HomeMy WebLinkAboutSDP 2023-0012; LEGOLAND CALIFORNIA PROJECT 2025; TRANSPORTATION STUDY - CEQA INFILL DEVELOPMENT CATEGORICAL EXEMPTION; 2023-07-27
LEGOLAND California Project 2025 – Transportation Review Page | 1
City of Carlsbad, CA
July 27, 2023
Jason Goff, Senior Planner
City of Carlsbad
1635 Faraday Ave.
Carlsbad, CA 92008
Jason.Goff@carlsbadca.gov
C2 Reference: 23.076
LEGOLAND California Project 2025 – California Environmental Quality Act (CEQA) Infill Development
Categorical Exemption (Transportation)
City of Carlsbad, CA
The Consulting Collective (C2) prepared the following transportation review for the LEGOLAND Galaxy project in
the City of Carlsbad. The review determines if the project qualifies for California Environmental Quality Act
(CEQA) Infill Development Categorical Exemption with respect to transportation.
Project Description
The project proposes a replacement of an existing attraction within the LEGOLAND theme park, LEGOLAND
California Project 2025. The project will be located at the site of the existing “Driving School” and “Junior Driving
School” attractions within FUN TOWN, which will be removed as part of the project. The site is approximately
103,470 square feet (2.83 acres) in size. No expansion of the existing LEGOLAND theme park footprint is
proposed. Existing site development to be removed includes the driving school courses, ride queues, shade
covers, a small retail facility, and landscaping.
The major components of the proposed project are as follows:
Headline attraction - an indoor roller coaster. The ride will be housed inside a new single-story,
approximately 32,197 square-foot building. Ancillary uses within the building include the ride queue, a
LEGO brick building attraction, retail, maintenance, mechanical and storage spaces.
Secondary attraction – an approximate 4,122 square-foot site area, including shaded outdoor ride queue,
and 66 square foot operator booth/mechanical building. The proposed ride will have three cantilever
arms which are lifted by hydraulic actuators and carry a counter-rotating gyro element with gondolas at
its end.
Playscape – an approximate 1,755 square-foot exterior area featuring a children’s play structure.
Toddler play area (“Tot Spot”) - an approximate 1,234 square-foot exterior area designed for young park
guests, with LEGO DUPLO play features, shade cover, and seating.
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Figure 1 illustrates the general location of the project with respect to the overall theme park. Figure 2 illustrates
the project site plan.
FIGURE 1
Project Location
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FIGURE 2
Project Site Plan
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Categorical CEQA Exemption
The State of California Public Resource Code requires CEQA Guidelines (Title 14. California Code of Regulations,
Chapter 3. Guidelines for Implementation of the CEQA, Article 19. Categorical Exemptions) to include classes of
projects which have been determined not to have a significant effect on the environment and therefore exempt
from the provisions of CEQA.
If a project falls within one of these classes, it may be declared to be categorically exempt from the requirement
of preparing environmental documents pursuant to CEQA. A total of 33 classes of projects have been identified
in the guidelines. For the purposes of the LEGOLAND California Project 2025, Class 32 - Infill Development Projects
(Section 15332) was considered.
Class 32 consists of projects characterized as infill development meeting the following conditions:
(a) The project is consistent with the applicable general plan designation and all applicable general plan
policies as well as with applicable zoning designation and regulations.
(b) The proposed development occurs within City limits on a project site of no more than five acres
substantially surrounded by urban uses.
(c) The project site has no value as habitat for endangered, rare or threatened species.
(d) Approval of the project would not result in any significant effects relating to traffic, noise, air quality, or
water quality.
(e) The site can be adequately served by all required utilities and public services.
Technical Approach
The following transportation review determines if the project qualifies for the Class 32 – Infill Development CEQA
exemption. From a transportation perspective, condition (d) was the basis of this qualification; “approval of the
project would not result in any significant effects relating to traffic…”.
Senate Bill 743 (SB 743) was signed into law in 2013 and changed the way transportation impacts are measured
under CEQA. The intent of SB 743 is to bring CEQA transportation analyses into closer alignment with other
statewide policies regarding greenhouse gases, active transportation, and infill development.
The Office of Planning and Research (OPR) published the Technical Advisory on Evaluating Transportation Impacts
in CEQA in 2018, representing the current statewide guidance for implementing SB 743. OPR recommended the
use of Vehicle Miles Traveled (VMT) as the required metric to replace automobile delay-based level of service
(LOS). VMT is a measure of vehicle demand on public roadways. It represents an efficiency metric of how the
transportation infrastructure and underlying land uses interact.
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VMT is a function of travel behavior metrics which include travel mode choice, trip length, trip generation, and
vehicle occupancy. Table 1 summarizes how each travel behavior metric influences VMT. Each metric was
reviewed to determine the project’s change VMT, if any, to determine if a transportation impact would be
triggered.
TABLE 1
Travel Behavior Metrics & VMT
Travel Behavior Metrics VMT Influence
Travel Mode Choice Increase in auto dependency, increases VMT
Trip Length Increase in trip length, increases VMT
Trip Generation Increase in trip generation, increases VMT
Vehicle Occupancy Decrease in vehicle occupancy, increases VMT
VMT Review
The following project context was considered to assist in evaluating the travel behavior metrics. While each
consideration on its own does not necessarily indicate a change in VMT, they provide important insights in
evaluating each metric and collectively determining any change in VMT.
Project Size Relative to the Existing Theme Park - the project site is approximately 2.38 acres. This
represents approximately 1.9% of the total existing theme park size (128 acres).
Increase in Existing Theme Park Size - no expansion of the existing LEGOLAND theme park footprint
is proposed.
Net Change in Major Attractions - the project will introduce two (2) new attractions (a Headline and
Secondary ride) with the replacement of two (2) existing attractions (“Driving School” and “Junior
Driving School”). Therefore, there is no net change in major attractions.
Travel Mode Choice, Trip Length, and Vehicle Occupancy are influenced by development density, land use
diversity, destination accessibility, and demand management. Given that the project is effectively a
replacement/re-theming of existing attractions of substantially the same purpose and consists of a nominal size
relative to the theme park, travel behavior for these metrics is not expected to change materially or permanently.
Trip Generation is influenced by the underlying land use type and the defined independent variable. Given the
discussion above, there is no measurable change to the land use type. LEGOLAND will continue to operate as a
theme park pre and post-project. An independent variable is a physical, measurable, or predictable unit
describing the project site or generator that can be used to predict the value of the dependent variable (i.e. trip
generation). Some examples of independent variables used include Acreage, Gross Floor Area (GFA), Employees,
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and Dwelling Units, etc. For a theme park, the typical independent variable is Acreage. Given no expansion of
the existing LEGOLAND theme park footprint is proposed and no measurable change to the land use type, trip
generation is not expected to change materially or permanently.
Given the travel behavior metrics are not expected to change materially or permanently; in-kind, overall VMT is
not expected to change due to the project.
VMT Screening
Per City of Carlsbad guidelines, a project may assume a less than significant transportation impact if at least one
of the VMT screening criteria is met. The screening criteria are summarized in Table 2.
For the case of the LEGOLAND California Project 2025, the project does meet the “Small Project” criteria given
the trip generation is not expected to change. Therefore, the project may assume a less than significant
transportation impact.
TABLE 2
VMT Screening Criteria
Project Type Screening Criteria
Project
Screened?
Small Projects Projects that generate less than 110 ADT after applying trip-reduction
strategies.
YES
Projects Located Near
Transit
Residential, retail, office projects, or projects that have a mix of those uses
whose project site boundaries are within 1/2 mile of an existing major transit
stop, planned major transit stop, or a stop/transit center along a high-quality
transit corridor. In the City of Carlsbad, this would apply to projects within 1/2
mile of the Carlsbad Village or Carlsbad Poinsettia Coaster stations, as well as
projects within 1/2 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.
No
Local-Serving Retail
and Similar Land Uses
Local-serving retail uses since they tend to attract trips from adjacent areas
that would have otherwise been made to more distant retail locations.
No
Local-Serving Public
Facilities
Local-serving public facilities, similar to local-serving retail. This would include
government facilities intended to serve the local public, parks, public
elementary schools, public middle schools, and public high schools. A study
evaluating the user capture area may be required in order to demonstrate that
a public facility is local-serving.
No
Affordable Housing
Projects
Residential projects that are 100% affordable housing located in infill areas
based on urban planning considerations.
No
Notes:
Screening criteria based on City of Carlsbad VMT Analysis Guidelines (October 3, 2022).
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CEQA Exemption Review
Given the following conditions, the project qualifies for the Class 32 – Infill Development CEQA exemption from
a transportation perspective.
The overall VMT is not expected to materially or permanently change due to the project; and,
Per City of Carlsbad guidelines, no significant effect relating to traffic/transportation would result
due to the project.
Conclusion
The project qualifies for the Class 32 – Infill Development CEQA exemption. From a transportation perspective,
condition (d) was the basis of this qualification; “approval of the project would not result in any significant effects
relating to traffic…”.
VMT is the metric used to determine transportation impacts under CEQA. Given the travel behavior metrics are
not expected to change materially or permanently; in-kind, overall VMT is not expected to change due to the
project.
Per City of Carlsbad guidelines, a project may assume a less than significant transportation impact if VMT
screening criteria are met. The project mets the “Small Project” criteria given the trip generation is not expected
to change. Therefore, the project is assumed to have a less-than-significant transportation impact.
Sincerely,
C2 Consulting Collective
Walter B. Musial, PE, RSP
President & Principal
California Registration: TR2382
cc. Tom Storer, LEGOLAND
Adam Kooienga, Hofman Planning Associates
File name: 23.076 LEGOLAND California project 2025 07.27.23