HomeMy WebLinkAbout2021-12-06; Traffic and Mobility Commission; ; Informational Presentation on Vehicle Miles Traveled Analysis Guidelines
Dec. 6, 2021 Item #4 Page 1 of 1
Item #4 - VEHICLE MILES TRAVELED ANALYSIS GUIDELINES – This item was pulled from the agenda due
to the late arrival of materials relating to the item. Staff needed additional time to review and draft responses to the material before presenting on the item. This item will be presented to the T&MC on Jan. 3, 2022.
Item 4
Meeting Date:
To:
Staff Contact:
Subject:
Dec. 6, 2021
Traffic and Mobility Commission
Jason Geldert, Engineering Manager
Jason.Geldert@Carlsbadca.gov or 760-602-2758
Jennifer Horodyski, Associate Engineer
Jennifer.Horodyski@Carlsbadca.gov or 760-602-2747
Informational Presentation on Vehicle Miles Traveled Analysis
Guidelines
Recommended Action
Review and provide input on the informational report and status update.
Executive Summary
California Senate Bill (SB) 743 was passed by the Legislature and signed into law in 2013. This
legislation led to a change in the way transportation impacts are measured under the California
Environmental Quality Act, or CEQA. Under SB 743, CEQA analysis can no longer use road
congestion or the amount of time a driver is delayed on the road – commonly measured by
vehicle level of service, or LOS. Instead of using LOS, a project’s environmental impacts must be
evaluated by the amount and distance people drive to destinations. SB 743 became effective on
July 1, 2020. On June 16, 2020, the City Council adopted vehicle miles traveled, or VMT,
thresholds of significance and VMT screening criteria to allow the city to quickly determine
whether projects can be presumed to have a less-than-significant VMT impact. City staff also
developed administrative guidelines, policies, and procedures (VMT Analysis Guidelines) as an
informational tool to help implement the adopted VMT thresholds and screening criteria and to
assist land use development applicants and their consultants when preparing and analyzing
transportation impact analyses for CEQA.
On July 27, 2021 the City Council adopted Resolution No. 2021-185, approving the City of
Carlsbad Traffic and Mobility Commission Work Plan for Fiscal Year 2021-22. The adopted Work
Plan includes a review and opportunity to provide input on the VMT Analysis Guidelines. In
response, this report is to provide a brief overview of the VMT Analysis Guidelines and
demonstrate how the city is working on the interpretation and implementation of SB 743.
Discussion
Policy Background
Dec. 6, 2021 Item #4 1
In the past, CEQA review of a project’s transportation impacts focused primarily on metrics
related to vehicle delay and LOS. These analysis requirements involved a quantitative analysis
to determine whether a project may have a significant impact on the roadway network
pursuant to CEQA. California SB 743, signed into law in 2013, initiated a significant departure
from past policy and practice regarding the analysis of transportation impacts. The law changed
the way local jurisdictions, like the City of Carlsbad, analyze transportation impacts from
development projects and identify mitigation measures to reduce those impacts. The bill was a
response to state emissions targets established in various senate bills and executive orders,
such as SB 32 and Executive Order B-30-15. These legislative mandates set aggressive
greenhouse gas emissions reduction targets and established unique emissions benchmarks for
various years in the future. SB 743 directed the Office of Planning and Research, or 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, 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 could
no longer to be considered in evaluating and determining whether a project will have a
significant impact on the environment.
The OPR identified the use of VMT as the most appropriate metric to use in evaluating a
project’s transportation impact that aligns with the goals of SB 743. VMT refers to the amount
and distance of vehicle travel that is attributable to a specific project or geographical region
over a given period. The California Natural Resources Agency certified and adopted revisions to
the CEQA guidelines based on the office’s recommendations in December 2018. OPR also
prepared a Technical Advisory on Evaluating Transportation Impacts in CEQA to provide advice
and recommendations for assessment of VMT. SB 743 and the technical advisory requires the
amount of driving to destinations and length of trips – as measured by VMT – be utilized to
assess transportation impacts on the environment for CEQA review (as of July 1, 2020). These
impacts will be reduced or “mitigated” by options such as increasing transit, providing for active
transportation such as walking and biking, and participating in mitigation banks. All jurisdictions
have the option to tailor requirements to their unique communities.
Since the approval of SB 743, jurisdictions and entities have been working on the interpretation
and implementation of the law, including the City of Carlsbad. On May 4, 2020, the Traffic &
Mobility Commission reviewed the VMT thresholds of significance and VMT screening criteria
and provided a recommendation of approval to the City Council. On June 16, 2020, the City
Council adopted Resolution No. 2020-114 to approve the VMT thresholds and screening
criteria. Furthermore, to help implement the state regulations that are now in effect, city staff
developed VMT Analysis Guidelines for proposed new developments, the expansion of existing
developments, and transportation projects. The guidelines for implementation of the VMT
thresholds are for informational purposes only to assist applicants and their consultants.
Recommendations in the guidelines are advisory and may inform the environmental review for
projects in the city, but do not commit the city to any specific course of regulatory action.
VMT thresholds and screening criteria must be adopted by ordinance or resolution of the City
Council. The VMT Analysis Guidelines may be amended administratively from time to time
without City Council approval provided that the changes do not impair or interfere with any
Dec. 6, 2021 Item #4 2
existing provision of law, ordinance, resolution, or policy. The VMT thresholds and screening
criteria of the city have not been amended or modified since their adoption on June 16, 2020.
The guidelines were last updated in September 2020; however, there are additional changes
that are currently under review.
VMT Analysis Guidelines Overview (June 2020)
Transportation impacts and their potential need for mitigation are important for any
community to consider with proposed new developments, the expansion of existing
developments, and transportation projects. Residents, businesses, other community members,
and permit decision-makers all have a stake in understanding and responding to additional
demands on the transportation system. A properly developed traffic study can provide the
factual basis for good decision-making and facilitate the timely implementation of effective
mitigation measures. To help implement the VMT thresholds and screening criteria, city staff
developed VMT Analysis Guidelines to provide uniform scoping procedures to encourage
consistency in VMT analysis across projects and to assist with the evaluation of discretionary
projects under CEQA. The adopted VMT thresholds and screening criteria are incorporated
therein. The rest of the guidelines are for informational purposes only to assist applicants and
their consultants when preparing and analyzing transportation impact analysis for CEQA.
OPR’s Technical Advisory allows a city or county to use models to estimate a project’s VMT. At
the time the draft guidelines were developed, staff created VMT analysis maps to help an
applicant quickly determine whether a proposed project will result in a significant impact from
VMT in a particular area of the city. In developing these maps, staff obtained data from regional
travel demand model, which is managed and operated by SANDAG. The VMT maps included in
the presentations to Traffic & Mobility Commission and City Council were based on the version
of the SANDAG travel demand model called Activity-Based Model, or ABM 1. Generally, for
small residential and office projects under 2,400 average daily trips, the vehicle miles traveled
for a project is determined by VMT maps based on the regional travel demand model. The VMT
analysis maps created by the city include VMT data for smaller geographic areas of the city.
These geographic areas are called traffic analysis zones (TAZ’s). The assumption for small
projects is that the project vehicle miles traveled per capita or per employee can be estimated
based on the average values for those metrics in the traffic analysis zone in which the project is
located. This methodology is consistent with the OPR Technical Advisory, which states that new
development in an area will likely result in a similar level of vehicle miles traveled. For larger
projects with over 2,400 average daily trips, a project-specific model run of the regional travel
demand model may be used to obtain vehicle miles traveled data for the project. The June
2020 guidelines are provided in Exhibit 1.
Updates to the VMT Analysis Guidelines
The VMT Analysis Guidelines help potential and future applicants know of the regulations so
they can address them accordingly. Since CEQA generally requires public agencies to inform
decision-makers and the public about the potential environmental impacts of proposed
projects, it is important to keep the VMT Analysis Guidelines relevant and up to date to ensure
that city transportation studies are in conformance with all applicable city, region, and state
regulations. Maintaining the guidelines as an informational tool, and updating them as
necessary, is crucial to promote predictability and consistency (over time and across reviewers)
Dec. 6, 2021 Item #4 3
in the environmental review process. The Engineering Division will continue to have the
authority and exercise the practice of updating the guidelines as necessary to ensure the proper
interpretation and application of SB 743. Updates to the guidelines may be necessary to reflect
substantive changes to assumptions underlying data, analytical methodologies and mitigation
approaches, as well as court decisions related to CEQA litigation.
Over the past year and a half, city staff has worked closely to monitor key developments in
regional transportation modeling and planning best practices and documented changing
requirements and procedures. In September 2020, the VMT Analysis Guidelines were updated
(revisions are shown in Exhibit 2 with strikeout typeface (i.e. strikeout) illustrating deletions and
underline typeface (i.e. underline) illustrating new text). A clean copy of the updated VMT
Analysis Guidelines is provided in Exhibit 3. The following section summarizes the September
2020 update. The following section also highlights some of the prospective changes that are
currently in review for a December 2021 update. In general, the two updates are administrative
updates, generally for the purposes of better aligning certain guidance with OPR’s Technical
Advisory and updating the analysis methodology in response to release of new SANDAG VMT
data.
A. September 2020 Update
After City Council approval of the VMT thresholds and screening criteria, SANDAG
released interactive VMT maps associated with a new version of the regional travel
demand model, ABM2. The updated travel demand model included new VMT data and
interactive maps for use by agencies, consultants, and the public. So that projects would
use the best available data, the VMT Analysis Guidelines needed to be updated to direct
projects to use SANDAG’s new interactive maps based on ABM2. SANDAG interactive
maps provide VMT data at the census tract level, so a project under 2,400 average daily
trips would assume its VMT per employee or VMT per capita is the same as the census
tract where it is located. Census tracts are geographic areas made up of several traffic
analysis zones. VMT per capita and VMT per employee maps developed by the city were
discontinued as the underlying data was based on ABM1, which is no longer the current
model version. Another necessary change to the VMT Analysis Guidelines was an update
to the guidance on use of models to be consistent with the recommendations in the
OPR Technical Advisory. The draft version of the guidelines had limited options for use
of models to evaluate VMT, and the updated version allows use of additional model
methodologies mentioned by the OPR Technical Advisory. It also allows use the
SANDAG model for projects under 2,400 average daily trips if the project is of the size
and type that is appropriate for inclusion in the regional model. The change allows
larger mixed-use projects or projects near the 2,400 average daily trip threshold to
conduct a more detailed and accurate analysis via the SANDAG model if determined to
be appropriate by city staff. In preparing the September 2020 update to the guidelines,
city staff also prepared clerical changes, such as to correct a typo and replace a word in
one of the appendices.
Dec. 6, 2021 Item #4 4
B. Scheduled December 2021 Update (Tentative)
In response to changes that have occurred regarding guidance and SANDAG data
referenced in the VMT Analysis Guidelines, administrative changes need to be made to
the guidelines in the coming months. The following are highlights of those revisions:
• It is anticipated that SANDAG will release a new travel demand model, ABM2+, in
December 2021. VMT per capita and VMT per employee maps will be developed
using TAZ’s and SANDAG’s updated VMT data. SANDAG plans on updating their
interactive maps using data from ABM2+ in January 2022. In addition, ABM2+
will become available for custom modeling analysis in January 2022.
• The VMT/employee metric calculation will be modified with the release of
ABM2+. The new metric will be focused only on the “work tour” or work related
VMT produced by employees, assigned to their place of employment. The
current VMT/employee metric includes “all” of an employee’s VMT (including
non-work related VMT), assigned to their place of employment. The
VMT/employee metric definition will be updated in the VMT Analysis Guidelines.
• Mitigation guidance will be updated based on the release of a new document for
quantifying VMT reductions called Handbook for Analyzing Greenhouse Gas
Emission Reductions, Assessing Climate Vulnerabilities, and Advancing Health
and Equity, referred to as the “GHG Handbook”. The GHG Handbook updates the
2010 California Air Pollution Control Officers Association, or CAPCOA,
Quantifying Greenhouse Gas Emissions document that is currently referenced in
the VMT Analysis Guidelines.
• Appendix A: VMT Analysis for Unique Land Use Types refers to the County of San
Diego Transportation Study Guidelines for additional guidance on unique land
use types. The Transportation Study Guidelines were rescinded by the Board of
Supervisors on September 15, and are no longer being used. Therefore,
Appendix A will be revised to remove the reference to the county guidelines and
incorporate updated guidance on unique land use types.
Next Steps
The Engineering Division intends to incorporate future updates to the VMT Analysis Guidelines
as needed to reflect substantive changes to assumptions underlying data, analytical
methodologies and mitigation approaches, as well as court decisions related to CEQA litigation.
For example, city staff will administratively update the guidelines and develop city specific VMT
maps after the release of SANDAG’s new travel demand model (ABM2+) data (anticipated for
mid-December).
Environmental Evaluation (CEQA)
The adoption of the city’s project screening criteria and significance thresholds in June 2020,
was determined by the City Council to be compliant with SB 743, a state mandate, and was
done in accordance with CEQA procedural requirements. The adopted VMT screening criteria
Dec. 6, 2021 Item #4 5
and thresholds of significance will serve as the basis to which the city will consider impacts to
be significant, and below which it will consider impacts to be less than significant.
The VMT Analysis Guidelines are an informational tool to help implement the VMT threshold
and screening criteria and to assist applicants and their consultants when preparing and
analyzing transportation impact analysis. The VMT Analysis Guidelines, and updates thereto,
inform the environmental review process for development projects, but do not commit the city
to any specific course of regulatory action. Acceptance of any transportation study derived
from implementing the guidelines does not deem approval of any content outlined in each
study, but rather an acknowledgment that the format of the study is acceptable for the
department to review and for consideration by the decision-making bodies. The project
proponent must still address CEQA compliance and other related procedural issues prior to
moving forward with the permitting process and the decision-makers must independently
review the record and determine that the project is proceeding forward in accordance with
CEQA, prior to approving the project.
Updating the VMT Analysis Guidelines, including the prospective changes to reflect the new
travel demand model, metric calculations, etc. therein, is exempt from further environmental
review under CEQA pursuant to CEQA Guidelines section 15308 (Actions by a Regulatory
Agency for Protection of the Environment) and, on a separate and independent basis, section
15378(b)(5) (Administrative Activities). The city will continue to use the guidelines for
implementation of the adopted VMT thresholds and screening criteria as part of a regulatory
process that involves procedures for protection of the environment. The guidelines are for
informational purposes only to assist applicants and their consultants with preparing project-
specific transportation information as part of the permit review process.
Exhibits
1)VMT Analysis Guidelines, June 2020
2)VMT Analysis Guidelines, June 2020 with strike-out underline changes
3)VMT Analysis Guidelines, September 2020
4)Comments on the City's VMT Analysis Guidelines from Vice-Chair Linke
Dec. 6, 2021 Item #4 6
VEHICLE MILES TRAVELED (VMT)
ANALYSIS GUIDELINES
June 2, 2020
DRAFT
Exhibit 1
Dec. 6, 2021 Item #4 7
113
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
3.3 Vehicle Miles Traveled Analysis .................................................................................................... 7
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
3.5 Mitigation .................................................................................................................................... 10
Exhibit 1
Dec. 6, 2021 Item #4 8
3.2.1
3.2.2
3.2.3
3.2.4
3.2.5
3.2.6
3.3.1
3.3.2
3.3.3
3.3.4
3.3.5
(city of
Carlsbad
Vehicle Miles Traveled Analysis Guidelines | ii
4 TRANSPORTATION PROJECTS .................................................................................................... 11
4.1 Screening Criteria ........................................................................................................................ 11
4.2 Vehicle Miles Traveled Analysis .................................................................................................. 12
4.3 Significance Thresholds ............................................................................................................... 13
4.4 Mitigation .................................................................................................................................... 13
5 ADDITIONAL RESOURCES FOR VEHICLE MILES TRAVELED ANALYSIS ........................................... 14
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 – Vehicel Miles Traveled Reduction Strategies and Effectiveness Calculations
Exhibit 1
Dec. 6, 2021 Item #4 9
(city of
Carlsbad
Vehicle Miles Traveled Analysis Guidelines | 1
1 BACKGROUND
This chapter provides background information on Senate Bill 743 (SB 743) and the need to conduct
vehicle miles traveled (VMT) analyses for CEQA transportation studies.
1.1 SB 743 Legislation
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.
Exhibit 1
Dec. 6, 2021 Item #4 10
(city of
Carlsbad
Vehicle Miles Traveled Analysis Guidelines | 2
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 C.
Exhibit 1
Dec. 6, 2021 Item #4 11
(city of
Carlsbad
Vehicle Miles Traveled Analysis Guidelines | 3
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 City of 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.
Exhibit 1
Dec. 6, 2021 Item #4 12
(city of
Carlsbad
Vehicle Miles Traveled Analysis Guidelines | 4
3 LAND DEVELOPMENT PROJECTS
This chapter provides guidance on conducting VMT analyses for land development projects, including
single-use projects, mixed-use projects, and redevelopment projects.
3.1 Overview of Analysis
The City of Carlsbad generally follows the VMT analysis methodology recommended in OPR’s
Technical Advisory. OPR recommends analyzing VMT for most residential and office projects based
on efficiency metrics. Projects evaluated in this way are analyzed using VMT/capita or
VMT/employee rather than total VMT.
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 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.
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. Reductions for internal trips and pass-by trips (if
appropriate) should be made prior to determination of project trip generation. If a project’s total
trip generation exceeds 2,400 daily trips but is reduced below this value after taking into account
internal trips and pass-by trips, it would not require a model run.
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 the 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. This threshold is also
used by the City of Carlsbad.
Exhibit 1
Dec. 6, 2021 Item #4 13
(city of
Carlsbad
Vehicle Miles Traveled Analysis Guidelines | 5
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.
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 the
regional 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. Further details on screening criteria can be found in OPR’s
Technical Advisory.
Small Projects
Per OPR’s Technical Advisory, projects that generate less than 110 ADT would be presumed
to have a less than significant transportation impact. Projects that can demonstrate that
they would generate an ADT of less than 110 after applying trip-reduction strategies would
be screened out from performing additional analysis.
Projects Located Near Transit
Per OPR’s Technical Advisory, residential, retail, 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.
Exhibit 1
Dec. 6, 2021 Item #4 14
3.2.1
3.2.2
3.2.3
(city of
Carlsbad
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 areas. 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 and regional public facilities would use a model run even if ADT is between 110 and 2,400.2.
1
2
Exhibit 1
Dec. 6, 2021 Item #4 15
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 public high
schools. A study evaluating the user capture area may be required in order to demonstrate
that a public facility is local-serving. Typically, private schools, charter schools, or public
facilities with unique uses will be required to provide a user capture area study. See
Appendix A for evaluating regional-serving public facilities.
Affordable Housing Projects
OPR’s Technical Advisory allows for a less than significant finding for transportation impacts
of residential projects that are 100% affordable housing located in infill areas. Affordable
housing projects in the City of Carlsbad could use this recommendation if they demonstrate
that they are located in infill areas based on urban planning considerations.
Redevelopment Projects That Result in a Net Reduction of VMT
Per CEQA, projects are considered to have a less than significant impact if they result in a
net reduction in the relevant performance measure (in this case VMT). Therefore,
redevelopment projects in the City of Carlsbad that generate less VMT than the existing
project they are replacing would be considered to have a less than significant impact on
VMT. Since VMT/capita and VMT/employee are efficiency metrics, a redevelopment
project that would produce more VMT than the existing project it is replacing would need
to conduct a VMT analysis assuming the proposed land use (with no credit taken for the
existing land use) to determine whether the proposed project meets the applicable
significance thresholds).
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.
3.3 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.
The methodology described below applies to projects that are consistent with the General Plan and
are evaluated using efficiency metrics (VMT/capita and VMT/employee). For projects that are
inconsistent with the General Plan or are evaluated using total VMT, a cumulative VMT analysis
Exhibit 1
Dec. 6, 2021 Item #4 16
3.2.4
3.2.5
3.2.6
(city of
Carlsbad
Vehicle Miles Traveled Analysis Guidelines | 8
may be required. Consultation with city staff should be conducted in these cases to determine the
appropriate VMT analysis methodology.
Single Land-Use Residential or Office Projects
Typical residential or office single land-use projects generating less than 2,400 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 the corresponding
threshold of significance, a 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 the project’s
VMT/capita or VMT/employee. If the resulting VMT/capita or VMT/employee exceeds the
corresponding threshold of significance, a significant impact would be indicated. Mitigation
measures would then be considered.
Mixed-Use Projects
Per OPR’s Technical Advisory, VMT analysis for mixed-use projects would be conducted by
analyzing each individual land use independently and applying the significance threshold
for each 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.
Mixed-use projects that generate more than 2,400 daily trips would use a model run of the
SANDAG regional travel demand model with the project to determine VMT/capita or
VMT/employee. Typically, the model would be set up so that the project has its own TAZ’s
and each land use within the project would have its own TAZ. The model would calculate
VMT/employee and VMT/capita values for each land use.
When the project generates less than 2,400 daily trips, the city’s VMT analysis maps may
be used for VMT analysis of mixed-use projects. The following approach can be considered
based on the methodology for VMT reduction of mixed-use projects provided in the
Regional Transportation Impact Study Guidelines:
1. Determine the percentage in VMT due to internal capture based on guidance provided
in the ITE Trip Generation manual, MXD methodologies or other techniques. An
approximation to convert reduction in external vehicle trips to VMT may be required.
If necessary, the resulting internal capture percentage should be reduced to match the
maximum recommended in CAPCOA guidance (see Appendix C).
2. Determine the total project mixed-use VMT for residential, office, and industrial land
uses (local-serving retail and similar uses will skip this step). This can be calculated by
multiplying the zonal VMT/capita or VMT/employee by the number of residents or
employees expected to be present at the project site.
Exhibit 1
Dec. 6, 2021 Item #4 17
3.3.1
3.3.2
(city of
Carlsbad
Vehicle Miles Traveled Analysis Guidelines | 9
3. Allocate the reduction in total VMT to residential, office, and industrial land uses. The
reduction in VMT should be allocated to individual land uses using the analyst’s
judgement. After allocating the reduction in VMT to each land use, determine
VMT/capita and VMT/employee values by dividing total VMT for each land use by the
number of residents or employees expected to occur with that land use.
4. After conducting this calculation, if all land uses are below the appropriate thresholds,
the project can presume a less than significant transportation impact. If not, mitigation
measures can be considered.
Redevelopment Projects
Redevelopment projects that do not meet the screening criteria above would need to
conduct a VMT analysis to determine whether they meet the appropriate significance
thresholds based on the project type. For analysis that uses efficiency metrics, it would be
based solely on the characteristics of the new project to be developed without any
consideration of the development that is being replaced.
Regional Retail Projects
All retail projects that do not meet the screening criteria above are considered regional
retail projects and require a 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. The ITE Trip Generation manual can be used as a
guide in determining which projects are industrial versus other land use types. The manual
includes the following categories of development as industrial:
General Light Industrial
Manufacturing
Warehousing (including high-cube warehouses, parcel hubs, fulfillment centers,
and cold storage warehouses)
Data Center
Utility
Special Trade Contractor
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 regional
average VMT/employee, a potentially significant impact would be indicated. Mitigation
measures would then be considered.
Exhibit 1
Dec. 6, 2021 Item #4 18
3.3.3
3.3.4
3.3.5
(city of
Carlsbad
Vehicle Miles Traveled Analysis Guidelines | 10
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 regional average VMT/employee, a potentially
significant impact would be indicated. Mitigation measures would then be considered.
It should be noted that goods movement is not subject to VMT analysis. Therefore, goods
movement trips associated with an industrial project would not be included when
determining VMT/employee.
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 regional 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 regional VMT per employee
City average VMT per capita and regional average 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
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 C for additional information on mitigation measures for land development projects.
Exhibit 1
Dec. 6, 2021 Item #4 19
(City of
Carlsbad
Vehicle Miles Traveled Analysis Guidelines | 11
4 TRANSPORTATION PROJECTS
SB 743 also applies to transportation projects, which are projects that improve transportation facilities for
any mode of travel. Per revised CEQA Section 15064.3, lead agencies have the discretion to 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
Exhibit 1
Dec. 6, 2021 Item #4 20
(city of
Carlsbad
Vehicle Miles Traveled Analysis Guidelines | 12
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.
Exhibit 1
Dec. 6, 2021 Item #4 21
(city of
Carlsbad
Vehicle Miles Traveled Analysis Guidelines | 13
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.
Exhibit 1
Dec. 6, 2021 Item #4 22
(City of
Carlsbad
Vehicle Miles Traveled Analysis Guidelines | 14
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: (Link to city web page 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
Exhibit 1
Dec. 6, 2021 Item #4 23
("city of
Carlsbad
VEHICLE MILES TRAVELED ANALYSIS GUIDELINES
APPENDIX A
VMT ANALYSIS
FOR NON-
STANDARD LAND
USE TYPES
Exhibit 1
Dec. 6, 2021 Item #4 24
(City of
Carlsbad
California
TABLE A-1: VMT ANALYSIS OF SAMPLE NON-STANDARD LAND USE TYPES
LAND USE TYPE BASIS FOR VMT ANALYSIS (1)
Religious (Local-Serving) See local-serving retail
Religious (Regional) See regional retail
Education (Local-Serving) See local-serving public facilities
Education (Regional) See regional retail
Hotel See office
Medical Office See office
Hospital or Regional-Service Medical See office
Regional-Serving Public Facilities See regional retail
Theme Parks See regional retail
(1) Check with city staff for guidance prior to conducting VMT analysis for the analysis of non-
standard land use types. For project types not listed above, the County of San Diego
Transportation Study Guidelines can be considered.
Exhibit 1
Dec. 6, 2021 Item #4 25
VEHICLE MILES TRAVELED ANALYSIS GUIDELINES
APPENDIX B
SCREENING
CRITERIA AND
THRESHOLD
EVIDENCE
Exhibit 1
Dec. 6, 2021 Item #4 26
(city of
Carlsbad
California
Vehicle Miles Traveled Analysis Guidelines | B-1
SCREENING CRITERIA AND THRESHOLD EVIDENCE
This appendix provides context and evidence for the screening criteria and threshold evidence included
in Chapters 3 for Land Development Projects and Chapter 4 for Transportation Projects.
Screening Criteria
Certain types of development projects are presumed to have less than significant impacts to the
transportation system, and therefore would not be required to conduct a VMT analysis, if any of the
following criteria are established, based on substantial evidence.
Small Projects
Small projects that would generate less than 110 average daily vehicle trips (ADT), would also not result
in significant transportation impacts on the transportation system:
Evidence – The OPR Technical Advisory states that “projects that generate or attract fewer than 110 trips
per day generally may be assumed to cause a less-than-significant impact.” This is supported by the fact
that CEQA provides a categorical exemption for existing facilities, including additions to existing structures
of up to 10,000 square feet, so long as the project is in an area where public infrastructure is available to
allow for maximum planned development, and the project is not in an environmentally sensitive area.
(CEQA Guidelines, § 15301(e)(2).) Typical project types for which trip generation increases relatively
linearly with building footprint (e.g., general office building, single tenant office building, office park, or
business park) generate or attract an additional 110- 124 trips per 10,000 square feet. Therefore, absent
substantial evidence otherwise, it is reasonable to conclude that the addition of 110 or fewer trips could
be considered not to lead to a significant impact.
Projects Located Near Transit
Per OPR’s Technical Advisory projects whose project site boundaries are within a half mile of an existing
or planned major transit stop or a major stop along a high-quality transit corridor can be screened out of
VMT analysis. Withing the City of Carlsbad, this would apply to projects within one half mile of the
Carlsbad Village or Carlsbad Poinsettia Coaster stations, as well as projects within one-half mile of the
Plaza Camino Real transit center. This presumption would not apply, however, if project-specific or
location-specific information indicates that the project will still generate significant levels of VMT.
Evidence – The OPR Technical Advisory states that “Proposed CEQA Guideline Section 15064.3,
subdivision (b)(1), states that lead agencies generally should presume that certain projects (including
residential, retail, and office projects, as well as projects that are a mix of these uses) proposed within ½
mile of an existing major transit stop or an existing stop along a high quality transit corridor will have a
less-than-significant impact on VMT. This presumption would not apply, however, if project-specific or
location-specific information indicates that the project will still generate significant levels of VMT.” Pub.
Resources Code, § 21064.3 clarifies the definition of a major transit stop (“ ‘Major transit stop’ means a
site containing an existing rail transit station, a ferry terminal served by either a bus or rail transit service,
or the intersection of two or more major bus routes with a frequency of service interval of 15 minutes or
less during the morning and afternoon peak commute periods.”). Pub. Resources Code, § 21155 clarifies
the definition of a major transit stop (“For purposes of this section, a high-quality transit corridor means
Exhibit 1
Dec. 6, 2021 Item #4 27
{city of
Carlsbad
California
Vehicle Miles Traveled Analysis Guidelines | B-2
a corridor with fixed route bus service with service intervals no longer than 15 minutes during peak
commute hours..”).
Local-Serving Retail and Similar Uses
Local-serving retail is defined in the City of Carlsbad as retail that is less than 50,000 square feet of total
gross floor area or retail development that is greater than 50,000 square feet that has a market area study
showing a market capture area that is primarily within Carlsbad and the adjacent cities of Oceanside, Vista,
San Marcos, and Encinitas.
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. Since the type of retail influences whether
it will be locally serving or retail serving (for example grocery, drug stores, convenience stores, etc.) and
the size of these facilities may be above 50,000 square feet, an applicant can provide a market survey
demonstrating that the project serves the local community if it is over 50,000 square feet.
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.
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
Exhibit 1
Dec. 6, 2021 Item #4 28
{city of
Carlsbad
California
Vehicle Miles Traveled Analysis Guidelines | B-3
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.” Per CEQA, projects are considered to have a less than
significant impact if they result in a net reduction in the relevant performance measure.
Thresholds
If a project is required to complete a VMT analysis, the project’s impacts to the transportation system
would be significant if the VMT would exceed any of the thresholds below.
Residential Projects
Threshold – 15% below city average household VMT/Capita.
Evidence – The OPR Technical Advisory provides that “residential development that would generate vehicle
travel that is 15 or more percent below the existing residential VMT per capita, measured against the
region or city, may indicate a less-than-significant transportation impact.”
Office/Employment Projects
Threshold – 15% below regional average VMT/Employee.
Evidence – The OPR Technical Advisory provides that “office projects that would generate vehicle travel
exceeding 15 percent below existing VMT per employee for the region may indicate a significant
transportation impact.”
Industrial Projects
Threshold – Above the regional average VMT/employee
Evidence – The OPR Technical Advisory provides that “[o]f land use projects, residential, office, and retail
projects tend to have the greatest influence on VMT. For that reason, OPR recommends the quantified
thresholds described above for purposes of analysis and mitigation. Lead agencies, using more location-
specific information, may develop their own more specific thresholds, which may include other land use
types.” Purely industrial uses are desired to be located in locations that are less dense and not within urban
areas which typically have higher VMT 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. It recognizes that industrial uses,
which generate relatively lower total VMT are most appropriate in areas that have a lower potential to
reduce VMT. This allows more available land within areas with a high potential to achieve VMT reductions
available for more dense development.
Exhibit 1
Dec. 6, 2021 Item #4 29
{city of
Carlsbad
California
Vehicle Miles Traveled Analysis Guidelines | B-4
Regional Retail
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
Exhibit 1
Dec. 6, 2021 Item #4 30
{city of
Carlsbad
California
Vehicle Miles Traveled Analysis Guidelines | B-5
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
Exhibit 1
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Vehicle Miles Traveled Analysis Guidelines | B-6
Addition of new or enhanced bike or pedestrian facilities on existing streets/highways or within
existing public rights-of-way
Addition of Class I bike paths, trails, multi-use paths, or other off-road facilities that serve non-
motorized travel
Installation of publicly available alternative fuel/charging infrastructure
Addition of passing lanes, truck climbing lanes, or truck brake-check lanes in rural areas that do
not increase overall vehicle capacity along the corridor
Evidence – The list above 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.
Exhibit 1
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{city of
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California
APPENDIX C
VEHICLE MILES
TRAVELED
REDUCTION
STRATEGIES AND
EFFECTIVENESS
CALCULATIONS
VEHICLE MILES TRAVELED ANALYSIS GUIDELINES
Exhibit 1
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Vehicle Miles Traveled Analysis Guidelines | C-1
VMT REDUCTION STRATEGIES UNDER CEQA
Projects can apply VMT reductions to lower their calculated VMT to 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 Citywide TDM Program), or that
have been observed 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
quantify the VMT reduction that results from combining strategies, the formula below can be applied
absent additional knowledge or information:
Exhibit 1
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Vehicle Miles Traveled Analysis Guidelines | C-2
𝑇𝑇𝑇𝑇𝑇𝑇𝑇𝑇𝑇𝑇 𝑉𝑉𝑉𝑉𝑇𝑇 𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑇𝑇𝑅𝑅𝑇𝑇𝑅𝑅 = (1 − 𝑃𝑃a) ∗ (1 – 𝑃𝑃b) ∗ (1 – 𝑃𝑃c) ∗ …
Where: 𝑃𝑃x = percent reduction of each VMT reduction strategy
For example, if two strategies were proposed with corresponding VMT reductions of 20 percent and 10
percent, the equation would be [1-(1-20%)*(1-10%)] or [1-(80%*90%)], which equates to a 28 percent
reduction rather than the 30 percent reduction that would otherwise result from a direct sum. This
adjustment methodology is simply a mathematical approach to dampening the potential effectiveness
and is not supported by research related to the actual effectiveness of combined strategies. As noted
above, this approach minimizes possibility of overstating VMT reduction effectiveness.
When calculating the 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.
Exhibit 1
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Vehicle Miles Traveled Analysis Guidelines | C-3
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
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.
Exhibit 1
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I
Vehicle Miles Traveled Analysis Guidelines | C-4
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
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. Depending on project location and availability of alternative transportation options, implementation of parking measures may require implementing other supportive strategies.
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.
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. Depending on project location and availability of alternative transportation options, implementation of parking measures may require implementing other supportive strategies.
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 X 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. Depending on project location and availability of alternative transportation options, implementation of parking measures may require implementing other supportive strategies.
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 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.
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 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.
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
Exhibit 1
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Vehicle Miles Traveled Analysis Guidelines | C-5
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
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
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.
Exhibit 1
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Vehicle Miles Traveled Analysis Guidelines | C-6
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 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.
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. Charging for electric passenger cars is not associated with a VMT reduction, but charging for NEV, electric bicycles, or other micromobility vehicles would support their use and associated VMT reduction.
Residential Retail Office Industrial Mixed-Use
SDT-8 grouped
Note that CAPCOA requires that this measure be grouped with NEV Network (SDT-3) in order to quantify its effectiveness. Other micromobility vehicles that are able to use the existing bike network would provide a VMT reduction without requiring implementation at the community level (i.e., electric bicycles).
Exhibit 1
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Vehicle Miles Traveled Analysis Guidelines | C-7
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
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.
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., Waze Carpool or equivalent).
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.
Exhibit 1
Dec. 6, 2021 Item #4 40
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Vehicle Miles Traveled Analysis Guidelines | C-8
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 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.
Commute Trip Reduction Marketing
Promote and advertise various transportation options, including promoting information and resources regarding Carlsbad’s Citywide TDM Plan as well as SANDAG’s iCommute program, which provides support to commuters through a variety of TDM measures such as carpool matching services, vanpool, and other services. As resources are available through Carlsbad’s Citywide TDM Program, those should be advertised and applied as well.
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.
Exhibit 1
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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
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.
Residential Retail Office Industrial Mixed-Use
TRT-9 Community-Level X
0.4-0.7% (CAPCOA) Up to 0.7% (SANDAG)
Note that available research documents effectiveness of car-share at the community level, and implementation of this strategy at that scale would require regional or local agency implementation and coordination and would not likely be applicable for individual development projects. However, individual projects are also expected to achieve VMT reductions through implementation of this measure.
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.
Residential Retail Office Industrial Mixed-Use
SDT-3 Community-Level X (only electric bike- and scooter-share)
0.5-12.7% (CAPCOA) Up to 0.1% (SANDAG)
Note that available research documents effectiveness of NEV networks at the community level, and implementation of this strategy at that scale would require regional or local agency implementation and coordination and would not likely be applicable for individual development projects. However, individual projects are also expected to achieve VMT reductions through implementation of electric bike share or other micromobility vehicles that can use the existing bike network.
Note that Project-Level and Community-Level measures cannot be combined.
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. Depending on project location and availability of alternative transportation options, implementation of parking measures may require implementing other supportive strategies.
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.
Exhibit 1
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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
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. Depending on project location and availability of alternative transportation options, implementation of parking measures may require implementing other supportive strategies.
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. Depending on project location and availability of alternative transportation options, implementation of parking measures may require implementing other supportive strategies.
Residential Retail Office Industrial Mixed-Use
PDT-2 X 2.6-13%
Exhibit 1
Dec. 6, 2021 Item #4 43
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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
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.
Exhibit 1
Dec. 6, 2021 Item #4 44
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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
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 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.
Exhibit 1
Dec. 6, 2021 Item #4 45
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Vehicle Miles Traveled Analysis Guidelines | C-13
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
Exhibit 1
Dec. 6, 2021 Item #4 46
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Vehicle Miles Traveled Analysis Guidelines | C-14
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
Exhibit 1
Dec. 6, 2021 Item #4 47
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Vehicle Miles Traveled Analysis Guidelines | C-15
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.
Exhibit 1
Dec. 6, 2021 Item #4 48
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Carlsbad
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June 2September 15, 2020
DRAFT
VEHICLE MILES TRAVELED (VMT)
ANALYSIS GUIDELINES
Exhibit 2
Dec. 6, 2021 Item #4 49
113
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 ........................................................................... 6
Local-Serving Public Facilities ................................................................................................ 8
Affordable Housing Projects ................................................................................................. 8
Redevelopment Projects That Result in a Net Reduction of VMT ........................................ 8
3.3 Vehicle Miles Traveled Analysis .................................................................................................... 8
Single Land-Use Residential or Office Projects ..................................................................... 9
Mixed-Use Projects ............................................................................................................... 9
Redevelopment Projects ..................................................................................................... 10
Regional Retail Projects ...................................................................................................... 10
Industrial Projects ............................................................................................................... 10
3.4 Significance Thresholds ............................................................................................................... 11
3.5 Mitigation .................................................................................................................................... 11
Exhibit 2
Dec. 6, 2021 Item #4 50
3.2.1
3.2.2
3.2.3
3.2.4
3.2.5
3.2.6
3.3.1
3.3.2
3.3.3
3.3.4
3.3.5
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Vehicle Miles Traveled Analysis Guidelines | ii
4 TRANSPORTATION PROJECTS ..................................................................................................... 11
4.1 Screening Criteria ........................................................................................................................ 11
4.2 Vehicle Miles Traveled Analysis .................................................................................................. 12
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 – Vehicel Miles Traveled Reduction Strategies and Effectiveness Calculations
Exhibit 2
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Vehicle Miles Traveled Analysis Guidelines | 1
1 BACKGROUND
This chapter provides background information on Senate Bill 743 (SB 743) and the need to conduct
vehicle miles traveled (VMT) analyses for CEQA transportation studies.
1.1 SB 743 Legislation
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.
Exhibit 2
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Vehicle Miles Traveled Analysis Guidelines | 2
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 C.
Exhibit 2
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(city of
Carlsbad
Vehicle Miles Traveled Analysis Guidelines | 3
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 City of 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.
Exhibit 2
Dec. 6, 2021 Item #4 54
(city of
Carlsbad
Vehicle Miles Traveled Analysis Guidelines | 4
3 LAND DEVELOPMENT PROJECTS
This chapter provides guidance on conducting VMT analyses for land development projects, including
single-use projects, mixed-use projects, and redevelopment projects.
3.1 Overview of Analysis
The City of Carlsbad generally follows the VMT analysis methodology recommended in OPR’s
Technical Advisory. OPR recommends analyzing VMT for most residential and office projects based
on efficiency metrics. Projects evaluated in this way are analyzed using VMT/capita or
VMT/employee rather than total VMT.
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 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. It may be acceptable for a project under 2,400
ADT to complete an individual model run if the project size and type are appropriate for inclusion
in the regional model.
If maps containing VMT/capita and VMT/employee are not available at the TAZ level using the most
recent SANDAG model series, then a project’s VMT/capita and VMT/employee are determined
using the most recent interactive maps provided by SANDAG. The VMT/capita or VMT/employee
of the project is estimated based on the average VMT/capita or VMT/employee for the census tract
in which the project is located.
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. Reductions for internal trips and pass-by trips (if
appropriate) should be made prior to determination of project trip generation. If a project’s total
trip generation exceeds 2,400 daily trips but is reduced below this value after taking into account
trip reductions such as internal trips and pass-by trips, it would not require a model run.
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.
Exhibit 2
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Vehicle Miles Traveled Analysis Guidelines | 5
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 the 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 an residentialoffice project may have a significant impact if its
VMT/employee exceeds a level 15% below regional VMT/employee. This threshold is also
used by the City of Carlsbad.
• 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.
• 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 the
regional 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. Further details on screening criteria can be found in OPR’s
Technical Advisory.
Small Projects
Per OPR’s Technical Advisory, projects that generate less than 110 ADT would be presumed
to have a less than significant transportation impact. Projects that can demonstrate that
they would generate an ADT of less than 110 after applying trip-reduction strategies would
be screened out from performing additional analysis.
Projects Located Near Transit
Per OPR’s Technical Advisory, residential, retail, 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.
Exhibit 2
Dec. 6, 2021 Item #4 56
3.2.1
3.2.2
(city of
Carlsbad
Vehicle Miles Traveled Analysis Guidelines | 6
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.
Exhibit 2
Dec. 6, 2021 Item #4 57
3.2.3
(city of
Carlsbad
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 areas. 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?
2. Regional retail and regional public facilities would use a model run even if ADT is between 110 and 2,400.
1
2
Exhibit 2
Dec. 6, 2021 Item #4 58
Vehicle Miles Traveled Analysis Guidelines | 8
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 public high
schools. A study evaluating the user capture area may be required in order to demonstrate
that a public facility is local-serving. Typically, private schools, charter schools, or public
facilities with unique uses will be required to provide a user capture area study. See
Appendix A for evaluating regional-serving public facilities.
Affordable Housing Projects
OPR’s Technical Advisory allows for a less than significant finding for transportation impacts
of residential projects that are 100% affordable housing located in infill areas. Affordable
housing projects in the City of Carlsbad could use this recommendation if they demonstrate
that they are located in infill areas based on urban planning considerations.
Redevelopment Projects That Result in a Net Reduction of VMT
Per CEQA, projects are considered to have a less than significant impact if they result in a
net reduction in the relevant performance measure (in this case VMT). Therefore,
redevelopment projects in the City of Carlsbad that generate less VMT than the existing
project they are replacing would be considered to have a less than significant impact on
VMT. Since VMT/capita and VMT/employee are efficiency metrics, a redevelopment
project that would produce more VMT than the existing project it is replacing would need
to conduct a VMT analysis assuming the proposed land use (with no credit taken for the
existing land use) to determine whether the proposed project meets the applicable
significance thresholds).
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.
3.3 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.
The methodology described below applies to projects that are consistent with the General Plan and
are evaluated using efficiency metrics (VMT/capita and VMT/employee). For projects that are
inconsistent with the General Plan or are evaluated using total VMT, a cumulative VMT analysis
Exhibit 2
Dec. 6, 2021 Item #4 59
3.2.4
3.2.5
3.2.6
(city of
Carlsbad
Vehicle Miles Traveled Analysis Guidelines | 9
may be required. Consultation with city staff should be conducted in these cases to determine the
appropriate VMT analysis methodology.
Single Land-Use Residential or Office Projects
Typical residential or office single land-use projects generating less than 2,400 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 the corresponding
threshold of significance, a 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 the project’s
VMT/capita or VMT/employee. If the resulting VMT/capita or VMT/employee exceeds the
corresponding threshold of significance, a significant impact would be indicated. Mitigation
measures would then be considered.
Mixed-Use Projects
Per OPR’s Technical Advisory, VMT analysis for mixed-use projects would be conducted by
analyzing each individual land use independently and applying the significance threshold
for each 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.
Mixed-use projects that generate more than 2,400 daily trips would use a model run of the
SANDAG regional travel demand model with the project to determine VMT/capita or
VMT/employee. Typically, the model would be set up so that the project has its own TAZ’s
and each land use within the project would have its own TAZ. The model would calculate
VMT/employee and VMT/capita values for each land use.
When the project generates less than 2,400 daily trips, the city’s VMT analysis maps may
be used for VMT analysis of mixed-use projects. The following approach can be considered
based on the methodology for VMT reduction of mixed-use projects provided in the
Regional Transportation Impact Study Guidelines:
1. Determine the percentage in VMT due to internal capture based on guidance provided
in the ITE Trip Generation manual, MXD methodologies or other techniques. An
approximation to convert reduction in external vehicle trips to VMT may be required.
If necessary, the resulting internal capture percentage should be reduced to match the
maximum recommended in CAPCOA guidance (see Appendix C).
2. Determine the total project mixed-use VMT for residential, office, and industrial land
uses (local-serving retail and similar uses will skip this step). This can be calculated by
multiplying the zonal VMT/capita or VMT/employee by the number of residents or
employees expected to be present at the project site.
Exhibit 2
Dec. 6, 2021 Item #4 60
3.3.1
3.3.2
(city of
Carlsbad
Vehicle Miles Traveled Analysis Guidelines | 10
3. Allocate the reduction in total VMT to residential, office, and industrial land uses. The
reduction in VMT should be allocated to individual land uses using the analyst’s
judgement. After allocating the reduction in VMT to each land use, determine
VMT/capita and VMT/employee values by dividing total VMT for each land use by the
number of residents or employees expected to occur with that land use.
4. After conducting this calculation, if all land uses are below the appropriate thresholds,
the project can presume a less than significant transportation impact. If not, mitigation
measures can be considered.
Redevelopment Projects
Redevelopment projects that do not meet the screening criteria above would need to
conduct a VMT analysis to determine whether they meet the appropriate significance
thresholds based on the project type. For analysis that uses efficiency metrics, it would be
based solely on the characteristics of the new project to be developed without any
consideration of the development that is being replaced.
Regional Retail Projects
All retail projects that do not meet the screening criteria above are considered regional
retail projects and require a 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. The ITE Trip Generation manual can be used as a
guide in determining which projects are industrial versus other land use types. The manual
includes the following categories of development as industrial:
• General Light Industrial
• Manufacturing
• Warehousing (including high-cube warehouses, parcel hubs, fulfillment centers,
and cold storage warehouses)
• Data Center
• Utility
• Special Trade Contractor
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 regional
average VMT/employee, a potentially significant impact would be indicated. Mitigation
measures would then be considered.
Exhibit 2
Dec. 6, 2021 Item #4 61
3.3.3
3.3.4
3.3.5
(city of
Carlsbad
Vehicle Miles Traveled Analysis Guidelines | 11
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 regional average VMT/employee, a potentially
significant impact would be indicated. Mitigation measures would then be considered.
It should be noted that goods movement is not subject to VMT analysis. Therefore, goods
movement trips associated with an industrial project would not be included when
determining VMT/employee.
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 regional 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 regional VMT per employee
City average VMT per capita and regional average 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
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 C for additional information on mitigation measures for land development projects.
Exhibit 2
Dec. 6, 2021 Item #4 62
(city of
Carlsbad
Vehicle Miles Traveled Analysis Guidelines | 12
4 TRANSPORTATION PROJECTS
SB 743 also applies to transportation projects, which are projects that improve transportation facilities for
any mode of travel. Per revised CEQA Section 15064.3, lead agencies have the discretion to 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
Exhibit 2
Dec. 6, 2021 Item #4 63
(city of
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Vehicle Miles Traveled Analysis Guidelines | 13
• 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.
Exhibit 2
Dec. 6, 2021 Item #4 64
(city of
Carlsbad
Vehicle Miles Traveled Analysis Guidelines | 14
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.
Exhibit 2
Dec. 6, 2021 Item #4 65
(city of
Carlsbad
Vehicle Miles Traveled Analysis Guidelines | 15
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: (Link to city web page 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
Exhibit 2
Dec. 6, 2021 Item #4 66
(city of
Carlsbad
VEHICLE MILES TRAVELED ANALYSIS GUIDELINES
APPENDIX A
VMT ANALYSIS
FOR NON-
STANDARD
UNIQUE LAND
USE TYPES
Exhibit 2
Dec. 6, 2021 Item #4 67
{'Cityof
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TABLE A-1: VMT ANALYSIS OF SAMPLE NON-STANDARDUNIQUE LAND USE TYPES
LAND USE TYPE BASIS FOR VMT ANALYSIS (1)
Religious (Local-Serving) See local-serving retail
Religious (Regional) See regional retail
Education (Local-Serving) See local-serving public facilities
Education (Regional) See regional retail
Hotel See office
Medical Office See office
Hospital or Regional-Service Medical See office
Regional-Serving Public Facilities See regional retail
Theme Parks See regional retail
(1) Check with city staff for guidance prior to conducting VMT analysis for the analysis of non-
standardunique land use types. For project types not listed above, the County of San
Diego Transportation Study Guidelines can be considered.
Exhibit 2
Dec. 6, 2021 Item #4 68
VEHICLE MILES TRAVELED ANALYSIS GUIDELINES
APPENDIX B
SCREENING
CRITERIA AND
THRESHOLD
EVIDENCE
Exhibit 2
Dec. 6, 2021 Item #4 69
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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 and Chapter 4 for Transportation Projects.
Screening Criteria
Certain types of development projects are presumed to have less than significant impacts to the
transportation system, and therefore would not be required to conduct a VMT analysis, if any of the
following criteria are established, based on substantial evidence.
Small Projects
Small projects that would generate less than 110 average daily vehicle trips (ADT), would also not result
in significant transportation impacts on the transportation system:
Evidence – The OPR Technical Advisory states that “projects that generate or attract fewer than 110 trips
per day generally may be assumed to cause a less-than-significant impact.” This is supported by the fact
that CEQA provides a categorical exemption for existing facilities, including additions to existing structures
of up to 10,000 square feet, so long as the project is in an area where public infrastructure is available to
allow for maximum planned development, and the project is not in an environmentally sensitive area.
(CEQA Guidelines, § 15301(e)(2).) Typical project types for which trip generation increases relatively
linearly with building footprint (e.g., general office building, single tenant office building, office park, or
business park) generate or attract an additional 110- 124 trips per 10,000 square feet. Therefore, absent
substantial evidence otherwise, it is reasonable to conclude that the addition of 110 or fewer trips could
be considered not to lead to a significant impact.
Projects Located Near Transit
Per OPR’s Technical Advisory projects whose project site boundaries are within a half mile of an existing
or planned major transit stop or a major stop along a high-quality transit corridor can be screened out of
VMT analysis. Withing the City of Carlsbad, this would apply to projects within one half mile of the
Carlsbad Village or Carlsbad Poinsettia Coaster stations, as well as projects within one-half mile of the
Plaza Camino Real transit center. This presumption would not apply, however, if project-specific or
location-specific information indicates that the project will still generate significant levels of VMT.
Evidence – The OPR Technical Advisory states that “Proposed CEQA Guideline Section 15064.3,
subdivision (b)(1), states that lead agencies generally should presume that certain projects (including
residential, retail, and office projects, as well as projects that are a mix of these uses) proposed within ½
mile of an existing major transit stop or an existing stop along a high quality transit corridor will have a
less-than-significant impact on VMT. This presumption would not apply, however, if project-specific or
location-specific information indicates that the project will still generate significant levels of VMT.” Pub.
Resources Code, § 21064.3 clarifies the definition of a major transit stop (“ ‘Major transit stop’ means a
site containing an existing rail transit station, a ferry terminal served by either a bus or rail transit service,
or the intersection of two or more major bus routes with a frequency of service interval of 15 minutes or
less during the morning and afternoon peak commute periods.”). Pub. Resources Code, § 21155 clarifies
the definition of a major transit stop (“For purposes of this section, a high-quality transit corridor means
Exhibit 2
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a corridor with fixed route bus service with service intervals no longer than 15 minutes during peak
commute hours..”).
Local-Serving Retail and Similar Uses
Local-serving retail is defined in the City of Carlsbad as retail that is less than 50,000 square feet of total
gross floor area or retail development that is greater than 50,000 square feet that has a market area study
showing a market capture area that is primarily within Carlsbad and the adjacent cities of Oceanside, Vista,
San Marcos, and Encinitas.
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. Since the type of retail influences whether
it will be locally serving or retail serving (for example grocery, drug stores, convenience stores, etc.) and
the size of these facilities may be above 50,000 square feet, an applicant can provide a market survey
demonstrating that the project serves the local community if it is over 50,000 square feet.
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.
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
Exhibit 2
Dec. 6, 2021 Item #4 71
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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.” Per CEQA, projects are considered to have a less than
significant impact if they result in a net reduction in the relevant performance measure.
Thresholds
If a project is required to complete a VMT analysis, the project’s impacts to the transportation system
would be significant if the VMT would exceed any of the thresholds below.
Residential Projects
Threshold – 15% below city average household VMT/Capita.
Evidence – The OPR Technical Advisory provides that “residential development that would generate vehicle
travel that is 15 or more percent below the existing residential VMT per capita, measured against the
region or city, may indicate a less-than-significant transportation impact.”
Office/Employment Projects
Threshold – 15% below regional average VMT/Employee.
Evidence – The OPR Technical Advisory provides that “office projects that would generate vehicle travel
exceeding 15 percent below existing VMT per employee for the region may indicate a significant
transportation impact.”
Industrial Projects
Threshold – Above the regional average VMT/employee
Evidence – The OPR Technical Advisory provides that “[o]f land use projects, residential, office, and retail
projects tend to have the greatest influence on VMT. For that reason, OPR recommends the quantified
thresholds described above for purposes of analysis and mitigation. Lead agencies, using more location-
specific information, may develop their own more specific thresholds, which may include other land use
types.” Purely industrial uses are desired to be located in locations that are less dense and not within urban
areas which typically have higher VMT 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. It recognizes that industrial uses,
which generate relatively lower total VMT are most appropriate in areas that have a lower potential to
reduce VMT. This allows more available land within areas with a high potential to achieve VMT reductions
available for more dense development.
Exhibit 2
Dec. 6, 2021 Item #4 72
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Regional Retail
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
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• 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
Exhibit 2
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Vehicle Miles Traveled Analysis Guidelines | B-6
• Addition of new or enhanced bike or pedestrian facilities on existing streets/highways or within
existing public rights-of-way
• Addition of Class I bike paths, trails, multi-use paths, or other off-road facilities that serve non-
motorized travel
• Installation of publicly available alternative fuel/charging infrastructure
• Addition of passing lanes, truck climbing lanes, or truck brake-check lanes in rural areas that do
not increase overall vehicle capacity along the corridor
Evidence – The list above 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.
Exhibit 2
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APPENDIX C
VEHICLE MILES
TRAVELED
REDUCTION
STRATEGIES AND
EFFECTIVENESS
CALCULATIONS
VEHICLE MILES TRAVELED ANALYSIS GUIDELINES
Exhibit 2
Dec. 6, 2021 Item #4 76
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Vehicle Miles Traveled Analysis Guidelines | C-1
VMT REDUCTION STRATEGIES UNDER CEQA
Projects can apply VMT reductions to lower their calculated VMT to 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 Citywide TDM Program), or that
have been observed 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
quantify the VMT reduction that results from combining strategies, the formula below can be applied
absent additional knowledge or information:
Exhibit 2
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Vehicle Miles Traveled Analysis Guidelines | C-2
𝑇𝑇𝑇𝑇𝑇𝑇𝑇𝑇𝑇𝑇 𝑉𝑉𝑉𝑉𝑇𝑇 𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑇𝑇𝑅𝑅𝑇𝑇𝑅𝑅 = (1 − 𝑃𝑃a) ∗ (1 – 𝑃𝑃b) ∗ (1 – 𝑃𝑃c) ∗ …
Where: 𝑃𝑃x = percent reduction of each VMT reduction strategy
For example, if two strategies were proposed with corresponding VMT reductions of 20 percent and 10
percent, the equation would be [1-(1-20%)*(1-10%)] or [1-(80%*90%)], which equates to a 28 percent
reduction rather than the 30 percent reduction that would otherwise result from a direct sum. This
adjustment methodology is simply a mathematical approach to dampening the potential effectiveness
and is not supported by research related to the actual effectiveness of combined strategies. As noted
above, this approach minimizes possibility of overstating VMT reduction effectiveness.
When calculating the 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.
Exhibit 2
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Vehicle Miles Traveled Analysis Guidelines | C-3
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
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.
Exhibit 2
Dec. 6, 2021 Item #4 79
I
(c ity of
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I
Vehicle Miles Traveled Analysis Guidelines | C-4
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
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. Depending on project location and availability of alternative transportation options, implementation of parking measures may require implementing other supportive strategies.
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.
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. Depending on project location and availability of alternative transportation options, implementation of parking measures may require implementing other supportive strategies.
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 X 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. Depending on project location and availability of alternative transportation options, implementation of parking measures may require implementing other supportive strategies.
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 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.
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 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.
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
Exhibit 2
Dec. 6, 2021 Item #4 80
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Vehicle Miles Traveled Analysis Guidelines | C-5
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
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
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.
Exhibit 2
Dec. 6, 2021 Item #4 81
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Vehicle Miles Traveled Analysis Guidelines | C-6
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 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.
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. Charging for electric passenger cars is not associated with a VMT reduction, but charging for NEV, electric bicycles, or other micromobility vehicles would support their use and associated VMT reduction.
Residential Retail Office Industrial Mixed-Use
SDT-8 grouped
Note that CAPCOA requires that this measure be grouped with NEV Network (SDT-3) in order to quantify its effectiveness. Other micromobility vehicles that are able to use the existing bike network would provide a VMT reduction without requiring implementation at the community level (i.e., electric bicycles).
Exhibit 2
Dec. 6, 2021 Item #4 82
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Vehicle Miles Traveled Analysis Guidelines | C-7
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
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.
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., Waze Carpool or equivalent).
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.
Exhibit 2
Dec. 6, 2021 Item #4 83
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Vehicle Miles Traveled Analysis Guidelines | C-8
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 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.
Commute Trip Reduction Marketing
Promote and advertise various transportation options, including promoting information and resources regarding Carlsbad’s Citywide TDM Plan as well as SANDAG’s iCommute program, which provides support to commuters through a variety of TDM measures such as carpool matching services, vanpool, and other services. As resources are available through Carlsbad’s Citywide TDM Program, those should be advertised and applied as well.
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.
Exhibit 2
Dec. 6, 2021 Item #4 84
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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
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.
Residential Retail Office Industrial Mixed-Use
TRT-9 Community-Level X
0.4-0.7% (CAPCOA) Up to 0.7% (SANDAG)
Note that available research documents effectiveness of car-share at the community level, and implementation of this strategy at that scale would require regional or local agency implementation and coordination and would not likely be applicable for individual development projects. However, individual projects are also expected to achieve VMT reductions through implementation of this measure.
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.
Residential Retail Office Industrial Mixed-Use
SDT-3 Community-Level X (only electric bike- and scooter-share)
0.5-12.7% (CAPCOA) Up to 0.1% (SANDAG)
Note that available research documents effectiveness of NEV networks at the community level, and implementation of this strategy at that scale would require regional or local agency implementation and coordination and would not likely be applicable for individual development projects. However, individual projects are also expected to achieve VMT reductions through implementation of electric bike share or other micromobility vehicles that can use the existing bike network.
Note that Project-Level and Community-Level measures cannot be combined.
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. Depending on project location and availability of alternative transportation options, implementation of parking measures may require implementing other supportive strategies.
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.
Exhibit 2
Dec. 6, 2021 Item #4 85
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Carlsbad
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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
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. Depending on project location and availability of alternative transportation options, implementation of parking measures may require implementing other supportive strategies.
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. Depending on project location and availability of alternative transportation options, implementation of parking measures may require implementing other supportive strategies.
Residential Retail Office Industrial Mixed-Use
PDT-2 X 2.6-13%
Exhibit 2
Dec. 6, 2021 Item #4 86
(c ity of
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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
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.
Exhibit 2
Dec. 6, 2021 Item #4 87
(c ity of
Carlsbad
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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
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 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.
Exhibit 2
Dec. 6, 2021 Item #4 88
(c ity of
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Vehicle Miles Traveled Analysis Guidelines | C-13
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
Exhibit 2
Dec. 6, 2021 Item #4 89
(c ity of
Carlsbad
Cal i forn ia
Vehicle Miles Traveled Analysis Guidelines | C-14
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
Exhibit 2
Dec. 6, 2021 Item #4 90
(c ity of
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Vehicle Miles Traveled Analysis Guidelines | C-15
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.
Exhibit 2
Dec. 6, 2021 Item #4 91
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Carlsbad
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VEHICLE MILES TRAVELED (VMT)
ANALYSIS GUIDELINES
September 15, 2020
Exhibit 3
Dec. 6, 2021 Item #4 92
113
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 ........................................................................... 6
Local-Serving Public Facilities ................................................................................................ 8
Affordable Housing Projects ................................................................................................. 8
Redevelopment Projects That Result in a Net Reduction of VMT ........................................ 8
3.3 Vehicle Miles Traveled Analysis .................................................................................................... 8
Single Land-Use Residential or Office Projects ..................................................................... 9
Mixed-Use Projects ............................................................................................................... 9
Redevelopment Projects ..................................................................................................... 10
Regional Retail Projects ...................................................................................................... 10
Industrial Projects ............................................................................................................... 10
3.4 Significance Thresholds ............................................................................................................... 11
3.5 Mitigation .................................................................................................................................... 11
Exhibit 3
Dec. 6, 2021 Item #4 93
3.2.1
3.2.2
3.2.3
3.2.4
3.2.5
3.2.6
3.3.1
3.3.2
3.3.3
3.3.4
3.3.5
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Vehicle Miles Traveled Analysis Guidelines | ii
4 TRANSPORTATION PROJECTS .................................................................................................... 11
4.1 Screening Criteria ........................................................................................................................ 11
4.2 Vehicle Miles Traveled Analysis .................................................................................................. 12
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 – Vehicel Miles Traveled Reduction Strategies and Effectiveness Calculations
Exhibit 3
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Vehicle Miles Traveled Analysis Guidelines | 1
1 BACKGROUND
This chapter provides background information on Senate Bill 743 (SB 743) and the need to conduct
vehicle miles traveled (VMT) analyses for CEQA transportation studies.
1.1 SB 743 Legislation
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.
Exhibit 3
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Vehicle Miles Traveled Analysis Guidelines | 2
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 C.
Exhibit 3
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Vehicle Miles Traveled Analysis Guidelines | 3
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 City of 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.
Exhibit 3
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(city of
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Vehicle Miles Traveled Analysis Guidelines | 4
3 LAND DEVELOPMENT PROJECTS
This chapter provides guidance on conducting VMT analyses for land development projects, including
single-use projects, mixed-use projects, and redevelopment projects.
3.1 Overview of Analysis
The City of Carlsbad generally follows the VMT analysis methodology recommended in OPR’s
Technical Advisory. OPR recommends analyzing VMT for most residential and office projects based
on efficiency metrics. Projects evaluated in this way are analyzed using VMT/capita or
VMT/employee rather than total VMT.
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 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. It may be acceptable for a project under 2,400
ADT to complete an individual model run if the project size and type are appropriate for inclusion
in the regional model.
If maps containing VMT/capita and VMT/employee are not available at the TAZ level using the most
recent SANDAG model series, then a project’s VMT/capita and VMT/employee are determined
using the most recent interactive maps provided by SANDAG. The VMT/capita or VMT/employee
of the project is estimated based on the average VMT/capita or VMT/employee for the census tract
in which the project is located.
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. Reductions for internal trips and pass-by trips (if
appropriate) should be made prior to determination of project trip generation. If a project’s total
trip generation exceeds 2,400 daily trips but is reduced below this value after taking into account
trip reductions such as internal trips and pass-by trips, it would not require a model run.
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.
Exhibit 3
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Vehicle Miles Traveled Analysis Guidelines | 5
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 the 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 an office project may have a significant impact if its VMT/employee
exceeds a level 15% below regional VMT/employee. This threshold is also used by the City
of Carlsbad.
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.
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 the
regional 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. Further details on screening criteria can be found in OPR’s
Technical Advisory.
Small Projects
Per OPR’s Technical Advisory, projects that generate less than 110 ADT would be presumed
to have a less than significant transportation impact. Projects that can demonstrate that
they would generate an ADT of less than 110 after applying trip-reduction strategies would
be screened out from performing additional analysis.
Projects Located Near Transit
Per OPR’s Technical Advisory, residential, retail, 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.
Exhibit 3
Dec. 6, 2021 Item #4 99
3.2.1
3.2.2
(city of
Carlsbad
Vehicle Miles Traveled Analysis Guidelines | 6
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.
Exhibit 3
Dec. 6, 2021 Item #4 100
3.2.3
(city of
Carlsbad
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 areas. 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 and regional public facilities would use a model even if ADT is between 110 and 2,400.2.
1
2
Exhibit 3
Dec. 6, 2021 Item #4 101
Vehicle Miles Traveled Analysis Guidelines | 8
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 public high
schools. A study evaluating the user capture area may be required in order to demonstrate
that a public facility is local-serving. Typically, private schools, charter schools, or public
facilities with unique uses will be required to provide a user capture area study. See
Appendix A for evaluating regional-serving public facilities.
Affordable Housing Projects
OPR’s Technical Advisory allows for a less than significant finding for transportation impacts
of residential projects that are 100% affordable housing located in infill areas. Affordable
housing projects in the City of Carlsbad could use this recommendation if they demonstrate
that they are located in infill areas based on urban planning considerations.
Redevelopment Projects That Result in a Net Reduction of VMT
Per CEQA, projects are considered to have a less than significant impact if they result in a
net reduction in the relevant performance measure (in this case VMT). Therefore,
redevelopment projects in the City of Carlsbad that generate less VMT than the existing
project they are replacing would be considered to have a less than significant impact on
VMT. Since VMT/capita and VMT/employee are efficiency metrics, a redevelopment
project that would produce more VMT than the existing project it is replacing would need
to conduct a VMT analysis assuming the proposed land use (with no credit taken for the
existing land use) to determine whether the proposed project meets the applicable
significance thresholds).
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.
3.3 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.
The methodology described below applies to projects that are consistent with the General Plan and
are evaluated using efficiency metrics (VMT/capita and VMT/employee). For projects that are
inconsistent with the General Plan or are evaluated using total VMT, a cumulative VMT analysis
Exhibit 3
Dec. 6, 2021 Item #4 102
3.2.4
3.2.5
3.2.6
(city of
Carlsbad
Vehicle Miles Traveled Analysis Guidelines | 9
may be required. Consultation with city staff should be conducted in these cases to determine the
appropriate VMT analysis methodology.
Single Land-Use Residential or Office Projects
Typical residential or office single land-use projects generating less than 2,400 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 the corresponding
threshold of significance, a 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 the project’s
VMT/capita or VMT/employee. If the resulting VMT/capita or VMT/employee exceeds the
corresponding threshold of significance, a significant impact would be indicated. Mitigation
measures would then be considered.
Mixed-Use Projects
Per OPR’s Technical Advisory, VMT analysis for mixed-use projects would be conducted by
analyzing each individual land use independently and applying the significance threshold
for each 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.
Mixed-use projects that generate more than 2,400 daily trips would use a model run of the
SANDAG regional travel demand model with the project to determine VMT/capita or
VMT/employee. Typically, the model would be set up so that the project has its own TAZ’s
and each land use within the project would have its own TAZ. The model would calculate
VMT/employee and VMT/capita values for each land use.
When the project generates less than 2,400 daily trips, the city’s VMT analysis maps may
be used for VMT analysis of mixed-use projects. The following approach can be considered
based on the methodology for VMT reduction of mixed-use projects provided in the
Regional Transportation Impact Study Guidelines:
1. Determine the percentage in VMT due to internal capture based on guidance provided
in the ITE Trip Generation manual, MXD methodologies or other techniques. An
approximation to convert reduction in external vehicle trips to VMT may be required.
If necessary, the resulting internal capture percentage should be reduced to match the
maximum recommended in CAPCOA guidance (see Appendix C).
2. Determine the total project mixed-use VMT for residential, office, and industrial land
uses (local-serving retail and similar uses will skip this step). This can be calculated by
multiplying the zonal VMT/capita or VMT/employee by the number of residents or
employees expected to be present at the project site.
Exhibit 3
Dec. 6, 2021 Item #4 103
3.3.1
3.3.2
(city of
Carlsbad
Vehicle Miles Traveled Analysis Guidelines | 10
3. Allocate the reduction in total VMT to residential, office, and industrial land uses. The
reduction in VMT should be allocated to individual land uses using the analyst’s
judgement. After allocating the reduction in VMT to each land use, determine
VMT/capita and VMT/employee values by dividing total VMT for each land use by the
number of residents or employees expected to occur with that land use.
4. After conducting this calculation, if all land uses are below the appropriate thresholds,
the project can presume a less than significant transportation impact. If not, mitigation
measures can be considered.
Redevelopment Projects
Redevelopment projects that do not meet the screening criteria above would need to
conduct a VMT analysis to determine whether they meet the appropriate significance
thresholds based on the project type. For analysis that uses efficiency metrics, it would be
based solely on the characteristics of the new project to be developed without any
consideration of the development that is being replaced.
Regional Retail Projects
All retail projects that do not meet the screening criteria above are considered regional
retail projects and require a model. 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. The ITE Trip Generation manual can be used as a
guide in determining which projects are industrial versus other land use types. The manual
includes the following categories of development as industrial:
General Light Industrial
Manufacturing
Warehousing (including high-cube warehouses, parcel hubs, fulfillment centers,
and cold storage warehouses)
Data Center
Utility
Special Trade Contractor
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 regional
average VMT/employee, a potentially significant impact would be indicated. Mitigation
measures would then be considered.
Exhibit 3
Dec. 6, 2021 Item #4 104
3.3.3
3.3.4
3.3.5
(city of
Carlsbad
Vehicle Miles Traveled Analysis Guidelines | 11
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 regional average VMT/employee, a potentially
significant impact would be indicated. Mitigation measures would then be considered.
It should be noted that goods movement is not subject to VMT analysis. Therefore, goods
movement trips associated with an industrial project would not be included when
determining VMT/employee.
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 regional 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 regional VMT per employee
City average VMT per capita and regional average VMT per employee values are determined using
the SANDAG regional travel demand model.
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
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 C for additional information on mitigation measures for land development projects.
Exhibit 3
Dec. 6, 2021 Item #4 105
(City of
Carlsbad
Vehicle Miles Traveled Analysis Guidelines | 12
4 TRANSPORTATION PROJECTS
SB 743 also applies to transportation projects, which are projects that improve transportation facilities for
any mode of travel. Per revised CEQA Section 15064.3, lead agencies have the discretion to 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
Exhibit 3
Dec. 6, 2021 Item #4 106
(city of
Carlsbad
Vehicle Miles Traveled Analysis Guidelines | 13
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.
Exhibit 3
Dec. 6, 2021 Item #4 107
(city of
Carlsbad
Vehicle Miles Traveled Analysis Guidelines | 14
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.
Exhibit 3
Dec. 6, 2021 Item #4 108
(City of
Carlsbad
Vehicle Miles Traveled Analysis Guidelines | 15
5 ADDITIONAL RESOURCES FOR VEHICLE MILES TRAVELED ANALYSIS
This chapter provides locations of websites that can be used to locate additional resources that may be
useful in conducting VMT analyses in the City of Carlsbad:
• Governor’s Office of Planning and Research (OPR): 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
Exhibit 3
Dec. 6, 2021 Item #4 109
("city of
Carlsbad
VEHICLE MILES TRAVELED ANALYSIS GUIDELINES
APPENDIX A
VMT ANALYSIS
FOR UNIQUE
LAND USE TYPES
Exhibit 3
Dec. 6, 2021 Item #4 110
(City of
Carlsbad
California
TABLE A-1: VMT ANALYSIS OF SAMPLE UNIQUE LAND USE TYPES
LAND USE TYPE BASIS FOR VMT ANALYSIS (1)
Religious (Local-Serving) See local-serving retail
Religious (Regional) See regional retail
Education (Local-Serving) See local-serving public facilities
Education (Regional) See regional retail
Hotel See office
Medical Office See office
Hospital or Regional-Service Medical See office
Regional-Serving Public Facilities See regional retail
Theme Parks See regional retail
(1) Check with city staff for guidance prior to conducting VMT analysis for the analysis of unique land
use types. For project types not listed above, the County of San Diego Transportation Study
Guidelines can be considered.
Exhibit 3
Dec. 6, 2021 Item #4 111
VEHICLE MILES TRAVELED ANALYSIS GUIDELINES
APPENDIX B
SCREENING
CRITERIA AND
THRESHOLD
EVIDENCE
Exhibit 3
Dec. 6, 2021 Item #4 112
(city of
Carlsbad
California
Vehicle Miles Traveled Analysis Guidelines | B-1
SCREENING CRITERIA AND THRESHOLD EVIDENCE
This appendix provides context and evidence for the screening criteria and threshold evidence included
in Chapters 3 for Land Development Projects and Chapter 4 for Transportation Projects.
Screening Criteria
Certain types of development projects are presumed to have less than significant impacts to the
transportation system, and therefore would not be required to conduct a VMT analysis, if any of the
following criteria are established, based on substantial evidence.
Small Projects
Small projects that would generate less than 110 average daily vehicle trips (ADT), would also not result
in significant transportation impacts on the transportation system:
Evidence – The OPR Technical Advisory states that “projects that generate or attract fewer than 110 trips
per day generally may be assumed to cause a less-than-significant impact.” This is supported by the fact
that CEQA provides a categorical exemption for existing facilities, including additions to existing structures
of up to 10,000 square feet, so long as the project is in an area where public infrastructure is available to
allow for maximum planned development, and the project is not in an environmentally sensitive area.
(CEQA Guidelines, § 15301(e)(2).) Typical project types for which trip generation increases relatively
linearly with building footprint (e.g., general office building, single tenant office building, office park, or
business park) generate or attract an additional 110- 124 trips per 10,000 square feet. Therefore, absent
substantial evidence otherwise, it is reasonable to conclude that the addition of 110 or fewer trips could
be considered not to lead to a significant impact.
Projects Located Near Transit
Per OPR’s Technical Advisory projects whose project site boundaries are within a half mile of an existing
or planned major transit stop or a major stop along a high-quality transit corridor can be screened out of
VMT analysis. Withing the City of Carlsbad, this would apply to projects within one half mile of the
Carlsbad Village or Carlsbad Poinsettia Coaster stations, as well as projects within one-half mile of the
Plaza Camino Real transit center. This presumption would not apply, however, if project-specific or
location-specific information indicates that the project will still generate significant levels of VMT.
Evidence – The OPR Technical Advisory states that “Proposed CEQA Guideline Section 15064.3,
subdivision (b)(1), states that lead agencies generally should presume that certain projects (including
residential, retail, and office projects, as well as projects that are a mix of these uses) proposed within ½
mile of an existing major transit stop or an existing stop along a high quality transit corridor will have a
less-than-significant impact on VMT. This presumption would not apply, however, if project-specific or
location-specific information indicates that the project will still generate significant levels of VMT.” Pub.
Resources Code, § 21064.3 clarifies the definition of a major transit stop (“ ‘Major transit stop’ means a
site containing an existing rail transit station, a ferry terminal served by either a bus or rail transit service,
or the intersection of two or more major bus routes with a frequency of service interval of 15 minutes or
less during the morning and afternoon peak commute periods.”). Pub. Resources Code, § 21155 clarifies
the definition of a major transit stop (“For purposes of this section, a high-quality transit corridor means
Exhibit 3
Dec. 6, 2021 Item #4 113
{city of
Carlsbad
California
Vehicle Miles Traveled Analysis Guidelines | B-2
a corridor with fixed route bus service with service intervals no longer than 15 minutes during peak
commute hours..”).
Local-Serving Retail and Similar Uses
Local-serving retail is defined in the City of Carlsbad as retail that is less than 50,000 square feet of total
gross floor area or retail development that is greater than 50,000 square feet that has a market area study
showing a market capture area that is primarily within Carlsbad and the adjacent cities of Oceanside, Vista,
San Marcos, and Encinitas.
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. Since the type of retail influences whether
it will be locally serving or retail serving (for example grocery, drug stores, convenience stores, etc.) and
the size of these facilities may be above 50,000 square feet, an applicant can provide a market survey
demonstrating that the project serves the local community if it is over 50,000 square feet.
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.
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
Exhibit 3
Dec. 6, 2021 Item #4 114
{city of
Carlsbad
California
Vehicle Miles Traveled Analysis Guidelines | B-3
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.” Per CEQA, projects are considered to have a less than
significant impact if they result in a net reduction in the relevant performance measure.
Thresholds
If a project is required to complete a VMT analysis, the project’s impacts to the transportation system
would be significant if the VMT would exceed any of the thresholds below.
Residential Projects
Threshold – 15% below city average household VMT/Capita.
Evidence – The OPR Technical Advisory provides that “residential development that would generate vehicle
travel that is 15 or more percent below the existing residential VMT per capita, measured against the
region or city, may indicate a less-than-significant transportation impact.”
Office/Employment Projects
Threshold – 15% below regional average VMT/Employee.
Evidence – The OPR Technical Advisory provides that “office projects that would generate vehicle travel
exceeding 15 percent below existing VMT per employee for the region may indicate a significant
transportation impact.”
Industrial Projects
Threshold – Above the regional average VMT/employee
Evidence – The OPR Technical Advisory provides that “[o]f land use projects, residential, office, and retail
projects tend to have the greatest influence on VMT. For that reason, OPR recommends the quantified
thresholds described above for purposes of analysis and mitigation. Lead agencies, using more location-
specific information, may develop their own more specific thresholds, which may include other land use
types.” Purely industrial uses are desired to be located in locations that are less dense and not within urban
areas which typically have higher VMT 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. It recognizes that industrial uses,
which generate relatively lower total VMT are most appropriate in areas that have a lower potential to
reduce VMT. This allows more available land within areas with a high potential to achieve VMT reductions
available for more dense development.
Exhibit 3
Dec. 6, 2021 Item #4 115
{city of
Carlsbad
California
Vehicle Miles Traveled Analysis Guidelines | B-4
Regional Retail
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
Exhibit 3
Dec. 6, 2021 Item #4 116
{city of
Carlsbad
California
Vehicle Miles Traveled Analysis Guidelines | B-5
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
Exhibit 3
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{city of
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California
Vehicle Miles Traveled Analysis Guidelines | B-6
Addition of new or enhanced bike or pedestrian facilities on existing streets/highways or within
existing public rights-of-way
Addition of Class I bike paths, trails, multi-use paths, or other off-road facilities that serve non-
motorized travel
Installation of publicly available alternative fuel/charging infrastructure
Addition of passing lanes, truck climbing lanes, or truck brake-check lanes in rural areas that do
not increase overall vehicle capacity along the corridor
Evidence – The list above 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.
Exhibit 3
Dec. 6, 2021 Item #4 118
{city of
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California
APPENDIX C
VEHICLE MILES
TRAVELED
REDUCTION
STRATEGIES AND
EFFECTIVENESS
CALCULATIONS
VEHICLE MILES TRAVELED ANALYSIS GUIDELINES
Exhibit 3
Dec. 6, 2021 Item #4 119
{city of
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California
Vehicle Miles Traveled Analysis Guidelines | C-1
VMT REDUCTION STRATEGIES UNDER CEQA
Projects can apply VMT reductions to lower their calculated VMT to 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 Citywide TDM Program), or that
have been observed 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
quantify the VMT reduction that results from combining strategies, the formula below can be applied
absent additional knowledge or information:
Exhibit 3
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Vehicle Miles Traveled Analysis Guidelines | C-2
𝑇𝑇𝑇𝑇𝑇𝑇𝑇𝑇𝑇𝑇 𝑉𝑉𝑉𝑉𝑇𝑇 𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑇𝑇𝑅𝑅𝑇𝑇𝑅𝑅 = (1 − 𝑃𝑃a) ∗ (1 – 𝑃𝑃b) ∗ (1 – 𝑃𝑃c) ∗ …
Where: 𝑃𝑃x = percent reduction of each VMT reduction strategy
For example, if two strategies were proposed with corresponding VMT reductions of 20 percent and 10
percent, the equation would be [1-(1-20%)*(1-10%)] or [1-(80%*90%)], which equates to a 28 percent
reduction rather than the 30 percent reduction that would otherwise result from a direct sum. This
adjustment methodology is simply a mathematical approach to dampening the potential effectiveness
and is not supported by research related to the actual effectiveness of combined strategies. As noted
above, this approach minimizes possibility of overstating VMT reduction effectiveness.
When calculating the 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.
Exhibit 3
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Vehicle Miles Traveled Analysis Guidelines | C-3
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
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.
Exhibit 3
Dec. 6, 2021 Item #4 122
I
(c ity of
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I
Vehicle Miles Traveled Analysis Guidelines | C-4
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
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. Depending on project location and availability of alternative transportation options, implementation of parking measures may require implementing other supportive strategies.
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.
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. Depending on project location and availability of alternative transportation options, implementation of parking measures may require implementing other supportive strategies.
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 X 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. Depending on project location and availability of alternative transportation options, implementation of parking measures may require implementing other supportive strategies.
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 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.
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 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.
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
Exhibit 3
Dec. 6, 2021 Item #4 123
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Vehicle Miles Traveled Analysis Guidelines | C-5
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
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
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.
Exhibit 3
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Vehicle Miles Traveled Analysis Guidelines | C-6
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 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.
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. Charging for electric passenger cars is not associated with a VMT reduction, but charging for NEV, electric bicycles, or other micromobility vehicles would support their use and associated VMT reduction.
Residential Retail Office Industrial Mixed-Use
SDT-8 grouped
Note that CAPCOA requires that this measure be grouped with NEV Network (SDT-3) in order to quantify its effectiveness. Other micromobility vehicles that are able to use the existing bike network would provide a VMT reduction without requiring implementation at the community level (i.e., electric bicycles).
Exhibit 3
Dec. 6, 2021 Item #4 125
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Vehicle Miles Traveled Analysis Guidelines | C-7
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
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.
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., Waze Carpool or equivalent).
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.
Exhibit 3
Dec. 6, 2021 Item #4 126
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Vehicle Miles Traveled Analysis Guidelines | C-8
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 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.
Commute Trip Reduction Marketing
Promote and advertise various transportation options, including promoting information and resources regarding Carlsbad’s Citywide TDM Plan as well as SANDAG’s iCommute program, which provides support to commuters through a variety of TDM measures such as carpool matching services, vanpool, and other services. As resources are available through Carlsbad’s Citywide TDM Program, those should be advertised and applied as well.
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.
Exhibit 3
Dec. 6, 2021 Item #4 127
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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
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.
Residential Retail Office Industrial Mixed-Use
TRT-9 Community-Level X
0.4-0.7% (CAPCOA) Up to 0.7% (SANDAG)
Note that available research documents effectiveness of car-share at the community level, and implementation of this strategy at that scale would require regional or local agency implementation and coordination and would not likely be applicable for individual development projects. However, individual projects are also expected to achieve VMT reductions through implementation of this measure.
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.
Residential Retail Office Industrial Mixed-Use
SDT-3 Community-Level X (only electric bike- and scooter-share)
0.5-12.7% (CAPCOA) Up to 0.1% (SANDAG)
Note that available research documents effectiveness of NEV networks at the community level, and implementation of this strategy at that scale would require regional or local agency implementation and coordination and would not likely be applicable for individual development projects. However, individual projects are also expected to achieve VMT reductions through implementation of electric bike share or other micromobility vehicles that can use the existing bike network.
Note that Project-Level and Community-Level measures cannot be combined.
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. Depending on project location and availability of alternative transportation options, implementation of parking measures may require implementing other supportive strategies.
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.
Exhibit 3
Dec. 6, 2021 Item #4 128
(c ity of
Carlsbad
Cal i forn ia
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
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. Depending on project location and availability of alternative transportation options, implementation of parking measures may require implementing other supportive strategies.
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. Depending on project location and availability of alternative transportation options, implementation of parking measures may require implementing other supportive strategies.
Residential Retail Office Industrial Mixed-Use
PDT-2 X 2.6-13%
Exhibit 3
Dec. 6, 2021 Item #4 129
(c ity of
Carlsbad
Cal i forn ia
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
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.
Exhibit 3
Dec. 6, 2021 Item #4 130
(c ity of
Carlsbad
Cal i forn ia
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
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 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.
Exhibit 3
Dec. 6, 2021 Item #4 131
(c ity of
Carlsbad
Cal i forn ia
Vehicle Miles Traveled Analysis Guidelines | C-13
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
Exhibit 3
Dec. 6, 2021 Item #4 132
(c ity of
Carlsbad
Cal i forn ia
Vehicle Miles Traveled Analysis Guidelines | C-14
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
Exhibit 3
Dec. 6, 2021 Item #4 133
(c ity of
Carlsbad
Cal i forn ia
Vehicle Miles Traveled Analysis Guidelines | C-15
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.
Exhibit 3
Dec. 6, 2021 Item #4 134
(c ity of
Carlsbad
Cal i forn ia
1
July 21, 2021
Tom Frank
Carlsbad Transportation Director
Re: 7/6/2021 Traffic and Mobility Commission vote to agendize an item for discussion of the 9/15/2020
staff revision of the Vehicle Miles Traveled Analysis Guidelines without public review
Mr. Frank:
After the above-referenced vote, you asked me to supplement my previous correspondence on the
topic to help guide the discussion. Below, I have provided a summary of my concerns followed by
details.
SUMMARY
•Carlsbad’s Vehicle Miles Traveled (VMT) Analysis Guidelines were developed between about
December 2019 and April 2020 by city staff and traffic consulting firms Fehr & Peers and VRPA
Technologies.
•During development of the guidelines, numerous SANDAG model runs were conducted by the
consultants over the course of several months to produce VMT calculations for many different
sets of VMT maps with multiple options.
•Staff (including senior staff) settled on dividing Carlsbad into 183 Traffic Analysis Zones (TAZs).
Larger projects—those that generate more than 2,400 average daily trips (ADT)—were to do
their own SANDAG model runs to calculate their VMT, while smaller projects were to use the
pre-calculated VMT levels from the maps based on their TAZ location.
•Multiple geographies for VMT comparisons were also reviewed by staff, including community,
citywide, and regional areas, and staff settled on citywide averages for both residential and
commercial VMT comparisons.
•On May 4, 2020, the guidelines were reviewed by the Traffic and Mobility Commission (T&MC),
which recommended adoption by the City Council.
•After the T&MC meeting, staff changed the commercial VMT comparison basis from the
citywide average to the regional average, which modestly reduced the likelihood (and amount)
of required mitigation for commercial projects.
•On June 16, 2020, the guidelines were reviewed and adopted by the City Council with an
effective date of July 1, 2020 (although multiple developments had already been allowed to use
VMT analysis before that).
•Then, on September 15, 2020 (just 2-1/2 months after the guidelines officially went into
effect), staff published a revised version of the guidelines with a couple of significant
changes—without any review by the public, the T&MC, or the City Council.
•One of the changes was that staff added an option for developers of smaller projects to
cherry-pick between the map method and doing a SANDAG model run, rather than requiring
Exhibit 4
Dec. 6, 2021 Item #4 135
2
the map method, even though Fehr & Peers had testified at the council meeting that SANDAG
model runs were not designed or appropriate for these small-scale projects.
• The other change was made directly to the “Significance Threshold” section and effectively
discarded Fehr & Peers’ 183-zone VMT maps and all of the associated VMT calculations, which
were central components of both the T&MC and council meeting presentations. These custom
Carlsbad maps were replaced with online VMT maps provided by SANDAG that divide
Carlsbad into just 18 Census Tracts and use SANDAG VMT calculations.
• This change was made despite the fact that staff had previously argued in environmental
documents (as part of their formal replies to my public comments) that SANDAG’s Census
Tract areas do not provide enough granularity in Carlsbad to appropriately evaluate project
VMT, and that, unlike Fehr & Peers’ VMT calculations, which are specifically intended for
CEQA use in Carlsbad, SANDAG’s calculations do not produce accurate VMT data.
• Under staff’s 9/15/2020 revision, one development (Amazon.com Parking Lot on Eagle Drive)
has already avoided a CEQA transportation analysis and mitigation that would have been
required by the guidelines that underwent public review, and it is unknown how other future
developments will be affected.
• Also, there does not seem to be any compelling reason why any change was necessary, and it is
very concerning that staff continues to tweak rules/guidelines, even after they have undergone
substantial public review. These were not typographical corrections or minor clarifications—
they are major changes that substantially affect the determination of the need for individual
projects to conduct CEQA analyses and the magnitude of the required mitigation.
• Accordingly, I am seeking the contemporaneous documentation (and any undocumented
rationale) related to the development of the 9/15/2020 revision to the guidelines, including:
(1) the legal and/or other justification staff used to establish the need to make the changes,
and (2) methodological justifications for the changes given the fact that staff’s and the VMT
consultant’s previous statements indicate that the changes were not suitable for VMT analysis
in Carlsbad.
DETAIL
VMT is the new standard to determine transportation-related environmental impacts of projects under
the California Environmental Quality Act (CEQA)—replacing the older level of service (LOS) approach. In
late 2019, the City of Carlsbad contracted with traffic consulting firms Fehr & Peers and VRPA
Technologies to develop our VMT Analysis Guidelines for CEQA analyses.
Work on the guidelines began on or around December 12, 2019, and several meetings were held over
the next five months between staff and the consultants, culminating in the presentation of the
guidelines to the T&MC and City Council in May and June of 2020, respectively.
A key step in VMT analysis is the estimation of VMT that will be generated by a project. To help calculate
VMT, SANDAG has developed travel models for the region. When provided with inputs such as the
Exhibit 4
Dec. 6, 2021 Item #4 136
3
geographic location and predicted numbers of residents and/or employees of the project, a SANDAG
“model run” will output data that can then be used to estimate project VMT by applying special VMT
“post-processing scripts.”
Due to the cost and complexity of SANDAG model runs and post-processing, it was decided by staff and
the consultants that development projects that are expected to generate 2,400 or less ADT would use
maps with pre-calculated VMT levels in pre-determined zones using existing populations. It was further
decided to divide Carlsbad into 183 such Traffic Analysis Zones (TAZs), which exist within 18 different
Census Tracts.1
Thus, SANDAG travel model runs were done by Fehr & Peers followed by post-processing with Fehr &
Peers’ custom VMT scripts for each TAZ to calculate “VMT per capita” (for residential projects) and
“VMT per employee” (for commercial projects). Projects that generate 2,400 or less ADT would then just
have to identify the TAZ in which their site was located and use the corresponding VMT calculation.2
The predicted project VMT (as determined by either the pre-calculated map data, or a custom SANDAG
model and post-processing) must then be compared to an existing VMT average for a larger
geographical area. The difference between the project VMT and the VMT of the larger area then defines
whether the project will have a significant environmental impact, requiring a full CEQA transportation
analysis, and, if so, how much mitigation is required to make the impact less than significant. Therefore,
staff and the consultants also discussed various geographical comparison options, including dividing
Carlsbad into various “communities” (e.g., the four council districts, or District 1 vs. the rest of the city),
using the entire “city,” or using a larger “regional” basis.
Over the approximately five-month guideline development period, at least four or five different sets of
residential and commercial VMT maps/calculations (many with multiple different sets of options) were
created by the consultants and reviewed by staff. Various combinations of different communities, city,
and regional comparisons were considered. Senior city staff was also involved in this selection process.3
On May 4, 2020, the guidelines and two TAZ-based VMT maps were presented to the T&MC. The
community-based comparisons had been abandoned in favor of using citywide averages as the basis of
comparison for both residential (22.52 “VMT per capita” city average) and commercial (25.87 “VMT per
employee” city average) projects. Generally, residential projects had to mitigate below 85% of the
1 There have been some references to Carlsbad having 23 Census Tracts, but the Fehr & Peers VMT data table only
includes 18 unique Census Tracts 2 Note that many of the 183 TAZs had too few residents/employees to be statistically relevant, so model runs and
post-processing were done at the larger Census Tract level for those. Based on my analysis of the final Fehr &
Peers VMT map data, a TAZ had to have at least 20 households (for “VMT per capita”) or 11 employees (for “VMT
per employee”) to calculate its own VMT. This resulted in 121 TAZs with unique residential VMT calculations and
125 TAZs with unique commercial VMT calculations—with the remainder of the 183 TAZs in each case using the
corresponding Census Tract calculations. 3 Many of the facts in this summary of the VMT Analysis Guidelines development process were derived from
dozens of staff email communications and associated attachments obtained through a public records request
(Reference No. R001545-072020).
Exhibit 4
Dec. 6, 2021 Item #4 137
4
citywide residential average, and larger (regional) retail projects had to mitigate below 100% of the
citywide commercial average.
The guidance in the VMT Analysis Guidelines reads as follows:
…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…
After reviewing the guidelines and maps, the T&MC recommended adoption to the City Council.
Within days of the T&MC’s vote, though, staff began the process of changing the basis of the VMT
comparison for commercial projects from the citywide average of 25.87 “VMT per employee” to the
regional average of 26.25 “VMT per employee.” This was a rather subtle change, but it reduced the
likelihood (and amount) of required mitigation for all potential projects, because the regional average
was higher than the citywide average.
The next month—on June 16, 2020—the guidelines (with the new regional average for commercial
projects) were presented to and adopted by the City Council with implementation effective July 1, 2020.
Fehr & Peers’ VMT maps and VMT averages were featured prominently in both the T&MC and council
presentations.
Despite the effective date of July 1, 2020, multiple developers, which benefited from using VMT rather
than LOS as their CEQA analysis approach, had been allowed to use the VMT approach even before
finalization or adoption of the guidelines. This included the Marja Acres project, which had gone through
many deficient LOS-based analyses over a few years, including a third-party review arising from a
disagreement about the approach—the culmination of which was an undocumented switch to VMT
analysis.
In addition, even though the Marja Acres project was projected to generate less than 2,400 ADT, they
were allowed by staff to do a model run instead of using the maps, which helped them significantly
reduce their mitigation requirement. That decision should be considered in the context of a
councilmember’s question about the 2,400 ADT threshold and the following answer provided by the
Fehr & Peers consultant in charge of development of the VMT Analysis Guidelines:
That number--2,400--has been used for the last several decades in our region for when detailed
modeling work would be done. And one of the reasons is that the regional travel demand model
is at a scale where it's really looking at the region as a whole. And so an individual project has to
be large enough for the model to actually be able to respond and produce data for it. And that
number is the size that has been used historically for when the model is appropriate to use for
an individual land use project.
Exhibit 4
Dec. 6, 2021 Item #4 138
5
Then, on September 15, 2020 (just 2-1/2 months after the guidelines officially went into effect), staff
published a revision with a couple of sweeping changes without any review by the public, the T&MC, or
the City Council.
One of the changes basically codified the ability of projects that generate 2,400 or less ADT to choose
between the map method and a new SANDAG model run—and to choose whichever one results in a
lower impact (the strategy employed by the Marja Acres project). The change was accomplished by the
addition of the following text to Section 3.1:
It may be acceptable for a project under 2,400 ADT to complete an individual model run if the
project size and type are appropriate for inclusion in the regional model.
The other major change was one that effectively abandoned the 183-zone TAZ maps produced by Fehr
& Peers, which had been painstakingly created and reviewed at significant cost over many months, and
replaced them with the cruder 18-zone Census Tract interactive maps made available free of charge by
SANDAG. This changed all of the VMT calculations in every area of the city, as well as the average VMTs
used as the bases of comparison, which determine whether projects will have a significant
environmental impact under CEQA.
For this change, staff deleted the following sentence from the CEQA Significance Thresholds section of
the guidelines (Section 3.4):
The appropriate values can be obtained from the City of Carlsbad analysis maps.
And they added the following to Section 3.1:
If maps containing VMT/capita and VMT/employee are not available at the TAZ level using the
most recent SANDAG model series, then a project’s VMT/capita and VMT/employee are
determined using the most recent interactive maps provided by SANDAG. The VMT/capita or
VMT/employee of the project is estimated based on the average VMT/capita or VMT/employee
for the census tract in which the project is located.
These changes have already allowed one developer (an Amazon delivery person parking lot on Eagle
Drive) to avoid a CEQA transportation impact analysis that would have been necessary under the version
reviewed by the City Council,4 and it is unknown how this has (or will) affect other projects in the
development pipeline.
These changes should also be considered in the context of staff responses to inquiries I made prior to
the revisions. For example, I asked about using TAZs vs. Census Tracts, and staff insisted that TAZs must
be used rather than Census Tracts to appropriately evaluate VMT in Carlsbad and remain consistent with
4 The parking lot project is in TAZ #1068, which has a higher than average VMT, which would have required a CEQA
analysis under the council-reviewed guidelines. However, most of the remaining TAZs in the same Census Tract
(#198.06) were lower than average, such that the average over the full Census Tract was lower than average,
allowing the project to avoid CEQA analysis enabled by staff’s 9/15/2020 revision to the guidelines.
Exhibit 4
Dec. 6, 2021 Item #4 139
6
the State’s Office of Planning and Research (OPR), including this formal response to one of my public
comments on a Mitigated Negative Declaration (MND)5:
In preparing the City’s VMT analysis guidelines, City of Carlsbad staff explained that 23 Census
Tracts did not provide enough granularity (i.e., detail) within the City to appropriately evaluate
project VMT. Therefore, the City, with Fehr & Peers’ concurrence, chose to use results at the
TAZ level, consistent with the OPR Technical Advisory and common modeling practices…
In addition, I noted to staff and SANDAG on several occasions (in email, verbally, and in public comments
on development projects) that the VMT calculations by Fehr & Peers using Fehr & Peers’ own custom
VMT “post-processing scripts” were significantly different than those calculated by SANDAG using
SANDAG scripts. For some reason, Census Tract VMT calculations by Fehr & Peers’ average about 20%
higher than SANDAG’s for “VMT/capita” and about 3% lower for “VMT/employee,” even though they all
originate from SANDAG model runs using the same data series (Series 13). Below is a comparison
showing how much higher or lower the Fehr & Peers’ post-processing results are relative to SANDAG’s
for each of the 18 Carlsbad Census Tracts6:
Census
Tract
VMT/
capita
VMT/
employee
171.09 +21.0% +7.7%
171.10 +7.9% -8.2%
178.01 +16.5% -3.4%
178.08 +18.0% 0.0%
178.09 +18.0% +5.4%
178.10 +17.5% +3.3%
178.11 +17.6% -1.7%
178.13 +17.0% -2.4%
179.00 +16.5% -3.0%
180.00 +13.4% -2.7%
198.03 +18.8% +1.1%
198.04 +18.4% +5.6%
198.06 +25.9% -2.8%
200.13 +22.3% +4.0%
200.14 +16.5% -2.6%
200.15 +16.0% +0.6%
200.16 +20.6% +9.4%
221.00 +21.5% -6.0%
5 Staff response to my public comments on the West Oaks project in the Final MND, dated 1/20/2021 6 Analysis of Fehr & Peers “Carlsbad SB 743 VMT Data from SANDAG ABM1.csv” data file provided to me on
7/13/2020 upon my written request and a download of Series 13 travel data from the SANDAG website.
Exhibit 4
Dec. 6, 2021 Item #4 140
7
I consistently received the following written response from Carlsbad staff on this topic (to both emails
and public comments)7:
Based on conversations with SANDAG and comparisons to the city’s results, SANDAG’s post
processing does not appear to include the internal to external and return trips. Since these trips
were not included, this caused SANDAG’s reported regional VMT averages to be lower than the
city’s VMT averages that are specifically intended for use in CEQA.
However, in my own communications with SANDAG employees in the department that handles VMT, as
well as their contractors, they have denied that there are problems with their post-processing scripts,
such as internal to external return trips, for either the Series 13 map data described above, or the newer
Series 14 map data they also provide.
Given the significant differences in results with the use of Fehr & Peers vs. SANDAG post-modeling
scripts, I have also stated that, for transparency purposes and to ensure accurate apples-to-apples
comparisons, developers need to provide more detail on their VMT analyses, including the nature of the
post-modeling scripts. For example, comparisons of project VMT calculated with SANDAG post-modeling
scripts with a citywide average calculated with the Fehr & Peers post-modeling scripts would create
extremely erroneous results. My requests for more details were denied. 8
So, staff had consistently argued that TAZs—and not Census Tracts—are the appropriate zones to
analyze VMT for CEQA purposes in Carlsbad. And they had consistently argued that the Fehr & Peers
map data is specifically intended for use in CEQA, while SANDAG’s map data is not, because it does not
properly account for internal to external and return trips. Yet, in their 9/15/2020 revision to the VMT
Analysis Guidelines—just 2-1/2 months after implementation—they switched to Census Tracts and
SANDAG’s map data!
Undoubtedly, staff will argue that they made the change due to the availability of Series 14 data (all of
the previous development had been done on Series 13). However, SANDAG had already switched to
Series 14 by late 2019, and they published the online interactive map tool that allowed VMT lookups by
Census Tract for Series 14 months before staff presented the guidelines to the T&MC and City Council. In
addition, there is no evidence from SANDAG that the Series 13 post-processing was defective, or that
any changes have been made to the Series 14 post-processing that would address staff’s alleged
problems (accounting for internal to external and return trips).
If staff wanted to use the SANDAG Series 14 maps, then that is what they should have presented for
public review in May and June of 2020. At the very least, they should have presented the guidelines
revision for public review before publishing it.
7 For example, in written responses to my public comments in the environmental documents for the Marja Acres
and West Oaks projects 8 For example, in written responses to my public comments in the environmental documents for the Marja Acres
and West Oaks projects
Exhibit 4
Dec. 6, 2021 Item #4 141
8
Beyond that, it is very unclear why this confusing and disruptive change was even necessary. There
should be no legal reason to immediately abandon our own system every time SANDAG updates their
travel model. If our own TAZ-based system takes 6 to 12 months to update every time a new travel
model is released by SANDAG, and we have to temporarily switch to the Census Tract-based system
during those transitions, that creates a very confusing and inconsistent review environment. We should
just keep using the TAZ-based system during any transitions, or we should just always use the SANDAG
Census Tract system.
The even bigger issue here, though, is that staff seems to feel comfortable making material changes to
guidelines immediately after they have been reviewed. Undoubtedly, staff will argue that only the
screening criteria and percentage thresholds were technically adopted by the City Council. However,
those become meaningless components when the text of the guidelines can be changed in such a way
that changes every single VMT calculation that decides whether any project will have an impact—and
when staff builds in the ability to make significant exceptions to the rules that are seemingly applied to
virtually every project, including:
• Marja Acres: Used VMT guidelines before they were finalized or adopted, and they used a model
run instead of the Carlsbad VMT maps, as required by the first version of the guidelines.
• BMW Carlsbad: Did not use either the Carlsbad VMT maps or a model run, as described in the
guidelines. Instead, they were allowed to come up with their own custom VMT calculation
method and were allowed to subtract VMT from their total based on displacement of a business
that, by definition under the guidelines, does not generate any VMT (among several other CEQA
avoidance strategies).
• Amazon Parking Lot: Did not have to conduct a VMT analysis due to staff’s 9/15/2020 revision to
the guidelines that replaced Carlsbad’s VMT maps produced by Fehr & Peers with SANDAG’s
Census Tract VMT maps.
Best regards,
Steve Linke
Carlsbad Traffic and Mobility Commission
Exhibit 4
Dec. 6, 2021 Item #4 142