HomeMy WebLinkAbout2022-02-07; Traffic and Mobility Commission; ; Informational Presentation on Vehicle Miles Traveled Analysis GuidelinesItem 4
Meeting Date: Feb. 7, 2022
To: Traffic and Mobility Commission
Staff Contact: Jason Geldert, Engineering Manager
Jason.Geldert@Carlsbadca.gov or 760-602-2758
Jennifer Horodyski, Associate Engineer
Jennifer.Horodyski@Carlsbadca.gov or 760-602-2747
Subject: Informational Presentation on Vehicle Miles Traveled Analysis
Guidelines.
Recommended Action
Review and provide input on the informational report and status update.
Discussion
The presentation of the Vehicle Miles Traveled (VMT) Analysis Guidelines was originally
included on the Dec. 6, 2021, agenda of the Traffic and Mobility Commission. Prior to the
meeting, Commissioner Linke submitted written comments (in the form of a PowerPoint
presentation). The VMT Analysis Guidelines presentation was postponed to the Feb. 7, 2022,
meeting to allow staff time to prepare a written response to the comments. City staff also
created an informational handout to assist the general public in obtaining more information
about VMT and the city’s permit processing requirements. Attached are the original staff
report, Commissioner Linke’s PowerPoint presentation and staff’s response to comments.
Exhibits
1.VMT Analysis Guidelines staff report, Dec. 6, 2021
2.Commissioner Linke’s PowerPoint presentation on VMT Analysis Guidelines
3.Staff’s responses to the PowerPoint presentation
Feb. 7, 2022 Item #4 1
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 (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 (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
Feb. 7, 2022 Item #4 2
Exhibit 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 (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 passage 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 and
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
Feb. 7, 2022 Item #4 3
Exhibit 1
existing provision of law, ordinance, resolution, or policy. The VMT thresholds and screening 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 (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 promoting predictability and consistency (over time and across
Feb. 7, 2022 Item #4 4
Exhibit 1
reviewers) 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 general 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.
Feb. 7, 2022 Item #4 5
Exhibit 1
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 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 15th 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
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.
Feb. 7, 2022 Item #4 6
Exhibit 1
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
Feb. 7, 2022 Item #4 7
Exhibit 1
Exhibit 1
Feb. 7, 2022 Item #4 8
VEHICLE MILES TRAVELED (VMT)
ANALYSIS GUIDELINES
June 2, 2020
DRAFT
Feb. 7, 2022 Item #4 9
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
Feb. 7, 2022 Item #4 10
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
Feb. 7, 2022 Item #4 11
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.
Feb. 7, 2022 Item #4 12
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.
Feb. 7, 2022 Item #4 13
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.
Feb. 7, 2022 Item #4 14
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.
Feb. 7, 2022 Item #4 15
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.
Feb. 7, 2022 Item #4 16
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
Feb. 7, 2022 Item #4 17
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
Feb. 7, 2022 Item #4 18
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.
Feb. 7, 2022 Item #4 19
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.
Feb. 7, 2022 Item #4 20
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.
Feb. 7, 2022 Item #4 21
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
Feb. 7, 2022 Item #4 22
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.
Feb. 7, 2022 Item #4 23
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.
Feb. 7, 2022 Item #4 24
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
Feb. 7, 2022 Item #4 25
VEHICLE MILES TRAVELED ANALYSIS GUIDELINES
APPENDIX A
VMT ANALYSIS
FOR NON-
STANDARD LAND
USE TYPES
Feb. 7, 2022 Item #4 26
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.
Feb. 7, 2022 Item #4 27
VEHICLE MILES TRAVELED ANALYSIS GUIDELINES
APPENDIX B
SCREENING
CRITERIA AND
THRESHOLD
EVIDENCE
Feb. 7, 2022 Item #4 28
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
Feb. 7, 2022 Item #4 29
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
Feb. 7, 2022 Item #4 30
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.
Feb. 7, 2022 Item #4 31
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
Feb. 7, 2022 Item #4 32
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
Feb. 7, 2022 Item #4 33
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.
Feb. 7, 2022 Item #4 34
APPENDIX C
VEHICLE MILES
TRAVELED
REDUCTION
STRATEGIES AND
EFFECTIVENESS
CALCULATIONS
VEHICLE MILES TRAVELED ANALYSIS GUIDELINES
Feb. 7, 2022 Item #4 35
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:
Feb. 7, 2022 Item #4 36
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.
Feb. 7, 2022 Item #4 37
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.
Feb. 7, 2022 Item #4 38
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
Feb. 7, 2022 Item #4 39
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.
Feb. 7, 2022 Item #4 40
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).
Feb. 7, 2022 Item #4 41
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.
Feb. 7, 2022 Item #4 42
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.
Feb. 7, 2022 Item #4 43
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.
Feb. 7, 2022 Item #4 44
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%
Feb. 7, 2022 Item #4 45
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.
Feb. 7, 2022 Item #4 46
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.
Feb. 7, 2022 Item #4 47
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
Feb. 7, 2022 Item #4 48
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
Feb. 7, 2022 Item #4 49
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.
Feb. 7, 2022 Item #4 50
Exhibit 2
Feb. 7, 2022 Item #4 51
June 2September 15, 2020
DRAFT
VEHICLE MILES TRAVELED (VMT)
ANALYSIS GUIDELINES
Feb. 7, 2022 Item #4 52
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
Feb. 7, 2022 Item #4 53
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
Feb. 7, 2022 Item #4 54
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.
Feb. 7, 2022 Item #4 55
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.
Feb. 7, 2022 Item #4 56
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.
Feb. 7, 2022 Item #4 57
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.
Feb. 7, 2022 Item #4 58
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.
Feb. 7, 2022 Item #4 59
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.
Feb. 7, 2022 Item #4 60
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
Feb. 7, 2022 Item #4 61
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
Feb. 7, 2022 Item #4 62
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.
Feb. 7, 2022 Item #4 63
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.
Feb. 7, 2022 Item #4 64
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.
Feb. 7, 2022 Item #4 65
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
Feb. 7, 2022 Item #4 66
• 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.
Feb. 7, 2022 Item #4 67
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.
Feb. 7, 2022 Item #4 68
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
Feb. 7, 2022 Item #4 69
VEHICLE MILES TRAVELED ANALYSIS GUIDELINES
APPENDIX A
VMT ANALYSIS
FOR NON-
STANDARD
UNIQUE LAND
USE TYPES
Feb. 7, 2022 Item #4 70
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.
Feb. 7, 2022 Item #4 71
VEHICLE MILES TRAVELED ANALYSIS GUIDELINES
APPENDIX B
SCREENING
CRITERIA AND
THRESHOLD
EVIDENCE
Feb. 7, 2022 Item #4 72
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
Feb. 7, 2022 Item #4 73
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
Feb. 7, 2022 Item #4 74
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.
Feb. 7, 2022 Item #4 75
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
Feb. 7, 2022 Item #4 76
• 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
Feb. 7, 2022 Item #4 77
• 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.
Feb. 7, 2022 Item #4 78
APPENDIX C
VEHICLE MILES
TRAVELED
REDUCTION
STRATEGIES AND
EFFECTIVENESS
CALCULATIONS
VEHICLE MILES TRAVELED ANALYSIS GUIDELINES
Feb. 7, 2022 Item #4 79
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:
Feb. 7, 2022 Item #4 80
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.
Feb. 7, 2022 Item #4 81
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.
Feb. 7, 2022 Item #4 82
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
Feb. 7, 2022 Item #4 83
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.
Feb. 7, 2022 Item #4 84
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).
Feb. 7, 2022 Item #4 85
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.
Feb. 7, 2022 Item #4 86
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.
Feb. 7, 2022 Item #4 87
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.
Feb. 7, 2022 Item #4 88
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%
Feb. 7, 2022 Item #4 89
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.
Feb. 7, 2022 Item #4 90
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.
Feb. 7, 2022 Item #4 91
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
Feb. 7, 2022 Item #4 92
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
Feb. 7, 2022 Item #4 93
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.
Feb. 7, 2022 Item #4 94
Exhibit 3
Feb. 7, 2022 Item #4 95
VEHICLE MILES TRAVELED (VMT)
ANALYSIS GUIDELINES
September 15, 2020
Feb. 7, 2022 Item #4 96
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
Feb. 7, 2022 Item #4 97
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
Feb. 7, 2022 Item #4 98
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.
Feb. 7, 2022 Item #4 99
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.
Feb. 7, 2022 Item #4 100
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.
Feb. 7, 2022 Item #4 101
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.
Feb. 7, 2022 Item #4 102
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.
Feb. 7, 2022 Item #4 103
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.
Feb. 7, 2022 Item #4 104
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
Feb. 7, 2022 Item #4 105
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
Feb. 7, 2022 Item #4 106
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.
Feb. 7, 2022 Item #4 107
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.
Feb. 7, 2022 Item #4 108
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.
Feb. 7, 2022 Item #4 109
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
Feb. 7, 2022 Item #4 110
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.
Feb. 7, 2022 Item #4 111
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.
Feb. 7, 2022 Item #4 112
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
Feb. 7, 2022 Item #4 113
VEHICLE MILES TRAVELED ANALYSIS GUIDELINES
APPENDIX A
VMT ANALYSIS
FOR UNIQUE
LAND USE TYPES
Feb. 7, 2022 Item #4 114
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.
Feb. 7, 2022 Item #4 115
VEHICLE MILES TRAVELED ANALYSIS GUIDELINES
APPENDIX B
SCREENING
CRITERIA AND
THRESHOLD
EVIDENCE
Feb. 7, 2022 Item #4 116
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
Feb. 7, 2022 Item #4 117
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
Feb. 7, 2022 Item #4 118
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.
Feb. 7, 2022 Item #4 119
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
Feb. 7, 2022 Item #4 120
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
Feb. 7, 2022 Item #4 121
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.
Feb. 7, 2022 Item #4 122
APPENDIX C
VEHICLE MILES
TRAVELED
REDUCTION
STRATEGIES AND
EFFECTIVENESS
CALCULATIONS
VEHICLE MILES TRAVELED ANALYSIS GUIDELINES
Feb. 7, 2022 Item #4 123
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:
Feb. 7, 2022 Item #4 124
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.
Feb. 7, 2022 Item #4 125
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.
Feb. 7, 2022 Item #4 126
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
Feb. 7, 2022 Item #4 127
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.
Feb. 7, 2022 Item #4 128
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).
Feb. 7, 2022 Item #4 129
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.
Feb. 7, 2022 Item #4 130
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.
Feb. 7, 2022 Item #4 131
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.
Feb. 7, 2022 Item #4 132
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%
Feb. 7, 2022 Item #4 133
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.
Feb. 7, 2022 Item #4 134
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.
Feb. 7, 2022 Item #4 135
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
Feb. 7, 2022 Item #4 136
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
Feb. 7, 2022 Item #4 137
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.
Feb. 7, 2022 Item #4 138
VMT Analysis Guidelines Review12/6/2021 T&MC meetingVice-Chair Steve LinkeExhibit 2Feb. 7, 2022Item #4139
Initial Recommendations1. Stay with “Series 13” Carlsbad VMT maps and SANDAG VMT model runs until problems with “Series 14” areworked out2. Going forward, do not change to new VMT models or maps without public review3. If projects under 2,400 ADT propose a VMT model run, they need to show the VMT map result for comparisonpurposes and provide a substantial justification that the regional model is statistically applicable4. If projects propose a custom VMT method, that should only be allowed in extremely rare/unique circumstances,and they need to conduct a model run for comparison purposes and provide substantial justification5. If a custom model based on total VMT is used, substantial justification must be provided for VMT subtractions,and VMT cannot be subtracted for displaced uses that were not generating net VMT6. If a mitigation measure is outside of the control of the applicant, they must still ensure that it is effective7. Long‐term compliance tracking of mitigation measures should be required, including assessing whether the goalis being achieved—not just the existence of the measure8. Substitution of mitigation measures should not be allowed, unless there is substantial published evidence9. Conflict of interest rules should be established for consultants who simultaneously develop the City’s VMTguidelines and also represent developers submitting VMT studies10. VMT reports need to include far more detail, including intermediate data (“black box”)Feb. 7, 2022Item #4140Exhibit 2
Background•VMT Guidelines developed from December 2019 to April 2020•Significant effort to produce many versions of VMT maps for reviewand selection–Significant billable hours by Fehr & Peers and VRPA Technologies–SANDAG model run computer time–Staff meetings/review•T&MC and City Council reviewed/adopted in May/June 2020–Major focus on VMT maps•Effective date 7/1/2020Feb. 7, 2022Item #4141Exhibit 2
“VMT per capita” map (residential)183 Traffic Analysis Zones (TAZs) within 18 Census TractsFeb. 7, 2022Item #4142Exhibit 2
SANDAG Census Tract maps allegedly not appropriate for VMT analysis in Carlsbad•“In preparing the City’s VMT analysis guidelines,City of Carlsbad staff explained that…CensusTracts did not provide enough granularity (i.e.,detail) within the City to appropriately evaluateproject VMT. Therefore, the City, with Fehr &Peers’ concurrence, chose to use results at theTAZ level, consistent with the OPR TechnicalAdvisory and common modeling practices.”Feb. 7, 2022Item #4143Exhibit 2
Alleged problems with SANDAG VMT data (internal‐external trips)•“…SANDAG’s post processing does not appear toinclude the internal to external and return trips.Since these trips were not included, SANDAG’sreported regional VMT averages were lower thanthe city’s VMT averages, the latter of which werespecifically intended for use in the CEQA context.”Feb. 7, 2022Item #4144Exhibit 2
Even more extensive problems with new Series 14 SANDAG data?•City of Carlsbad comment on 2021 SANDAG RTP–The assumed development patterns are no longerconsistent with Carlsbad’s adopted land use andtransportation policies–Assumptions of GHG reduction and VMT are notsubstantially supported with factsFeb. 7, 2022Item #4145Exhibit 2
Predictability/consistency and necessity•Staff report: “Maintaining the guidelines as an informational tool,and updating them as necessary, is crucial to promote predictabilityand consistency (over time and across reviewers) in theenvironmental review process.”•Chaos:–Some types of model runs have not been available under Series 14(ABM2)–Upcoming switch to Series 14 (ABM2+)–Switching back‐and‐forth between 183‐zone maps and 18‐zone maps•Rapid adoption of the changes and the latest model “necessary”?Feb. 7, 2022Item #4146Exhibit 2
Feb. 7, 2022Item #4147Exhibit 2
VMT traffic consultant quote•“That number‐‐2,400‐‐has been used for the last several decades inour region for when detailed modeling work would be done. Andone of the reasons is that the regional travel demand model is at ascale where it's really looking at the region as a whole. And so anindividual project has to be large enough for the model to actuallybe able to respond and produce data for it. And that number is thesize that has been used historically for when the model isappropriate to use for an individual land use project.”•901‐ADT project allowed to do model run, reducing VMT mitigationrequirement from 20% to 8%Feb. 7, 2022Item #4148Exhibit 2
Allowances for custom VMT methods and inappropriate VMT subtractions (car dealership example)•Sales, parts, service, and collision repair•Move and major expansion from another city•Total size increasing from ~39,000 sq‐ft to ~100,000 sq‐ft•Signed and certified TDM Plan showed increase from 90 to 133 employeesFeb. 7, 2022Item #4149Exhibit 2
Allowances for custom VMT methods and inappropriate VMT subtractions (car dealership example)•Collision repair component separated into different submission•For VMT analysis, claimed they decided to stay with current 90 employees•“Regional‐serving retail” development requires model run•Claimed that car dealerships are too unique a land use in the SANDAGregion for a model runFeb. 7, 2022Item #4150Exhibit 2
Allowances for custom VMT methods and inappropriate VMT subtractions (car dealership example)•Allowed to use custom VMT “sketch” method–Compared distances of current employees and customers from currentto new location–Method criticized by experts–Numerous other custom methods (inconsistency)•Still had increase in VMT, requiring CEQA study/mitigation•Subtracted VMT for a replaced business that was producingno VMTFeb. 7, 2022Item #4151Exhibit 2
Long‐term monitoring of mitigation effectiveness•Unbundled Parking Policy–Number of parking spaces far exceeds reduction goal–Measure effective only in areas very close to destinations (development is in industrial area)–Should include monitoring of rented spaces—not simple existence of program•Mixed‐Use based on off‐site commercial area–Has not been built and may never be built–In reference to the reliance on offsite projects for mitigation, CAPCOA states: “The [entity that]needs the mitigation remains obligated to ensure that the project is implemented and theemission reductions occur.”–Should include alternative mitigation, if commercial area not built•Transit pass subsidies–Bus service is currently very poor there (average of 1 to 3 boardings per day)–Should monitor usage of transit passes/increases in boardings thereFeb. 7, 2022Item #4152Exhibit 2
Mitigation method substitutions•Car‐Share Program–Single shared car provided to a 192‐unit residential development considered equivalent to aCAPCOA “Car‐Share Program,” which is defined as a “city‐wide fleet” of shared vehicles–A “car‐share” program cannot be effectively scaled down to a single vehicle in a single project•Neighborhood Electric Vehicle Network–Eight shared e‐bikes considered equivalent to a CAPCOA “Neighborhood Electric Vehicle (NEV)Network”–CAPCOA defines an NEV Network as individually owned NEVs on a dedicated street networkwith special striping and signage–California Vehicle Code: NEVs are four‐wheeled, electrically powered vehicle that conforms tofederal automobile safety standards–Same consultant that included this substitution has advised governmental entities againstallowing even real NEV network‐based VMT mitigation due to weak evidence that they workFeb. 7, 2022Item #4153Exhibit 2
VMT consultant conflict of interest?•On contract with the city to create and updateVMT guidelines and maps and aidinterpretation•Simultaneously on contract with developers toconduct and submit VMT studiesFeb. 7, 2022Item #4154Exhibit 2
Response to Written Comments
The following are responses to written comments from Vice-Chair Linke that were presented in the
form of a PowerPoint presentation. Responses are arranged to correspond with the PowerPoint slide
that contains comment.
No comment/response
1.SANDAG has produced transportation forecasts for nearly 40 years. Each forecast serves as an
integral part of the SANDAG planning process and supports long range transportation and
planning efforts. Evolving trends, policies, and data necessitate changes in forecasting
methodologies. The Series 13 forecast was completed during the recovery period of the Great
Recession. Series 13 is retired, and SANDAG no longer supports the data. The Series 14
Regional Growth Forecast is the basis for San Diego Forward: The 2019 Federal Regional
Transportation Plan (2019 Federal RTP).
Each forecast process contains a set of assumptions and input data. Regarding Series 14
concerns, Carlsbad VMT maps and SANDAG maps are based on data from the base year of a
model. The “base year” or “baseline” data refers to the subregional allocation method that is
used to determine the location of units, population, and jobs to certain geographies of the
region. Series 14 concerns have to do with future year assumptions and not the base year data.
Therefore, the maps are not influenced by future year assumption. Rather, the maps provide
Exhibit 3
Feb. 7, 2022 Item #4 155
baseline VMT data by census tract for use in screening for potential traffic impacts during the
CEQA process for developments.
2.Travel demand models are produced by SANDAG. The city does not have control over how
SANDAG conducts public review of new the models. However, forecasting at SANDAG is an
open process in that the models, inputs, and results are presented to professionals and
policymakers at public forums. The estimated data in these maps are an analysis of travel using
SANDAG’s ABM. The currently approved ABM version is ABM2 using Land Use Series 14 data
source. Because new models contain the most current VMT information, the maps must be
changed when that new data is available.
3.A custom model run is based on a simulation for VMT accounting for influence from a specific
project. In a case where a project will use a custom model run, there will be expected
differences to existing maps because of project characteristics, such as size or land use, that are
not reflective in the maps. Therefore, comparing maps to a custom model run will not yield any
value.
4.There are many instances where VMT maps or custom models runs are not appropriate and do
not provide accurate results. Models to be used are chosen based on sensitivity to project
features that affect VMT. In accordance with OPR recommendations, travel demand models,
sketch models, spreadsheet models, research, and data can all be used to calculate and estimate
VMT. Therefore, comparing a localized sketch model that accounts for specific project related
VMT to a custom model run will not yield any value.
5.Substantial evidence is required to support assumptions, such as net VMT. Staff agrees that
VMT should not be subtracted for displaced uses that do not generate VMT.
6.Mitigation measures are reviewed on a case by case basis to ensure that they are site
appropriate, accurate, and sufficiently detailed to be effective at the time they are applied to
the project. For that reason, the adequacy of each environmental document is subject to a
public review comment period. Monitoring and reporting requirements are described in the
project environmental document, so the public will always have the ability to make sure that
recurring mitigations measures are tailored appropriately to the project. According to CEQA,
the city may create standardized policies and requirements to guide individually adopted
monitoring or reporting programs, including a framework process for informing staff and
decision makers of the relative success of mitigation measures and using those results to
improve future mitigation measures. However, adoption of city standardized policies and
requirements are outside the scope of the VMT Analysis Guidelines.
7.Please see item 6 above.
8.Mitigation measures should allow for some flexibility, where appropriate, or opportunities for
modification if circumstances change following approval of the environmental document.
Flexibility may both allow for better protection of environmental resources and avoid problems
Feb. 7, 2022 Item #4 156
Exhibit 3
with project implementation. With respect to best practices, mitigation measures used in CEQA
should be supported by substantial evidence. Research around the effectiveness of mitigation is
constantly updated and projects use the best available research at the time. The measures that
are highlighted in slide 15 are results of new technologies that did not widely exist at the time of
the development of the CAPCOA document in 2010. Those measures were valid and are
supported by substantial evidence. Currently, there is a new “GHG Handbook,” that replaces the
2010 CAPCOA document, with updated guidance on VMT reductions.
Since mitigation measures for a specific project are reviewed on a case-by-case basis (see
response to comment no. 6), the city must adopt a mitigation monitoring and reporting program
for each project to ensure the measures are implemented. As applied, if the city decision-
making body determines, following public review comment period of an environmental
document, that a proposed mitigation measure is not feasible or would not reduce potential
effects to a less-than-significant level, it may choose to substitute the measure with a different
measure. CEQA Guidelines section 15074.1 summarizes the requirements for substituting
equivalent or more effective mitigation measures.
9.At the time that the consultant represented a developer regarding VMT, the development of the
VMT Analysis Guidelines project was completed. There was no conflict of interest with that
consultant. To avoid a perception of conflict of interest in the future, the conflict of interest
clause in consultant contracts has been updated. The clause specifies that consultants may not
represent clients in the City of Carlsbad whose activities are related to the scope of work in the
contract.
10.This comment refers to SANDAG custom model runs and the resulting data that is provided in
the studies. The level of detail in VMT studies are consistent with SANDAG’s level of detail that
is provided. The SANDAG model is a complex software tool for use by practitioners in the field.
SANDAG modeling is very technical and not intended for general public use. Additional
information and specifics on assumptions and procedures used in the SANDAG regional travel
demand model are available on the SANDAG website and do not need to be included in project
studies.
Feb. 7, 2022 Item #4 157
Exhibit 3
For clarification, City Council adopted Thresholds of Significance and Screening Criteria. The draft VMT
Guidelines were provided for context and informational purposes.
No comment/response
Staff does think that the TAZ maps provide the most detail. In the absence of TAZ maps, census tract
level maps are adequate and are what many other jurisdictions in the region are using. Use of census
tract level VMT maps in the City of Carlsbad is temporary until the TAZ level maps are developed based
on new SANDAG data. Staff anticipates that new TAZ level VMT maps will be available in late February.
Feb. 7, 2022 Item #4 158
Exhibit 3
All models have boundaries with limitations where VMT is not tracked outside the boundary. In post-
processing (after the model is run) adjustments can be made for VMT outside of the model boundary.
SANDAG understands this limitation of the model and supports jurisdictions making the adjustments
accordingly. Carlsbad will have these adjustments reflected on the TAZ level VMT maps and on project
model run outputs from SANDAG. Carlsbad is making these adjustments to comply with OPR statement
that VMT should not be truncated due to model boundaries.
VMT maps use base year data for VMT analysis. Concerns with Series 14 do not affect VMT baseline
maps for project analysis. The concerns expressed by the comment are for “assumed development
patterns”, which are correlated with future year travel predictions. Please see response to Slide 2, item
1.
Feb. 7, 2022 Item #4 159
Exhibit 3
Projects should use the latest available data to support assumptions. As new data is released from
SANDAG, changes to maps will be made as necessary to reflect the new data. 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. When new data is released, census tract level VMT maps are
used until Carlsbad TAZ level VMT maps are developed.
No comment/response
in this instant, the “901 ADT” mentioned in the comment represented the net ADT for the
project. The project changed from all commercial to mixed-use with a high residential content.
Feb. 7, 2022 Item #4 160
Exhibit 3
The project had a gross ADT above 2,400. Therefore, it was appropriate to use the regional
model to analyze the mixed-use project.
A model run is not required and is an option if it is the most appropriate method. Based on the
detailed customer and employee data, a sketch model was the most reliable methodology to
analyze the VMT and was supported by substantial evidence.
Please see response to slide 2, item 6.
Feb. 7, 2022 Item #4 161
Exhibit 3
Please see response to slide 2, item 8.
Please see response to slide 2, item 9.
Feb. 7, 2022 Item #4 162
Exhibit 3
VMT Analysis Guidelines Review
Feb. 7, 2022, T&MC meeting
Vice-Chair Steve Linke
Consultant conflict of interest
•Simultaneously on contract with developers to conduct and submit VMT studies
–Today’s staff report:
•“At the time that the consultant represented a developer regarding VMT, the development of the VMT Analysis Guidelines project was completed. There was no conflict of interest with that consultant.”
–VMT Guidelines developed between 12/2019 and 5/2020
–VMT Memo from Fehr & Peers for project submitted 4/2020
2
Background:
Level of service (LOS) approach
•Two standards to be met
–Carlsbad: Growth Management Plan (GMP)
–California Environmental Quality Act
•Before July 2020, both standards were based on same LOS approach congestion
–Letter grades (e.g., A through F) assigned from:
•Number of vehicles relative to street capacity
•Average delay at intersections
3
Vehicle LOS grading system
Source: Maryland Department of Transportation Policy Manual 4
Defective Carlsbad mid-block LOS method
5
Background:
Vehicle miles traveled (VMT) approach
•As of July 2020
–Carlsbad GMP LOS approach still required
•Vehicle, transit, bicycle, and pedestrian
–State CEQA VMT approach now required
•Proposed projects that will exceed specific VMT
thresholds must mitigate
6
7
Case study in how the VMT Analysis Guidelines
are being inadequately applied/enforced
•Luxury car dealership
–Sales, parts, service, and
collision repair
–Move and major expansion from Encinitas
•~40,000 to ~100,000 sq-ft
Sales, parts, service
Collision repair, admin
~70k ft2
~30k ft2
8
Case Study Issue #1: Piece-mealing
•Collision repair/admin offices submitted separately a few months after sales/parts/service
–Same developer
–All components co-located in both old and new locations
•Called “North Campus” and “South Campus” in Carlsbad
–Share same customer base
–Applications were under planning review simultaneously
–Re-labeled “Ancillary Facilities” and admin changed to storage
•Recommendation: Include and enforce anti-piece-mealinglanguage and consider cumulative impacts
9
Case Study Issue #2: Definition of local
vs. regional serving retail
•Current definition sets a threshold of 50k sq.ft.
–Local serving retail does not create VMT reduces VMT
–Regional retail must conduct VMT analysis
•Collision repair component of car dealership is ~30k sq.ft.
–Claims “local serving retail” in VMT assessment, but it serves the same regional customers as sales/parts/service component
•Significant portions from far away (e.g., LA, Simi Valley, etc.)
•VMT analysis should have been required, but allowed to screen out
•Recommendation: Exceptions should be made by staff when retail is <50k sq.ft., but clearly regional
10
Case Study Issue #3: ADT inappropriately
subtracted for existing uses during screening
•Collision repair component of business projected 1,937 gross ADT—far in excess of the 110 ADT threshold to require VMT analysis
•1,858 ADT was subtracted for existing uses to achieve 79 net ADT
–There have not been any businesses there for many years, so the subtraction is a bit imaginary
•Even if one accepts the number, the subtraction is only appropriate for LOS analysis—not VMT analysis
–Should not have been used to screen out
•Recommendation: ADT subtractions for existing uses need to be explicitly prohibited and rejected
11
Case Study Issue #4: Justifying not
using a model-based method
•VMT Guidelines:
–“All retail projects that do not meet the screening criteria…are considered regional retail projects and require a model [run]…even if ADT is between 110 and 2,400.”
•VMT Analysis Memorandum claim:
–“The VMT analysis was conducted consistent with the methodologies described in the City of Carlsbad’s VMT Analysis Guidelines, June 2020.”
•However, it used a non-model approach not described in any fashion in the guidelines
12
Justifying not using a model-based
method (continued)
•VMT Analysis Memorandum justification:
–SANDAG travel demand model “does not distinguish between types of retail uses,” which have different travel behaviors
–Any retailer could claim uniqueness
•Recommendation: Better define what types of retail can suggest a non-model-based method and require substantial evidence that the model will not be accurate
13
Case Study Issue #5: “Wild west” of
non-model-based VMT methods
•Method options in OPR guidance:
–Travel demand models (only method described in our guidelines)
–Sketch models
–Spreadsheet models
–Research
–Data
•Sketch model examples: CalEEMod, Sketch7, VMT Impact Tool/Salon, Green TRIP Connect, UrbanFootprint, Envision Tomorrow, CA Smart Growth Tool, TRIMMS, MXD+, TDM+
•Infinite possibilities, leading to inconsistency and “cherry-picking”
14
“Wild west” of non-model-based VMT
methods
•Car dealership method:
–Simple calculation of roundtrip mileage of existing customers and employees from their home zip code
–Staff report claims this approach is supported by “substantial evidence”
•Recommendation: Define a small number of allowable alternative methods and/or a minimum level of evidence required
15
Case Study Issue #6:
Unrealistic trip projections
•If just one or two additional customers or employees was estimated, VMT threshold would have been exceeded
•Building footprint ~doubling with newly constructed building
•TDM Plan (3/3/2021) increase from 90 to 133 employees
•VMT Analysis Memorandum (3/16/2021) stay at 90 employees and no new customers
•Recommendation: Trip generation must be done using conventional methods--not based solely on unverifiable claims of a developer
16
Case Study Issue #7: Inappropriate VMT
subtraction for displaced local serving retail
•VMT still over threshold
•Subtracted VMT for displaced businesses
•But displaced businesses are local-serving retail, so moving/removing them adds VMT
•Recommendation: Do not allow VMT subtractions
•Recommendation: Overhaul the public review process
•Recommendation: Overhaul the staff review process, perhaps switching responsibility to the Transportation Department
17
Carlsbad (Fehr & Peers)
183 Traffic Analysis Zones (TAZs)…SANDAG
…within ~18 Census Tracts
18
SANDAG Census Tract maps not
appropriate for VMT analysis in Carlsbad
•“Census Tracts [do] not provide enough granularity
(i.e., detail) within the City to appropriately evaluate
project VMT.”
•SANDAG model runs/maps not compliant with OPR
guidance without additional post-processing to
account for external trips
19
Predictability/consistency, necessity
•Staff report: “Maintaining the guidelines as an informational tool, and updating them as necessary, is crucial to promote predictability and consistency (over time and across reviewers) in the environmental review process.”
•SANDAG model changes every few years
–Series 13 ABM1
–Series 14 ABM2
–Series 14 ABM2+
–Series 15
–Etc.
•Switching back-and-forth between 183-zone maps and 18-zone maps (17 months in current case)
•Certain model runs (land use changes?) not available when new series released?
•Inconsistent accounting for external trips between traffic consultants?
•Infinite set of sketch tools, spreadsheet tools, research, and data?
•City’s official stance on SANDAG Census tract maps: not appropriate for VMT analysis in Carlsbad and not consistent with OPR guidance
20
Long-term monitoring of mitigation
effectiveness
•Unbundled Parking Policy
–Number of parking spaces far exceeds reduction goal
–Measure effective only in areas very close to destinations (development is in industrial area)
–Should include monitoring of rented spaces—not simple existence of program
•Mixed-Use based on off-site commercial area
–Has not been built and may never be built
–In reference to the reliance on offsite projects for mitigation, CAPCOA states: “The [entity that] needs the mitigation remains obligated to ensure that the project is implemented and the emission reductions occur.”
–Should include alternative mitigation, if commercial area not built
•Transit pass subsidies
–Bus service is currently very poor there (average of 1 to 3 boardings per day)
–Should monitor usage of transit passes/increases in boardings there
21
Mitigation method substitutions
•Car-Share Program
–Single shared car provided to a 192-unit residential development considered equivalent to a CAPCOA “Car-Share Program,” which is defined as a “city-wide fleet” of shared vehicles
–A “car-share” program cannot be effectively scaled down to a single vehicle in a single project
•Neighborhood Electric Vehicle Network
–Eight shared e-bikes considered equivalent to a CAPCOA “Neighborhood Electric Vehicle (NEV) Network”
–CAPCOA defines an NEV Network as individually owned NEVs on a dedicated street network with special striping and signage
–California Vehicle Code: NEVs are four-wheeled, electrically powered vehicle that conforms to federal automobile safety standards
–Same consultant that included this substitution has advised governmental entities against allowing even real NEV network-based VMT mitigation due to weak evidence that they work
22