/employee at the census tract level. Analysts would
use this tool to determine the project’s VMT/employee or VMT/capita to be compared to community, city,
and/or regional averages.
Definitions of VMT/capita and VMT/employee that are used in SANDAG’s VMT calculation tool are as
follows:
VMT/Capita: Includes all vehicle-based person trips grouped and summed to the home location of
individuals who are drivers or passengers on each trip. It includes home-based and non-home-
based trips. The VMT for each home is then summed for all homes in a particular census tract and
divided by the population of that census tract to arrive at Resident VMT/Capita.
VMT/Employee: Includes all vehicle-based person trips grouped and summed to the work location
of individuals on the trip. This includes all trips, not just work-related trips. The VMT for each work
location is then summed for all work locations in a particular census tract and divided by the
number of employees of that census tract to arrive at Employee VMT/Employee.
The recommended methodology for projects over 2,400 ADT is to run the regional transportation model
with and without the project to determine the project’s net increase in VMT and then use that value to
determine VMT/employee or VMT/capita to be compared to community, city, and/or regional averages.
REDVELOPMENT PROJECTS
Recommendations for VMT analysis of redevelopment projects are based on guidance provided by OPR
with the clarifications provided below.
Redevelopment projects represent a special case since the recommended VMT thresholds for SB 743
implementation represent an efficiency metric. Under SB 743, the primary goal is for all new land
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development projects to achieve efficiency from a VMT point of view. The efficiency or lack of efficiency of
the existing land use is typically not relevant per OPR.
The following methodology is recommended:
A redevelopment project that reduces absolute VMT (i.e. the total VMT with the project is less than
the total VMT without the project) would be presumed to have less than significant VMT impacts.
If a project increases absolute VMT, it is recommended that the VMT analysis methodology
described above be applied to the proposed land use, as if the project was proposed on a vacant
parcel (i.e. the existing land use didn’t exist).
OPR’s technical advisory includes specific recommendations that relate to redevelopment projects that
replace affordable residential units with a smaller number of market-rate residential units. Those
recommendations are also considered applicable for the purposes of these guidelines.
MIXED-USE PROJECTS
Recommendations for VMT analysis of mixed-use projects are based on guidance provided by OPR with
additional clarifications recommended for use in the San Diego region.
The following steps are recommended:
Calculate trip generation separately for each component of the mixed-use project using standard
practice.
Determine the reduction in external vehicle trips due to internal capture based on guidance
provided in the ITE Trip Generation manual, MXD methodologies or other techniques.
Apply the reduction in trips to the individual land uses so that the total trip generation of the
individual land uses is equal to the total project trip generation, including internal capture.
Using the reduced trip generation, determine the VMT/capita or VMT/employee for applicable land
uses. SANDAG’s online VMT calculation tool may be used to determine an average trip length for
the land uses within a mixed-use development based on the reported VMT/capita or
VMT/employee in the census tract where the project is located. The number of residents or
employees will need to be estimated for each applicable land use. When using SANDAG’s VMT
calculation tool to estimate average trip length, analysts should be aware that the data produced by
the SANDAG VMT calculation tool is based all resident VMT/capita, so it includes the VMT
associated with all trips made by the resident for the day, for example trip from home to daycare to
office; office to meeting to office; office to store to home. The ITE trip generation rate for residential
is only home-based trips, i.e. trips that start or end at the residence. The effect of the distinction
between ITE’s data and the data produced by the SANDAG VMT calculation tool will vary by
location, type of project, and other factors.
Compare the VMT/capita or VMT/employee values calculated using the reduced trip generation to
applicable VMT thresholds to determine whether the individual components of the mixed-use
development would be expected to have a significant VMT impact. If any component of the mixed-
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use development would be expected to have a significant VMT impact, the project as a whole
would be considered to have a significant VMT impact.
Local-serving retail within a mixed-use development can be presumed to have a less than
significant VMT impact.
PROJECTS IN RURAL AREAS
Land development projects in rural areas may be given special consideration due to their unique trip-
making characteristics. OPR’s technical advisory contains the following guidance regarding projects in rural
areas:
“In rural areas of non-MPO counties (i.e., areas not near established or incorporated cities or
towns), fewer options may be available for reducing VMT, and significance thresholds may be best
determined on a case-by-case basis. Note, however, that clustered small towns and small town
main streets may have substantial VMT benefits compared to isolated rural development, similar to
the transit oriented development described above.”
If interpreted literally, this guidance would not apply to the San Diego region since it is an MPO County.
However, rural areas are considered to have similar trip-making characteristics regardless of whether they
are located in an MPO County or not. Therefore, different thresholds than described above could be
considered for the rural areas of San Diego County. In order to apply this concept, local agencies would
designate a portion of their jurisdiction as rural and then establish a separate threshold for the
determination of significant VMT impacts.
PHASED PROJECTS
For projects proposed to be built in phases, it is recommended that each phase of the project be evaluated
separately. This evaluation would include a determination of whether significant VMT impacts would occur
and whether mitigation is recommended. The evaluation of VMT for each phase would include
consideration of the previous project phases. For example, a project with three phases would include the
following analyses:
VMT Analysis of Phase 1: Assumes development of Phase 1 only.
VMT Analysis of Phase 2: Assumes development of Phases 1 and 2.
VMT Analysis of Complete Project: Assumes development of Phases 1, 2, and 3.
LAND DEVELOPMENT PROJECTS WITH A ROADWAY COMPONENT
Some individual land development projects and specific plans include the implementation of roadways as a
component of the project. This requires additional consideration since land development and roadway
projects are likely have different significance thresholds for VMT analysis. See Chapter 6 for
recommendations for VMT analysis of roadways and other transportation projects. Land development
projects may also include transit, bicycle, and pedestrian facilities as components of the project, but these
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types of projects would generally not be considered to increase VMT and would normally not need to be
considered in the VMT analysis of a land development project.
For land development projects and specific plans with a roadway component, the following
recommendations are provided:
If it can be demonstrated that the roadway component of the project built on its own would have a
less than significant impact, the roadway component of the project can be ignored and the VMT
analysis can proceed based on analysis of the VMT aspects of the land development component of
the project.
If it can be demonstrated that the project as a whole would cause a net decrease in VMT, the VMT
impact of the project may be considered less than significant.
For projects with both land use and roadway components that are outside the circumstances
described above, it is recommended that the VMT analysis be based on consideration of the net
increase or decrease in VMT with the project implemented as compared to conditions without the
project. For projects that would be expected to cause a net increase in VMT, the project would be
expected to provide mitigation measures to reduce VMT to the level of the no project condition in
order to have a less than significant impact. For projects in which the roadway component would
require analysis of induced travel demand (see Chapter 6), the VMT generated by the induced
travel should also be considered in the analysis.
MITIGATION
If a project’s VMT exceeds the thresholds identified above for individual land development projects and
specific plans, it may have a significant transportation impact. According to the OPR’s technical advisory,
when a significant impact is determined, feasible mitigation measures must be identified that could avoid or
substantially reduce the impact. Lead agencies are generally given the discretion to determine what
mitigation actions are “feasible,” but they must rely on substantial evidence in making these determinations.
In addition, CEQA requires the identification of feasible alternatives that could avoid or substantially reduce
a project’s significant environmental impacts.
Not all mitigation measures are physical improvements to the transportation network. A sample mitigation
measure might include telework options for employees to reduce vehicular travel. Examples of other
mitigation measures based on OPR’s technical advisory include but are not limited to the following:
Improve or increase access to transit.
Increase access to common goods and services, such as groceries, schools, and daycare.
Incorporate affordable housing into the project.
Incorporate a neighborhood electric vehicle network.
Orient the project toward transit, bicycle, and pedestrian facilities.
Improve pedestrian or bicycle networks, or transit service.
Provide traffic calming as a way to incentivize bicycling and/or walking.
Provide bicycle parking.
Limit or eliminate parking supply.
Unbundle parking costs.
Provide parking cash-out programs.
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Implement or provide access to a commute reduction program.
Provide car-sharing, bike sharing, and ride-sharing programs.
Provide partially or fully subsidized transit passes.
Shift single occupancy vehicle trips to carpooling or vanpooling by providing ride-matching services
or shuttle services.
Provide telework options.
Provide incentives or subsidies that increase the use of modes other than a single-occupancy
vehicle.
Provide on-site amenities at places of work, such as priority parking for carpools and vanpools,
secure bike parking, showers and locker rooms, and bicycle repair services.
Provide employee transportation coordinators at employment sites.
Provide a guaranteed ride home service to users of non-auto modes.
Contribute to a mobility fee program that funds multimodal transportation improvements, such as
those described above.
Additional mitigation measures may become acceptable as agencies continue to innovate and find new
ways to reduce vehicular travel.
Changes to the project design or location could potentially reduce VMT. Project alternatives based on
OPR’s technical advisory that may reduce vehicle miles of travel include but are not limited to the following:
Locate the project in an area of the region that already exhibits low VMT.
Locate the project near transit.
Increase project density.
Increase the mix of uses within the project or within the project’s surroundings.
Increase connectivity and/or intersection density on the project site.
OPR’s technical advisory notes that because VMT is largely a regional impact, regional VMT-reduction
programs may be an appropriate form of mitigation. In-lieu fees and development impact fees have been
found to be valid mitigation where there is both a commitment to pay fees and evidence that mitigation will
actually occur.
Fee programs are particularly useful to address cumulative impacts. The physical improvements that
constitute the mitigation program as a whole must undergo CEQA evaluation, and the imposition of
development impact fees or in-lieu fees shall be in accordance with applicable regulations, such as the
Mitigation Fee Act. Other mitigation must be evaluated on a project-specific basis. That CEQA evaluation
could be part of a larger program, such as a regional transportation plan analyzed in a Program EIR.
Quantifying the reduction in VMT associated with potential mitigation measures for land development
projects and specific plans is a relatively new endeavor for transportation engineers and planners.
Therefore, these guidelines do not recommend a methodology that has been in practice or has generally
been accepted for local use.
One current resource that has been identified to quantify the reduction in vehicle miles traveled associated
with a particular mitigation measure is the latest edition of California Air Pollution Control Officers
Association’s Quantifying Greenhouse Gas Mitigation Measures, A Resource for Local Government to
Assess Emission Reductions from Green Gas Mitigation Measures (CAPCOA, August 2010), also known
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as the CAPCOA Report. This report provides a methodology to quantify the reductions in vehicle miles
traveled for many of the mitigation measures listed above. At the time of preparation of these guidelines,
new research was underway that would provide an update to the CAPCOA Report.
The following elements should be considered when utilizing the CAPCOA Report:
The CAPCOA VMT reduction strategies include built environment changes and transportation
demand management (TDM) actions. The built environment changes are scalable from the project
site to larger geographic areas and are often captured in regional travel forecasting models such as
the SANDAG model. Prior to any application of a built environment change to a project as
mitigation, the project analyst should verify that the project VMT forecasting tool or model is
appropriately accurate and sensitive to built-environment effects and that no double counting will
occur in the application of the mitigation measure. The TDM actions are sensitive to the project site
and ultimate building tenants. As such, VMT reductions associated with TDM actions cannot be
guaranteed through CEQA mitigation without ongoing monitoring and adjustment.
There are rules for calculating the VMT reduction when applying multiple mitigation measures. The
CAPCOA Report rules should be considered.
Only “new” mitigation measures should be included in the analysis to prevent double counting. For
example, if the project is located near transit, the VMT reduction cannot be applied if the project
utilized a model that factored in the project’s proximity to transit. In addition, telecommuting is
included in SANDAG’s base model.
Mitigation measures should be applied to the appropriate user group (employees, guest/patrons,
etc.). If a certain measure applies to multiple user groups, the weighted average should be
considered as the effect of the mitigation measure will vary based on the user group.
A second resource that is available is the VMT calculation tool that was provided as part of SANDAG’s
Mobility Management Toolbox project.
Additional VMT calculation tools are currently available or under development by several local agencies in
California. Although these tools are being developed for specific jurisdictions, they could be adopted or
modified for use in individual jurisdictions in San Diego County. At the time of development of these
guidelines, the following calculation tools were publicly available.
City of San Jose: A VMT calculation tool and other information can be found at the following
website: http://www.sanjoseca.gov/vmt.
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5.0 COMMUNITY PLANS AND GENERAL PLANS
The recommended methodology for conducting a VMT analysis for community plans and general plans is
to compare the existing VMT/capita for the community plan or general plan area with the expected horizon
year VMT/capita. The recommended target is to achieve a lower VMT/capita in the horizon year with the
proposed plan than occurs for existing conditions.
The calculation of VMT for a planning area requires different considerations than the calculation of VMT for
an individual project or a specific plan. Generally, the use of a computerized travel forecasting model (such
as the SANDAG regional model) would be needed. For details on the calculation of VMT for a planning
area, analysts are referred to ITE’s paper on VMT calculations (Vehicle Miles Travelled Calculations Using
the SANDAG Regional Model, 2013).
If VMT analysis for a community plan or general plan requires consideration of mitigation measures to
mitigate significant VMT impacts, potential mitigation measures would be similar to those used for land
development projects with some modifications. The following measures could be considered:
Modify the land use plan to increase development in areas with low VMT/capita characteristics
and/or decrease development in areas with high VMT/capita characteristics.
Provide enhanced bicycle and/or pedestrian facilities.
Add roadways to the street network if those roadways would provide shorter travel paths for
existing and/or future trips.
Improve or increase access to transit.
Increase access to common goods and services, such as groceries, schools, and daycare.
Incorporate a neighborhood electric vehicle network.
Provide traffic calming to incentivize bicycling and walking.
Limit or eliminate parking supply.
Unbundle parking costs.
Provide parking or roadway pricing or cash-out programs.
Implement or provide access to a commute reduction program.
Provide car-sharing, bike sharing, and ride-sharing programs.
Shift single occupancy vehicle trips to carpooling or vanpooling by providing ride-matching services
or shuttle services.
Provide telework options beyond those already assumed in current plans.
Provide incentives or subsidies that increase the use of modes other than a single-occupancy
vehicle.
Provide employee transportation coordinators at employment sites.
Provide a guaranteed ride home service to users of non-auto modes.
Additional mitigation measures may become acceptable as agencies continue to innovate and find new
ways to reduce vehicular travel.
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6.0 TRANSPORTATION PROJECTS
STATEWIDE GUIDANCE
Statewide guidance for the analysis of transportation projects after the implementation of SB 743 is based
on the revisions to CEQA guidelines adopted in December 2018 and OPR’s technical advisory dated
December 2018. This guidance may be summarized as follows:
The revised CEQA guidelines allow lead agencies the discretion to choose a performance measure
and significance thresholds for the determination of the significant impacts of transportation
projects, including the continued use of level of service as a performance measure.
OPR’s technical advisory recommends the use of VMT as the appropriate performance measure
for transportation projects, but it does not include a recommendation for significance thresholds. It
also states that transit, bicycle, and pedestrian projects can generally be presumed to have less
than significant VMT impacts.
If VMT is selected as the performance measure for roadway projects, OPR’s technical advisory
recommends the inclusion of induced travel demand in the VMT calculations for roadway projects.
Induced travel demand is the travel demand that would be generated by new land development
projects that are built as a result of reduced travel times provided by a new roadway project.
RECOMMENDATIONS FOR THE SAN DIEGO REGION
The approach to analysis of transportation projects recommended for use in the San Diego Region is
summarized as follows:
Transit, bicycle, and pedestrian projects can generally be presumed to have less than significant
VMT impacts since they will tend to reduce VMT, as suggested by OPR’s technical advisory.
For roadway projects, VMT is the recommended performance measure. This performance
measure is considered to be best suited to meeting the intent of SB 743, since focusing on VMT
tends to encourage smart growth development, a reduction in vehicle trips, and the construction of
multimodal transportation networks.
VMT analysis for roadway projects can best be considered at regional, citywide, and community
levels prior to the consideration of individual projects. Most roadway projects are included in the
Regional Transportation Plan/Sustainable Communities Strategy (RTP/SCS), city circulation
elements of the general plan, and/or in the circulation elements of community plans. A typical
process would be for a roadway to be added to a citywide or community plan first, then
incorporated into the RTP/SCS prior to the initiation of a CEQA analysis for the project. Inclusion in
the citywide or community plan is considered to be a point at which the project has been accepted
into the future planning process. Therefore, inclusion of a project in the citywide or community plan
is recommended as the threshold of significance for VMT analysis. It is recommended that projects
included in the citywide or community plan may be presumed to have less than significant VMT
impacts.
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Individual roadway projects that are not included in the citywide or community plan could be
presumed to have less than significant VMT impacts if they have no net increase in VMT compared
to the no project condition or if they provide mitigation measures that would reduce VMT to levels
at or below the no project condition.
Additional details are provided below.
VMT is the recommended performance measure for the analysis of transportation projects. The
recommended methodology for conducting a VMT analysis for transportation projects is to compare the
project with the community plan or general plan in which the project is located to determine whether the
project would increase VMT as compared to the VMT that would be expected to occur with the community
plan or general plan. This is summarized in Figure 6-1. The analysis would vary depending on the mode of
travel associated with the project and based on whether the project is currently included in the community
plan or general plan.
Transit, bicycle, and pedestrian projects that would encourage the use of these modes of travel
would be expected to reduce VMT, would not require a detailed VMT analysis, and would be
presumed to have a less than significant impact on transportation. For these project types, the
presumption of less than significant impact would apply even if the project was not in the
community plan or general plan.
Roadway projects (or multimodal projects that include roadways) that are included in the
community or general plan would be presumed to have less than significant VMT impacts. In the
case of some projects, a similar project may have been included in the community plan or general
plan, but revisions or refinements have been incorporated. If the revisions or refinements are
expected to cause increases in VMT, analysis should be conducted to compare the proposed
project to the project description in the community plan or general plan. Projects that cause VMT
increases, in comparison to similar projects proposed in the community plan or general plan, would
need to reduce VMT levels below the level of VMT expected in the community plan or general plan
in order to avoid a significant VMT impact.
Roadway projects (or multimodal projects that include roadways) that are not included in the
community or general plan would need a detailed analysis of VMT to determine whether the project
would be expected to increase or decrease VMT as compared to VMT levels in the community plan
or general plan. For small projects, the VMT analysis could be conducted using sketch planning
techniques. For large projects, the analysis would generally require the use of a computerized
travel forecasting model (such as the SANDAG regional model). For very large projects (i.e.
projects that would reduce travel time by five minutes or more for any individual trips),
consideration should be given to conducting an analysis of induced demand as described in OPR’s
technical advisory. The five-minute threshold for analysis of induced demand is based on a
research paper published by the Transportation Research Board (Effects of Increased Highway
Capacity: Results of Household Travel Behavior Survey, Richard G. Dowling and Steven B.
Colman, Transportation Research Record 1493, Transportation Research Board, 1995). This
research concluded that projects that decrease travel time by more than five minutes for a large
number of trips would probably warrant an upward adjustment of travel demand.
The statewide guidance for VMT analysis of transportation projects is less specific than the guidance
provided for land development projects. In the case of transportation projects, new CEQA guidance allows
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lead agencies the discretion to choose the performance measure for transportation analysis, including the
use of level of service and delay as a performance measure. OPR’s technical advisory provides guidance
indicating that VMT is the preferred measure of effectiveness for transportation projects but it has no
authority to require the use of VMT as a performance measure. Although OPR’s technical advisory
encourages the use of VMT as a performance measure, it does not recommend a particular threshold of
significance for VMT.
Given the available statewide guidance, these guidelines recommend the use of VMT as the performance
measure for transportation projects. The recommended significance threshold is the level of VMT expected
based on the community plan or general plan in which the project is located. This methodology is
recommended for the following reasons:
Although the new CEQA guidance allows for the use of any appropriate performance measure for
the analysis of transportation projects, the intent of the SB 743 legislation was taken into
consideration in the selection of a performance measure. SB 743 is intended to promote
multimodal transportation networks, encourage infill development, and promote reduction of
greenhouse gases. VMT is considered to be the performance measure that best reflects this intent.
OPR’s technical advisory encourages the use of VMT as a performance measure. Although this
recommendation is not binding, the intent of these guidelines is to follow OPR’s guidance, except
in cases where there are regional characteristics or other factors that suggest a revision or
clarification.
The use of community plan or general plan consistency as a VMT threshold is based on the
process by which transportation projects are incorporated into a community plan or general plan.
In order for a transportation project to be incorporated into a community or general plan, a
considerable amount of analysis is typically conducted. Community plans and general plans
typically include the preparation of an Environmental Impact Report that considers a variety of
environmental impacts, including transportation impacts. Since community plans and general plans
are considered to represent sound urban planning decisions, consistency with these plans is
considered to be a reasonable benchmark for the determination of a VMT significance threshold.
While the guidance described above is considered to be appropriate for larger transportation projects,
smaller projects would be presumed to have less than significant VMT impacts based on their size or other
considerations. Following is a list of projects considered to be in this category. This list in based on
information in OPR’s technical advisory, with revisions and clarifications based on local conditions:
1. Rehabilitation, maintenance, replacement and repair projects designed to improve the condition of
existing transportation assets (e.g., highways, roadways, bridges, culverts, tunnels, transit
systems, and assets that serve bicycle and pedestrian facilities) and that do not add motor vehicle
capacity
2. Roadside safety devices or hardware installation such as median barriers and guardrails
Consistency with the General Plan /
Community Plan
VMT Analysis Methodology Level of Significance and Mitigation
Figure 6-1
VMT Analysis Flow Chart for Transportation Projects
Similar project included in
General Plan / Community
Plan?
VMT with Project exceeds
VMT of similar project in
General Plan / Community
Plan?
Determine amount of VMT
increase compared to
similar project in General
Plan / Community Plan
Determine amount of VMT
increase compared to
General Plan / Community
Plan
YES
NO
YES
Less than Significant
Impact
Significant ImpactLess than
Significant Impact
NO
Mitigate to Below
Threshold?
NOYES
JI · I I II
-
.
~ .
-I -
.I ,
I
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3. Roadway shoulder enhancements to provide “breakdown space,” dedicated space for use only by
transit vehicles, to provide bicycle access, or otherwise to improve safety, but which will not be
used as automobile vehicle travel lanes
4. Addition of an auxiliary lane of less than two miles in length
5. Installation, removal, or reconfiguration of traffic lanes at intersections that are intended to provide
operational or safety improvements
6. Addition of roadway capacity on local or collector streets provided the project also includes
appropriate improvements for pedestrians, cyclists, and, if applicable, transit
7. 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
8. Addition of a new lane that is intended to be restricted to use only by transit vehicles
9. Reduction in number of through lanes
10. 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
11. Installation, removal, or reconfiguration of traffic control devices, including Transit Signal Priority
(TSP) features
12. Installation of traffic metering systems, detection systems, cameras, changeable message signs,
and other electronics designed to optimize vehicle, bicycle, or pedestrian flow
13. Timing of signals to optimize vehicle, bicycle, or pedestrian flow
14. Installation of roundabouts or traffic circles
15. Installation or reconfiguration of traffic calming devices
16. Adoption of or increase in tolls
17. Addition of tolled lanes, where tolls are sufficient to mitigate any potential VMT increase
18. Initiation of new transit service
19. Conversion of streets from one-way to two-way operation with no net increase in number of traffic
lanes
20. Removal or relocation of off-street or on-street parking spaces
21. Adoption or modification of on-street parking or loading restrictions (including meters, time limits,
accessible spaces, and preferential/reserved parking permit programs)
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22. Addition of traffic wayfinding signage
23. Addition of new or enhanced bike or pedestrian facilities on existing streets/highways or within
existing public rights-of-way
24. Addition of Class I bike paths, trails, multi-use paths, or other off-road facilities that serve non-
motorized travel
25. Installation of publicly available alternative fuel/charging infrastructure
26. 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
27. Roadway striping modifications that don’t change the number of through lanes
Regardless of the project type and analysis method, projects that would be expected to have a significant
VMT increase would be expected to consider mitigation measures. Potential mitigation measures would
include the following:
Deploy management strategies (e.g., pricing, vehicle occupancy requirements) on roadways or
roadway lanes.
Improve pedestrian or bicycle networks, or transit service.
Additional mitigation measures may become acceptable as agencies continue to innovate and find new
ways to reduce vehicular travel.
Guidelines for Transportation Impact Studies in the San Diego Region
PART II – LOCAL TRANSPORTATION ANALYSIS
Guidelines for Transportation Impact Studies in the San Diego Region
Page 7-1
7.0 ROADWAY
It is recommended that consideration be given to preparation of a local transportation analysis (LTA) for all
land development and transportation projects. This section describes the recommended methodology for
analysis of local roadway conditions.
The purpose of the roadway analysis portion of an LTA is to forecast, describe, and analyze how a
development will affect existing and future circulation infrastructure for users of the roadway system,
including vehicles, bicycles, pedestrians, and transit. The LTA assists transportation engineers and
planners in both the development community and public agencies when making land use, mobility
infrastructure, and other development decisions. An LTA quantifies the expected changes in transportation
conditions and translates these changes into transportation system effects in the vicinity of a project.
The roadway transportation analysis included in an LTA is separate from the transportation impact analysis
conducted as part of the environmental (CEQA) project review process, as described in Part I. The purpose
of the roadway transportation analysis is to ensure that all projects provide a fair share of roadway
infrastructure improvements in order to accommodate their multimodal transportation demands.
The following guidelines were prepared to assist local agencies throughout the San Diego Region in
promoting consistency and uniformity in local transportation studies. These guidelines do not establish a
legal standard for these functions but are intended to supplement any individual manuals or level of service
objectives for the various jurisdictions. These guidelines attempt to consolidate regional efforts to identify
when an LTA is needed, what professional procedures should be followed, and what constitutes a
significant traffic effect that should be dealt with.
The instructions outlined in these guidelines are subject to update as future conditions and experience
become available. Special situations may call for variation from these guidelines. It is recommended that
consultants who prepare an LTA submit a scoping letter (methodology memo) for review by the lead
agency to verify the application of these guidelines and to identify any analysis needed to address special
circumstances. The scoping letter in this context is used for transportation analysis only and is not related
to a formal scoping process that occurs with preparation of a CEQA study. Caltrans and lead agencies
should agree on the specific methods used in local transportation analysis studies involving any State
Route facilities, including metered and unmetered freeway ramps.
NEED FOR A STUDY
Figure 7-1 shows the flow chart for determination of when a roadway analysis should be conducted. A
roadway analysis should be prepared for all projects which generate traffic greater than 1,000 total average
daily driveway trips (ADT) or 100 peak-hour trips. If a proposed project is not in conformance with the land
use and/or transportation element of the general or community plan, use threshold rates of 500 ADT or 50
peak-hour trips.
Early consultation with any affected jurisdictions is strongly encouraged since a “focused” or “abbreviated”
roadway analysis may still be required – even if the above threshold rates are not met. An understanding of
the level of detail and the assumptions required for the analysis should be reached. A pre-submittal in-
person conference may not be required. However, the applicant should prepare a scoping letter for the
agency’s review and approval prior to preparation of the analysis.
Guidelines for Transportation Impact Studies in the San Diego Region
Page 7-2
Figure 7-1
FLOW CHART FOR LTA ROADWAY ANALYSIS
* Check with Caltrans for current ramp metering rates. (See Attachment B – Ramp Metering Analysis)
** However, for health and safety reasons, and/or local and residential street issues, an “abbreviated” or
“focused” LTA may still be requested by a local agency. (For example, this may include traffic backed
up beyond an off-ramp’s storage capacity or may include diverted traffic through an existing
neighborhood.)
Does project conform to the Land Use &
Transportation Elements of the General/
Community Plan?
Project traffic > 500 ADT, or
50 peak-hour trips?
Project traffic > 1,000 ADT, or
110 peak-hour trips?
LTA required
NO
NO
NO
Yes
Yes
Yes
Yes
NO
LTA probably not
required**
Will project add 20 or more peak hour trips to
any existing on- or off-ramp?*
LTA may not be required.
A freeway/metered
“focused” LTA might
suffice. Consult lead
agency and Caltrans*
►
Guidelines for Transportation Impact Studies in the San Diego Region
Page 7-3
STUDY PARAMETERS
It is recommended that the geographic area examined in the LTA include the following for roadways:
All local roadway segments between signalized intersections (including all State surface routes),
intersections, and mainline freeway locations where the proposed project will add 50 or more peak-
hour trips in either direction to the existing roadway traffic.
All freeway entrance and exit ramps where the proposed project will add a substantial number of
peak-hour trips to cause any traffic queues to exceed ramp storage capacities (see Figure 1).
(NOTE: Care must be taken to include other ramps and intersections that may receive project
traffic diverted as a result of already existing or project causing congestion at freeway entrances
and exits.)
The data used in the LTA should generally not be more than two years old and should not reflect a
temporary interruption (special events, construction detour, etc.) in the normal traffic patterns unless that is
the nature of the project itself. If recent traffic data is not available, current counts should be made by the
project applicant’s consultant. For areas near beaches or bays, counts should be taken during summer or
adjusted to reflect summer conditions.
In general, the region-wide goal for roadway level of service (LOS) on all freeways, roadway segments, and
intersections is “D.” For central urbanized areas, the goal may be to achieve a level of service of “E.”
Individual jurisdictions have slightly different LOS objectives.
SCENARIOS TO BE STUDIED
The following scenarios are recommended to be addressed in the roadway analysis (unless there is
concurrence with the lead agency that one or more of these scenarios may be omitted). Some exceptions
are noted at the end of this list:
Existing Conditions: Document existing traffic levels and peak-hour levels of service in the study area.
Identify locations where roadways do not meet target levels of service for existing conditions.
Existing Plus Project Conditions: Analyze the effect of the proposed project in addition to existing
conditions. This scenario identifies the effect of a project on the transportation network with no other
changes in conditions.
Near-term (approved and pending): Analyze the cumulative conditions resulting from the development of
“other” approved and “reasonably foreseeable” pending projects (application on file) that are expected to
influence the study area. This is the baseline against which project effects are assessed. The lead agency
may be able to provide copies of the traffic studies for the “other” projects if they are already approved. If
data is not available for near-term cumulative projects, an ambient growth factor should be used. If
applicable, transportation network improvements should also be included in this scenario. This would
include programmed and fully funded network improvements that are scheduled to open prior to the
project’s expected opening day.
Guidelines for Transportation Impact Studies in the San Diego Region
Page 7-4
Near-term + Proposed Project: Analyze the effects of the proposed project at its expected opening day in
addition to near-term baseline conditions. For phased projects, a separate analysis could be conducted for
each phase.
Horizon Year: Identify traffic forecasts, typically 20 years in the future, through the output of a SANDAG
model forecast or other computer model approved by the local agency.
Horizon Year + Proposed Project: Analyze the additional project traffic effect to the horizon year condition.
When justified, and particularly in the case of very large developments or new general/community plans, a
transportation model should be run with, and without, the additional development to show the net effect on
all parts of the area’s transportation system.
Analysis of near-term scenarios may not be necessary if this scenario is incorporated in the agency’s
Traffic Impact Fee (TIF) program. If an agency has established a fee program to cover near-term
improvements on all key roadways, the payment of traffic impact fees could be considered to be sufficient
to offset a project’s effect on these roadways.
Horizon year studies may not be needed, depending on the discretion of the lead agency. Reasons for
including these scenarios may vary, but they would generally be added because the proposed project is
substantially different than was expected in the Community Plan/General Plan, or if the area near the
project is expected to experience land use or network changes that have not been adequately accounted
for in previous planning studies.
In order to use LOS criteria to determine the need for roadway improvements (see Table 7-1), proposed
model or manual forecast adjustments must be made to address scenarios both with and without the
project. Model data should be carefully verified to ensure accurate project and “other” cumulative project
representation. In these cases, regional or subregional models conducted by SANDAG need to be
reviewed for appropriateness.
PROJECT TRAFFIC GENERATION
Use of SANDAG [Traffic Generators Manual and (Not So) Brief Guide….] or City of San Diego (Trip
Generation Manual) rates should first be considered. Trip generation rates from ITE’s latest Trip Generation
Manual or ITE Journal articles could also be considered. Smart growth projects should consider use of the
SANDAG Smart Growth Trip Generation and Parking Study guidelines. If local and sufficient national data
do not exist, conduct trip generation studies at multiple sites with characteristics similar to those of the
proposed project.
Reasonable reductions to trip rates may also be considered: (a) with proper analysis of pass-by and
diverted traffic on adjacent roadways, (b) for developments near transit stations, and (c) for mixed-use
developments. (Note: Caltrans and local agencies may use different trip reduction rates. Early consultation
with the reviewing agencies is strongly recommended.)
Project trips can be assigned and distributed either manually or by a computer model based upon review
and approval of the local agency Traffic Engineer. The magnitude of the proposed project will usually
determine which method is employed.
Guidelines for Transportation Impact Studies in the San Diego Region
Page 7-5
If the manual method is used, the trip distribution percentages could be derived from existing local traffic
patterns or optionally (with local agency approval) by professional judgement. If the computer model is
used, the trip distribution percentages could be derived from a computer generated “select zone
assignment.” The centroid connectors should accurately represent project access to the street network.
Preferably the project would be represented by its own traffic zone. Some adjustments to the output
volumes may be needed (especially at intersections) to smooth out volumes, quantify peak volumes, adjust
for pass-by and diverted trips, and correct illogical output.
ANALYSIS OF PROJECT EFFECT ON THE ROADWAY SYSTEM
It is recommended that the roadway analysis determine the effect that a project will have for each of the
previously outlined study scenarios. Peak-hour capacity analyses for freeways, roadway segments (ADTs
may be used here to estimate V/C ratios), intersections, and freeway ramps can be conducted for existing,
near-term, and long-term conditions. The methodologies used in determining the traffic effects are not only
critical to the validity of the analysis, they are pertinent to the credibility and confidence the decision-makers
have in the resulting findings, conclusions, and recommendations. Methodologies for roadway capacity
analyses vary by agency and change over time so it is recommended that consultation be conducted with
the lead agency and/or Caltrans to determine an appropriate methodology for a particular study.
NEED FOR ROADWAY IMPROVEMENTS
Table 7-1 indicates when a project’s effect on the roadway system is considered to justify need for roadway
improvements. That is, if a project’s traffic effect causes the values in this table to be exceeded, roadway
improvements should be considered. Table 7-2 provides guidance on the levels of ADT that can be
accommodated on various types of roadways, based on level of service.
It is the responsibility of Caltrans, on Caltrans initiated projects, to analyze the effect of ramp metering, for
initial as well as future operational effect, on local streets that intersect and feed entrance ramps to the
freeway. Developers and/or local agencies, however, should consider improvements to existing ramp meter
facilities, future ramp meter installations, or local streets, when those effects are attributable to new
development and/or local agency roadway improvement projects. When conducting analyses related to
ramp meters, it is recommended that analysts consider calibrating the analysis in the transportation impact
study to observed conditions in the field.
Not all improvement measures can feasibly consist of roadway widening (new lanes or new capacity). A
sample improvement might include financing toward a defined ITS (Intelligent Transportation System)
project, enhanced traffic signal communications project, or active transportation projects. This type of
improvement would allow a project applicant (especially with a relatively small project) to provide
improvements to the roadway system by paying into a local or regional fee program, providing the fee can
be established in the near future.
Other improvement measures may include Transportation Demand Management recommendations –
transit facilities, bike facilities, walkability, telecommuting, traffic rideshare programs, flex-time, carpool
incentives, parking cash-out, complete or partial subsidization of transit passes, etc. Additional
improvement measures may be identified as future technologies and policies evolve.
Guidelines for Transportation Impact Studies in the San Diego Region
Page 7-6
Table 7-1
DETERMINATION OF THE NEED FOR ROADWAY IMPROVEMENTS
LEVEL OF
SERVICE WITH
PROJECT*
ALLOWABLE CHANGE DUE TO PROJECT EFFECT**
FREEWAYS
ROADWAY SEGMENTS
INTERSECTIONS
RAMP***
METERING
V/C SPEED (MPH) V/C SPEED (MPH) DELAY (SEC.) DELAY(MIN.)
E, & F (OR RAMP
METER DELAYS
ABOVE 15 MIN.)
0.01 1 0.02 1 2 2
NOTES:
* All level of service measurements are based upon Highway Capacity Manual (HCM) procedures for peak-
hour conditions. However, V/C ratios for Roadway Segments may be estimated on an ADT/24-hour traffic
volume basis (using Table 7-2 or a similar LOS chart for each jurisdiction). The target LOS for freeways,
roadways, and intersections is generally “D.” For metered freeway ramps, LOS does not apply; however,
ramp meter delays above 15 minutes are considered excessive.
** If a proposed project’s traffic causes the values shown in the table to be exceeded, the effects of the project
are determined to justify improvements. These changes may be measured from appropriate computer
programs or expanded manual spreadsheets. The project applicant shall then identify feasible improvements
within the LTA report that will maintain the traffic facility at the target LOS or restore to pre-project conditions.
If the LOS with the proposed project becomes worse than the target (see above * note), or if the project adds
a significant amount of peak-hour trips to cause any traffic queues to exceed on- or off-ramp storage
capacities, roadway improvements should be considered.
*** See Attachment B for ramp metering analysis.
KEY: V/C = Volume to Capacity ratio
Speed = Speed measured in miles per hour
Delay = Average stopped delay per vehicle measured in seconds for intersections, or minutes
for ramp meters
LOS = Level of Service
Guidelines for Transportation Impact Studies in the San Diego Region
Page 7-7
Table 7-2
ROADWAY CLASSIFICATIONS, LEVELS OF SERVICE (LOS)
AND AVERAGE DAILY TRAFFIC (ADT)
LEVEL OF SERVICE W/ADT
STREET
CLASSIFICATION
LANES
A
B
C
D
E
Expressway 6 lanes 30,000 42,000 60,000 70,000 80,000
Prime Arterial 6 lanes 25,000 35,000 50,000 55,000 60,000
Major Arterial 6 lanes 20,000 28,000 40,000 45,000 50,000
Major Arterial 4 lanes 15,000 21,000 30,000 35,000 40,000
Major Arterial (One-Way) 3 lanes 12,500 16,500 22,500 25,000 27,500
Major Arterial (One-Way) 2 lanes 10,000 13,000 17,500 20,000 22,500
Secondary Arterial/
Collector 4 lanes 10,000 14,000 20,000 25,000 30,000
Collector
(no center lane)
4 lanes
5,000
7,000 10,000
13,000
15,000
Collector
(continuous left-turn lane)
2 lanes
5,000
7,000 10,000
13,000
15,000
Collector
(no fronting property)
2 lanes
4,000
5,500
7,500
9,000
10,000
Collector
(commercial- industrial fronting)
2 lanes
2,500
3,500
5,000
6,500
8,000
Collector
(multi-family) 2 lanes 2,500 3,500 5,000 6,500 8,000
Collector (One-Way) 3 lanes 11,000 14,000 19,000 22,500 26,000
Collector (One-Way) 2 lanes 7,500 9,500 12,500 15,000 17,500
Collector (One-Way) 1 lane 2,500 3,500 5,000 6,500 7,500
Sub-Collector
(single-family) 2 lanes --- --- 2,200 --- ---
NOTES:
1. The volumes and the average daily level of service listed above are only intended as a general planning guideline.
2. Levels of service are not applied to residential streets since their primary purpose is to serve abutting lots, not carry
through traffic. Levels of service normally apply to roads carrying through traffic between major trip generators and
attractors.
Guidelines for Transportation Impact Studies in the San Diego Region
Page 8-1
8.0 TRANSIT
It is recommended that the geographic area examined in the LTA include the following for transit:
All existing transit lines and transit stops within a ½ mile walking distance of the project
Any planned transit lines or upgrades within a ½ mile walking distance of the project
In general, the region-wide goal for evaluating pedestrian, bicycle, and transit facilities is to identify
opportunities to increase connectivity, frequency of service, and level of comfort. Individual jurisdictions
may have different qualitative or quantitative ways of performing these evaluations.
Guidelines for Transportation Impact Studies in the San Diego Region
Page 9-1
9.0 BICYCLE
It is recommended that the geographic area examined in the LTA include the following for bicycle travel:
All roadways adjacent to the project, extending in each direction to the nearest intersection with a
classified roadway or with a Class I path
Both directions of travel should be evaluated
In general, the region-wide goal for evaluating pedestrian, bicycle, and transit facilities is to identify
opportunities to increase connectivity and level of comfort. Individual jurisdictions may have different
qualitative or quantitative ways of performing these evaluations.
Guidelines for Transportation Impact Studies in the San Diego Region
Page 10-1
10.0 PEDESTRIAN
It is recommended that the geographic area examined in the LTA include the following for pedestrians:
All pedestrian facilities directly connected to project access points or adjacent to the project
development, extending in each direction to the nearest intersection with a classified roadway or
connection with a Class I path
Facilities connecting to transit stops within two blocks of the project
Only facilities on the side of the project or along the walking route to transit stop
Additional geographic areas may be included in certain cases to address special cases such as
schools or retail centers
In general, the region-wide goal for evaluating pedestrian, bicycle, and transit facilities is to identify
opportunities to increase connectivity and level of comfort. Individual jurisdictions may have different
qualitative or quantitative ways of performing these evaluations.
Guidelines for Transportation Impact Studies in the San Diego Region
Appendices
APPENDICES
GUIDELINES FOR TRANSPORTATION IMPACT
STUDIES
IN THE SAN DIEGO REGION
Guidelines for Transportation Impact Studies in the San Diego Region
Appendices Page A-1
APPENDIX A
Guidelines for Transportation Impact Studies in the San Diego Region
Appendices Page A-2
ATTACHMENT A Completed by Staff:
Date Received __________________
LOCAL TRANSPORTATION ANALYSIS Reviewer ______________________
SCREEN CHECK Date Screen Check ______________
To be completed by consultant (including page #):
Name of Study _____________________________________________
Consultant ________________________________________________
Date Submitted ____________________________________________
Satisfactory
Indicate Page # in report:
YES
NO
NOT
REQUIRED
pg. ____1. Table of contents, list of figures and list of tables.
pg. ____2. Executive summary.
pg. ____3. Map of the proposed project location.
4. General project description and background information:
pg. ____a. Proposed project description (acres, dwelling units….)
pg. ____b. Total trip generation of proposed project.
pg. ____c. Community plan assumption for the proposed site.
pg. ____5. Parking, transit and on-site circulation discussions are included.
pg. ____6. Map of the Study Area and specific intersections studied in the
traffic report.
pg. ____7. Existing Transportation Conditions:
a. Figure identifying roadway conditions including raised
medians, median openings, separate left and right turn lanes,
roadway and intersection dimensions, bike lanes, parking,
number of travel lanes, posted speed, intersection controls,
turn restrictions and intersection lane configurations.
b. Figure indicating the daily (ADT) and peak-hour volumes.
c. Figure or table showing level of service (LOS) for intersections
during peak hours and roadway sections within the study area
(include analysis sheets in an appendix).
8. Project Trip Generation:
pg. ____Table showing the calculated project generated daily (ADT) and
peak hour volumes.
pg. ____9. Project Trip Distribution using the current travel demand model
(provide a computer plot) or manual assignment if previously
approved. (Identify which method was used.)
10. Project Traffic Assignment:
pg. ____a. Figure indicating the daily (ADT) and peak-hour volumes.
pg. ____b. Figure showing pass-by-trip adjustments, and, if cumulative
trip rates are used.
11. Existing Near-term Cumulative Conditions:
pg. ____a. Figure indicating the daily (ADT) and peak-hour volumes.
pg. ____b. Figure or table showing the projected LOS for intersections
during peak hours and roadway sections within the study area
(analysis sheets included in the appendix).
pg. ____c. Traffic signal warrant analysis (Caltrans Traffic Manual) for
Guidelines for Transportation Impact Studies in the San Diego Region
Appendices Page A-3
Satisfactory
Indicate Page # in report:
YES
NO
NOT
REQUIRED
appropriate locations.
12. Existing Near-term Cumulative Conditions + Proposed Project
(each phase when applicable)
pg. ____a. Figure or table showing the projected LOS for intersections
during peak hours and roadway sections with the project
(analysis sheets included in the appendix).
pg. ____b. Figure showing other projects that were included in the study,
and the assignment of their site traffic.
pg. ____c. Traffic signal warrant analysis for appropriate locations.
13. Horizon Year Transportation Conditions (if project conforms to the
General/ Community Plan):
pg. ____a. Horizon Year ADT and street classification that reflect the
Community Plan.
pg. ____b. Figure or table showing the horizon LOS for intersections
during peak hours and roadway sections with and without the
project (analysis sheets included in the appendix).
pg. ____c. Traffic signal warrant analysis at appropriate locations.
14. Horizon Year Transportation Conditions + Proposed Project (if
project does not conform to the General/Community Plan):
pg. ____a. Horizon Year ADT and street classification as shown in the
Community Plan.
pg. ____b. Horizon Year ADT and street classification for two scenarios:
with the proposed project and with the land use assumed in
the Community Plan.
pg. ____c. Figure or table showing the horizon LOS for intersections
during peak hours and roadway sections for two scenarios:
with and without the proposed project and with the land use
assumed in the Community Plan (analysis sheets included in
the appendix).
pg. ____d. Traffic signal warrant analysis at appropriate locations with the
land use assumed in the General/Community Plan.
pg. ____15. A summary table showing the comparison of Existing, Existing +
Near-term Cumulative, Existing + Near-term Cumulative +
Proposed Project, Horizon Year, and Horizon Year + Proposed
Project (if different from General/Community Plan), LOS on
roadway sections and intersections during peak hours.
pg. ____16. A summary table showing the project’s “significant traffic effects.”
17. Transportation Improvements:
pg. ____a. Table identifying the improvements required that are the
responsibility of the developer and others. A phasing plan is
required if improvements are proposed in phases.
pg. ____b. Figure showing all proposed improvements that include:
intersection lane configurations, lane widths, raised medians,
median openings, roadway and intersection dimensions, right-
of-way, offset, etc.
pg. ____18. The Highway Capacity Manual Operation Method or other
approved method is used at appropriate locations within the study
area.
pg. ____20. Appropriate freeway analysis is included.
Guidelines for Transportation Impact Studies in the San Diego Region
Appendices Page A-4
Satisfactory
Indicate Page # in report:
YES
NO
NOT
REQUIRED
pg. ____21. Appropriate freeway ramp metering analysis is included.
pg. ____22. The traffic study is signed by a California Registered Traffic
Engineer.
THE STUDY SCREEN CHECK FOR THE SUBJECT PROJECT IS:
____________ Approved
____________ Not approved because the following items are missing:
_______________________________________________________________
_______________________________________________________________
_______________________________________________________________
Guidelines for Transportation Impact Studies in the San Diego Region
Appendices
APPENDIX B
Guidelines for Transportation Impact Studies in the San Diego Region
Appendices Page B-1
ATTACHMENT B
RAMP METERING ANALYSIS
Ramp metering analysis should be performed for each horizon year scenario in which ramp metering is
expected. The following table shows relevant information that should be included in the ramp meter
analysis, “Summary of Freeway Ramp Metering Effects.”
LOCATION
DEMAND
(veh/hr)1
METER
RATE
(veh/hr)2
EXCESS
DEMAND
(veh/hr)3
DELAY
(min)4
QUEUE
(feet)5
NOTES:
1 DEMAND is the peak hour demand expected to use the on-ramp.
2 METER RATE is the peak hour capacity expected to be processed through the ramp meter. This value
should be obtained from Caltrans.
3 EXCESS DEMAND = (DEMAND) – (METER RATE) or zero, whichever is greater.
EXCESS DEMAND
4 DELAY = --------------------------- X 60 MINUTES/HOUR
METER RATE
5 QUEUE = (EXCESS DEMAND) X 29 feet/vehicle
NOTE: Delay will be less at the beginning of metering. However, since peaks will almost always be more than one
hour, delay will be greater after the first hour of metering. (See discussion on next page.)
SUMMARY OF FREEWAY RAMP METERING EFFECTS
(Lengthen as necessary to include all affected meter locations)
LOCATION(S)
PEAK
HOUR
PEAK HOUR
DEMAND
D
FLOW
(METER RATE)
F
EXCESS
DEMAND
E
DELAY
(MINUTES)
QUEUE
Q (feet)
AM
PM
AM
PM
AM
PM
Guidelines for Transportation Impact Studies in the San Diego Region
Appendices Page B-2
DISCUSSION OF RAMP METER ANALYSIS
A. CAUTION: The ramp metering analysis shown in Attachment B may lead to grossly understated
results for delay and queue length, since important aspects of queue growth are ignored. Also, the
draft guidelines method derives average values instead of maximum values for delay and queue
length. Utilizing average values instead of maximum values can lead to obscuring important effects,
particularly in regard to queue length.
Predicting ramp meter delays and queues requires a storage-discharge type of analysis, where a
pattern of arriving traffic at the meter is estimated by the analyst, and the discharge, or meter rate, is
a somewhat fixed value set by Caltrans for each individual metered ramp.
Since a ramp meter queue continues to grow longer during all times that the arrival rate exceeds the
discharge rate, the maximum queue length (and hence, the maximum delay) usually occurs after the
end of the peak (or highest) one hour. This leads to the need for an analysis for the entire time period
during which the arrival rate exceeds the meter rate, not just the peak hour. For a similar reason, the
analysis needs to consider that a substantial queue may have already formed by the beginning of the
“peak hour.” Traffic arriving during the peak hour is then stacked onto an existing queue, not just
starting from zero as the draft analysis suggests.
Experience shows that the theoretical queue length derived by this analysis often does not material-
ize. Motorists, after a brief time of adjustment, seek alternate travel paths or alternate times of arrival
at the meter. The effect is to approximately minimize total trip time by seeking out the best combina-
tions of route and departure time at the beginning of the trip. This causes at least two important
changes in the pattern or arriving traffic at ramp meters. First, the peak period is spread out, with
some traffic arriving earlier and some traffic arriving later than predicted. Second, a significant pro-
portion of the predicted arriving traffic will use another ramp, use another freeway, or stay on surface
streets.
It is acceptable to make reasonable estimates of these temporal and spatial (time and occupying
space) diversions as long as all assumptions are stated and that the unmodified, or theoretical
values are shown for comparison.
B. Additional areas for study include being able to define acceptable levels of service (LOS) and
“significant” thresholds (e.g., a maximum ramp meter delay of 15 minutes) for metered freeway
entrance ramps.
Currently there are no acceptable software programs for measuring project effects on metered
freeway ramps nor does the Highway Capacity Manual (HCM) adequately address this issue.
Hopefully in the near future a regionwide study will be initiated to determine what metering rate
(at each metered ramp) would be required in order to guarantee that traffic will flow (even at LOS
“E”) on the entire freeway system during peak-hour conditions. From this, the ramp delays and
resultant queue lengths might then be calculated. Overall, this is a very complex issue that needs
considerable research and refinement in cooperation with Caltrans.
Guidelines for Transportation Impact Studies in the San Diego Region
Appendices
APPENDIX C
Guidelines for Transportation Impact Studies in the San Diego Region
Appendices Page C-1
LEVEL OF SERVICE (LOS) DEFINITIONS (generally used by Caltrans)
The concept of Level of Service (LOS) is defined as a qualitative measure describing operational
conditions within a traffic stream, and their perception by motorists and/or passengers. A Level of Services
definition generally describes these conditions in terms of such factors as speed, travel time, freedom to
maneuver, comfort and convenience, and safety. Levels of Service definitions can generally be
categorized as follows:
LOS D/C* Congestion/Delay Traffic Description
(Used for freeways, expressways and conventional highwaysA)
“A” <0.41 None Free flow.
“B” 0.42-0.62 None Free to stable flow, light to moderate
volumes.
“C” 0.63-0.79 None to minimal Stable flow, moderate volumes, freedom to
maneuver noticeably restricted.
“D” 0.80-0.92 Minimal to substantial Approaches unstable flow, heavy volumes,
very limited freedom to maneuver.
“E” 0.93-1.00 Significant Extremely unstable flow, maneuverability and
psychological comfort extremely poor.
(Used for conventional highways)
“F” >1.00 Considerable Forced or breakdown. Delay measured in
average flow, travel speed (MPH). Signal-
ized segments experience delays >60.0
seconds/vehicle.
(Used for freeways and expressways)
“F0” 1.01-1.25 Considerable
0-1 hour delay
Forced flow, heavy congestion, long queues
form behind breakdown points, stop and go.
“F1” 1.26-1.35 Severe
1-2 hour delay
Very heavy congestion, very long queues.
“F2” 1.36-1.45 Very severe
2-3 hour delay
Extremely heavy congestion, longer queues,
more numerous breakdown points, longer
stop periods.
“F3” >1.46 Extremely severe
3+ hours of delay
Gridlock.
s Level of Service can generally be calculated using the latest Highway Capacity Manual. However,
contact Caltrans for more specific information on determining existing “free-flow” freeway speeds.
* Demand/Capacity ratio used for forecasts (V/C ratio used for operational analysis, where V = volume)
A Arterial LOS is based upon average “free-flow” travel speeds, and should refer to definitions in the
HCM.
N:\Projects\2019_Projects\0341_Carlsbad SB 743 Implementation\GIS\MXD\Carlsbad Layer_TAZ Layering_cleaned_v3.mxd2012 Vehicle Miles Traveled (VMT) per Capita by Traffic Analysis Zone (TAZ)Comparison to City-Wide Average
Carlsbad City Limit
Rail Alignment
2012 VMT/capita compared to City Average 2.52907capita
85% of average or less
85% - 100% of average
Above 100% (above average)
Minimal development (<20 households) defaults to Census Tract value
Note that the VMT/capita presented here was developed by Fehr & Peers using a script to analyze SANDAG model outputs. SANDAG applies their own script which may produce different results. Furthermore, these numbers are based on the ABM1 model version and should be updated as SANDAG releases model updates.
0
-+-
D
D
D
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N:\Projects\2019_Projects\0341_Carlsbad SB 743 Implementation\GIS\MXD\Carlsbad Layer_TAZ Layering_cleaned_v3.mxd2012 Vehicle Miles Traveled (VMT) per Employee by Traffic Analysis Zone (TAZ)Comparison to City-Wide Average&DUOVEDG&LW\/LPLWRail Alignment2012 VMT/HPSOR\HH compared to CityAverage 907HPSOR\HH RIDYHUDJHRUOHVV RIDYHUDJH $ERYH DERYHDYHUDJH 0LQLPDOGHYHORSPHQW HPSOR\HHV GHIDXOWVWR&HQVXV7UDFWYDOXH1RWHWKDWWKH907HPSOR\HHSUHVHQWHGKHUHZDVGHYHORSHGE\)HKU 3HHUVXVLQJDVFULSWWRDQDO\]H6$1'$*PRGHORXWSXWV6$1'$*DSSOLHVWKHLURZQVFULSWZKLFKPD\SURGXFHGLIIHUHQWUHVXOWV)XUWKHUPRUHWKHVHQXPEHUVDUHEDVHGRQWKH$%0PRGHOYHUVLRQDQGVKRXOGEHXSGDWHGDV6$1'$*UHOHDVHVPRGHOXSGDWHV0 -+-D D D @
DRAFT
VEHICLE MILES TRAVELED (VMT)
ANALYSIS GUIDELINES
April 20, 2020
Vehicle Miles Traveled Analysis Guidelines | i
TABLE OF CONTENTS
1 BACKGROUND ............................................................................................................................1
1.1 SB 743 Legislation ......................................................................................................................... 1
1.2 Governor’s Office of Planning and Research (OPR) Technical Advisory ....................................... 1
1.3 Regional Transportation Impact Study Guidelines ....................................................................... 2
1.4 Consistency with City Goals and Policies ...................................................................................... 2
1.5 Discussion of Climate Action Plan and Transportation Demand Management Ordinance .......... 2
2 PURPOSE AND OBJECTIVE OF VMT ANALYSIS ..............................................................................3
2.1 Purpose of VMT Analysis............................................................................................................... 3
2.2 Purpose of VMT Analysis Guidelines............................................................................................. 3
2.3 Coordination with Other Agencies ................................................................................................ 3
2.4 Necessary Qualifications of Individuals Preparing VMT Analyses ................................................ 3
3 LAND DEVELOPMENT PROJECTS ..................................................................................................4
3.1 Overview of Analysis ..................................................................................................................... 4
3.2 Screening Criteria .......................................................................................................................... 5
Small Projects ........................................................................................................................ 5
Projects Located Near Transit ............................................................................................... 5
Local-Serving Retail and Similar Land Uses ........................................................................... 5
Local-Serving Public Facilities ................................................................................................ 7
Affordable Housing Projects ................................................................................................. 7
Redevelopment Projects That Result in a Net Reduction of VMT ........................................ 7
Projects Located in Efficient VMT Areas ............................................................................... 7
3.3 Vehicle Miles Traveled Analysis .................................................................................................... 8
Single Land-Use Residential or Office Projects ..................................................................... 8
Mixed-Use Projects ............................................................................................................... 8
Redevelopment Projects ....................................................................................................... 9
Regional Retail Projects ........................................................................................................ 9
Industrial Projects ................................................................................................................. 9
3.4 Significance Thresholds ............................................................................................................... 10
3.2.1
3.2.2
3.2.3
3.2.4
3.2.5
3.2.6
3.2.7
3.3.1
3.3.2
3.3.3
3.3.4
3.3.5
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3.5 Mitigation .................................................................................................................................... 10
4 TRANSPORTATION PROJECTS .................................................................................................... 12
4.1 Screening Criteria ........................................................................................................................ 12
4.2 Vehicle Miles Traveled Analysis .................................................................................................. 13
4.3 Significance Thresholds ............................................................................................................... 14
4.4 Mitigation .................................................................................................................................... 14
5 ADDITIONAL RESOURCES FOR VEHICLE MILES TRAVELED ANALYSIS ........................................... 15
LIST OF FIGURES
Figure 3-1 – Vehicle Miles Traveled Analysis for Land Use Projects ................................................... 6
APPENDICES
Appendix A – VMT Analysis of Non-Standard Land Use Types
Appendix B – Screening Criteria and Threshold Evidence
Appendix C – Glossary of Terms
Appendix D - Mitigation
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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
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 will be measured under the California
Environmental Quality Act (CEQA). Starting on July 1, 2020, automobile delay and level of service
(LOS) may no longer be 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 will be required. Although there is no requirement to use any particular
metric, the use of VMT has been recommended by the Governor’s Office of Planning and Research
(OPR). This requirement does not modify the discretion lead agencies have to develop their own
methodologies or guidelines, or to analyze impacts to other components of the transportation
system, such as walking, bicycling, transit, and safety. SB 743 also applies to transportation
projects, although agencies were given flexibility in the determination of the performance measure
for these types of projects.
The intent of SB 743 is to bring CEQA transportation analyses into closer alignment with other
statewide policies regarding greenhouse gases, complete streets, and smart growth. Using VMT as
a performance measure instead of LOS is intended to discourage suburban sprawl, reduce
greenhouse gas emissions, and encourage the development of smart growth, complete streets, and
multimodal transportation networks.
1.2 Governor’s Office of Planning and Research (OPR) Technical Advisory
The SB 743 legislation designated OPR to write detailed guidelines for implementation. The process
of writing guidelines started in January 2014 and concluded in 2018. SB 743 was incorporated into
CEQA by the Natural Resources Agency in December 2018 with a required implementation date of
July 1,2020. The incorporation documents included a December 2018 Technical Advisory written
by OPR 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 they are also 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.
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1.3 Regional Transportation Impact Study Guidelines
In May of 2019, the San Diego Section of the Institute of Transportation Engineers (ITE) prepared
an update to the regional Transportation Impact Study Guidelines to incorporate SB 743. The
regional guidelines provided information on aspects of VMT analysis that were not addressed in
OPR’s Technical Advisory. In addition, the regional guidelines differed from some of the
recommendations provided by OPR to address situations local to the San Diego region. In cases
where the regional guidelines differed from OPR’s recommendations, justification was provided
that may be able to be used as substantial evidence.
The regional guidelines do not provide guidance on every aspect of SB 743 and VMT analysis. For
some key decisions, analysis is provided along with a recommendation that final decisions need to
be made by the lead agency.
The regional guidelines prepared by ITE are a technical resource that are not officially sanctioned
by any public agency. Local agencies in the San Diego region can choose to adopt all or portions of
the regional guidelines for use in their agencies and they are also able to develop their own
guidelines if desired.
1.4 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: Walking, Biking, Public Transportation, and Connectivity; Sustainability; and Neighborhood
Revitalization, Community Design, and Livability. It is also consistent with many of the goals and
policies included in the General Plan.
In addition, SB 743 is consistent with the city’s Climate Action Plan and Transportation Management
Ordinance as described below.
1.5 Discussion of Climate Action Plan and Transportation Demand Management
Ordinance
One of the goals of the city’s Climate Action Plan is to reduce greenhouse gases. SB 743 seeks to
reduce VMT. Since the vehicle miles traveled by automobiles produce greenhouse gases, SB 743’s
goal of reducing VMT is consistent with the Climate Action Plan’s goal of reducing greenhouse gas
emissions. The VMT generated by automobiles produces a substantial portion of total greenhouse
gas emissions.
The city’s Transportation Demand Management Ordinance (TDM Ordinance) seeks to reduce the
number of trips generated in the city by encouraging travelers to use ridesharing, transit, bicycling,
and walking. SB 743 seeks to reduce VMT through similar mode shifts. Therefore, the two policies
are consistent even though the TDM Ordinance uses trips as the performance measure and SB 743
uses VMT as a performance measure. Reduction in automobile traffic and a shift to other modes is
a common goal that is shared by these two policies. Additional information is provided in Section
3.5 under mitigation for land development projects and in Appendix D.
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2 PURPOSE AND OBJECTIVE OF VMT ANALYSIS
2.1 Purpose of VMT Analysis
Given the information provided in Chapter 1, the purposes of VMT analysis can be stated as follows:
VMT analysis is needed to meet statewide requirements for transportation analyses
conducted under CEQA.
VMT analysis (along with efforts to reduce VMT) can help support the City of Carlsbad’s
goals and policies related to its General Plan, Climate Action Plan, and Carlsbad Core Values.
2.2 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 in the City of Carlsbad.
They generally follow the state guidance provided in OPR’s Technical Advisory but add detail that
is specific to the San Diego region and the City of Carlsbad.
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.
2.3 Coordination with Other Agencies
Preparation of a VMT analysis will 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 will be needed if a model run of the SANDAG regional travel
model is required.
• Coordination with the North County Transit District (NCTD) will 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.
2.4 Necessary Qualifications of Individuals Preparing VMT Analyses
Normally, a VMT analysis would be prepared under the direction of an individual who is 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.
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3 LAND DEVELOPMENT PROJECTS
This chapter provides guidance on conducting VMT analyses for land development projects, including
single-use projects, mixed-use projects, redevelopment projects, and specific plans.
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.
For large projects (over 2,400 average daily trips), a model run of the regional travel model operated
by the San Diego Association of Governments (SANDAG) is used to determine the project’s
VMT/capita or VMT/employee. For small projects (under 2,400 average daily trips), VMT/capita
and VMT/employee are also based on the regional travel model. However, rather than using an
individual model run for each project, VMT/capita and VMT/employee are determined from maps
prepared by the City of Carlsbad using output from the model. The VMT analysis maps show
VMT/capita and VMT/employee for each traffic analysis zone (TAZ) in the city. TAZ’s are
geographical areas of varying size set up in the regional travel model. The assumption for small
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.
In its Technical Advisory, OPR refers to the process described above for small projects as “map-
based screening”. OPR recommends this methodology for determining which projects are located
in VMT-efficient areas and can therefore be “screened out” from requiring a VMT analysis. The
more detailed process described above for calculating project VMT/capita and VMT/employee
values is recommended in the San Diego Regional Transportation Impact Study Guidelines.
Thresholds of significance for VMT analysis are also based on OPR’s recommendations, but some
refinements have been made to reflect regional and local conditions:
OPR recommends that a residential project may have a significant impact if its VMT/capita
exceeds a level 15% below both regional or city VMT/capita. The City of Carlsbad uses the
same threshold but only uses a comparison to city VMT/capita.
OPR recommends that a residential project may have a significant impact if its
VMT/employee exceeds a level 15% below regional VMT/employee. The City of Carlsbad
uses the same threshold but uses a comparison to city VMT/employee rather than regional
VMT/employee.
OPR recommends that a regional retail project may have a significant impact if causes a net
increase in total VMT. This threshold is also used by the City of Carlsbad.
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OPR does not recommend a specific threshold for industrial projects. In the City of
Carlsbad, an industrial project has a significant impact if its VMT/employee exceeds average
VMT/employee. 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.
Figure 3-1 shows a flow chart that summarizes the VMT analysis process.
3.2 Screening Criteria
Following is a description of projects that would have a less than significant transportation impact
due to project type or location. 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.
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. Project trip generation should
normally be determined using the SANDAG trip generation guide (Not So Brief Guide of
Vehicular Traffic Generation Rates in the San Diego Region, April 2002). Other reliable
sources, such as the current edition of the Institute of Transportation Engineers (ITE) Trip
Generation Manual may be used in cases where the SANDAG trip generation guide has
insufficient information for a particular land use type.
Projects Located Near Transit
Per OPR’s Technical Advisory, residential, retail, or office projects or projects that have a
mix of those uses whose project site boundaries are within one half mile of an existing or
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.
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.
3.2.1
3.2.2
3.2.3
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Figure 3-1
VMT Analysis for Land Development Projects
Daily Project Trips
VMT impacts presumed to be less than significant for certain projects, including local-serving retail projects, affordable
housing projects, and projects within transit priority area. See section 3.2
1.
0 - 110 ADT
VMT Analysis Methodology Level of Significance and Mitigations
Less than significant Impact
110 - 2,400 ADT
Use Carlsbad
VMT Analysis
Maps
Below Threshold
Exceeds Threshold
Less than significant Impact
Mitigate to Below Threshold?
>2,400 ADT
Run SANDAG
Model
Less Than
Significant
Impact
Significant
Impact
YES NO
Project Screening
Yes
No
Is project screened out
from VMT analysis due
to project type or
location?
Regional retail, regional recreation, and regional public facilities would use a model run even if ADT is between 110 and 2,400.2.
1
2
Vehicle Miles Traveled Analysis Guidelines | 7
In the City of Carlsbad, local-serving retail is defined as retail development that is less than
50,000 sq. ft. or retail development greater than 50,000 sq. ft. with an approved market
study indicating that it serves primarily local uses.
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, and public elementary schools, public middle schools, and high schools.
Private schools and charter schools would need to provide a market study to demonstrate
that they are local-serving in order to fit into this category.
Affordable Housing Projects
OPR’s Technical Advisory allows for a less than significant finding for transportation impacts
of residential projects that that are 100% affordable housing located in infill areas.
Affordable housing projects in the City of Carlsbad could take advantage of this
recommendation if they are able to 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 (i.e. a value 15% below the appropriate city average VMT/capita or
VMT/employee).
Projects Located in Efficient VMT Areas
Developments located in certain areas of the City of Carlsbad have been shown to generate
VMT/capita or VMT/employee levels below 15% of city-wide averages and are considered
VMT efficient areas of the city. Typical land development projects located in these areas
would be considered to have a less than significant impact on VMT regardless of project
size.
Mixed-use projects located in efficient VMT areas would be considered to have a less than
significant impact for the entire project if each component of the project was shown to be
below relevant VMT significance thresholds. Otherwise a VMT analysis would need to be
conducted to determine the level of significance.
3.2.4
3.2.5
3.2.6
3.2.7
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3.3 Vehicle Miles Traveled Analysis
For projects that do not meet the criteria listed above, a detailed VMT analysis would be needed.
This section provides guidance on how a VMT analysis would be conducted for various types of land
development projects. See Appendix A or consult city staff for project types that are not listed
below.
Single Land-Use Residential or Office Projects
Typical residential or office single land-use projects generating less than 2,400 ADT 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 a value 15% below the city
average VMT/capita or VMT/employee, a potentially significant impact would be indicated.
Mitigation measures would then be considered.
Typical single land-use projects generating more than 2,400 ADT would use a model run of
the SANDAG regional travel demand model with the project to determine VMT/capita or
VMT/employee. If the resulting VMT/capita or VMT/employee exceeds a value 15% below
the city-wide average VMT/capita or VMT/employee, a potentially 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 project type. Internal capture should be considered in the evaluation of each use.
The Regional Transportation Impact Study Guidelines provide one methodology for
accounting for internal capture, which is described as follows. However, any method used
to evaluate a mixed-project is required to be based on substantial evidence.
Calculate trip generation separately for each component of the mixed-use project using
standard practice.
Determine the reduction in external vehicle trips due to internal capture based on guidance
provided in the ITE Trip Generation manual, MXD methodologies or other techniques.
Apply the reduction in trips to the individual land uses so that the total trip generation of
the individual land uses is equal to the total project trip generation, including internal
capture.
Using the reduced trip generation, determine the VMT/capita or VMT/employee for
applicable land uses. The city’s VMT analysis maps may be used to determine an average
trip length for the land uses within a mixed-use development based on the reported
VMT/capita or VMT/employee in the traffic analysis zone where the project is located. The
number of residents or employees will need to be estimated for each applicable land use.
When using the city’s VMT analysis maps to estimate average trip length, analysts should
be aware that the data produced by the SANDAG is based all resident VMT/capita, so it
3.3.1
3.3.2
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includes the VMT associated with all trips made by the resident for the day, for example
trip from home to daycare to office; office to meeting to office; office to store to home. The
ITE trip generation rate for residential is only home-based trips, i.e. trips that start or end
at the residence. The effect of the distinction between ITE’s data and the data produced
by the SANDAG VMT calculation tool will vary by location, type of project, and other factors.
Compare the VMT/capita or VMT/employee values calculated using the reduced trip
generation to applicable VMT thresholds to determine whether the individual components
of the mixed-use development would be expected to have a significant transportation
impact. If any component of the mixed-use development would be expected to have a
significant transportation impact, the collective project would be considered to have a
significant transportation impact.
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 (i.e. a value 15% below the city average VMT/capita
or VMT/employee or total VMT). Since this analysis would be an efficiency analysis, 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 regional retail projects require a model run. 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 establishment whose primary
purpose is the manufacture of goods. Verify with the city’s Planning Division regarding
whether the project can be considered to be an industrial project. The ITE Trip Generation
manual can be used as a guide in determining which projects are industrial versus other
land use type. The manual includes the following categories of development as industrial:
General Light Industrial
Industrial
Manufacturing
Warehousing (including high-cube warehouses, parcel hubs, fulfillment centers,
and cold storage warehouses)
Data Center
Utility
Special Trade Contractor
3.3.3
3.3.4
3.3.5
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Typical industrial projects generating less than 2,400 ADT 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 city 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 with the project to determine VMT/employee. If
the resulting VMT/employee exceeds the city-wide 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.
3.4 Significance Thresholds
Significance thresholds for land development projects are summarized below. Additional
discussion and substantial evidence can be found in Appendix B.
Residential Projects: A significant transportation impact occurs if the project VMT per
capita exceeds a level 15% below the city average VMT per capita
Office Projects: A significant transportation impact occurs if the project VMT per employee
exceeds a level 15% below the city average VMT per 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 per
employee exceeds the average city VMT per employee
City average VMT per capita and VMT per employee values are determined using the SANDAG
regional travel demand model. The appropriate values can be obtained from the City of Carlsbad
analysis maps.
3.5 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. TDM strategies are included as part of the
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City of Carlsbad Climate Action Plan (see Section 4.8 of the Climate Action Plan) that provides a
long-range approach to reduce Carlsbad’s greenhouse gas (GHG) emissions. By reducing
transportation VMT, TDM measures contribute to reduced GHG emissions.
See Appendix D for additional information on mitigation measures for land development projects.
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4 TRANSPORTATION PROJECTS
SB 743 also applies to transportation projects. Per the adoption language when SB 743 was incorporated
into CEQA by the Natural Resources Agency, lead agencies have the discretion to continue using level of
service and delay as the performance measure to determine the impacts of transportation projects or to
choose a different performance measure. As recommended in OPR’s Technical Advisory, the City of
Carlsbad has decided to use 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
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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, the typical approach would be to use the SANDAG
regional travel model 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 may also be possible to manually calculate VMT for a small-scale transportation project
if the size of the project would so small as to be inappropriate for inclusion in a regional travel
model.
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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 or the San Diego Regional Transportation Impact Study Guidelines.
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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:
• City of Carlsbad VMT Analysis Maps: (To be added later)
• Governor’s Office of Planning and Research (ORP): http://www.opr.ca.gov/ceqa/updates/sb-
743/
• California Air Pollution Control Officers Association (CAPCOA). This organization has provided
one of the most widely used resources for VMT mitigation (Quantifying Greenhouse Gas
Mitigation Measures, August2010). It can be found at the following website:
http://www.capcoa.org/wp-content/uploads/2010/11/CAPCOA-Quantification-Report-9-14-
Final.pdf
• SANDAG Mobility Management Project and VMT Reduction Tool:
https://www.icommutesd.com/planners/tdm-local-governments
• Caltrans SB 743 Website: https://dot.ca.gov/programs/transportation-planning/office-of-smart-
mobility-climate-change/sb-743
• San Diego Section of the Institute of Transportation Engineers and the San Diego Regional
Transportation Impact Study Guidelines: https://sandiegoite.org/tcm-task-force
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VEHICLE MILES TRAVELED ANALYSIS GUIDELINES
APPENDIX A
VMT ANALYSIS
FOR NON-
STANDARD LAND
USE TYPES
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TABLE A-1: VMT OF NON-STANDARD LAND USE TYPES
LAND USE TYPE BASIS FOR DETERMINATION OF A
SIGNIGICANT VEHICLE MILES TRAVELED
(VMT) IMPACT
Religious (Local-Serving) See local-serving retail
Religious (Regional) See regional retail
Education (Local-Serving) See local-serving retail
Education (Regional) See regional retail
Hotel See office
Medical Office (Local-Serving) See local-serving retail
Hospital or Regional-Service Medical See regional retail
Library See local-serving retail
VEHICLE MILES TRAVELED ANALYSIS GUIDELINES
APPENDIX B
SCREENING
CRITERIA AND
THRESHOLD
EVIDENCE
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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, Chapter 4 for Update of the General Plan and Community
plans, and Chapter 5 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 VMT analysis, if any of the
following criteria are established, based on substantial evidence.
Projects in Low VMT Areas
If a residential project is located in an area where VMT per capita is does not exceed 15 percent below
the city average, or an office project is located in an area where VMT per employee does not exceed 15
percent below the city average, or an industrial project is located in an area where the VMT per employee
is below the city average, the project is presumed to result in a less than significant transportation impact.
Evidence – This presumption is consistent with the Office of Planning and Research Technical Advisory on
Evaluating Transportation Impacts in CEQA (December 2018) (OPR Technical Advisory), which provides
that “residential and office projects that locate in areas with low VMT, and that incorporate similar
features (i.e., density, mix of uses, transit accessibility), will tend to exhibit similarly low VMT. Maps
created with data from a travel survey or travel demand model can illustrate areas that are currently
below threshold. Because new development in such locations would likely result in a similar level of VMT,
such maps can be used to screen out residential and office projects from needing to prepare a detailed
VMT analysis.”
Evidence – Purely industrial uses are desired to be located in less VMT efficient, higher VMT areas in the
City of Carlsbad. Placing these land intensive uses in areas with less efficient VMT allows land in efficient
VMT areas to be more effectively utilized as high density residential and commercial uses. This threshold
will encourage industrial uses to develop in locations appropriate for industrial uses, leaving infill and more
VMT efficient areas available for more dense uses.
Specifically, the OPR Technical Advisory provides that “of 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.”
Small Projects
Small projects, which are whole projects with independent utility 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
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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. Withing the City of
Carlsbad, this would apply to projects within one half mile of the Carlsbad Village or Carlsbad Poinsettia
Coaster stations. 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.”).
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.
Evidence – The OPR Technical Advisory provides that “because new retail 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.” 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.
Local-Serving Public Facilities
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.
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Evidence – 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
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.
Redevelopment Projects That Cause a Net Reduction in VMT
A redevelopment project 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 – 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.”
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 per capita, measured against the
region or city, may indicate a less-than-significant transportation impact.”
Office/Employment Projects
Threshold – 15% below city average VMT/Employee.
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Evidence – The OPR Technical Advisory provides that “office projects that would generate vehicle travel
exceeding 15 percent below existing VMT per employee for the region may indicate a significant
transportation impact.”
Evidence – Although the OPR Technical Advisory provides evidence on a statewide basis that employment
projects only be compared to regional VMT/employee averages, the San Diego region in which the City of
Carlsbad in located is the third largest region in California (after the Los Angeles Area and the San Francisco
Bay Area). While some employment trips are made across the region (or even outside the region), there
is a large incentive to live and work within a relatively short distance, even within the same city or
community, to avoid the relatively long commute distances that can be experienced by traveling across
the region during peak commute hours. Comparison on a regional basis would compare employment trips
based in Carlsbad to employment trips based in distant employment areas such as downtown San Diego
and Otay Mesa. Due to the size of the San Diego region, it is appropriate to apply the threshold OPR
recommends for residential projects (i.e. comparison to either the regional or City average) to office
projects in the City of Carlsbad.
Evidence - Use of an employment project VMT threshold based on regional averages would favor projects
that are built in VMT-efficient areas of the San Diego region. These areas are generally located in relatively
distant areas outside the City of Carlsbad. While this would appear to lower VMT on a project-by-project
basis, analysis of VMT at an overall level produces a different result. Employers located in the City of
Carlsbad tend to attract employees from Carlsbad and the neighboring cities. Location of all future
employment projects in VMT-efficient areas of the region would produce a jobs/housing imbalance in the
City of Carlsbad and the neighboring cities. From the overall VMT point of view, a more favorable result
would be to locate future employment in VMT-efficient areas of the City of Carlsbad based on a
VMT/employee threshold calculated using the city-wide VMT/employee average. This would promote
shorter commute distances and lower levels of VMT generation for employees within Carlsbad and the
neighboring cities. Per Senate Bill 743, the criteria used to evaluate transportation impacts shall promote
a diversity of land uses.
Industrial Projects
Threshold – At or below city 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 per employee. Industrial land uses are land intensive; therefore,
placing industrial land uses in less urban areas characterized by having higher VMT per 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 as it recognizes that industrial uses,
which are relatively lower total VMT generating uses are most appropriate in areas that have a lower
potential to reduce VMT because it results in more available land within areas with a high potential to
achieve VMT reductions available for more dense development.
Regional Retail
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Regional retail uses are retail uses that are larger than 50,000 square feet of total gross floor area and 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 retail 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…Regional-serving retail development,… which can lead to
substitution of longer trips for shorter ones, may tend to have a significant impact. Where such
development decreases VMT, lead agencies should consider the impact 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
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
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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
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
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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 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.
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APPENDIX C
GLOSSARY OF
TERMS
VEHICLE MILES TRAVELED ANALYSIS GUIDELINES
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To Be Included in Next Revision
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APPENDIX D
MITIGATION
VEHICLE MILES TRAVELED ANALYSIS GUIDELINES
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VMT REDUCTION STRATEGIES UNDER CEQA
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. TDM strategies are included as part of the City of Carlsbad
Climate Action Plan (see Section 4.8 of the Climate Action Plan) that provides a long-range approach to
reduce Carlsbad’s greenhouse gas (GHG) emissions. By reducing transportation VMT, TDM measures
contribute to reduced GHG emissions.
QUANTIFYING TDM EFFECTIVENESS
To be effective mitigation measures, TDM strategies must have sufficient evidence to quantify the level
of VMT reduction that a strategy could achieve for a given project site. In general, the TDM strategies
can be quantified using the methodologies described in Quantifying Greenhouse Gas Mitigation
Measures (California Air Pollution Control Officers Association (CAPCOA), 2010) or the SANDAG Mobility
Management Guidebook/VMT Reduction Calculator Tool; however, there are some important
limitations for project site applications and combining strategies as explained below. Other
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.
Table 1 identifies common TDM measures that are included in the CAPCOA report, the SANDAG
calculator tool, the City of Carlsbad TDM Menu of Options (from the Ordinance), or that Fehr & Peers
has observed used in other jurisdictions within the County of San Diego. This table provides a
description of each measure with example applications where applicable, notes on which measures
must be grouped with others to be effective, a range of effectiveness (if available), and guidance for the
application of each measure for VMT reduction.
Some of the 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. As described in the CAPCOA report, 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
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quantify the VMT reduction that results from combining strategies, the formula below can be applied
absent additional knowledge or information:
𝑇𝑜𝑡𝑎𝑙 𝑉𝑀𝑇 𝑅𝑒𝑑𝑢𝑐𝑡𝑖𝑜𝑛 = (1 − 𝑃a) ∗ (1 – 𝑃b) ∗ (1 – 𝑃c) ∗ …
Where:
𝑃x = 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 VMT reduction of a combination of strategies, the effectiveness of each strategy
should be calculated using the same method consistently. For example, the effectiveness of a program
with both parking policies and a carpool program should not calculate the reduction due to parking
using the CAPCOA formula and the reduction due to carpooling using the SANDAG calculator tool.
Instead, the same tool should be applied to all strategies before determining the total VMT reduction by
using the dampening equation.
While the SANDAG calculator tool includes this dampening equation for determining combined VMT
effectiveness, the calculator tool has other limitations that must be noted. For one, the SANDAG
calculator tool is divided into two scales: 1) Project scale and 2) Community/City scale. The calculator
tool does not allow for community/city level strategies to be applied at the project scale, which limits
project scale strategies to: employer commute programs, land use strategies (mixed-use development
and transit-oriented development), and parking (parking cash-out and pricing). Furthermore, care must
be taken when utilizing the calculator tool because the tool can result in very large VMT reductions for
certain strategies, including in suburban contexts. The calculator tool does not account for the category
and global maximum reductions that are reasonable for a project based on the land use context, as
CAPCOA does (see CAPCOA report page 55).
Per CAPCOA, category-specific maximum reasonable VMT reductions are identified depending on the
surrounding land use of a project. For the City of Carlsbad, which is comprised mostly of suburban land
uses, CAPCOA indicates that the combination of any land uses strategies is expected to provide a
maximum feasible combined reduction of 5 percent. Similar maximums are provided for each category
of measures, as well as for combined effectiveness across categories. Within Carlsbad, the combination
of all measures is expected to have a maximum feasible overall reduction of 20 percent. For a TDM
Program consisting of many measures, care must be taken to verify that the calculated VMT reductions
account for these maximums within each category and combined effectiveness across categories.
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Table 1: TDM Measure Summary
TDM Method Description Applicable
Land Use
CAPCOA
Measure (if
applicable)1
SANDAG Calculator
Tool Application
Level (if applicable)2
Part of Carlsbad
TDM Menu?
Range of
Effectiveness3 CAPCOA Calculation Notes SANDAG Mobility Management
Toolbox Calculation Notes
Employment Measures
Voluntary
Employer
Commute Program
A multi-strategy program implemented by employers on a
voluntary basis. The program includes:
Carpooling encouragement
Ride-matching assistance
Preferential carpool parking
Flexible works schedules for carpools
Half time transportation coordinator
Vanpool assistance
Bicycle end-trip facilities
Retail
Office
Industrial
Mixed-Use
TRT-1 Project-Level
1.0-6.2%
(CAPCOA)
Up to 6.2%
(SANDAG)
The TDM calculation should be based
on the effectiveness of the program
and not each individual measure to
avoid double-counting. Also, either but
not both of a Voluntary and Mandatory
Program should be applied to prevent
double-counting.
The SANDAG Tool ensures that
double-counting does not occur with
individual carpool, vanpool, or transit
subsidy mitigation measures. The
SANDAG Tool also ensures that
double-counting does not occur
between multi-strategy programs by
requiring that either but not both of a
Voluntary and Mandatory Program be
selected. Note that Project-Level and
Community-Level measures cannot be
combined.
Mandatory
Employer
Commute Program
A similar program to the Voluntary one described above, but
where participation is required. A reduction goal is specified, and
ongoing monitoring and reporting assesses the program’s
effectiveness.
It is noted that the City of Carlsbad TDM Ordinance does not
qualify as a mandatory employer commute program because
employees are not necessarily required to participate in the
provided TDM program under the Ordinance.
Retail
Office
Industrial
Mixed-Use
TRT-2 Project-Level
4.2-21.0%
(CAPCOA)
Up to 26.0%
(SANDAG)
The TDM calculation should be based
on the effectiveness of the program
and not each individual measure to
avoid double-counting. Also, either but
not both of a Voluntary and Mandatory
Program should be applied to prevent
double-counting.
The SANDAG Tool ensures that
double-counting does not occur with
individual carpool, vanpool, or transit
subsidy mitigation measures. The
SANDAG Tool also ensures that
double-counting does not occur
between multi-strategy programs by
requiring that either but not both of a
Voluntary and Mandatory Program be
selected. However, the tool allows a
maximum reduction of 26 percent for
this measure, which exceeds the
maximum feasible reduction for a
suburban area (20 percent) as
provided by the CAPCOA report. Also
note that Project-Level and
Community-Level measures cannot be
combined.
Telecommuting
and Alternative
Work Schedules
This strategy relies on effective internet access and speeds to
individual project sites/buildings to provide the opportunity for
telecommuting. The effectiveness of the strategy depends on the
ultimate building tenants and this should be a factor in
considering the potential VMT reduction. Example applications
include: telework, compressed work week, staggered shifts.
Retail
Office
Industrial
Mixed-Use
TRT-6 Project-Level X (only flex-work
aspect)
0.07-5.50%
(CAPCOA)
Up to 44.0%
(SANDAG)
The SANDAG tool allows a maximum
reduction of 44 percent for this
measure, which exceeds the maximum
feasible reduction for a suburban area
(20 percent) as provided by the
CAPCOA report. Also note that
Project-Level and Community-Level
measures cannot be combined.
Price Workplace
Parking
Implement workplace parking via charging for parking, charge
above market rate pricing, and/or validating parking for guests.
Reductions apply only if complementary strategies are in place to
limit spill-over to on-street parking.
Retail
Office
Industrial
Mixed-Use
TRT-14 Project-Level X
0.1-19.7%
(CAPCOA)
Up to 7.5%
(SANDAG)
The SANDAG Tool ensures that
double-counting does not occur with
Voluntary or Mandatory Commute
Programs. Note that Project-Level and
Community-Level measures cannot be
combined.
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Table 1: TDM Measure Summary
TDM Method Description Applicable
Land Use
CAPCOA
Measure (if
applicable)1
SANDAG Calculator
Tool Application
Level (if applicable)2
Part of Carlsbad
TDM Menu?
Range of
Effectiveness3 CAPCOA Calculation Notes SANDAG Mobility Management
Toolbox Calculation Notes
Employee Parking
Cashout
Provide employees with a choice of forgoing parking for a cash
payment equivalent to the cost of the parking space to the
employer. Reductions apply only if complementary strategies are
in place to limit spill-over to on-street parking.
Retail
Office
Industrial
Mixed-Use
TRT-15 Project-Level X
0.6-7.7%
(CAPCOA)
Up to 12.0%
(SANDAG)
The SANDAG Tool ensures that
double-counting does not occur with
Voluntary or Mandatory Commute
Programs. Note that Project-Level and
Community-Level measures cannot be
combined.
Bike Parking in
Non-Residential
Projects
Provide short-term and long-term bicycle parking facilities to meet
peak season demand.
Retail
Office
Industrial
Mixed-Use
SDT-6 grouped
Note that this measure must be
grouped with Improve Design of
Development (LUT-9) in order to
quantify its effectiveness.
Market Pricing for
Public Parking
(On-Street)
Implement a pricing strategy for on-street parking near the project
for all CBD/employment center/retail center on-street parking.
Pricing should be designed to encourage “park once” behavior.
Retail
Office
Mixed-Use
PDT-3 2.8-5.5%
Note that this measure is only effective
if spillover parking is controlled (i.e.,
residential permits). This measure may
not be effective in areas outside of
central business/activity centers.
Subsidize Walking
Expenses
Subsidize walking expenses in order to encourage employees to
walk. Example applications include reimbursing cost of shoes,
reflective vests, headlamps/flashlight.
Retail
Office
Industrial
Mixed-Use
grouped grouped
Note that this measure must be
grouped with a Commute Trip
Reduction Program (TRT-1 or TRT-2) in
order to quantify its effectiveness.
Subsidize Bicycle
Expenses
Subsidize bicycling expenses in order to encourage employees to
bike. Example applications include monetary contributions for
bikes, bike repair, helmets, reflective vests, etc.
Retail
Office
Industrial
Mixed-Use
grouped grouped
Note that this measure must be
grouped with a Commute Trip
Reduction Program (TRT-1 or TRT-2) in
order to quantify its effectiveness.
Commuter
Recognition
Program
Implement a program to track employee commute trips and
recognize top commuters with prizes, newsletter features, and
email blasts.
Retail
Office
Industrial
Mixed-Use
grouped X grouped
Promotional
Events
Participate and promote regional events that encourage
alternative commute options, and possibly organize worksite
events in parallel with regional events.
Retail
Office
Industrial
Mixed-Use
X
Note that this measure must be
grouped with a Commute Trip
Reduction Program (TRT-1 or TRT-2) in
order to quantify its effectiveness.
Raffle Contests Reward employees who commute using alternate modes by
entering them into raffle drawings for prizes.
Retail
Office
Industrial
Mixed-Use
X
Guaranteed Ride
Home (GRH)
Refer individuals to iCommute to sign up for the program for
employees who use non-driving for their commute to have a
safety net when they have an emergency.
Retail
Office
Industrial
Mixed-Use
grouped X grouped
Note that this measure must be
grouped with a Commute Trip
Reduction Program (TRT-1 or TRT-2) in
order to quantify its effectiveness.
Pre-Tax Commuter
Benefits
Allow employees to set aside pre-tax income for qualified
commute expenses.
Retail
Office
Industrial
Mixed-Use
X
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Table 1: TDM Measure Summary
TDM Method Description Applicable
Land Use
CAPCOA
Measure (if
applicable)1
SANDAG Calculator
Tool Application
Level (if applicable)2
Part of Carlsbad
TDM Menu?
Range of
Effectiveness3 CAPCOA Calculation Notes SANDAG Mobility Management
Toolbox Calculation Notes
Residential Measures
Affordable and
Below Market Rate
Housing
Provide affordable housing, which provides greater opportunity for
lower income families to live closer to jobs centers and achieve
jobs/housing match near transit, and allows a greater number of
families to be accommodated within a given building footprint.
Residential
Mixed-Use LUT-6 0.04-1.2%
School Pool
Program
Provide a ridesharing program for school children who do not
currently have access to school bus service due to location or type
of school.
Residential
Mixed-Use TRT-10 7.2-15.8% Note that this measure’s effectiveness
only applies to school-related VMT.
School Bus
Program
Coordinate with school district to expand school bus service to the
project site.
Residential
Mixed-Use TRT-13 38.0-63.0% Note that this measure’s effectiveness
only applies to school-related VMT.
Bike Parking with
Multi-Unit
Residential
Projects
Provide long-term bicycle parking in apartment complexes or
condominiums without garages. Residential SDT-7 grouped
Note that this measure must be
grouped with Improve Design of
Development (LUT-9) in order to
quantify its effectiveness.
Employment and Residential Measures
Increase Land Use
Density
Increase the density of land use in an area in order to lower vehicle
mode share. This is particularly effective when focused near major
transit stops as Transit Oriented Development.
Residential
Retail
Office
Industrial
Mixed-Use
LUT-1 1.5-30.0%
Increase Location
Efficiency
Locate projects within infill or suburban center areas in order to
take advantage of built-out centers offering a variety of land uses.
Residential
Retail
Office
Industrial
Mixed-Use
LUT-2 10.0-65.0%
Increase Land Use
Diversity
Provide a variety of land uses within a single project. In the
suburban context of Carlsbad, projects would include three of the
following within ¼ mile of the project:
- Residential
- Retail
- Park
- Open Space
- Office
Mixed-Use LUT-3 Project-Level
9-30%
(CAPCOA)
Up to 30.0%
(SANDAG)
The SANDAG tool allows a maximum
reduction of 30 percent for this
measure, which exceeds the maximum
feasible reduction for a suburban area
(20 percent) as provided by the
CAPCOA report. Also note that
Project-Level and Community-Level
measures cannot be combined.
Increase
Destination
Accessibility
Locate the project near a major job center.
Residential
Retail
Office
Industrial
Mixed-Use
LUT-4 6.7-20.0%
Increase Transit
Accessibility
Locate the project near a major transit center to increase the
likelihood of project site/building tenants utilizing transit for travel.
Residential
Retail
Office
Industrial
Mixed-Use
LUT-5 Project-Level
0.5-24.6%
(CAPCOA)
Up to 14.4%
(SANDAG)
Note that Project-Level and
Community-Level measures cannot be
combined.
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Table 1: TDM Measure Summary
TDM Method Description Applicable
Land Use
CAPCOA
Measure (if
applicable)1
SANDAG Calculator
Tool Application
Level (if applicable)2
Part of Carlsbad
TDM Menu?
Range of
Effectiveness3 CAPCOA Calculation Notes SANDAG Mobility Management
Toolbox Calculation Notes
Orient Project
Toward Non-Auto
Corridor
Design the project around an existing or planned transit, bicycle,
or pedestrian corridor to encourage alternative mode use. This
measure is most effective when applied in combination of multiple
design elements that encourage non-auto use.
Residential
Retail
Office
Industrial
Mixed-Use
LUT-7 grouped
This measure must be grouped with
Increase Land Use Diversity (LUT-3) in
order to quantify its effectiveness.
Locate Project near
Bike Path/Bike
Lane
Locate the project near an existing or planned bike lane or bike
path. This measure is most effective when applied in combination
of multiple design elements that encourage bike use.
Residential
Retail
Office
Industrial
Mixed-Use
LUT-8 grouped
This measure must be grouped with
Increase Destination Accessibility
(LUT-4) in order to quantify its
effectiveness.
Improve Design of
Development
Enhance walkability and connectivity through characteristics such
as block size, intersection density, sidewalk coverage, pedestrian
crossings, etc.
Residential
Retail
Office
Industrial
Mixed-Use
LUT-9 Community-Level
3.0-21.3%
(CAPCOA)
Up to 6.0%
(SANDAG)
Note that Project-Level and
Community-Level measures cannot be
combined.
Bike Lane Street
Design (on-site)
Incorporate bicycle lanes, routes, and shared-use paths
throughout street systems, new subdivisions, and large
developments. Example applications include: bicycle facilities,
signage and green paint.
Residential
Retail
Office
Industrial
Mixed-Use
SDT-5 grouped
Note that this measure is grouped with
Improve Design of Development
(LUT-9) in order to quantify its
effectiveness.
Electric Vehicle
Charging
Provide accessible electric vehicle charging and parking spaces
with signage to prohibit parking for non-electric vehicles. This
could also include electrified parking for bicycles or micromobility.
Residential
Retail
Office
Industrial
Mixed-Use
SDT-8 grouped
Note that this measure must be
grouped with NEV Network (SDT-3) in
order to quantify its effectiveness.
Pedestrian
Network
Improvements
Create a pedestrian network within the project and provide
connections to nearby destinations. Projects in the City of Carlsbad
tend to be smaller so the emphasis of this strategy would likely be
the construction of network improvements that connect the
project site directly to nearby destinations. Alternatively,
implementation could occur through an impact fee program or
benefit/assessment district targeted to various areas in the city
designated for improvements through local or regional plans.
Example applications include:
Construction of pedestrian resting area/recreation node
Widening of sidewalk within the existing right-of-way
Pop-outs or curb extensions
High-visibility crosswalk
Enhanced crosswalk paving
Pedestrian enhancing hardscape (ex. median refuges)
Pedestrian countdown signals
Widening sidewalk (beyond required)
Residential
Retail
Office
Industrial
Mixed-Use
SDT-1 Community-Level X
0.0-2.0%
(CAPCOA)
Up to 1.4%
(SANDAG)
Note that Project-Level and
Community-Level measures cannot be
combined.
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Table 1: TDM Measure Summary
TDM Method Description Applicable
Land Use
CAPCOA
Measure (if
applicable)1
SANDAG Calculator
Tool Application
Level (if applicable)2
Part of Carlsbad
TDM Menu?
Range of
Effectiveness3 CAPCOA Calculation Notes SANDAG Mobility Management
Toolbox Calculation Notes
Bicycle Network
Improvements
Provided dedicated bike facilities to provide connections to nearby
destinations. Projects in the City of Carlsbad tend to be smaller so
the emphasis of this strategy would likely be the construction of
network improvements that connect the project site directly to
nearby destinations. Alternatively, implementation could occur
through an impact fee program or benefit/assessment district
targeted to various areas in the city designated for improvements
through local or regional plans. Example applications include:
Enhanced bicycle conflict paving
Bike signals
Protected intersections
Widening or upgrading bike facility (beyond required)
Residential
Retail
Office
Industrial
Mixed-Use
Community-Level X Up to 5.0%
(SANDAG)
The SANDAG Tool ensures that
double-counting does not occur
between implementing a
comprehensive bicycle network
expansion as opposed to adding
individual bike facilities. Note that
Project-Level and Community-Level
measures cannot be combined.
Non-Motorized
Zones
Convert a percentage of roadway miles in a central business
district to transit malls, linear parks, or other non-motorized zones.
Residential
Retail
Office
Industrial
Mixed-Use
SDT-4 grouped
Note that this measure must be
grouped with Pedestrian Network
Improvements (SDT-1) in order to
quantify its effectiveness.
Vanpool/Shuttle
Program
Program offering employer-purchased or leased vehicles to
provide commute transportation for project site/building tenants.
Residential
Office
Industrial
Mixed-Use
TRT-11 Project-Level X
0.3-13.4%
(CAPCOA)
Up to 7.1%
(SANDAG)
While CAPCOA does not indicate that
this measure is applicable to residential
projects, the iCommute program would
allow for residential developments in
the San Diego region to leverage this
TDM measure.
Note that Project-Level and
Community-Level measures cannot be
combined.
Ride-sharing
Program
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.,
Uber Pool, Lyft Line, Waze Carpool).
Residential
Retail
Office
Industrial
Mixed-Use
TRT-3 Project-Level X
1.0-15.0%
(CAPCOA)
Up to 7.1%
(SANDAG)
Note that Project-Level and
Community-Level measures cannot be
combined.
Transit Fare
Reduction Reduce transit fares system-wide or in specific zones.
Small citywide
Large Multi-use
Developments
Community-Level Up to 1.2%
(SANDAG)
Note that Project-Level and
Community-Level measures cannot be
combined.
Transit Pass
Subsidy
Subsidized or discounted public transit passes are provided to
project site/building tenants. Example applications include:
Subsidized/discounted daily or monthly public transit
passes
Free transfers between all shuttles and transit
Residential
Retail
Office
Industrial
Mixed-Use
TRT-4 Project-Level X
0.3-20.0%
(CAPCOA)
Up to 10.9%
(SANDAG)
Note that Project-Level and
Community-Level measures cannot be
combined.
End of Trip
Facilities
Non-residential projects provide facilities such as showers or
secure bike lockers to encourage commuting by bike. This strategy
is supportive in nature and can help boost the effectiveness of the
other strategies listed.
Residential
Retail
Office
Industrial
Mixed-Use
TRT-5 X grouped
Note that this measure must be
grouped with the Voluntary Employer
Commute Program (TRT-1), Mandatory
Employer Commute Program (TRT-2),
or Employer Ride-sharing Program
(TRT-3) in order to quantify
effectiveness. The measure should only
be grouped with one of the above
measures to avoid double-counting.
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Table 1: TDM Measure Summary
TDM Method Description Applicable
Land Use
CAPCOA
Measure (if
applicable)1
SANDAG Calculator
Tool Application
Level (if applicable)2
Part of Carlsbad
TDM Menu?
Range of
Effectiveness3 CAPCOA Calculation Notes SANDAG Mobility Management
Toolbox Calculation Notes
Commute Trip
Reduction
Marketing
Promote and advertise various transportation options, including
promoting information and resources regarding SANDAG’s
iCommute program, which provides support to commuters
through a variety of TDM measures such as carpool matching
services, vanpool, and other services.
Residential
Retail
Office
Industrial
Mixed-Use
TRT-7 Community-Level X
0.8-4.0%
(CAPCOA)
Up to 2.0%
when grouped
with customized
travel planning
(SANDAG)
Note that Project-Level and
Community-Level measures cannot be
combined.
Preferential
Parking Permit
Incentivize carpool, vanpool, ride-share, car-share, or alternatively
fueled vehicles through discounted or priority parking.
Residential
Retail
Office
Industrial
Mixed-Use
TRT-8 X grouped
Note that this measure must be
grouped with the Voluntary Employer
Commute Program (TRT-1), Mandatory
Employer Commute Program (TRT-2),
or Employer Ride-sharing Program
(TRT-3) in order to quantify
effectiveness. The measure should only
be grouped with one of the above
measures to avoid double-counting.
Car-Sharing
Program
Provide convenient access to a shared vehicle in order to reduce
the need to own a vehicle or reduce the number of vehicles owned
by a household. Note that implementation of this strategy would
require regional or local agency implementation and coordination
and would not likely be applicable for individual development
projects.
Residential
Retail
Office
Industrial
Mixed-Use
TRT-9 Community-Level X
0.4-0.7%
(CAPCOA)
Up to 0.7%
(SANDAG)
Note that Project-Level and
Community-Level measures cannot be
combined.
Bike-sharing
Program
Provide shared bicycles for employees to use to access nearby
transit or commercial centers. Note that this measure is most
applicable to the suburban-center areas of Carlsbad, and will be
most effective when complemented by enhanced bike facilities.
Residential
Retail
Office
Industrial
Mixed-Use
TRT-12 Community-Level X
grouped
(CAPCOA)
Up to 0.1%
(SANDAG)
Note that this measure must be
grouped with Incorporate Bike Lane
Street Design (SDT-5) or Improve
Design of Development (LUT-9) in
order to quantify its effectiveness.
Note that Project-Level and
Community-Level measures cannot be
combined.
Neighborhood
Electric Vehicle
(NEV) Network
Create a local “light” vehicle network that provides a network for
NEVs or other similar “low speed vehicles”. The necessary
infrastructure including the following should also be implemented:
NEV parking, charging facilities, striping, signage, and education
tools.
In Carlsbad, an electric bike share program would combine a bike
share program with electric bikes, which is a type of electric vehicle
similar to the NEV program considered by CAPCOA. Placed
strategically throughout the city, this measure would support the
provision of a low-stress bicycle network as more people would
have access to bicycles. The electric features of the bicycles also
make cycling feasible for longer trips with greater elevation
changes than would be appealing with a standard bicycle.
Small citywide
Large Multi-use
Developments
SDT-3 Community-Level
X (only electric
bike- and
scooter-share)
0.5-12.7%
(CAPCOA)
Up to 0.1%
(SANDAG)
Note that Project-Level and
Community-Level measures cannot be
combined.
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Table 1: TDM Measure Summary
TDM Method Description Applicable
Land Use
CAPCOA
Measure (if
applicable)1
SANDAG Calculator
Tool Application
Level (if applicable)2
Part of Carlsbad
TDM Menu?
Range of
Effectiveness3 CAPCOA Calculation Notes SANDAG Mobility Management
Toolbox Calculation Notes
Residential Area
Parking Permits
Require the purchase of residential parking permits (RPPs) for
long-term use of on-street parking in residential areas. Projects
with non-residential land use may institute residential area parking
permits in order to limit spillover parking from their employees.
Residential
Retail
Office
Industrial
Mixed-Use
PDT-4 grouped
Note that this measure must be
grouped with at least one of the
following: Parking Supply Limitations
(PDT-1), Unbundle Parking Costs from
Property Cost (PDT-2), Market Rate
Parking Pricing (PDT-3) in order to
quantify its effectiveness.
Limit Parking
Supply
Eliminate or reduce minimum parking requirements, create
maximum parking requirements, provision of shared parking.
Reductions apply only if complementary strategies are in place to
limit spill-over to on-street parking. Note that this may require
coordination with the local agency as proposed supply may not be
consistent with policy requirements.
Residential
Retail
Office
Industrial
Mixed-Use
PDT-1 X (only shared
parking) 5-12.5%
Traffic Calming
Measures
Provide traffic calming measures, including:
Marked or high-visibility crosswalks
Count-down signal timers
Curb extensions
Speed tables
Raised crosswalks
Raised intersections
Median islands
Tight corner radii
Roundabouts or mini-circles
On-street parking
Planter strips with street trees
Chicanes/chokers
Speed feedback signs
Enhanced crosswalk paving
Traffic calming measures encourage people to walk or bike instead
of taking a vehicle.
Residential
Retail
Office
Industrial
Mixed-Use
SDT-2 0.25-1%
Dedicate Land for
Bike Trails
Provide for, contribute to, or dedicate land for off-street and off-
site bicycle trails linking the project to existing routes or key
destinations
Residential
Retail
Office
Industrial
Mixed-Use
SDT-9 grouped
Note that this measure must be
grouped with Improve Design of
Development (LUT-9) in order to
quantify its effectiveness.
Unbundle Parking
Unbundle parking by separating parking from property cost and
requiring and additional cost for parking spaces. Reductions apply
only if complementary strategies are in place to limit spill-over to
on-street parking. Note that this may require coordination with the
local agency as proposed supply may not be consistent with policy
requirements.
Residential
Retail
Office
Industrial
Mixed-Use
PDT-2 X 2.6-13%
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Table 1: TDM Measure Summary
TDM Method Description Applicable
Land Use
CAPCOA
Measure (if
applicable)1
SANDAG Calculator
Tool Application
Level (if applicable)2
Part of Carlsbad
TDM Menu?
Range of
Effectiveness3 CAPCOA Calculation Notes SANDAG Mobility Management
Toolbox Calculation Notes
Transit Access
Improvements
Improve access to transit facilities by providing sidewalk/crosswalk
safety enhancements and bus shelter improvements at transit
stops serving the project site. Example applications include:
Benches
Public art
Static schedule and route display
Trash receptacles
Bike parking
Addition of shelter/weather protection
Real time user information monitors
Lighting
Enhanced sense of security
Communicating/providing a direct link to a transit stop
(map, signage, pathway improvements)
On-site transit pass outlet to purchase transit passes on-
site
Residential
Retail
Office
Industrial
Mixed-Use
TST-2 X grouped
Note that this measure must be
grouped with Transit Network
Expansion (TST-3) or Transit Service
Frequency and Speed (TST-4) in order
to quantify its effectiveness.
Transit
Encouragement
Programs
Provide transit encouragement programs to encourage
employees/residents to take transit. Example applications include:
Transit route planning assistance/transit riders guide
Free trial transit rides
Transit field trips
Creating transit groups or buddies
Providing incentives
Gamifying transit use (i.e. prizes/incentives for number of
transit trips taken)
Creation of a transit app that provides stop information
for private shuttles and public transit
Residential
Retail
Office
Industrial
Mixed-Use
grouped grouped
Note that this measure must be
grouped with a Commute Trip
Reduction Program (TRT-1 or TRT-2) in
order to quantify its effectiveness.
Expand Transit
Network
Expand local transit network by adding or modifying existing
transit service to best serve the project.
Residential
Retail
Office
Industrial
Mixed-Use
TST-3 Community-Level
0.1-8.2%
(CAPCOA)
Up to 5.9%
(SANDAG)
Note that Project-Level and
Community-Level measures cannot be
combined.
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Vehicle Miles Traveled Analysis Guidelines | C-9
Table 1: TDM Measure Summary
TDM Method Description Applicable
Land Use
CAPCOA
Measure (if
applicable)1
SANDAG Calculator
Tool Application
Level (if applicable)2
Part of Carlsbad
TDM Menu?
Range of
Effectiveness3 CAPCOA Calculation Notes SANDAG Mobility Management
Toolbox Calculation Notes
Increase Transit
Service
Frequency/Speed
Provide reduced transit headways and increase transit speed by
increasing the number of transit vehicles, installing a bus-only
lane, or other measures. Recently, a demand-responsive service
was started known as the Carlsbad Connector, which helps to
encourage commuters to Carlsbad to use the COASTER by
offering low-cost and convenient connections from the Poinsettia
Station to nearby offices, as well as offering mid-day service from
offices to lunch destinations. This program and/or existing North
County Transit District (NCTD) bus service could be expanded to
cover a larger service area, duplicated at the Carlsbad Village
station, and/or supplemented with service for those commuting
from Carlsbad. Bus Rapid Transit (BRT) could also offer addition
travel time competitive options for regional connections that
aren’t served by the COASTER commuter rail. Note that
implementation of this strategy would require regional or local
agency implementation, substantial changes to current transit
practices, and would not likely be applicable for individual
development projects.
Residential
Retail
Office
Industrial
Mixed-Use
TST-4 Community-Level
0.02-2.5%
(CAPCOA)
Up to 8.2%
(SANDAG)
Note that Project-Level and
Community-Level measures cannot be
combined. The SANDAG Tool
separately calculates the benefit of
increasing frequency and the benefit
of increasing speed/reliability through
supportive treatments.
Bike Parking Near
Transit
Provide short-term and long-term bicycle parking near transit to
encourage bicycling between the transit station and the project
site and encourage the use of transit.
Residential
Retail
Office
Industrial
Mixed-Use
TST-5 grouped
Note that this measure must be
grouped with Transit Network
Expansion (TST-3) or Transit Service
Frequency and Speed (TST-4) in order
to quantify its effectiveness.
Provide Local
Shuttles
Provide local shuttle service, like the Carlsbad Connector, that
connects the project site to existing transit or destinations. This
shuttle service could be provided using small electric vehicles,
similar to NEVs or golf carts.
Residential
Retail
Office
Industrial
Mixed-Use
TST-6 X grouped
Note that this measure must be
grouped with Transit Network
Expansion (TST-3) or Transit Service
Frequency and Speed (TST-4) in order
to quantify its effectiveness.
Walking
Supportive
Measures
Provide walking supportive measures to encourage walking to
work or for short trips within the project area. Example
applications include:
Mapping walking routes
Creating walking groups or buddies
Providing incentives
Gamifying walking (i.e. prizes/incentives for number of
days walked)
Residential
Retail
Office
Industrial
Mixed-Use
grouped grouped
Note that this measure must be
grouped with a Commute Trip
Reduction Program (TRT-1 or TRT-2) in
order to quantify its effectiveness.
Bicycle riders guide
Provide a bicycle riders guide to assist residents/employees with
riding a bicycle. Example applications include: Handout, posted
materials, or app with information on connected bicycle facilities
and amenities (i.e. parking, showers, etc.)
Residential
Retail
Office
Industrial
Mixed-Use
grouped grouped
Note that this measure must be
grouped with a Commute Trip
Reduction Program (TRT-1 or TRT-2) in
order to quantify its effectiveness.
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Vehicle Miles Traveled Analysis Guidelines | C-10
Table 1: TDM Measure Summary
TDM Method Description Applicable
Land Use
CAPCOA
Measure (if
applicable)1
SANDAG Calculator
Tool Application
Level (if applicable)2
Part of Carlsbad
TDM Menu?
Range of
Effectiveness3 CAPCOA Calculation Notes SANDAG Mobility Management
Toolbox Calculation Notes
Bicycle Supportive
Measures
Provide bicycling supportive measures to encourage biking to
work or for short trips within the project area. Example
applications include:
Bike-to-work day
Creating biking groups
Developing a bicycle buddies program
Gamifying bicycling (i.e. prizes/incentives for number of
days biked)
Residential
Retail
Office
Industrial
Mixed-Use
grouped grouped
Note that this measure must be
grouped with a Commute Trip
Reduction Program (TRT-1 or TRT-2) in
order to quantify its effectiveness.
Bicycle Repair
Station
Provide on-site tools and space for bicycle repair, including repair
stands, air pumps, and wrenches/screwdrivers.
Residential
Retail
Office
Industrial
Mixed-Use
grouped X grouped
Note that this measure must be
grouped with Provide End of Trip
Facilities (TRT-5), a Commute Trip
Reduction Program (TRT-1 or TRT-2), or
Provide Ride-Sharing Program (TRT-3).
Real-Time Parking
Demand
Management
Provide real-time information on parking availability to reduce the
time it takes to find parking and distribute parking across different
facilities.
Residential
Retail
Office
Industrial
Mixed-Use
X
On-site Transit
Pass Sales
Sell transit passes on-site for employees and tenants to
conveniently purchase passes at a regular or discounted price.
Residential
Retail
Office
Industrial
Mixed-Use
X
Personalized
Commute
Assistance
Provide trip planning assistance and resources for employees or
tenants to create a customized commute plan.
Residential
Retail
Office
Industrial
Mixed-Use
grouped Community-Level X
grouped
(CAPCOA)
Up to 2.0%
when grouped
with marketing
(SANDAG)
Note that this measure must be
grouped with an Employer Commute
Program (TRT-1 or TRT-2) in order to
quantify its effectiveness.
Note that Project-Level and
Community-Level measures cannot be
combined.
Transportation
Coordinator
Designate a key person at worksites or residential developments
to act as the main point of contact regarding commuter benefits
and to promote trip reduction programs.
Residential
Retail
Office
Industrial
Mixed-Use
grouped X grouped
Note that this measure must be
grouped with an Employer Commute
Program (TRT-1 or TRT-2) in order to
quantify its effectiveness.
Free Bicycle Tune-
Ups
Provide complimentary bike tune-ups to employees or tenants
who travel by bike.
Residential
Retail
Office
Industrial
Mixed-Use
X
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Vehicle Miles Traveled Analysis Guidelines | C-11
Table 1: TDM Measure Summary
TDM Method Description Applicable
Land Use
CAPCOA
Measure (if
applicable)1
SANDAG Calculator
Tool Application
Level (if applicable)2
Part of Carlsbad
TDM Menu?
Range of
Effectiveness3 CAPCOA Calculation Notes SANDAG Mobility Management
Toolbox Calculation Notes
Bicycle Safety &
Maintenance
Classes
Offer classes about basic bike safety & maintenance.
Residential
Retail
Office
Industrial
Mixed-Use
X
Free Bike Safety
Incentives
Provide complimentary bike safety gear, such as helmets and bike
lights, to employees or tenants who travel by bike.
Residential
Retail
Office
Industrial
Mixed-Use
X
Fitness
Membership
Provide subsidized or complimentary fitness membership to a
nearby gym for employees or tenants.
Residential
Retail
Office
Industrial
Mixed-Use
X
Bikeshare
Membership
Provide subsidized or complimentary bikeshare memberships for
employees or tenants.
Residential
Retail
Office
Industrial
Mixed-Use
X
Free “Try Transit”
Passes Provide free, limited-use passes for first-time transit commuters.
Residential
Retail
Office
Industrial
Mixed-Use
X
Wayfinding Install wayfinding signage to help people navigate the site and
find mobility services and facilities.
Residential
Retail
Office
Industrial
Mixed-Use
X
On-Site Amenities Provide on-site services such as coffee, food, fitness, dry cleaners,
day care, etc. to reduce the number of trips made in the day.
Residential
Retail
Office
Industrial
Mixed-Use
X
Internal
Transportation
Website
Provide employees or tenants access to transportation information
electronically on the site-specific web portal.
Residential
Retail
Office
Industrial
Mixed-Use
X
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Vehicle Miles Traveled Analysis Guidelines | C-12
Table 1: TDM Measure Summary
TDM Method Description Applicable
Land Use
CAPCOA
Measure (if
applicable)1
SANDAG Calculator
Tool Application
Level (if applicable)2
Part of Carlsbad
TDM Menu?
Range of
Effectiveness3 CAPCOA Calculation Notes SANDAG Mobility Management
Toolbox Calculation Notes
WiFi Provide free public WiFi at transit stops and/or mobility hubs to
help riders check arrival times and stay productive while waiting.
Residential
Retail
Office
Industrial
Mixed-Use
X
New
Employee/Tenant
Information
Package
New employee/tenant information packages should include
information about mobility options/services, incentive programs,
and subsidies.
Residential
Retail
Office
Industrial
Mixed-Use
X
Transit Ridership
Education Host workshops that teach individuals how to take transit.
Residential
Retail
Office
Industrial
Mixed-Use
X
Real-Time Travel
Information
Provide real-time transit and shared mobility service information
via digital or app-based displays.
Residential
Retail
Office
Industrial
Mixed-Use
X
Information Kiosk
or Bulletin Board
A real-time or static display with information about transit,
rideshare, multimodal access guide, etc.
Residential
Retail
Office
Industrial
Mixed-Use
X
Build a Mobility
Hub
Construct a transportation terminal designed to integrate diverse
travel options and support services. Example applications include:
Bus or train station
Ferry terminal
Comprehensive transit stations
Residential
Retail
Office
Industrial
Mixed-Use
Source: Fehr & Peers, 2020.
1 CAPCOA Designations: LUT: Land Use/Location; SDT: Neighborhood/Site Design; TRT: Trip Reduction Programs; TST: Transit System Improvement; PDT: Parking Policies/Pricing
2 Care must be taken when utilizing the SANDAG Mobility Management Toolbox calculator tool because the tool can result in very large VMT reductions for some strategies, including in suburban contexts. The SANDAG Mobility Management Toolbox and calculator tool is divided into two scales: 1) Project
scale and 2) Community/City scale. The community/city level strategies are not allowed to be applied at the project scale, which limits project scale strategies to: employer commute programs, land use strategies (mixed-use development and transit-oriented development), and parking (parking cash-out
and pricing).
3 Range of effectiveness is based on the CAPCOA report unless otherwise specified. Recent research conducted by the California Air Resources Board (CARB) has indicated that the ranges of effectiveness provided for measures in the CAPCOA report are higher than currently justified. Future publications are
expected to include reduced effectiveness. Measures that are “grouped” and measures without a range provided are those that have not been researched in order to determine their individual effectiveness.
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May 4, 2020 Traffic and Mobility Commission Comments and Questions by Pete Penseyres
Item 2:
What were the results of the public survey regarding the two alternatives for trenching? How many
votes for each option?
One NextDoor post from a Barrio resident suggested that if residents were voting for the long extension,
that they make a comment that the crossing at Chestnut should remain bikes and pedestrians only. Why
was that option not included in the survey? When I tried to add this comment to my survey response, I
did not see a place to add the comment. Will there be another survey and more public education/input
before the City provides the official recommendation on this issue? Since Chestnut has been chosen by
the City to receive pedestrian and bicycle enhancements by CalTrans and the street has been designated
as a future “bicycle boulevard” leading to the Coastal Rail Trail and the Beach by an overpass (or a bridge
if the trench is not constructed), opening another crossing to the beach for motorized traffic would
seem to defeat the objectives stated in the Barrio and Village Master Plan.
In addition, since Carlsbad Village Drive and Grand Ave will have overpasses, it is essential to provide
another motor vehicle overpass at Oak? What is the cost difference between a ped/bike vs motor
vehicle overpass that includes pedestrian and bicycle infrastructure? It seems that we are defeating the
primary purpose of traffic calming in the Village and Barrio plan by focusing on automobiles.
Item 3:
The southbound approach to PAR on Melrose includes a long Class II Bike Lane between the leftmost
RTO land and rightmost straight through lane. There are currently Bikes May Use Full Lane signs to
educate motorists and cyclists that they may use the RTO lanes to turn right or to transition to the
straight through Bike Lane. The approach is a steep grade which results in a high-speed differential
between cyclists and motorists. With the addition of the third lane and restriping, could there be
additional space to widen the bike lane and/or to paint it green to make it more visible? Two
experienced North County Cycle Club members were seriously injured there recently when a motorist
made an unsafe lane change. The addition of a third straight through lane may further reduce the
visibility of cyclists on this section of roadway.
Upon completion of this Project, I noted that with 7 travel lanes southbound plus 4 northbound and
Class II Bike lanes on both sides, LOS will STILL be deficient! Will it be the widest intersection in
Carlsbad?
If a bicyclist enters this intersection on PAR on a “stale” green light in either direction, will they have
enough time at 15 MPH (22 ft/sec) to get all the way across before ECR drivers get a green light? And if
more cyclists become so intimidated that they use the pedestrian PB’s to get across, how much will that
negatively impact the LOS?
There was an earlier Item from Commissioner by Commissioner Hunter regarding the northbound
Melrose lane stripping. It was to consider realignment of the lanes on the south approach to better align
drivers in the #1 through lane continue to use the #1 lane rather than the #2 lane so that drivers to their
right are not pushed toward the #4 transition lane which becomes a RTO lane. This was mentioned to
also potentially help northbound cyclists weave left to transition to the Bike Lane when the RTO lane
begins. I had asked if the hashed off space adjacent to the median could be moved to the right of the
double left turn lanes and to consider if that space could be used for a buffered LTO Bike lane to the
right of the vehicle LTO lanes. Is this a different CIP? When will it be brought to the Commission?
Item 4:
Exhibit 2 Item 5 typo “substernal” = “substantial”
Staff has provided an excellent menu of options for resolving the concerns of the public and City Council
with respect to Councilmember Schumacher’s Minute Motion, even including single as well as two lane
roundabout options.
Option 1 is the easiest, cheapest, and fastest to implement, but it appears to simply “kick the can
down the road” rather than address the concerns now. And as pointed out, it has many cons, including
the fact that it is unlikely to produce more than a limited and waning driver response.
Option 2 may best be described as “lipstick on a pig” as it retains the existing traffic lights with all of
their inherent safety, capacity, and delay issues. It is also costly and wasteful if it does not resolve the
concerns.
Option 3 appears to be the best solution to all safety concerns. My personal experiences with
roundabouts as a cyclist, pedestrian, and motorist in Australia as well as in my current home adjacent to
the Carlsbad Blvd./State St. roundabout have reinforced my strong preference for this people and
environmentally friendly, traffic calming/control device.
When I previously lived in Oceanside, I was a member of the Coast Highway Corridor Steering
Committee and Co-Chair of the Pedestrian and Bicycle Committee. Both citizen groups became stronger
proponents of single lane roundabouts along Coast Highway as they learned more about their
advantages.
The reduction of fatal crashes in roundabouts vs. traffic light or stop controlled intersections is typically
90%. Reference: City of Fort Worth, Texas website (http://fortworthtexas.gov/roundabouts/benefits/)
which uses FHWA studies and documents for the following discussion:
“Roundabouts are the safest type of at-grade intersection. They create slower speeds, fewer conflict
points for pedestrians and motorists, and reduced collision angles compared to stop sign or traffic signal
control. A national study of intersections converted to modern roundabouts had the following
significant findings:
•A reduction in collisions of all types of 40 percent.
•A reduction in injury collisions of 75 percent.
• A reduction in fatal and incapacitating collisions of about 90 percent.”
In the process of researching single lane roundabouts I found many more benefits but believe that the
safety advantages are overwhelming.
Education is key to overcoming opposition and to ensure proper usage by all users after they are
installed. There are websites where roundabouts have been installed in spite of heavy opposition where,
after installation, many opponents admitted that they were wrong. For example:
https://www.youtube.com/watch?v=dHnY8IGv1sY
My experience with teaching Traffic Skills 101 (aka Smart Cycling) and in riding with friends is that some
cyclists don’t like roundabouts until they learn how to ride through them correctly. Certified League of
American Bicyclists Instructors in San Diego County have included classroom presentations and, in
Oceanside and Carlsbad, on the road practice in safely navigating the Carlsbad roundabout. We first
dismount and become pedestrians and later ride through just as we would as motorists.
There is a video on the Carlsbad City website that connects to a video from the Federal Highway
Administration entitled “Modern Roundabouts, A Safer Choice” It has been viewed 484 times and can be
seen here:
https://www.youtube.com/watch?v=ZMpqH0kohaM&list=PLCEF0BD7835D6E0B0&index=4
Tips on how to use the Carlsbad roundabout were posted on the City Website when it was new in 2014
and can be seen here:
https://www.youtube.com/watch?v=XGc5aHbMfb4
Note that despite being on the City Website for more than 5 years, it has only been viewed 649 times.
There is also an excellent Power Point that was developed by John Kim for our Traffic Safety Commission
that I can’t find. These hard to find and little observed educational items can be overwhelmed by one
negative inflammatory Next Door or Facebook post based on emotion rather than facts.
This was done successfully by a relatively small group of South Oceanside residents who will retain their
end of Coast Highway as 4 lanes. The same result was accomplished in Solana Beach by another small
group opposed to all roundabouts in the City and specifically on Lomas Santa Fe.
Perhaps College Ave should not be the first arterial location to install single lane roundabouts due to the
potential capacity limitation/congestion and public opposition?
Single lane roundabouts were rejected on the Poinsettia extension, even though the LSA traffic analysis
showed that they would have provided LOS A for the foreseeable future and there was a “fresh palette”
along with more than adequate ROW that would have substantially reduced their cost compared to
removing and rebuilding the extra turn lanes, medians and traffic light infrastructure. That project was
taken to the City Council without our Commission recommendations since we received it after the
decision was made as an Information Only Item.
We had a discussion at the time, but arguments against it included a desire to maintain this little used
(13K ADT in 2035) road as a high speed 50 MPH multi lane arterial (using “typology”) with minimum
width 5’ unbuffered Bike Lanes and computer based Traffic Signal Management to platoon traffic and
even potentially punish speeding downhill traffic on Cassia street with Red light initiations and “No Right
Turn on Red” restrictions.
Perhaps our Commission should include a recommendation that City Council reconsider/reverse their
decision to install traffic lights on Poinsettia so that single lane roundabouts become more familiar and
accepted by the public?
Option 4 would also solve the traffic safety issues and would increase capacity beyond current pre-
COVID-19 usage. However, no two-lane roundabouts have been installed on any arterial in San Diego
County and would likely receive even more opposition.
In addition, although they still reduce fatal and serious injury crashed as well as single lane installations,
they do result in more property damage collisions. The following recent article in the Wall Street Journal
discussed this issue.
As noted in the WSJ article, “fender bender” crashes do increase upon installation of roundabouts.
Carlsbad experience was similar in that there were 20 reported crashes in the first two years, 17
occurred at night and 18 were DUI drivers. The “dirty little secret” of our roundabout is that it serves as
an “unmanned check point” which protects all other downstream motorists, cyclists and pedestrians.
Options 5 & 6 are not credible solutions for all the reasons stated.
Item 5:
The informal point system indicates 5 points for Collisions if Ped related. Is that 5 points for each
collision and if so, what period of time is used for that parameter? What was the basis for this? Should it
be higher?
Item 6:
For both sections of El Camino Real, the slight reduction in travel lane width to create a buffer for
cyclists will increase their comfort level and perhaps even increase cycling that displaces car trips for
commuting or shopping. The intersection treatment is important from a safety standpoint as a majority
of car/bike crashes take place when turning or lane change movements are made.
There are 5 intersections involved on El Camino Real from Faraday to Cannon. There are several more
from Arenal to Levante. How will the striping for the Bike Lanes be done at each of these intersections?
Will all of them have RTO lanes with the Bike lanes correctly placed to the left of the RTO lanes? If not,
how will the shared 11’ space be striped? Where will the green paint be applied? Will there be “Begin
Right Turn Lane Yield to Bikes” R4-4 signs installed at all locations where separate RTO lanes exist?
Where RTO lanes do not and will not exist, these “shared” lanes will need careful markings, signage, and
striping to prevent drivers from passing cyclists and making right turns illegally from the rightmost
through lane. As students from the Aviara Oaks middle school explained to us, one of the most common
car bike crashes occurs when drivers turn right across a cyclist’s path. The risk of high speed “right hook”
type crashes is high when motorists do not yield and merge into the bike lane when it begins to be
dashed.
Please supply the detailed striping, painting, and signage plans for review when they become available.
Item 7:
If possible, I would like a paper copy of this item to read without sitting in front of a computer screen. I
did not have enough time to read and comment on this item. However, after a quick scan, it appears
that the VMT guidelines contradict some of the actions we have recommended to improve LOS on
congested roadways, and especially to create 4 travel lanes on the Poinsettia extension without
considering the possibility of a road diet. or GHG saving roundabouts in place of more traffic lights.