2020-06-18 Planning Commission Agenda Pkt 06-23-201
Nichole Romane
From:Carlos Flores
Sent:Thursday, June 18, 2020 5:35 PM
To:Bradon Welker;pat@mlalandscape.com;Adam Ford
Subject:FW: Planning Commission Agenda Packet - June 23, 2020
Attachments:PC PACKET 06.23.20.pdf
Hello,
Please find attached the packet for Tuesday’s Planning Commission meeting,which will begin at 5:00 pm.Participation
in the meeting will occur via telephone,with participants being able to call in as needed.Regards,
Carlos Flores Senior Planner
Design and Development
City of La Quinta
78495 Calle Tampico La Quinta,CA 92253
Ph.760.777.7069
www.laquintaca.gov
PLANNING COMMISSION AGENDA 1 JUNE 23, 2020
PLANNING COMMISSION
AGENDA
CITY HALL COUNCIL CHAMBER
78-495 Calle Tampico, La Quinta
REGULAR MEETING on TUESDAY, JUNE 23, 2020 AT 5:00 P.M.
SPECIAL NOTICE
Teleconferencing and Telephonic Accessibility In Effect
Pursuant to Executive Orders N-25-20, N-29-20, N-33-20, and N-35-20, executed
by the Governor of California in response to the state of emergency relating to
novel coronavirus disease 2019 (COVID-19) and enabling teleconferencing
accommodations by suspending or waiving specified provisions in the Ralph M.
Brown Act (Government Code § 54950 et seq.), members of the Planning
Commission, the City Attorney, City Staff, and City Consultants may participate in
this meeting by teleconference. Additionally, pursuant to the above-referenced
executive orders, the public is not permitted to physically attend at City Hall the
meeting to which this agenda applies, but any member of the public may listen or
participate in the open session of this meeting as specified below.
Members of the public wanting to listen to this meeting may do so by tuning-in live
via http://laquinta.12milesout.com/video/live.
Members of the public wanting to address the Planning Commission, either for
public comment or for a specific agenda item, or both, are requested to send an
email notification to the Planning Commission Secretary Wanda Wise-Latta at
WLatta@LaQuintaCA.Gov , and specify the following information:
1) Full Name 4) Public Comment or Agenda Item Number
2) City of Residence 5) Subject
3) Phone Number 6) Written or Verbal Comments
The email “subject line” must clearly state “Written Comments” or “Verbal
Comments.”
Planning Commission agendas and
staff reports are now available on the
City’s web page: www.LaQuintaCA.Gov
PLANNING COMMISSION AGENDA 2 JUNE 23, 2020
Verbal public comments – requests to speak must be emailed to the
Commission Secretary no later than 4:00 p.m. on the day of the meeting;
the City will facilitate the ability for a member of the public to be audible to the
Planning Commission and general public for the item(s) by contacting him/her via
phone and queuing him/her to speak during the discussion.
Only one person at a time may speak by telephone and only after being
recognized by the Planning Commission’s Chairperson.
Written public comments, received prior to the adjournment of the meeting, will
be distributed to the Planning Commission, incorporated into the agenda packet
and public record of the meeting, and will not be read during the meeting unless,
upon the request of the Planning Commission Chairperson, a brief summary of any
public comment is asked to be read, to the extent the Commission Secretary can
accommodate such request.
It would be appreciated that any email communications for public comments
related to the items on the agenda, or for general public comment, are provided to
the Design and Development Department at the email address listed above prior
to the commencement of the meeting. If that is not possible, and to accommodate
public comments on items that may be added to the agenda after its initial posting
or items that are on the agenda, every effort will be made to attempt to review
emails received by the Design and Development Department during the course of
the meeting. The Planning Commission’s Chairperson will endeavor to take a brief
pause before action is taken on any agenda item to allow the Commission Secretary
to review emails and share any public comments received during the meeting. All
emails received by the Commission Secretary, at the email address above, until
the adjournment of the meeting, will be included within the public record relating
to the meeting.
CALL TO ORDER
ROLL CALL: Commissioners Bettencourt, Currie, Libolt Varner, McCune, Nieto,
Proctor and Chairperson Caldwell
PLEDGE OF ALLEGIANCE
PUBLIC COMMENT ON MATTERS NOT ON THE AGENDA
At this time, members of the public may address the Planning Commission on any
matter not listed on the agenda. Please email “Written Public Comments” to
WLatta@LaQuintaCA.Gov and limit your comments to three (3) minutes
approximately 350 words). The Commission values your comments; however, in
accordance with State law, no action shall be taken on any item not appearing on
the agenda unless it is an emergency item authorized by the Brown Act
Government Code Section 54654.2(b)].
PLANNING COMMISSION AGENDA 3 JUNE 23, 2020
CONFIRMATION OF AGENDA
ANNOUNCEMENTS, PRESENTATIONS AND WRITTEN COMMUNICATIONS -
None
CONSENT CALENDAR
NOTE: Consent Calendar items are routine in nature and can be approved by one
motion.
1. APPROVE MINUTES OF MAY 26, 2020
Declarations regarding Public Contacts
BUSINESS SESSION
1. ADOPT A RESOLUTION TO APPROVE FINAL LANDSCAPE PLAN 2020-0002
FOR THE RESIDENCE INN. APPLICANT: PORTER BROTHERS. CEQA:
PROJECT WAS PREVIOUSLY REVIEWED UNDER ENVIRONMENTAL
ASSESSMENT 2018-0005 AND IS CONSISTENT WITH THE ANALYSIS
PREVIOUSLY APPROVED AND DETERMINED NO FURTHER ENVIRONMENTAL
REVIEW IS REQUIRED. LOCATION: 79675 HIGHWAY 111 [RESOLUTION NO.
2020-004]
2. ADOPT A RESOLUTION TO APPROVE MINOR USE PERMIT 2020-0002 FOR
MECHANICAL EQUIPMENT WITHIN A SIDE YARD SETBACK. APPLICANT:
PAUL VOTTA. CEQA: THE DESIGN & DEVELOPMENT DEPARTMENT
REVIEWED THE PROJECT IN COMPLIANCE WITH THE REQUIREMENTS OF
THE CALIFORNIA ENVIRONMENTAL QUALITY ACT (CEQA) AND DETERMINED
THAT THE PROJECT IS CATEGORICALLY EXEMPT UNDER CEQA GUIDELINES
15301, MINOR ALTERATIONS TO EXISTING FACILITIES. LOCATION: 54927
WINGED FOOT [RESOLUTION NO. 2020-005]
STUDY SESSION - NONE
PUBLIC HEARINGS
1. ADOPT A RESOLUTION APPROVING A VEHICLE MILES TRAVELED ANALYSIS
POLICY IN COMPLIANCE WITH STATE SENATE BILL 743. CEQA: EXEMPT
PURSUANT TO SECTION 15061 (b)(3) REVIEW FOR EXEMPTIONS –
COMMON SENSE RULE [RESOLUTION NO. 2020-006]
REPORTS AND INFORMATIONAL ITEMS - None
COMMISSIONERS’ ITEMS
STAFF ITEMS
1. PROJECTS UPDATE
ADJOURNMENT
PLANNING COMMISSION AGENDA 4 JUNE 23, 2020
The next regular meeting of the Planning Commission will be held on July 14,
2020, commencing at 5:00 p.m. with the Call to Order, at the City Hall Council
Chamber, 78-495 Calle Tampico, La Quinta, California.
DECLARATION OF POSTING
I, Wanda Wise-Latta, Commission Secretary, do hereby declare June 23, 2020 was
posted on the City’s website, near the entrance to the Council Chamber at 78-495
Calle Tampico, and the bulletin boards at the Stater Brothers Supermarket at 78-
630 Highway 111, and the La Quinta Cove Post Office at 51-321 Avenida Bermudas,
on June 18, 2020.
DATED: June 18, 2020
WANDA WISE-LATTA, Commission Secretary
City of La Quinta, California
Public Notices
The La Quinta City Council Chamber is handicapped accessible. If special equipment is needed for the hearing
impaired, please call the Planning Division of the Design and Development Department at 777-7118, twenty-
four (24) hours in advance of the meeting and accommodations will be made.
If special electronic equipment is needed to make presentations to the Commission, arrangements should be
made in advance by contacting the Planning Division of the Design and Development Department at 777-
7118. A one (1) week notice is required.
If background material is to be presented to the Commission during a Planning Commission meeting, please
be advised that ten (10) copies of all documents, exhibits, etc., must be supplied to the Executive Assistant
for distribution. It is requested that this take place prior to the beginning of the meeting.
Any writings or documents provided to a majority of the Commission regarding any item(s) on this agenda
will be made available for public inspection at the Design and Development Department’s counter at City Hall
located at 78-495 Calle Tampico, La Quinta, California, 92253, during normal business hours.
PLANNING COMMISSION MINUTES 1 MAY 26, 2020
PLANNING COMMISSION
MINUTES
TUESDAY, MAY 26, 2020
CALL TO ORDER
A regular meeting of the La Quinta Planning Commission was called to order at
6:00 p.m. by Chairperson Caldwell.
This meeting was held by teleconference pursuant to Executive Orders N-25-20, N-
29-20, N-33-20, and N-35-20, executed by the Governor of California in response
to the state of emergency relating to novel coronavirus disease 2019 (COVID-19)
and enabling teleconferencing accommodations by suspending or waiving specified
provisions of the Ralph M. Brown Act (Government Code § 54950 et seq.).
PRESENT: Commissioners Bettencourt, Currie, McCune, Nieto, Proctor and
Chairperson Caldwell
ABSENT: Commissioner Libolt Varner
STAFF PRESENT: Design & Development Director Danny Castro, Planning Manager
Cheri L. Flores, Senior Planner Carlos Flores, Associate Planner
Siji Fernandez, Consulting Planner Nicole Sauviat Criste, Public
Works Director/City Engineer Bryan McKinney, Building Official
Anthony Ortega and Commission Secretary Wanda Wise-Latta
PLEDGE OF ALLEGIANCE
Chairperson Caldwell led the Planning Commission (Commission) in the Pledge of
Allegiance.
PUBLIC COMMENT ON MATTERS NOT ON THE AGENDA
There were no requests to speak under the ‘Public Comment on Matters Not on the
Agenda’ section of the meeting and Staff will continue to monitor emails should
written comments or requests for verbal comments be received.
CONFIRMATION OF AGENDA
MOTION – A motion was made and seconded by Commissioners
Bettencourt/Proctor to approve the Consent Calendar as submitted. AYES:
Commissioners Bettencourt, Currie, McCune, Nieto, Proctor and Chairperson
Caldwell. NOES: None. ABSENT: Commissioner Libolt Varner. ABSTAIN: None.
Motion passed.
CONSENT CALENDAR ITEM NO. 1
PLANNING COMMISSION MINUTES 2 MAY 26, 2020
ANNOUNCEMENTS, PRESENTATIONS AND WRITTEN COMMUNICATION
1. SILVERROCK MODIFICATIONS BY APPLICANT (MBA2020-0005 AND -0006)
Consulting Planner Criste presented the staff report which is on file in the Design
and Development Department.
Staff responded to the Commission’s inquiries and comments regarding the number
of modifications by applicant allowed under the Municipal Code; and shared factors
that might result in plan changes.
Commissioners shared their thoughts regarding the substance of the modifications
and felt those modifications were significant.
PUBLIC SPEAKER: Mr. John Gamlin, The Robert Green Company – introduced
himself and continued the presentation.
Commissioners thanked Mr. Gamlin for the presentation and shared their comments
and inquiries regarding the project.
Mr. Gamlin and staff clarified for the Commission that the red-line drawings on the
attachments were the SDP-approved profile; explained the rooftop elements on the
Pendry elevations; and spoke about the height of Pendry and its visibility from
Jefferson Street or from Avenue 52.
Mr. Gamlin appreciated a Commissioner’s comments about the site’s condition
particularly regarding the perimeter fencing and weed control.
Commissioners shared their thoughts regarding staff’s administrative authority in
making their determination given the documentation that was provided; the pool
re-design; and the legibility of the staff report attachments.
Staff noted that should the Commission desire additional information regarding an
item on a Commission agenda, staff would be happy to provide the information.
CONSENT CALENDAR
1. APPROVAL OF MINUTES DATED MAY 12, 2020
MOTION – A motion was made and seconded by Commissioners Currie/Bettencourt
to approve the Consent Calendar as submitted. AYES: Commissioners Bettencourt,
Currie, McCune, Nieto, Proctor and Chairperson Caldwell. NOES: None. ABSENT:
Commissioner Libolt Varner. ABSTAIN: None. Motion passed.
BUSINESS SESSION – None
PLANNING COMMISSION MINUTES 3 MAY 26, 2020
STUDY SESSION
1. REVIEW OF RECREATIONAL VEHICLE PARKING IN COVE RESIDENTIAL
DISTRICT
Senior Planner Flores presented the staff report which is on file in the Design and
Development Department.
Staff responded to Commission inquiries and comments regarding recreational
vehicle (RV) parking in front yards and its impact on aesthetic quality of
neighborhood; references to RV parking in the Municipal Code; giving consideration
to requiring a permit to park an RV in front yard so as to assure that the RV
belongs to the homeowner/resident; protecting and enhancing neighborhood
values; if RV parking is restricted consider grandfathering but limit to current RV;
multiple RVs parked at a residence; side yard RV parking and setbacks; impacts on
street parking; code compliance and enforcement; and how best to obtain
community input.
Staff stated that most complaints received by Code Compliance are related to 72-
hour parking violations; noted that Planning staff had not received other complaints
about RV parking in the Cove but did receive correspondence about relaxing RV
parking in front yards in another area of the City.
Commission and staff discussed options for obtaining community input with the
assurance that all residents and property owners in the Cove Residential District
would have the opportunity to provide their input.
PUBLIC HEARINGS – None
REPORTS AND INFORMATIONAL ITEMS - None
COMMISSIONERS’ ITEMS
Commissioner Bettencourt stated that he hoped staff would be able to provide
meeting materials in a user-friendly, three-ring binder format for ease of review by
the Commission especially when staff reports and attachments are voluminous;
suggested Commissioners visit the Montage Cabo San Lucas website to view the
photo gallery; and inquired if there are regulatory measures that the City needs to
address to facilitate the transition to normal business operations especially with
regards to curbside pickup.
Director Castro updated the Commission regarding the City’s Al Fresco Dining
program.
Chairperson Caldwell inquired if Planning staff is still attending Vista Santa Rosa
meetings. Senior Planner Flores confirmed that he will be attending the next Vista
Santa Rosa Community meeting.
PLANNING COMMISSION MINUTES 4 MAY 26, 2020
STAFF ITEMS
1. UPCOMING PROJECTS UPDATE
Planning Manager Flores presented the staff report which is on file in the Design
and Development Department.
Staff advised the Commission that the Travertine project held a scoping meeting in
2018 and no further scoping meeting was required; and noted that the applicant is
planning to coordinate community meetings in the future.
A Commissioner asked if staff could provide an update on the SilverRock Venue Site
and the La Quinta Auto Center at the next Planning Commission meeting.
ADJOURNMENT
There being no further business, it was moved and seconded by Commissioners
Bettencourt/Proctor to adjourn at 6:55 p.m. Motion passed.
Respectfully submitted,
WANDA WISE-LATTA, Commission Secretary
City of La Quinta, California
City of La Quinta
PLANNING COMMISSION MEETING: June 23, 2020
STAFF REPORT
AGENDA TITLE: ADOPT A RESOLUTION TO APPROVE FINAL LANDSCAPING
PLAN 2020-0002 FOR RESIDENCE INN
PROJECT INFORMATION
CASE NUMBER: FINAL LANDSCAPE PLAN 2020-0002
APPLICANT: PORTER BROTHERS
PROPERTY OWNER: SUNRIDGE PROPERTIES
REQUEST: ADOPT RESOLUTION TO APPROVE THE FINAL
LANDSCAPE PLAN FOR NEW RESIDENCE INN
LOCATION: 79675 HIGHWAY 111
CEQA: THIS PROJECT WAS PREVIOUSLY REVIEWED UNDER
ENVIRONMENTAL ASSESSMENT 2018-0005. THE
PROJECT IS CONSISTENT WITH THE ANALYSIS
PREVIOUSLY APPROVED. NO FURTHER
ENVIRONMENTAL REVIEW IS REQUIRED UNDER THE
CALIFORNIA ENVIRONMENTAL QUALITY ACT.
RECOMMENDATION
Approve Final Landscape Plan 2020-0002.
EXECUTIVE SUMMARY
The City of La Quinta Planning Commission on March 12, 2019, approved
a Site Development Permit for construction of a new Residence Inn by
Marriott to be located on the south side of Highway 111.
A condition of approval was added that required Planning Commission
approval of landscaping abutting Highway 111.
BACKGROUND/ANALYSIS
The La Quinta Redevelopment Agency (RDA) purchased a 22-acre property south
of Highway 111 and 300 feet east of Dune Palms Road in 2007 to facilitate
development of affordable housing and infill commercial development. On June
5, 2018, City Council entered into a purchase and sale agreement with Sunridge
Properties on development of a hotel on a 2.9-acre portion of the northern 10
acres of the site, contingent upon securing the necessary entitlements. The
BUSINESS SESSION ITEM NO. 1
Planning Commission on March 12, 2019, approved a Site Development Permit
for construction of a new 4-story, 108-room Residence Inn by Marriott, complete
with a reception area, outdoor pool and patio, and golf putting green.
The Planning Commission added the following Condition of Approval to the Site
Development Permit: “Two parking stalls located on the northeast corner of the
project site directly abutting Highway 111 shall be removed and converted to
landscaped area. This change shall be reflected on all applicable construction
documents, including, but not limited to, grading plans, building permits, and
Final Landscape Plans. Planning Commission approval of Final Landscape Plan
is required for all landscaping abutting Highway 111, including converted
landscaped area.”
The applicant has submitted a Final Landscaping Plan which is consistent with
the preliminary Landscaping Plan that was approved with the SDP (Attachment
1). New landscaping is proposed throughout the entire perimeter of the site and
building, the parking lot, and hotel entrance. The assorted species of plants and
trees, including date palms, gold and purple lantanas, and Palo Verdes, add
character to the proposed development, and are consistent with desert
landscaping palettes in the City.
The focus of the condition of approval is on “landscaping abutting Highway 111,
including converted landscaped area”. The applicant has provided detailed
information on the landscaping abutting Highway 111, providing detail on the
sufficient screening that will be provided by this landscaping (Attachment 2).
The tree maturation, lining of shrubs, and ground mounding heights provides
adequate screening of the parking stalls abutting Highway 111.
ENVIRONMENTAL REVIEW
The Design and Development Department determined that the project was
previously reviewed under Environmental Assessment 2018-0005 and is
consistent with the analysis previously approved.
Prepared by: Carlos Flores, Senior Planner
Approved by: Danny Castro, Design and Development Director
Attachments: 1. Final Landscaping Plans
2. Detailed Highway 111 Landscaping Plans
1
PLANNING COMMISSION RESOLUTION 2020 -
A RESOLUTION OF THE PLANNING
COMMISSION OF THE CITY OF LA QUINTA,
CALIFORNIA, APPROVING A FINAL
LANDSCAPING PLAN FOR RESIDENCE INN
CASE NUMBER:
FINAL LANDSCAPE PLAN 2020-0002
APPLICANT: PORTER BROTHERS
WHEREAS, the Planning Commission of the City of La Quinta,
California did, on the 23th day of June, 2020, consider a request by Porter
Brothers for approval of a Final Landscaping Plan for Residence Inn.
Final Landscaping Plan
WHEREAS, upon hearing and considering all testimony and
arguments, if any, of all interested persons desiring to be heard, said
Planning Commission did find:
1. The proposed landscaping plan conforms to the requirements of
Section 8.13, insofar as it provides a variety of plant species in an
aesthetically pleasing design that meets the City’s water efficiency
requirements.
2. The Design and Development Department has determined that the
project was previously reviewed under Environmental Assessment
2018-0005 and is consistent with the analysis previously approved.
NOW, THEREFORE, BE IT RESOLVED by the Planning Commission
of the City of La Quinta, California, as follows:
SECTION 1. That the above recitations are true and constitute the Findings
of the Planning Commission in this case;
SECTION 2. That the above project be determined by the Planning
Commission to be consist with Environmental Assessment 2018-0005;
SECTION 3. That it does hereby approve Final Landscaping Plan 2020-0002,
subject to the attached Conditions of Approval, for the reasons set forth in
this Resolution.
Planning Commission Resolution 2020 -
Final Landscaping Plan 2020-0002
Residence Inn
Adopted:
Page 2 of 2
PASSED, APPROVED, and ADOPTED at a regular meeting of the
City of La Quinta Planning Commission, held on this the 23th day of June
2020, by the following vote:
AYES:
NOES:
ABSENT:
ABSTAIN:
MARY CALDWELL, Chairperson
City of La Quinta, California
ATTEST:
DANNY CASTRO, Design and Development Director
City of La Quinta, California
PLANNING COMMISSION RESOLUTION 2020-
CONDITIONS OF APPROVAL – RECOMMENDED
FINAL LANDSCAPE PLAN 2020-0002
RESIDENCE INN
ADOPTED:
Page 1 of 1
1. Final Landscape Plan 2020-0002 shall comply with all applicable conditions
and/or mitigation measures for the following related approvals:
Site Development Permit 2018-0007
Tentative Parcel Map 37683
Environmental Assessment 2018-0005
Specific Plan 2018-0002 (Specific Plan 2008-085, Amendment 1)
In the event of any conflict(s) between approval conditions and/or provisions
of these approvals, the Design and Development Director shall adjudicate the
conflict by determining the precedence.
2. City staff will provide the applicant a Certificate of Completion prior to
landscaping installation commencing, which will need to be completed and
submitted to Design and Development department prior to final Planning
inspection.
3. The final landscape plans shall be stamped and approved by the Coachella
Valley Water District (CVWD).
4. A final Planning inspection will be required for the landscaping work.
City of La Quinta
PLANNING COMMISSION MEETING: June 23, 2020
STAFF REPORT
AGENDA TITLE: ADOPT A RESOLUTION TO APPROVE A MINOR USE PERMIT
2020-0002 FOR MECHANICAL EQUIPMENT WITHIN THE SIDE YARD SETBACK AT
54927 WINGED FOOT
PROJECT INFORMATION
CASE NUMBER: MINOR USE PERMIT 2020-0002
APPLICANT: PAUL VOTTA (VOTTA ENTERPRISES)
PROPERTY OWNER: BRIAN AND REBECCA WAINWRIGHT
REQUEST: ADOPT RESOLUTION TO APPROVE A MINOR USE PERMIT
FOR MECHANICAL EQUIPMENT WITHIN THE SIDE YARD
SETBACK
LOCATION: 54927 WINGED FOOT
CEQA: THE DESIGN & DEVELOPMENT DEPARTMENT REVIEWED
THE PROJECT IN COMPLIANCE WITH THE
REQUIREMENTS OF THE CALIFORNIA ENVIRONMENTAL
QUALITY ACT (CEQA). THE DEPARTMENT HAS
DETERMINED THAT THE PROJECT IS CATEGORICALLY
EXEMPT UNDER CEQA GUIDELINES 15301, MINOR
ALTERATIONS TO EXISTING FACILITIES.
RECOMMENDATION
Approve Minor Use Permit 2020-0002.
EXECUTIVE SUMMARY
Paul Votta (Applicant), on behalf of the Owner, applied for a Mechanical
Building permit to replace existing Air Conditioning (AC) units with new
units.
The new units were installed within the five (5) foot (ft) side yard setback.
Proposing AC units within this setback requires Planning Commission
approval of a Minor Use Permit (MUP).
BUSINESS SESSION ITEM NO. 2
BACKGROUND/ANALYSIS
On January 30, 2020, the Applicant, an AC contractor, applied for a Mechanical
Building permit to replace existing AC units with two new units at 54927 Winged
Foot. On February 6, 2020, the City of La Quinta Building staff completed their
first inspection of the new units and disapproved of the installation because the
new units had been installed within the five (5) ft side yard setback. Per La
Quinta Municipal Code Section 9.60.075(C): “Mechanical equipment may be in a
side yard of five feet or less if: … (2) if approved by the planning commission
through a minor use permit if findings are made that extenuating circumstances
exist”. The new units were installed in a different location than the AC units that
were previously installed at this residence. City Planning, Fire, and Building staff
followed up with multiple conversations with applicant and owner regarding
options on complying with La Quinta Municipal Code and California Building and
Fire Code, which was then followed by submittal of a MUP application.
The Applicant is requesting approval for these new units due to site
configurations and performance ability of the new units (Attachment 1). This
performance ability includes energy and noise efficiency. The Applicant has
communicated that these units are the quietist units they offer. The two (2)
new units are proposed to be setback 20” from the side yard property line wall
and measure 47” in height, 35-1/2” in width, and 39-1/2” in depth (Attachment
3). The property line wall between the units and the neighbor is a six foot high
masonry block wall, set back an additional five feet from the neighbor’s house.
City Building and Fire staff reviewed the proposed location and found the location
to be acceptable in providing adequate egress and emergency access, meanwhile
meeting all product specifications. None of the bedrooms and the emergency
egress windows are in a location that would impede egress through the egress
court as affected by the new locations of the condenser units. All bedrooms have
a 36-inch clear width egress court and access to a safe refuge yard space or
public way not affected by the condenser units, meeting Fire code requirements.
PUBLIC REVIEW
Per La Quinta Municipal Code Section 9.60.075(C), notification was provided to
adjoining impacted property owners ten days prior to this meeting. No
comments have been received.
ENVIRONMENTAL REVIEW
The Design and Development Department has determined that the project is
categorically exempt under CEQA guidelines 15301 – Minor Alterations to
Existing Facilities.
Prepared by: Carlos Flores, Senior Planner
Approved by: Danny Castro, Design and Development Director
Attachments: 1. Applicant Justification Letter
2. Site Plan
1
PLANNING COMMISSION RESOLUTION 2020 -
A RESOLUTION OF THE PLANNING
COMMISSION OF THE CITY OF LA QUINTA,
CALIFORNIA, APPROVING A MINOR USE
PERMIT FOR MECHANICAL EQUIPMENT WITHIN
SIDE YARD SETBACK 54927 WINGED FOOT
CASE NUMBERS:
MINOR USE PERMIT 2020-0002
APPLICANT: VOTTA ENTERPRISES
WHEREAS, the Planning Commission of the City of La Quinta,
California did, on the 23th day of June, 2020, consider a request by Votta
Enterprises for approval of a Minor Use Permit at 54927 Winged Foot.
Minor Use Permit
WHEREAS, upon hearing and considering all testimony and
arguments, if any, of all interested persons desiring to be heard, said
Planning Commission did find:
1. Consistency with General Plan. The land use is consistent with
the general plan.
2. Consistency with Zoning Code. The use is consistent with the
provisions of this zoning code. Mechanical equipment is allowed
within the side yard setbacks with approval of a minor use
permit.
3. Compliance with CEQA. The Design and Development
Department has determined that the project is categorically
exempt under CEQA guidelines 15301 – Minor Alterations to
Existing Facilities.
4. Surrounding Uses. Approval of the application will not create
conditions materially detrimental to the public health, safety and
general welfare or injurious to or incompatible with other
properties or land uses in the vicinity. The mechanical
equipment within the side yard setback provides adequate
emergency egress and access and are high performing units with
acceptable noise and energy efficiency.
Planning Commission Resolution 2020 -
Minor Use Permit 2020-0002
Votta Enterprises
Adopted:
Page 2 of 2
NOW, THEREFORE, BE IT RESOLVED by the Planning Commission
of the City of La Quinta, California, as follows:
SECTION 1. That the above recitations are true and constitute the Findings
of the Planning Commission in this case;
SECTION 2. That the above project be determined by the Planning
Commission to be exempt from CEQA under Section 15301, Minor
Alterations to Existing Facilities;
SECTION 3. That it does hereby approve Minor Use Permit 2020-0002,
subject to the attached Conditions of Approval, for the reasons set forth in
this Resolution.
PASSED, APPROVED, and ADOPTED at a regular meeting of the
City of La Quinta Planning Commission, held on this the 23th day of June
2020, by the following vote:
AYES:
NOES:
ABSENT:
ABSTAIN:
MARY CALDWELL, Chairperson
City of La Quinta, California
ATTEST:
DANNY CASTRO, Design and Development Director
City of La Quinta, California
PLANNING COMMISSION RESOLUTION 2020-
CONDITIONS OF APPROVAL – RECOMMENDED
MINOR USE PERMIT 2020-0002
VOTTA ENTERPRISES
ADOPTED:
Page 1 of 1
1. The units will need to consistently meet the following clearances:
A. 30” service clearance
B. 24” separation between units
2. Side yards shall not be utilized as the only emergency escape route
3. The applicant agrees to defend, indemnify and hold harmless the City of La
Quinta (“City”), its agents, officers and employees from any claim, action or
proceeding to attack, set aside, void, or annul the approval of this Site
Development Permit. The City shall have sole discretion in selecting its
defense counsel.
The City shall promptly notify the applicant of any claim, action or proceeding
and shall cooperate fully in the defense.
Comfort Air
72248 Northshore St Suite 101
Thousand Palms , CA 92276
760-637-1962
paulvotta@comfortac.com
May 28, 2020
City Of La Quinta
78495 Calle Tampico
La Quinta, CA 92253
Dear Planning Commission
If all homes are designed similar to this property it will be a challenge for any
Mechanical Contractor and Homeowner looking to install new HVAC units. From a
performance stand point the cavity or enclosure built for AC Units and original to the
house is poorly designed. The work that was performed at property is in perfect balance
to maximize proximity to the original placement, accommodate the manufacturer’s
clearance specifications and provide as wide as possible and as uniform as possible a
walkway.
Because the original units were both squeezed into a confined space not allowing them to
breathe correctly, their placement made them (a R-22 2 Ton and a 5 Ton) prone to
constant shutdown. Such a tight space will not only affect the performance of the units,
but also the future service and up keep are questionable.
The units now installed at the property were placed on the outside of the cavity for
performance purposes and to protect their longevity and workings in conformity with the
clearance requirements from the manufacturer. Those specifications, listed in the product
manual, have been provided. The units have been relocated adjacent to the enclosure to
meet the height requirements for the top discharge, otherwise the hot air trapped overhead
is drawn back into the compressor causing undue strain, decreasing its functionality and
resulting in equipment failure. Even one single unit placed inside the cavity does not
allow the system to perform the way it should nor does it meet the manufacturer’s height
clearance requirement which is why both units were placed outside of the cavity.
Previously, no allowance was made for mechanical equipment in the five foot setback.
The ordinance was changed in recognition of exigent circumstances: contemporary
compressors need to be placed into the five foot setback for central air conditioning to
function in this climate.
ATTACHMENT 1
The new units are installed in close proximity to indoor FAU (Forced Air Units) that also
helps performance greatly; we find when units are further away from indoor units or
refrigerant lines are extended too far it impacts the efficiency of the units.
As can be seen from the layout diagram provided, the bedroom just behind the
compressors has two exit windows to the side yard which provides direct access to the
golf course which fronts on the back of the property. The interior door to the garage is
just in front of the compressors and provides access to the house as well.
As time progresses, we find the newer HVAC units are much more efficient and larger in
size and the variable speed compressor technology makes the system much quieter when
they operate and run. The quietness of the new units is not only a benefit for the
homeowner, but also for the surrounding neighbors.
In my professional opinion, the size of the current units is reflective of industry trends,
their placement is in conformity with the manufacturer’s clearance requirements and their
placement will maximize performance. Future service and maintenance work will be able
to be performed.
Paul Votta
Votta Enterprises Inc. DBA Comfort Air
ATTACHMENT 2
City of La Quinta
PLANNING COMMISSION MEETING: June 23, 2020
STAFF REPORT
AGENDA TITLE: ADOPT A RESOLUTION APPROVING A VEHICLE MILES
TRAVELED ANALYSIS POLICY IN COMPLIANCE WITH STATE SENATE BILL 743;
CEQA: EXEMPT PURSUANT TO SECTIONS 15308, 15307 AND 15061 (b)(3).
RECOMMENDATION
Adopt a resolution finding that approving this policy is exempt from
environmental review under the California Environmental Quality Act
CEQA) pursuant to Section 15308, Actions by Regulatory Agencies for
Protection of the Environment, Section 15307, Actions by Regulatory
Agencies for Protection of Natural Resources, and Section 15061(b)(3),
Review for Exemptions – Common Sense Rule and approve a Vehicle
Miles Traveled Analysis Policy in compliance with State Senate Bill 743.
EXECUTIVE SUMMARY
Senate Bill (SB) 743, adopted in 2013 and codified in Public Resources
Code Section 21099, requires changes to the CEQA Guidelines regarding
the analysis of transportation impacts.
SB 743 is effective July 1, 2020 at which time lead agencies must analyze
CEQA traffic impacts using Vehicle Miles Traveled (VMT), and automobile
delay, as measured by Level of Service (LOS), will no longer constitute a
significant impact under CEQA.
Staff has reviewed the requirements and prepared a policy to be
consistent with State guidelines and guide consultants in preparing their
VMT analyses.
BACKGROUND/ANALYSIS
The State has for many years been attempting to reduce greenhouse gas
GHG) emissions to combat climate change. In order to achieve the State’s
long-term climate goals and promote the reduction of GHG emissions, the
development of multimodal transportation networks, and a diversity of land
uses, the Governor’s Office of Planning and Research (OPR) and the California
Natural Resources Agency have determined that VMT is the most appropriate
metric to evaluate a project’s transportation impacts. SB 743 changes how
transportation impacts are analyzed under CEQA to use VMT as the appropriate
metric to evaluate a project’s transportation impacts. Automobile delay, as
measured by LOS or similar metrics, no longer constitutes a significant
PUBLIC HEARING ITEM NO. 1
environmental impact. To assist jurisdictions with evaluation of VMT impacts,
OPR issued a technical advisory in December 2018 that contains technical
recommendations regarding the assessment of VMT, thresholds of significance,
and mitigation measures, and provides guidance and recommendation to
implement the requirements of SB 743 (Attachment 1). Using this guidance,
Staff has prepared a policy which establishes methodology for analyzing
transportation impacts using VMT, establishes thresholds for significance for
use in CEQA analysis as provided for in CEQA Guidelines section 15064.3 and
provides options for mitigation. VMT analysis will need to be incorporated into
any environmental documents circulated after July 1, 2020.
Projects will go through several steps during the VMT analysis process. A
screening process would be conducted first to determine if a VMT analysis is
necessary. The screening process helps quickly identify projects that are
expected to cause a less than significant impact without conducting a full
analysis. If a project meets the screening criteria, it would not need to conduct
a VMT analysis. If it does not meet the criteria, it would need to conduct the
VMT analysis, consistent with the methodology outlined in the VMT Analysis
Policy (Exhibit A). Transportation impacts would be determined based on the
thresholds set forth within the policy, which are consistent with OPR’s Technical
Advisory on Evaluating Transportation Impacts in CEQA (Attachment 1).
Various land uses would have different thresholds which are summarized below.
Residential Uses
o VMT exceeding a level of 15 percent below the Citywide or regional
VMT per resident, whichever is more stringent
General Employment Uses – including offices and R&D establishments
o VMT per employee exceeding a level of 15 percent below existing
regional VMT per employee
Industrial Employment Uses - including warehouse, manufacturing and
distribution
o VMT per employee exceeding existing regional VMT per employee
Retail Uses – including hotels
o A net increase in the total existing VMT for the region
Mixed-Uses
o Each land use component of a mixed-use project will be analyzed
independently, applying the significance threshold for each land use
component
Change of Use or Additions to Existing Development
o Changes of use or additions to existing development will be
analyzed applying the significance threshold for each land use
component.
Urban Village, Station Area Plans, Development Policy, Specific Strategy
or Other Area Plans
o Each land use component analyzed independently, applying the
significance threshold for each land use component
General Plan Amendments
o General Plan Amendments will be analyzed in conformance with the
General Plan’s definition of VMT. An increase in City total VMT is a
significant transportation impact.
Transportation Projects
o Net increase in VMT greater than that consistent with the SCAG’s
Regional Transportation Plan/Sustainable Communities Strategy.
Significant impacts would occur if these thresholds are exceeded and mitigation
measures would need to be implemented. Mitigation measures available to
applicants consist of modifying the project’s built environment characteristics to
reduce VMT generated by the project, usually through reallocation of land uses,
or to implement transportation demand management measures to reduce VMT
generated by the project as included in Chapter 9.180 of the La Quinta
Municipal Code. If mitigation measures are not able to reduce impacts to less
than significant levels, the project must prepare an EIR with a Statement of
Overriding Considerations and written findings as defined in CEQA Guidelines
Sections 15091 and 15093.
PUBLIC REVIEW
This project was advertised in The Desert Sun newspaper on June 12, 2020. To
date, no comments have been received. Comments from other City
Departments and Divisions were considered.
ENVIRONMENTAL REVIEW
The Design and Development Department has determined that the proposed
policy is exempt from environmental review under CEQA, pursuant to Section
15308, Actions by Regulatory Agencies for Protection of the Environment,
Section 15307, Actions by Regulatory Agencies for Protection of Natural
Resources and Section 15061(b)(3), Review for Exemptions – Common Sense
Rule. The revised CEQA thresholds and other requirements within the Policy,
are compliant with a State mandate (Senate Bill 743) and will be used in a
regulatory process that involves procedures for the protection of the
environment. The policy will provide the City with project specific transportation
information that can be used in the local regulatory process in which protection
of the environment is considered. Additionally, the decision to adopt the policy
will have no direct impact on the environment as it will inform the analysis of
future projects and does not include any activity that would directly impact the
environment.
Prepared by: Cheri Flores, Planning Manager
Approved by: Danny Castro, Design and Development Director
PLANNING COMMISSION RESOLUTION 2020 –
A RESOLUTION OF THE PLANNING COMMISSION
OF THE CITY OF LA QUINTA, CALIFORNIA,
ADOPTING A VEHICLE MILES TRAVELED
ANALYSIS POLICY INCLUDING THRESHOLDS OF
SIGNIFICANCE FOR PURPOSES OF ANALYZING
TRANSPORTATION IMPACTS UNDER THE
CALIFORNIA ENVIRONMENTAL QUALITY ACT
WHEREAS, the Planning Commission of the City of La Quinta, California
did, on the 23RD day of June, 2020, hold a duly noticed Public Hearing to
consider the adoption of a Vehicle Miles Traveled Analysis Policy (the “Policy”),
attached hereto as Exhibit A, including thresholds of significance for purposes
of analyzing transportation impacts under the California Environmental Quality
Act (CEQA); and
WHEREAS, said Policy has complied with the requirements of "The
Rules to Implement the California Environmental Quality Act of 1970" (CEQA)
as amended (Resolution 83-63). The Design and Development Department
has determined that the proposed Policy adoption is exempt from
environmental review pursuant to Sections 15308 (Actions by a Regulatory
Agency for Protection of the Environment), 15307 (Actions by Regulatory
Agencies for Protection of Natural Resources) and 15061(b)(3) (Review for
Exemptions – Common Sense Rule), in that the Policy is compliant with a
State mandate (Senate Bill 743) and will be used in a regulatory process that
involves procedures for the protection of the environment, will provide the
City with project specific transportation information that can be used in the
local regulatory process in which protection of the environment is considered
and the decision to adopt the new Policy will have no direct impact on the
environment as it will inform the analysis of future projects and does not
include any activity that would directly impact the environment; and
WHEREAS, the Design and Development Department published a public
hearing notice in The Desert Sun newspaper on June 12, 2020 as prescribed
by the Municipal Code; and
WHEREAS, the CEQA Guidelines encourage public agencies to develop
and publish generally applicable thresholds of significance to be used in
determining the significance of a project’s environmental effects; and
WHEREAS, CEQA Guidelines section 15064.7(a) defines a threshold of
significance as “an identifiable quantitative, qualitative or performance level
Planning Commission Resolution 2020
Vehicle Miles Traveled Analysis Policy
June 23, 2020
Page 2 of 5
of a particular environmental effect, noncompliance with which means the
effect will normally be determined to be significant by the agency and
compliance with which means the effect normally will be determined to be less
than significant”; and
WHEREAS, CEQA Guidelines section 15064.7(b) requires that
thresholds of significance must be adopted by ordinance, resolution, rule, or
regulations, developed through a public review process, and be supported by
substantial evidence; and
WHEREAS, pursuant to CEQA Guidelines section 15064.7(c), when
adopting thresholds of significance, a public agency may consider thresholds
of significance adopted or recommended by other public agencies provided
that the decision of the agency is supported by substantial evidence; and
WHEREAS, Senate Bill 743, enacted in 2013 and codified in Public
Resources Code section 21099, required changes to the CEQA Guidelines
regarding the criteria for determining the significance of transportation
impacts of projects; and
WHEREAS, in 2018, the Governor’s Office of Planning and Research
OPR) proposed, and the California Natural Resources Agency certified and
adopted, new CEQA Guidelines section 15064.3 that identifies vehicle miles
traveled (VMT) – meaning the amount and distance of automobile travel
attributable to a project – as the most appropriate metric to evaluate a
project’s transportation impacts; and
WHEREAS, in December of 2018, the OPR issued a technical advisory,
entitled “Technical Advisory: On Evaluating Transportation Impacts in CEQA”,
that contains technical recommendations regarding the assessment of VMT,
thresholds of significance, and mitigation measures, and provides guidance
and recommendation to implement the requirements of Public Resources Code
section 21099; and
WHEREAS, as a result, automobile delay, as measured by level of
service and other similar metrics, generally no longer constitutes a significant
environmental effect under CEQA; and
Planning Commission Resolution 2020
Vehicle Miles Traveled Analysis Policy
June 23, 2020
Page 3 of 5
WHEREAS, CEQA Guidelines section 15064.3 goes into effect on July 1,
2020, though public agencies could elect to be governed by this section
immediately; and
WHEREAS, the City of La Quinta, following a public review process
consisting of a public hearing before the Planning Commission, wishes to adopt
the attached VMT thresholds of significance for determining the significance
of transportation impacts under CEQA (Exhibit A), implemented through the
City of La Quinta Engineering Bulletin 06-13, Traffic Impact Study
Specifications, to provide notice and promulgate CEQA thresholds of
significance.
NOW, THEREFORE, BE IT RESOLVED by the Planning Commission of
the City of La Quinta as follows:
SECTION 1. The City of La Quinta Planning Commission hereby approves, and
adopts and incorporates by reference, the Vehicles Miles Traveled Analysis
Policy (“Policy”), attached hereto as Exhibit A, and finds that the policies
therein are consistent with the policies of the City’s existing General Plan and
the purpose of the City’s Zoning Code (City of La Quinta Municipal Code, Title
9). After reviewing the OPR’s Technical Advisory, the Planning Commission
further finds that the Policy is consistent with the recommendations and
analysis found therein.
SECTION 2. The Policy has been promulgated pursuant to State CEQA
Guidelines Section 15064.7, formally subject to a public review process, is
supported by substantial evidence, and is hereby adopted as the City of La
Quinta’s thresholds of significance for traffic and transportation analysis
pursuant to CEQA, to be implemented through the City of La Quinta
Engineering Bulletin 06-13, Traffic Impact Study Specifications, to provide
notice and promulgate CEQA thresholds of significance.
SECTION 3. This project has been assessed in accordance with the authority
and criteria contained in the California Environmental Quality Act (Public
Resources Code Sections 21000 et seq.), the State CEQA Guidelines
California Code of Regulations, Title 14, Sections 15000 et seq.), and the
environmental regulations of the City. The project qualifies for a Class 8
categorical exemption (Actions by a Regulatory Agency for Protection of the
Environment) in accordance with the requirements of Section 15308 of the
State CEQA Guidelines. Likewise, the project qualifies for a Class 7 categorical
Planning Commission Resolution 2020
Vehicle Miles Traveled Analysis Policy
June 23, 2020
Page 4 of 5
exemption (Actions by Regulatory Agencies for Protection of Natural
Resources) in accordance with the requirements of Section 15307 of the State
CEQA Guidelines. Lastly, the project is exempt from CEQA review under the
common sense exemption in accordance with the requirements of Section
15061(b)(3) of the State CEQA Guidelines.
The revised CEQA thresholds and other requirements within the Policy, are
compliant with a State mandate (Senate Bill 743) and will be used in a
regulatory process that involves procedures for the protection of the
environment. The new Policy will provide the City with project specific
transportation information that can be used in the local regulatory process in
which protection of the environment is considered. Additionally, the decision
to adopt the new Policy will have no direct impact on the environment as it
will inform the analysis of future projects and does not include any activity
that would directly impact the environment. Therefore, the Planning
Commission finds the project exempt from further review under CEQA.
SECTION 4. This Resolution shall take effect immediately upon its adoption by
the Planning Commission.
PASSED, APPROVED, and ADOPTED at a regular meeting of the City
of La Quinta Planning Commission, held on this the 23RD day of June, 2020,
by the following vote:
AYES:
NOES:
ABSENT:
ABSTAIN:
MARY CALDWELL, Chairperson
City of La Quinta, California
Planning Commission Resolution 2020
Vehicle Miles Traveled Analysis Policy
June 23, 2020
Page 5 of 5
ATTEST:
DANNY CASTRO, Design and Development Director
City of La Quinta, California
1
CITY OF LA QUINTA
VEHICLE MILES TRAVELED ANALYSIS POLICY
Senate Bill (SB) 743, signed in 2013, requires changes to the guidelines
implementing the California Environmental Quality Act (CEQA) regarding the
analysis of transportation impacts. A key element of SB 743 is the elimination of
automobile delay and Level of Service (LOS) as the sole basis of determining CEQA
impacts and analyzing Vehicle Miles Traveled (VMT), with the goal of reducing
greenhouse gas emissions to meet State mandates for 2030 and beyond. The most
recent CEQA guidelines, effective January 1, 2020, recommend VMT as the most
appropriate measure of project transportation impacts. However, SB 743 does not
prevent a city or county from continuing to analyze delay or LOS as part of other
plans (i.e., the general plan), studies, or ongoing network monitoring. The following
policy assists in determining VMT impact thresholds and mitigation requirements for
Traffic Impact Analysis (TIA) preparation as recommended by the Technical Advisory
on Evaluating Transportation Impacts in CEQA published by the Governor’s Office of
Planning and Research (OPR) (https://www.opr.ca.gov/docs/20190122-
743_Technical_Advisory.pdf).
VMT Analysis Methodology
All projects may be required to submit a TIA or Focused Traffic Impact Memo as
determined by the City Engineer. For purposes of SB 743 compliance, these may
include a VMT analysis, as deemed necessary by the Traffic Division, depending on
screening criteria, and also analyze the effects of a project on transportation, access,
circulation, and related safety elements proximate to the Project and establish
consistency with the General Plan and other City requirements.
Project Screening
Projects will first go through a screening process to determine if a VMT analysis is
necessary. If a project meets the screening criteria, the project would not need to
conduct a VMT analysis. If a project does not meet screening criteria, the project
will need to conduct the VMT analysis.
EXHIBIT A
2
There are three types of screening that can apply to effectively screen projects from
project-level assessment. The following describes the available screening criteria
pursuant to California Environmental Quality Act (CEQA) guidance provided by the
Office of Planning and Research (OPR).
Step 1: Project Type Screening
Local serving retail projects less than 50,000 square feet may be presumed to have
a less than significant impact absent substantial evidence to the contrary. Local
serving retail generally improves the convenience of shopping close to home and
has the effect of reducing vehicle travel.
In addition to local serving retail, the following uses can also be presumed to have
a less than significant impact absent substantial evidence to the contrary as their
uses are local serving in nature:
Local-serving K-12 schools
Local parks
Day care centers
Local-serving gas stations
Local-serving banks
Local-serving hotels (e.g. non-destination hotels)
Small Infill Projects
Local-Serving Public Facilities
Transit Supportive Projects in Planned Growth Areas with Low VMT and
High-Quality Transit
Restricted Affordable, Transit Supportive Residential Projects in Planned
Growth Areas with High-Quality Transit
Transportation Projects that reduce or do not increase VMT
Student housing projects
Local serving community colleges that are consistent with the assumptions
noted in the RTP/SCS
Projects generating less than 110 daily vehicle trips 1
1 This threshold ties directly to the OPR technical advisory and notes 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, subd. (e)(2).) Typical project types for which trip generation
increases relatively linearly with building footprint (i.e., general office building, single tenant office building, office park, and
business park) generate or attract an additional 110-124 trips per 10,000 square feet. Therefore, absent substantial
3
This generally corresponds to the following “typical” development
potentials:
o 11 single family housing units
o 16 multi-family, condominiums, or townhouse housing units
o 10,000 sq. ft. of office
o 15,000 sq. ft. of light industrial 2
o 63,000 sq. ft. of warehousing2
o 79,000 sq. ft. of high cube transload and short-term storage
warehouse2
Step 2: Transit Priority Area (TPA) Screening
Projects located within a TPA 3 may be presumed to have a less than significant
impact absent substantial evidence to the contrary. This presumption may NOT be
appropriate if the project:
1. Has a Floor Area Ratio (FAR) of less than 0.75;
2. Includes more parking for use by residents, customers, or employees of the
project than required by the jurisdiction (if the jurisdiction requires the project
to supply parking);
3. Is inconsistent with the applicable Sustainable Communities Strategy (as
determined by the City of La Quinta, with input from the Southern California
Association of Governments); or
4. Replaces affordable residential units with a smaller number of moderate or
high-income residential units.
Step 3: Low VMT Area Screening
Residential and office projects located within a low VMT-generating area may be
presumed to have a less than significant impact absent substantial evidence to the
contrary. In addition, other employment-related and mixed-use land use projects
may qualify for the use of screening if the project can reasonably be expected to
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.
2 Threshold may be higher depending on the tenant and the use of the site. This number was estimated using rates from
ITE’s Trip Generation Manual.
3 A TPA is defined as a half mile area around an existing major transit stop or an existing stop along a high-quality transit
corridor.
4
generate VMT per resident, per worker, or per service population that is similar to
the existing land uses in the low VMT area.
For this screening in the CVAG / City of La Quinta area, the Riverside County Travel
Demand Model (RIVTAM / RIVCOM) is used to measure VMT performance for
individual jurisdictions and for individual traffic analysis zones (TAZs). TAZs are
geographic polygons similar to Census block groups used to represent areas of
homogenous travel behavior. Total daily VMT per service population (population plus
employment) is estimated for each TAZ. Those TAZs that perform at or below the
jurisdictional (City, Subarea, County, or CVAG) average of total VMT per service
population under base year conditions are considered low VMT areas. This
presumption may not be appropriate if the project land uses would alter the existing
built environment in such a way as to increase the rate or length of vehicle trips.
To identify if the project is in a low VMT-generating area, the analyst must identify
if the project is consistent with the existing land use within that TAZ and use
professional judgement that there is nothing unique about the project that would
otherwise be mis-represented utilizing the data from the travel demand model.
VMT Assessment for Non-Screened Land Use Development Projects
Projects not screened through the steps above should complete VMT analysis and
forecasting through the RIVTAM / RIVCOM model to determine if they have a
significant VMT impact. This analysis should include ‘project generated VMT’ and
project effect on VMT’ estimates for the project TAZ (or TAZs) under the following
scenarios:
Baseline Conditions - Typically baseline conditions align with the project’s
Notice of Preparation (NOP). Baseline VMT for the year of the NOP can be
interpolated between VMT estimates calculated using the base and future
year model.
Baseline Plus Project – This scenario represents the “project generated
VMT” and is determined by adding the project land use to the project TAZ
or a separate TAZ would be created to contain the project land uses. A full
base year model run would be performed and VMT changes would be
isolated for the project TAZ and across the full model network. The model
5
output must include reasonableness checks of the production and attraction
balancing to ensure the project effect is accurately captured. If this
scenario results in a less-than-significant impact, then additional
cumulative scenario analysis may not be required.
Cumulative No Project – This scenario would consider background/ambient
growth including other proposed projects (other than proposed project) in
the City but without the proposed project’s contribution.
Cumulative Plus Project - The project land use would either be added to
the project TAZ or a separate TAZ would be created to contain the project
land uses. The addition of project land uses should be accompanied by a
reallocation of a similar amount of land use from other TAZs; especially if
the proposed project is significant in size such that it would change other
future developments. Land use projects will generally not change the
cumulative no project control totals for population and employment
growth. Instead, they will influence the land use supply through changes
in general plan land use designations and zoning. If project land uses are
simply added to the cumulative no project scenario, then the analysis
should reflect this limitation in the methodology and acknowledge that the
analysis may overestimate the project’s effect on VMT.
The model output should include total VMT, which includes all vehicle trips and trip
purposes, and VMT per service population (population plus employment). Total VMT
by speed bin) is needed as an input for air quality, greenhouse gas (GHG), and
energy impact analysis while total VMT per service population is recommended for
transportation impact analysis 4
Both “plus project” scenarios noted above will summarize two types of VMT: (1)
project generated VMT per service population and comparing it back to the
appropriate benchmark noted in the thresholds of significance, and (2) the project
effect on VMT, comparing how the project changes VMT on the network looking at
a sub-regional VMT per service population and comparing it to the no project
condition.
4 This assumes that the lead agency will use VMT per service population for its impact threshold. If a lead agency decides to
isolate VMT by trip purpose, then the lead agency would need to update this section of the recommended guidelines.
6
Project-generated VMT shall be extracted from the travel demand model using the
origin-destination trip matrix and shall multiply that matrix by the final assignment
skims. The project-effect on VMT shall be estimated using a sub-regional boundary
City limit) and extracting the total link-level VMT for both the no project and plus
project condition.
VMT Metrics
VMT should always be normalized based on the number of residents and employees
present in the zone, City, or regional area for comparative purposes to determine
impacts. The following presents the metrics to normalize VMT. The metrics used in
the VMT analysis are dependent upon the method in which the VMT is calculated.
Total VMT per service population - includes the VMT generated divided by the
population and employment in a given area (TAZ, City, or sub-region).
An important note regarding service population is that the calculation includes
the employment and population coded into the travel demand model. This
calculation excludes VMT-generating groups such as visitors, patients, guests
and students. Each project should consider if it is appropriate to add VMT-
generating groups to its service population.
Home-based VMT per resident - includes the VMT generated only by home-
based work and home-based other productions divided by the population in a
given area (TAZ, City, or sub-region). This method does not include trips with
one trip end outside of the model. Zones without any residential uses will
generate zero home-based VMT per resident.
Home-based work VMT per worker - includes the VMT generated only by
home-based work attractions divided by the number of employees in a given
area (TAZ, City, or sub-region). This method does not include trips with one
trip end outside of the model. Zones with no commercial uses will generate
zero home-based VMT per worker.
7
VMT Analysis Methodology for Land Use Plans
Land use plans are not subject to screening and require specific VMT analysis. Land
use plans should be tested for significant impacts under cumulative conditions using
the same cumulative threshold options (or lead agency thresholds) as the land use
projects. These thresholds require modeling land use plan changes to determine
VMT impacts. To capture the project effect on VMT, the same cumulative year
population and employment growth totals should be used model-wide.
VMT Analysis Methodology for Transportation Projects
Use of VMT as an environmental impact metric for transportation projects is
discretionary under the Section 15064.3(b)(2) of the updated CEQA Guidelines.
Using VMT as a transportation project impact metric would allow for a variety of
transit, bicycle, and pedestrian projects to be presumed to have a less than
significant impact. Smaller roadway network modifications such as intersection
restriping could also be presumed to have a less than significant impact. Roadway
capacity expansion projects are types of projects that can increase vehicle travel
and VMT by changing people’s travel behavior including making new vehicle trips
and making longer vehicle trips.
Thresholds for Determination of Significant Transportation
Impact
Project-Generated VMT Impacts
Residential Uses
VMT per resident exceeding a level of:
o 15 percent below the Citywide per resident VMT, OR
o 15 percent below regional VMT per resident, whichever is more stringent
General Employment Uses
Includes offices and R&D establishments
VMT per employee exceeding a level of 15 percent below existing regional VMT
per employee
8
Industrial Employment Uses
Includes warehouse, manufacturing and distribution uses
VMT per employee exceeding existing regional VMT per employee
Retail Uses
Includes Hotels
A net increase in the total existing VMT for the region
Public/Quasi-Public Uses
Public/Quasi-Public land use projects will be analyzed using the most relevant
threshold as determined by the Public Works Director for the proposed use on
the site
Mixed-Uses
Each land use component of a mixed-use project will be analyzed
independently, applying the significance threshold for each land use
component
Change of Use or Additions to Existing Development
Changes of use or additions to existing development will be analyzed applying
the significance threshold for each land use component
Urban Village, Station Area Plans, Development Policy, Specific Strategy or Other
Area Plans
Each land use component will be analyzed independently, applying the
significance threshold for each land use component
General Plan Amendments
General Plan Amendments will be analyzed in conformance with the General
Plan’s definition of VMT. An increase in City total VMT is a significant
transportation impact
Transportation Projects
Net increase in VMT greater than that consistent with the SCAG’s Regional
Transportation Plan/Sustainable Communities Strategy
9
Project-Generated VMT Impacts
A project would result in a significant project-generated VMT impact if either of the
following conditions are satisfied:
1. The baseline project-generated VMT per service population exceeds the City
of La Quinta baseline VMT per service population, or
2. The cumulative project-generated VMT per service population exceeds the
City of La Quinta baseline VMT per service population
Project Effect on VMT Impacts
The project’s effect on VMT would be considered significant if it resulted in either of
the following conditions to be satisfied:
1. The baseline link-level boundary VMT per service population (City or sub-
regional boundary) to increase under the plus project condition compared to
the no project condition, or
2. The cumulative link-level boundary VMT per service population (City or sub-
regional boundary) to increase under the plus project condition compared to
the no project condition.
Public Transit Impacts
Potential impacts to public transit, pedestrian facilities and travel, and bicycle
facilities and travel can be evaluated using the following criteria.
A significant impact occurs if the project conflicts with adopted policies,
plans, or programs regarding public transit, bicycle, or pedestrian facilities,
or otherwise decreases the performance or safety of such facilities.
The TIA should include analysis of a project to examine if it is inconsistent with
adopted policies, plans, or programs regarding active transportation or public transit
facilities, or otherwise decreases the performance or safety of such facilities and
10
make a determination as to whether it has the potential to conflict with existing or
proposed facilities supporting these travel modes.
VMT Mitigation Measures
To mitigate VMT impacts, the following choices are available to the applicant:
1. Modify the project’s built environment characteristics to reduce VMT
generated by the Project
2. Implement Transportation Demand Management (TDM) measures to
reduce VMT generated by the project consistent with La Quinta Municipal
Code Chapter 9.180 5
For proposed improvements to intersections or road segments located outside the
City of La Quinta, if an agency such as another City or the County of Riverside has
adopted a program to mitigate impacts from future development that commits that
agency to construct the improvement projects included in the program or to obtain
the balance of the funding needed to construct the improvements through some
other means, the applicant in the City of La Quinta shall be required to pay its fair
share into the program of that agency.
5 For non-residential developments, mitigation measures should consider Transportation Demand Management Strategies
which are designed to reduce the overall trip generation for the project and the need for road related improvements. Such
strategies may include the following:
Establishing preferential parking for carpool or vanpool vehicles.
Providing bus pass or Vanpool subsidies.
Allowing employees that arrive to work by alternative modes some level of leeway on their arrival times due to the
unforeseen transit delays.
Implement alternate work schedules to reduce employee trips during peak hours.
Provide shower facilities and lockers for employees that arrive to work by walking, bicycling, or other alternative
modes.
Providing bicycle parking where bicycles can be locked to an appropriate device or lockable bicycle lockers.
11
APPENDIX A
GLOSSARY OF TERMS
Active Transportation - A means of getting around that is powered by human
energy, primarily walking and biking.
Alternative Transportation Modes - Sustainable transportation methods that are
alternative to personal motorized vehicles, primarily walking, biking, and riding
transit.
Approved Trip Inventory (ATI) - A City-maintained database of vehicle-trips
generated by projects for which an entitlement to build has been granted that have
yet been built or occupied. Consists of assigned vehicle-trips by turn movement at
signalized intersections.
Area Development Policy (ADP) - A City-adopted implementation policy of an
Area Plan.
Area Plan - A City-adopted plan that coordinates transportation infrastructure
improvements and land use development in support of a unique vision for a subarea
of the City (e.g. an Urban Village Plan).
Boundary VMT Method - A method used to calculate total VMT on roadways
bounded within the City. VMT per service population, a performance metric for
General Plan amendments, is based on this method.
Effect - Project-related effects on elements of the transportation system for which
no transportation standards or CEQA thresholds of significance have been
established by the City. Distinct from “impact”.
Existing VMT - Current VMT levels for the existing buildings within a one-half mile
buffer of a development project.
High-Quality Transit Areas - Areas are within half a mile of a high-quality transit
corridor or major transit stop.
12
High-Quality Transit Corridor - A corridor with fixed route bus service with
service intervals no longer than 15 minutes during peak commute hours (Pub.
Resources Code § 21155 (b)).
Impact - Refer to a project’s impacts as determined by the transportation standards
or CEQA thresholds of significance established by the City. Distinct from “effect”.
Improvement - A change that addresses the effects, particularly adverse effects,
of a project on elements of the transportation system for which no transportation
standards or CEQA thresholds of significance have been established by the City.
Distinct from “mitigation’.
Induced Trips - Increase in traffic volume that occurs soon after a new road is
opened, or a previously congested road is widened. Increases in roadway capacity
are typically quickly filled up with additional traffic.
Infill Opportunity Zone (IOZ) - Areas designated by the City that exempt
intersection operations standards in the Congestion Management Program (CMP).
CMP facilities located within IOZs are exempt from provisions of the CMP’s
operations standard requirements.
Internal Trips - Trips between different land use types within the same
development project that are accommodated at the project site. Trips that are not
internal are those with the project at one end and other locations at the other end.
Intersection Operations Standard - A measure of automobile vehicle delays
through a signalized intersection, graded on a scale A through F.
Major Transit Stop - A 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 § 21064.3).
Mitigation - A change that addresses the CEQA impacts of a project on elements
of the transportation system for which transportation standards or CEQA thresholds
of significance have been established. Distinct from “improvement”.
13
Mixed-Use Project - A development project that combines two or more land uses.
Mode Share - The share of all person-trips to and from a project taken by each
transportation mode (personal motorized vehicles, transit, bicycle, and pedestrian).
Multimodal Improvement Plan (MIP) - VTA terminology for “Deficiency Plan” as
defined by CMA statue. VTA’s plans developed to identify offsetting measures to
improve transportation conditions on CMP facilities in lieu of making physical traffic
capacity improvements such as widening a roadway.
Multimodal Transportation Improvement Plan (MTIP) - The City’s area-based
prioritized list of projects and programs intended to facilitate realization of goals and
objectives identified in a long-range plan.
Net Change in Total VMT - Difference in total VMT in the area with and without
the project. Performance metric for regional retail projects and transportation
projects.
Origin-Destination (O-D) VMT Method - A method used to calculate the total
vehicle-miles traveled a study area (e.g. a development project, the City, or the
region) is expected to generate in a day. For a personal motorized vehicle-trip to be
included in the VMT calculation using the OD VMT method, one of the trip ends must
be within the study area. The OD Method accounts for all trips, including external
trips that have one trip end outside of the model boundary, and therefore provides
a more complete capture of all travel within the study area.
Production/Attraction (PA) VMT Method - A method used to calculate the total
vehicle-miles traveled a study area (e.g. a development project, the City, or the
region) is expected to generate in a day. The PA Method allows project VMT to be
evaluated based on trip purpose which is consistent with OPR’s recommendations.
PA matrices do not include external trips that have one trip end outside of the model
boundary, and therefore do not include those trips in the VMT estimates.
Passive Parks - Less structured recreational activities and casual pursuit of hobbies
that allow for the preservation of natural habitat.
14
Peak Hour - The highest morning or evening hour of travel reported on a
transportation network or street.
Personal Motorized Vehicles - Mainly personal motor vehicles that transport
people rather than goods. VMT is based on only personal motor vehicles.
Physical VMT Reduction Strategies - Strategies that development projects can
physically construct to encourage the shift from driving alone to walking, biking, and
riding transit. Include three of the four VMT reduction strategies – project
characteristics, multimodal network improvements, and parking measures.
Project VMT - Calculated VMT generation of a development project.
Service Population - The sum of residents and workers in an area such as the City
of La Quinta.
Sphere of influence - Area in which travel patterns are expected to change due to
a transportation project.
Transportation Demand Management (TDM) - Programmatic measures that
discourage drive-alone trips and encourage pedestrian, bicycle, and transit use. One
of the four categories of VMT reduction strategies for development projects.
Trip Cap - A maximum number of vehicle-trips that a development project is
allowed to generate in a day.
Trip Adjustments - Effort to reduce the number of vehicle-trips to and from a
project.
Trip Assignment - An assignment of vehicle-trips to transportation facilities based
on trip distribution percentages.
Trip Distribution - A forecast of the travel direction of vehicle-trips to and from a
project.
Trip Generation - The estimated total number of vehicle-trips to and from a
project.
15
Vehicle-Miles Traveled - The total miles of travel by motorized on-road passenger
vehicles in a day. A measure on which a project’ transportation impact(s) are based.
VMT per Capita - The sum of VMT for personal motorized vehicle-trips made by all
residents of a development project, divided by the total number of residents of the
project.
VMT per Employee - The sum of VMT for personal motorized vehicle-trips made
by all workers of an office or industrial development project, divided by the total
number of workers at the project.
ON EVALUATING TRANSPORTATION
IMPACTS IN CEQA
TECHNICAL ADVISORY
December 2018
ATTACHMENT 1
Contents
A. Introduction ...................................................................................................................................... 1
B. Background ....................................................................................................................................... 2
C. Technical Considerations in Assessing Vehicle Miles Traveled ......................................................... 4
1. Recommendations Regarding Methodology ................................................................................ 4
D. General Principles to Guide Consideration of VMT .......................................................................... 7
E. Recommendations Regarding Significance Thresholds .................................................................... 8
1. Screening Thresholds for Land Use Projects ............................................................................... 12
2. Recommended Numeric Thresholds for Residential, Office, and Retail Projects ....................... 15
3. Recommendations Regarding Land Use Plans ............................................................................ 18
4. Other Considerations .................................................................................................................. 19
F. Considering the Effects of Transportation Projects on Vehicle Travel ........................................... 19
1. Recommended Significance Threshold for Transportation Projects .......................................... 22
2. Estimating VMT Impacts from Transportation Projects ............................................................. 23
G. Analyzing Other Impacts Related to Transportation ...................................................................... 25
H. VMT Mitigation and Alternatives .................................................................................................... 26
Appendix 1. Considerations About Which VMT to Count ....................................................................... 29
Appendix 2. Induced Travel: Mechanisms, Research, and Additional Assessment Approaches ............ 32
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December 2018
A. Introduction
This technical advisory is one in a series of advisories provided by the Governor’s Office of Planning and
Research (OPR) as a service to professional planners, land use officials, and CEQA practitioners. OPR
issues technical assistance on issues that broadly affect the practice of land use planning and the
California Environmental Quality Act (CEQA) (Pub. Resources Code, § 21000 et seq.). (Gov. Code, §
65040, subds. (g), (l), (m).) The purpose of this document is to provide advice and recommendations,
which agencies and other entities may use at their discretion. This document does not alter lead agency
discretion in preparing environmental documents subject to CEQA. This document should not be
construed as legal advice.
Senate Bill 743 (Steinberg, 2013), which was codified in Public Resources Code section 21099, required
changes to the guidelines implementing CEQA (CEQA Guidelines) (Cal. Code Regs., Title 14, Div. 6, Ch. 3,
15000 et seq.) regarding the analysis of transportation impacts. As one appellate court recently
explained: “During the last 10 years, the Legislature has charted a course of long-term sustainability
based on denser infill development, reduced reliance on individual vehicles and improved mass transit,
all with the goal of reducing greenhouse gas emissions. Section 21099 is part of that strategy . . . .”
Covina Residents for Responsible Development v. City of Covina (2018) 21 Cal.App.5th 712, 729.)
Pursuant to Section 21099, the criteria for determining the significance of transportation impacts must
promote the reduction of greenhouse gas emissions, the development of multimodal transportation
networks, and a diversity of land uses.” (Id., subd. (b)(1); see generally, adopted CEQA Guidelines, §
15064.3, subd. (b) [Criteria for Analyzing Transportation Impacts].) To that end, in developing the
criteria, OPR has proposed, and the California Natural Resources Agency (Agency) has certified and
adopted, changes to the CEQA Guidelines that identify vehicle miles traveled (VMT) as the most
appropriate metric to evaluate a project’s transportation impacts. With the California Natural Resources
Agency’s certification and adoption of the changes to the CEQA Guidelines, automobile delay, as
measured by “level of service” and other similar metrics, generally no longer constitutes a significant
environmental effect under CEQA. (Pub. Resources Code, § 21099, subd. (b)(3).)
This advisory contains technical recommendations regarding assessment of VMT, thresholds of
significance, and mitigation measures. Again, OPR provides this Technical Advisory as a resource for the
public to use at their discretion. OPR is not enforcing or attempting to enforce any part of the
recommendations contained herein. (Gov. Code, § 65035 [“It is not the intent of the Legislature to vest
in the Office of Planning and Research any direct operating or regulatory powers over land use, public
works, or other state, regional, or local projects or programs.”].)
This December 2018 technical advisory is an update to the advisory it published in April 2018. OPR will
continue to monitor implementation of these new provisions and may update or supplement this
advisory in response to new information and advancements in modeling and methods.
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December 2018
B. Background
VMT and Greenhouse Gas Emissions Reduction. Senate Bill 32 (Pavley, 2016) requires California to
reduce greenhouse gas (GHG) emissions 40 percent below 1990 levels by 2030, and Executive Order B-
16-12 provides a target of 80 percent below 1990 emissions levels for the transportation sector by 2050.
The transportation sector has three major means of reducing GHG emissions: increasing vehicle
efficiency, reducing fuel carbon content, and reducing the amount of vehicle travel. The California Air
Resources Board (CARB) has provided a path forward for achieving these emissions reductions from the
transportation sector in its 2016 Mobile Source Strategy. CARB determined that it will not be possible to
achieve the State’s 2030 and post-2030 emissions goals without reducing VMT growth. Further, in its
2018 Progress Report on California’s Sustainable Communities and Climate Protection Act, CARB found
that despite the State meeting its 2020 climate goals, “emissions from statewide passenger vehicle
travel per capita [have been] increasing and going in the wrong direction,” and “California cannot meet
its [long-term] climate goals without curbing growth in single-occupancy vehicle activity.”1 CARB also
found that “[w]ith emissions from the transportation sector continuing to rise despite increases in fuel
efficiency and decreases in the carbon content of fuel, California will not achieve the necessary
greenhouse gas emissions reductions to meet mandates for 2030 and beyond without significant
changes to how communities and transportation systems are planned, funded, and built.”2
Thus, to achieve the State’s long-term climate goals, California needs to reduce per capita VMT. This can
occur under CEQA through VMT mitigation. Half of California’s GHG emissions come from the
transportation sector3, therefore, reducing VMT is an effective climate strategy, which can also result in
co-benefits.4 Furthermore, without early VMT mitigation, the state may follow a path that meets GHG
targets in the early years, but finds itself poorly positioned to meet more stringent targets later. For
example, in absence of VMT analysis and mitigation in CEQA, lead agencies might rely upon verifiable
offsets for GHG mitigation, ignoring the longer-term climate change impacts resulting from land use
development and infrastructure investment decisions. As stated in CARB’s 2017 Scoping Plan:
California’s future climate strategy will require increased focus on integrated land use planning
to support livable, transit-connected communities, and conservation of agricultural and other
lands. Accommodating population and economic growth through travel- and energy-efficient
land use provides GHG-efficient growth, reducing GHGs from both transportation and building
energy use. GHGs can be further reduced at the project level through implementing energy-
efficient construction and travel demand management approaches.”5 (Id. at p. 102.)
1 California Air Resources Board (Nov. 2018) 2018 Progress Report on California’s Sustainable
Communities and Climate Protection Act, pp. 4, 5, available at
https://ww2.arb.ca.gov/sites/default/files/2018-11/Final2018Report_SB150_112618_02_Report.pdf.
2 Id., p. 28.
3 See https://ca50million.ca.gov/transportation/
4 Fang et al. (2017) Cutting Greenhouse Gas Emissions Is Only the Beginning: A Literature Review of the
Co-Benefits of Reducing Vehicle Miles Traveled.
5 California Air Resources Board (Nov. 2017) California’s 2017 Climate Change Scoping Plan, p. 102,
available at https://www.arb.ca.gov/cc/scopingplan/scoping_plan_2017.pdf.
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December 2018
In light of this, the 2017 Scoping Plan describes and quantifies VMT reductions needed to achieve our
long-term GHG emissions reduction goals, and specifically points to the need for statewide deployment
of the VMT metric in CEQA:
Employing VMT as the metric of transportation impact statewide will help to ensure GHG
reductions planned under SB 375 will be achieved through on-the-ground development, and will
also play an important role in creating the additional GHG reductions needed beyond SB 375
across the State. Implementation of this change will rely, in part, on local land use decisions to
reduce GHG emissions associated with the transportation sector, both at the project level, and
in long-term plans (including general plans, climate action plans, specific plans, and
transportation plans) and supporting sustainable community strategies developed under SB
375.”6
VMT and Other Impacts to Health and Environment. VMT mitigation also creates substantial benefits
sometimes characterized as “co-benefits” to GHG reduction) in both in the near-term and the long-
term. Beyond GHG emissions, increases in VMT also impact human health and the natural environment.
Human health is impacted as increases in vehicle travel lead to more vehicle crashes, poorer air quality,
increases in chronic diseases associated with reduced physical activity, and worse mental health.
Increases in vehicle travel also negatively affect other road users, including pedestrians, cyclists, other
motorists, and many transit users. The natural environment is impacted as higher VMT leads to more
collisions with wildlife and fragments habitat. Additionally, development that leads to more vehicle
travel also tends to consume more energy, water, and open space (including farmland and sensitive
habitat). This increase in impermeable surfaces raises the flood risk and pollutant transport into
waterways.7
VMT and Economic Growth. While it was previously believed that VMT growth was a necessary
component of economic growth, data from the past two decades shows that economic growth is
possible without a concomitant increase in VMT. (Figure 1.) Recent research shows that requiring
development projects to mitigate LOS may actually reduce accessibility to destinations and impede
economic growth.8,9
6 Id. at p. 76.
7 Fang et al. (2017) Cutting Greenhouse Gas Emissions Is Only the Beginning: A Literature Review of the
Co-Benefits of Reducing Vehicle Miles Traveled, available at https://ncst.ucdavis.edu/wp-
content/uploads/2017/03/NCST-VMT-Co-Benefits-White-Paper_Fang_March-2017.pdf.
8 Haynes et al. (Sept. 2015) Congested Development: A Study of Traffic Delays, Access, and Economic
Activity in Metropolitan Los Angeles, available at http://www.its.ucla.edu/wp-
content/uploads/sites/6/2015/11/Haynes_Congested-Development_1-Oct-2015_final.pdf.
9 Osman et al. (Mar. 2016) Not So Fast: A Study of Traffic Delays, Access, and Economic Activity in the
San Francisco Bay Area, available at http://www.its.ucla.edu/wp-
content/uploads/sites/6/2016/08/Taylor-Not-so-Fast-04-01-2016_final.pdf.
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December 2018
Figure 1. Kooshian and Winkelman (2011) VMT and Gross Domestic Product (GDP), 1960-2010.
C. Technical Considerations in Assessing Vehicle Miles Traveled
Many practitioners are familiar with accounting for VMT in connection with long-range planning, or as
part of the CEQA analysis of a project’s greenhouse gas emissions or energy impacts. This document
provides technical information on how to assess VMT as part of a transportation impacts analysis under
CEQA. Appendix 1 provides a description of which VMT to count and options on how to count it.
Appendix 2 provides information on induced travel resulting from roadway capacity projects, including
the mechanisms giving rise to induced travel, the research quantifying it, and information on additional
approaches for assessing it.
1. Recommendations Regarding Methodology
Proposed Section 15064.3 explains that a “lead agency may use models to estimate a project’s vehicle
miles traveled . . . .” CEQA generally defers to lead agencies on the choice of methodology to analyze
impacts. (Santa Monica Baykeeper v. City of Malibu (2011) 193 Cal.App.4th 1538, 1546; see Laurel
Heights Improvement Assn. v. Regents of University of California (1988) 47 Cal.3d 376, 409 [“the issue is
not whether the studies are irrefutable or whether they could have been better” … rather, the “relevant
issue is only whether the studies are sufficiently credible to be considered” as part of the lead agency’s
overall evaluation].) This section provides suggestions to lead agencies regarding methodologies to
analyze VMT associated with a project.
Vehicle Types. Proposed Section 15064.3, subdivision (a), states, “For the purposes of this section,
vehicle miles traveled’ refers to the amount and distance of automobile travel attributable to a
project.” Here, the term “automobile” refers to on-road passenger vehicles, specifically cars and light
trucks. Heavy-duty truck VMT could be included for modeling convenience and ease of calculation (for
example, where models or data provide combined auto and heavy truck VMT). For an apples-to-apples
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December 2018
comparison, vehicle types considered should be consistent across project assessment, significance
thresholds, and mitigation.
Residential and Office Projects. Tour- and trip-based approaches 10 offer the best methods for assessing
VMT from residential/office projects and for comparing those assessments to VMT thresholds. These
approaches also offer the most straightforward methods for assessing VMT reductions from mitigation
measures for residential/office projects. When available, tour-based assessment is ideal because it
captures travel behavior more comprehensively. But where tour-based tools or data are not available
for all components of an analysis, a trip-based assessment of VMT serves as a reasonable proxy.
Models and methodologies used to calculate thresholds, estimate project VMT, and estimate VMT
reduction due to mitigation should be comparable. For example:
A tour-based assessment of project VMT should be compared to a tour-based threshold, or a
trip-based assessment to a trip-based VMT threshold.
Where a travel demand model is used to determine thresholds, the same model should also be
used to provide trip lengths as part of assessing project VMT.
Where only trip-based estimates of VMT reduction from mitigation are available, a trip-based
threshold should be used, and project VMT should be assessed in a trip-based manner.
When a trip-based method is used to analyze a residential project, the focus can be on home-based
trips. Similarly, when a trip-based method is used to analyze an office project, the focus can be on
home-based work trips.
When tour-based models are used to analyze an office project, either employee work tour VMT or VMT
from all employee tours may be attributed to the project. This is because workplace location influences
overall travel. For consistency, the significance threshold should be based on the same metric: either
employee work tour VMT or VMT from all employee tours.
For office projects that feature a customer component, such as a government office that serves the
public, a lead agency can analyze the customer VMT component of the project using the methodology
for retail development (see below).
Retail Projects. Generally, lead agencies should analyze the effects of a retail project by assessing the
change in total VMT 11 because retail projects typically re-route travel from other retail destinations. A
retail project might lead to increases or decreases in VMT, depending on previously existing retail travel
patterns.
10 See Appendix 1, Considerations About Which VMT to Count, for a description of these approaches.
11 See Appendix 1, Considerations About Which VMT to Count, “Assessing Change in Total VMT” section,
for a description of this approach.
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December 2018
Considerations for All Projects. Lead agencies should not truncate any VMT analysis because of
jurisdictional or other boundaries, for example, by failing to count the portion of a trip that falls outside
the jurisdiction or by discounting the VMT from a trip that crosses a jurisdictional boundary. CEQA
requires environmental analyses to reflect a “good faith effort at full disclosure.” (CEQA Guidelines, §
15151.) Thus, where methodologies exist that can estimate the full extent of vehicle travel from a
project, the lead agency should apply them to do so. Where those VMT effects will grow over time,
analyses should consider both a project’s short-term and long-term effects on VMT.
Combining land uses for VMT analysis is not recommended. Different land uses generate different
amounts of VMT, so the outcome of such an analysis could depend more on the mix of uses than on
their travel efficiency. As a result, it could be difficult or impossible for a lead agency to connect a
significance threshold with an environmental policy objective (such as a target set by law), inhibiting the
CEQA imperative of identifying a project’s significant impacts and providing mitigation where feasible.
Combining land uses for a VMT analysis could streamline certain mixes of uses in a manner disconnected
from policy objectives or environmental outcomes. Instead, OPR recommends analyzing each use
separately, or simply focusing analysis on the dominant use, and comparing each result to the
appropriate threshold. Recommendations for methods of analysis and thresholds are provided below.
In the analysis of each use, a mixed-use project should take credit for internal capture.
Any project that includes in its geographic bounds a portion of an existing or planned Transit Priority
Area (i.e., the project is within a ½ mile of an existing or planned major transit stop or an existing stop
along a high quality transit corridor) may employ VMT as its primary metric of transportation impact for
the entire project. (See Pub. Resources Code, § 21099, subds. (a)(7), (b)(1).)
Cumulative Impacts. A project’s cumulative impacts are based on an assessment of whether the
incremental effects of an individual project are considerable when viewed in connection with the
effects of past projects, the effects of other current projects, and the effects of probable future
projects.” (Pub. Resources Code, § 21083, subd. (b)(2); see CEQA Guidelines, § 15064, subd. (h)(1).)
When using an absolute VMT metric, i.e., total VMT (as recommended below for retail and
transportation projects), analyzing the combined impacts for a cumulative impacts analysis may be
appropriate. However, metrics such as VMT per capita or VMT per employee, i.e., metrics framed in
terms of efficiency (as recommended below for use on residential and office projects), cannot be
summed because they employ a denominator. A project that falls below an efficiency-based threshold
that is aligned with long-term environmental goals and relevant plans would have no cumulative impact
distinct from the project impact. Accordingly, a finding of a less-than-significant project impact would
imply a less than significant cumulative impact, and vice versa. This is similar to the analysis typically
conducted for greenhouse gas emissions, air quality impacts, and impacts that utilize plan compliance as
a threshold of significance. (See Center for Biological Diversity v. Department of Fish & Wildlife (2015) 62
Cal.4th 204, 219, 223; CEQA Guidelines, § 15064, subd. (h)(3).)
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December 2018
D. General Principles to Guide Consideration of VMT
SB 743 directs OPR to establish specific “criteria for determining the significance of transportation
impacts of projects[.]” (Pub. Resources Code, § 21099, subd. (b)(1).) In establishing this criterion, OPR
was guided by the general principles contained within CEQA, the CEQA Guidelines, and applicable case
law.
To assist in the determination of significance, many lead agencies rely on “thresholds of significance.”
The CEQA Guidelines define a “threshold of significance” to mean “an identifiable quantitative,
qualitative 12 or performance level of a particular environmental effect, non-compliance with which
means the effect will normally be determined to be significant by the agency and compliance with
which means the effect normally will be determined to be less than significant.” (CEQA Guidelines, §
15064.7, subd. (a) (emphasis added).) Lead agencies have discretion to develop and adopt their own, or
rely on thresholds recommended by other agencies, “provided the decision of the lead agency to adopt
such thresholds is supported by substantial evidence.” (Id. at subd. (c); Save Cuyama Valley v. County of
Santa Barbara (2013) 213 Cal.App.4th 1059, 1068.) Substantial evidence means “enough relevant
information and reasonable inferences from this information that a fair argument can be made to
support a conclusion, even though other conclusions might also be reached.” (Id. at § 15384 (emphasis
added); Protect the Historic Amador Waterways v. Amador Water Agency (2004) 116 Cal.App.4th 1099,
1108-1109.)
Additionally, the analysis leading to the determination of significance need not be perfect. The CEQA
Guidelines describe the standard for adequacy of environmental analyses:
An EIR should be prepared with a sufficient degree of analysis to provide decision makers
with information which enables them to make a decision which intelligently takes
account of environmental consequences. An evaluation of the environmental effects of
a proposed project need not be exhaustive, but the sufficiency of an EIR is to be reviewed
in the light of what is reasonably feasible. Disagreement among experts does not make
an EIR inadequate, but the EIR should summarize the main points of disagreement among
the experts. The courts have looked not for perfection but for adequacy, completeness,
and a good faith effort at full disclosure.
CEQA Guidelines, § 15151 (emphasis added).)
These general principles guide OPR’s recommendations regarding thresholds of significance for VMT set
forth below.
12 Generally, qualitative analyses should only be conducted when methods do not exist for undertaking a
quantitative analysis.
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December 2018
E.Recommendations Regarding Significance Thresholds
As noted above, lead agencies have the discretion to set or apply their own thresholds of significance.
Center for Biological Diversity v. California Dept. of Fish & Wildlife (2015) 62 Cal.4th 204, 218-223 [lead
agency had discretion to use compliance with AB 32’s emissions goals as a significance threshold]; Save
Cuyama Valley v. County of Santa Barbara (2013) 213 Cal.App.4th at p. 1068.) However, Section 21099
of the Public Resources Code states that the criteria for determining the significance of transportation
impacts must promote: (1) reduction of greenhouse gas emissions; (2) development of multimodal
transportation networks; and (3) a diversity of land uses. It further directed OPR to prepare and develop
criteria for determining significance. (Pub. Resources Code, § 21099, subd. (b)(1).) This section provides
OPR’s suggested thresholds, as well as considerations for lead agencies that choose to adopt their own
thresholds.
The VMT metric can support the three statutory goals: “the reduction of greenhouse gas emissions, the
development of multimodal transportation networks, and a diversity of land uses.” (Pub. Resources
Code, § 21099, subd. (b)(1), emphasis added.) However, in order for it to promote and support all three,
lead agencies should select a significance threshold that aligns with state law on all three. State law
concerning the development of multimodal transportation networks and diversity of land uses requires
planning for and prioritizing increases in complete streets and infill development, but does not mandate
a particular depth of implementation that could translate into a particular threshold of significance.
Meanwhile, the State has clear quantitative targets for GHG emissions reduction set forth in law and
based on scientific consensus, and the depth of VMT reduction needed to achieve those targets has
been quantified. Tying VMT thresholds to GHG reduction also supports the two other statutory goals.
Therefore, to ensure adequate analysis of transportation impacts, OPR recommends using quantitative
VMT thresholds linked to GHG reduction targets when methods exist to do so.
Various legislative mandates and state policies establish quantitative greenhouse gas emissions
reduction targets. For example:
Assembly Bill 32 (2006) requires statewide GHG emissions reductions to 1990 levels by 2020 and
continued reductions beyond 2020.
Senate Bill 32 (2016) requires at least a 40 percent reduction in GHG emissions from 1990 levels
by 2030.
Pursuant to Senate Bill 375 (2008), the California Air Resources Board GHG emissions reduction
targets for metropolitan planning organizations (MPOs) to achieve based on land use patterns
and transportation systems specified in Regional Transportation Plans and Sustainable
Community Strategies (RTP/SCS). Current targets for the State’s largest MPOs call for a 19
percent reduction in GHG emissions from cars and light trucks from 2005 emissions levels by
2035.
Executive Order B-30-15 (2015) sets a GHG emissions reduction target of 40 percent below 1990
levels by 2030.
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Executive Order S-3-05 (2005) sets a GHG emissions reduction target of 80 percent below 1990
levels by 2050.
Executive Order B-16-12 (2012) specifies a GHG emissions reduction target of 80 percent below
1990 levels by 2050 specifically for transportation.
Executive Order B-55-18 (2018) established an additional statewide goal of achieving carbon
neutrality as soon as possible, but no later than 2045, and maintaining net negative emissions
thereafter. It states, “The California Air Resources Board shall work with relevant state agencies
to develop a framework for implementation and accounting that tracks progress toward this
goal.”
Senate Bill 391 requires the California Transportation Plan to support 80 percent reduction in
GHGs below 1990 levels by 2050.
The California Air Resources Board Mobile Source Strategy (2016) describes California’s strategy
for containing air pollutant emissions from vehicles, and quantifies VMT growth compatible with
achieving state targets.
The California Air Resources Board’s 2017 Climate Change Scoping Plan Update: The Strategy for
Achieving California’s 2030 Greenhouse Gas Target describes California’s strategy for containing
GHG emissions from vehicles, and quantifies VMT growth compatible with achieving state
targets.
Considering these various targets, the California Supreme Court observed:
Meeting our statewide reduction goals does not preclude all new development. Rather,
the Scoping Plan … assumes continued growth and depends on increased efficiency and
conservation in land use and transportation from all Californians.
Center for Biological Diversity v. California Dept. of Fish & Wildlife, supra, 62 Cal.4th at p. 220.) Indeed,
the Court noted that when a lead agency uses consistency with climate goals as a way to determine
significance, particularly for long-term projects, the lead agency must consider the project’s effect on
meeting long-term reduction goals. (Ibid.) And more recently, the Supreme Court stated that “CEQA
requires public agencies . . . to ensure that such analysis stay in step with evolving scientific knowledge
and state regulatory schemes.” (Cleveland National Forest Foundation v. San Diego Assn. of
Governments (2017) 3 Cal.5th 497, 504.)
Meeting the targets described above will require substantial reductions in existing VMT per capita to
curb GHG emissions and other pollutants. But targets for overall GHG emissions reduction do not
translate directly into VMT thresholds for individual projects for many reasons, including:
Some, but not all, of the emissions reductions needed to achieve those targets could be
accomplished by other measures, including increased vehicle efficiency and decreased fuel
carbon content. The CARB’s First Update to the Climate Change Scoping Plan explains:
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December 2018
Achieving California’s long-term criteria pollutant and GHG emissions goals will require four
strategies to be employed: (1) improve vehicle efficiency and develop zero emission
technologies, (2) reduce the carbon content of fuels and provide market support to get these
lower-carbon fuels into the marketplace, (3) plan and build communities to reduce vehicular
GHG emissions and provide more transportation options, and (4) improve the efficiency and
throughput of existing transportation systems.”13 CARB’s 2018 Progress Report on California’s
Sustainable Communities and Climate Protection Act states on page 28 that “California cannot
meet its climate goals without curbing growth in single-occupancy vehicle activity.” In other
words, vehicle efficiency and better fuels are necessary, but insufficient, to address the GHG
emissions from the transportation system. Land use patterns and transportation options also
will need to change to support reductions in vehicle travel/VMT.
New land use projects alone will not sufficiently reduce per-capita VMT to achieve those targets,
nor are they expected to be the sole source of VMT reduction.
Interactions between land use projects, and also between land use and transportation projects,
existing and future, together affect VMT.
Because location within the region is the most important determinant of VMT, in some cases,
streamlining CEQA review of projects in travel efficient locations may be the most effective
means of reducing VMT.
When assessing climate impacts of some types of land use projects, use of an efficiency metric
e.g., per capita, per employee) may provide a better measure of impact than an absolute
numeric threshold. (Center for Biological Diversity, supra.)
Public Resources Code section 21099 directs OPR to propose criteria for determining the significance of
transportation impacts. In this Technical Advisory, OPR provides its recommendations to assist lead
agencies in selecting a significance threshold that may be appropriate for their particular projects. While
OPR’s Technical Advisory is not binding on public agencies, CEQA allows lead agencies to “consider
thresholds of significance . . . recommended by other public agencies, provided the decision to adopt
those thresholds is supported by substantial evidence.” (CEQA Guidelines, § 15064.7, subd. (c).) Based
on OPR’s extensive review of the applicable research, and in light of an assessment by the California Air
Resources Board quantifying the need for VMT reduction in order to meet the State’s long-term climate
goals, OPR recommends that a per capita or per employee VMT that is fifteen percent below that of
existing development may be a reasonable threshold.
Fifteen percent reductions in VMT are achievable at the project level in a variety of place types.14
Moreover, a fifteen percent reduction is consistent with SB 743’s direction to OPR to select a threshold
that will help the State achieve its climate goals. As described above, section 21099 states that the
13 California Air Resources Board (May 2014) First Update to the Climate Change Scoping Plan, p. 46
emphasis added).
14 CAPCOA (2010) Quantifying Greenhouse Gas Mitigation Measures, p. 55, available at
http://www.capcoa.org/wp-content/uploads/2010/11/CAPCOA-Quantification-Report-9-14-Final.pdf.
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criteria for determining significance must “promote the reduction in greenhouse gas emissions.” In its
document California Air Resources Board 2017 Scoping Plan-Identified VMT Reductions and Relationship
to State Climate Goals 15, CARB assesses VMT reduction per capita consistent with its evidence-based
modeling scenario that would achieve State climate goals of 40 percent GHG emissions reduction from
1990 levels by 2030 and 80 percent GHG emissions reduction levels from 1990 by 2050. Applying
California Department of Finance population forecasts, CARB finds per-capita light-duty vehicle travel
would need to be approximately 16.8 percent lower than existing, and overall per-capita vehicle travel
would need to be approximately 14.3 percent lower than existing levels under that scenario. Below
these levels, a project could be considered low VMT and would, on that metric, be consistent with 2017
Scoping Plan Update assumptions that achieve climate state climate goals.
CARB finds per capita vehicle travel would need to be kept below what today’s policies and plans would
achieve.
CARB’s assessment is based on data in the 2017 Scoping Plan Update and 2016 Mobile Source Strategy.
In those documents, CARB previously examined the relationship between VMT and the state’s GHG
emissions reduction targets. The Scoping Plan finds:
While the State can do more to accelerate and incentivize these local decisions, local actions
that reduce VMT are also necessary to meet transportation sector-specific goals and achieve the
2030 target under SB 32. Through developing the Scoping Plan, CARB staff is more convinced
than ever that, in addition to achieving GHG reductions from cleaner fuels and vehicles,
California must also reduce VMT. Stronger SB 375 GHG reduction targets will enable the State to
make significant progress toward needed reductions, but alone will not provide the VMT growth
reductions needed; there is a gap between what SB 375 can provide and what is needed to meet
the State’s 2030 and 2050 goals.”16
Note that, at present, consistency with RTP/SCSs does not necessarily lead to a less-than-significant VMT
impact.17 As the Final 2017 Scoping Plan Update states,
VMT reductions are necessary to achieve the 2030 target and must be part of any strategy
evaluated in this Plan. Stronger SB 375 GHG reduction targets will enable the State to make
significant progress toward this goal, but alone will not provide all of the VMT growth reductions
that will be needed. There is a gap between what SB 375 can provide and what is needed to
meet the State’s 2030 and 2050 goals.”18
15 California Air Resources Board (Jan. 2019) California Air Resources Board 2017 Scoping Plan-Identified
VMT Reductions and Relationship to State Climate Goals, available at
https://ww2.arb.ca.gov/resources/documents/carb-2017-scoping-plan-identified-vmt-reductions-and-
relationship-state-climate.
16 California Air Resources Board (Nov. 2017) California’s 2017 Climate Change Scoping Plan, p. 101.
17 California Air Resources Board (Feb. 2018) Updated Final Staff Report: Proposed Update to the SB 375
Greenhouse Gas Emission Reduction Targets, Figure 3, p. 35, available at
https://www.arb.ca.gov/cc/sb375/sb375_target_update_final_staff_report_feb2018.pdf.
18 California Air Resources Board (Nov. 2017) California’s 2017 Climate Change Scoping Plan, p. 75.
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Also, in order to capture the full effects of induced travel resulting from roadway capacity projects, an
RTP/SCS would need to include an assessment of land use effects of those projects, and the effects of
those land uses on VMT. (See section titled “Estimating VMT Impacts from Transportation Projects”
below.) RTP/SCSs typically model VMT using a collaboratively-developed land use “vision” for the
region’s land use, rather than studying the effects on land use of the proposed transportation
investments.
In summary, achieving 15 percent lower per capita (residential) or per employee (office) VMT than
existing development is both generally achievable and is supported by evidence that connects this level
of reduction to the State’s emissions goals.
1. Screening Thresholds for Land Use Projects
Many agencies use “screening thresholds” to quickly identify when a project should be expected to
cause a less-than-significant impact without conducting a detailed study. (See e.g., CEQA Guidelines, §§
15063(c)(3)(C), 15128, and Appendix G.) As explained below, this technical advisory suggests that lead
agencies may screen out VMT impacts using project size, maps, transit availability, and provision of
affordable housing.
Screening Threshold for Small Projects
Many local agencies have developed screening thresholds to indicate when detailed analysis is needed.
Absent substantial evidence indicating that a project would generate a potentially significant level of
VMT, or inconsistency with a Sustainable Communities Strategy (SCS) or general plan, projects that
generate or attract fewer than 110 trips per day19 generally may be assumed to cause a less-than-
significant transportation impact.
Map-Based Screening for Residential and Office Projects
Residential and office projects that locate in areas with low VMT, and that incorporate similar features
i.e., density, mix of uses, transit accessibility), will tend to exhibit similarly low VMT. Maps created with
VMT data, for example from a travel survey or a travel demand model, can illustrate areas that are
19 CEQA provides a categorical exemption for existing facilities, including additions to existing structures
of up to 10,000 square feet, so long as the project is in an area where public infrastructure is available to
allow for maximum planned development and the project is not in an environmentally sensitive area.
CEQA Guidelines, § 15301, subd. (e)(2).) Typical project types for which trip generation increases
relatively linearly with building footprint (i.e., general office building, single tenant office building, office
park, and business park) generate or attract an additional 110-124 trips per 10,000 square feet.
Therefore, absent substantial evidence otherwise, it is reasonable to conclude that the addition of 110
or fewer trips could be considered not to lead to a significant impact.
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December 2018
currently below threshold VMT (see recommendations below). Because new development in such
locations would likely result in a similar level of VMT, such maps can be used to screen out residential
and office projects from needing to prepare a detailed VMT analysis.
Figure 2. Example map of household VMT that could be used to
delineate areas eligible to receive streamlining for VMT analysis.
Source: City of San José, Department of Transportation, draft output of
City Transportation Model.)
Presumption of Less Than Significant Impact Near Transit Stations
Proposed CEQA Guideline Section 15064.3, subdivision (b)(1), states that lead agencies generally should
presume that certain projects (including residential, retail, and office projects, as well as projects that
are a mix of these uses) proposed within ½ mile of an existing major transit stop20 or an existing stop
20 Pub. Resources Code, § 21064.3 (“‘Major transit stop’ means a site containing an existing rail transit
station, a ferry terminal served by either a bus or rail transit service, or the intersection of two or more
major bus routes with a frequency of service interval of 15 minutes or less during the morning and
afternoon peak commute periods.”).
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along a high quality transit corridor21 will have a less-than-significant impact on VMT. This presumption
would not apply, however, if project-specific or location-specific information indicates that the project
will still generate significant levels of VMT. For example, the presumption might not be appropriate if
the project:
Has a Floor Area Ratio (FAR) of less than 0.75
Includes more parking for use by residents, customers, or employees of the project than
required by the jurisdiction (if the jurisdiction requires the project to supply parking)
Is inconsistent with the applicable Sustainable Communities Strategy (as determined by the lead
agency, with input from the Metropolitan Planning Organization)
Replaces affordable residential units with a smaller number of moderate- or high-income
residential units
A project or plan near transit which replaces affordable residential units22 with a smaller number of
moderate- or high-income residential units may increase overall VMT because the increase in VMT of
displaced residents could overwhelm the improvements in travel efficiency enjoyed by new residents.23
If any of these exceptions to the presumption might apply, the lead agency should conduct a detailed
VMT analysis to determine whether the project would exceed VMT thresholds (see below).
Presumption of Less Than Significant Impact for Affordable Residential Development
Adding affordable housing to infill locations generally improves jobs-housing match, in turn shortening
commutes and reducing VMT.24,25 Further, “… low-wage workers in particular would be more likely to
choose a residential location close to their workplace, if one is available.”26 In areas where existing jobs-
housing match is closer to optimal, low income housing nevertheless generates less VMT than market-
21 Pub. Resources Code, § 21155 (“For purposes of this section, a high-quality transit corridor means a
corridor with fixed route bus service with service intervals no longer than 15 minutes during peak
commute hours.”).
22 Including naturally-occurring affordable residential units.
23 Chapple et al. (2017) Developing a New Methodology for Analyzing Potential Displacement, Chapter 4,
pp. 159-160, available at https://www.arb.ca.gov/research/apr/past/13-310.pdf.
24 Karner and Benner (2016) The convergence of social equity and environmental sustainability: Jobs-
housing fit and commute distance (“[P]olicies that advance a more equitable distribution of jobs and
housing by linking the affordability of locally available housing with local wage levels are likely to be
associated with reduced commuting distances”).
25 Karner and Benner (2015) Low-wage jobs-housing fit: identifying locations of affordable housing
shortages.
26 Karner and Benner (2015) Low-wage jobs-housing fit: identifying locations of affordable housing
shortages.
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rate housing.27,28 Therefore, a project consisting of a high percentage of affordable housing may be a
basis for the lead agency to find a less-than-significant impact on VMT. Evidence supports a
presumption of less than significant impact for a 100 percent affordable residential development (or the
residential component of a mixed-use development) in infill locations. Lead agencies may develop their
own presumption of less than significant impact for residential projects (or residential portions of mixed
use projects) containing a particular amount of affordable housing, based on local circumstances and
evidence. Furthermore, a project which includes any affordable residential units may factor the effect
of the affordability on VMT into the assessment of VMT generated by those units.
2.Recommended Numeric Thresholds for Residential, Office, and Retail
Projects
Recommended threshold for residential projects: A proposed project exceeding a level of 15
percent below existing VMT per capita may indicate a significant transportation impact. Existing
VMT per capita may be measured as regional VMT per capita or as city VMT per capita. Proposed
development referencing a threshold based on city VMT per capita (rather than regional VMT per
capita) should not cumulatively exceed the number of units specified in the SCS for that city, and
should be consistent with the SCS.
Residential development that would generate vehicle travel that is 15 or more percent below the
existing residential VMT per capita, measured against the region or city, may indicate a less-than-
significant transportation impact. In MPO areas, development measured against city VMT per capita
rather than regional VMT per capita) should not cumulatively exceed the population or number of units
specified in the SCS for that city because greater-than-planned amounts of development in areas above
the region-based threshold would undermine the VMT containment needed to achieve regional targets
under SB 375.
For residential projects in unincorporated county areas, the local agency can compare a residential
project’s VMT to (1) the region’s VMT per capita, or (2) the aggregate population-weighted VMT per
capita of all cities in the region. In MPO areas, development in unincorporated areas measured against
aggregate city VMT per capita (rather than regional VMT per capita) should not cumulatively exceed the
population or number of units specified in the SCS for that city because greater-than-planned amounts
of development in areas above the regional threshold would undermine achievement of regional targets
under SB 375.
27 Chapple et al. (2017) Developing a New Methodology for Analyzing Potential Displacement, available
at https://www.arb.ca.gov/research/apr/past/13-310.pdf.
28 CAPCOA (2010) Quantifying Greenhouse Gas Mitigation Measures, pp. 176-178, available at
http://www.capcoa.org/wp-content/uploads/2010/11/CAPCOA-Quantification-Report-9-14-Final.pdf.
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These thresholds can be applied to either household (i.e., tour-based) VMT or home-based (i.e., trip-
based) VMT assessments.29 It is critical, however, that the agency be consistent in its VMT measurement
approach throughout the analysis to maintain an “apples-to-apples” comparison. For example, if the
agency uses a home-based VMT for the threshold, it should also be use home-based VMT for calculating
project VMT and VMT reduction due to mitigation measures.
Because new retail development typically redistributes shopping trips rather than creating new trips,30
estimating the total change in VMT (i.e., the difference in total VMT in the area affected with and
without the project) is the best way to analyze a retail project’s transportation impacts.
By adding retail opportunities into the urban fabric and thereby improving retail destination proximity,
local-serving retail development tends to shorten trips and reduce VMT. Thus, lead agencies generally
may presume such development creates a less-than-significant transportation impact. Regional-serving
retail development, on the other hand, which can lead to substitution of longer trips for shorter ones,
may tend to have a significant impact. Where such development decreases VMT, lead agencies should
consider the impact to be less-than-significant.
Many cities and counties define local-serving and regional-serving retail in their zoning codes. Lead
agencies may refer to those local definitions when available, but should also consider any project-
29 See Appendix 1 for a description of these approaches.
30 Lovejoy, et al. (2013) Measuring the impacts of local land-use policies on vehicle miles of travel:
The case of the first big-box store in Davis, California, The Journal of Transport and Land Use.
Recommended threshold for retail projects: A net increase in total VMT may indicate a significant
transportation impact.
Office projects that would generate vehicle travel exceeding 15 percent below existing VMT per
employee for the region may indicate a significant transportation impact. In cases where the region is
substantially larger than the geography over which most workers would be expected to live, it might be
appropriate to refer to a smaller geography, such as the county, that includes the area over which nearly
all workers would be expected to live.
Office VMT screening maps can be developed using tour-based data, considering either total employee
VMT or employee work tour VMT. Similarly, tour-based analysis of office project VMT could consider
either total employee VMT or employee work tour VMT. Where tour-based information is unavailable
for threshold determination, project assessment, or assessment of mitigation, home-based work trip
VMT should be used throughout all steps of the analysis to maintain an “apples-to-apples” comparison.
Recommended threshold for office projects: A proposed project exceeding a level of 15 percent
below existing regional VMT per employee may indicate a significant transportation impact.
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specific information, such as market studies or economic impacts analyses that might bear on
customers’ travel behavior. Because lead agencies will best understand their own communities and the
likely travel behaviors of future project users, they are likely in the best position to decide when a
project will likely be local-serving. Generally, however, retail development including stores larger than
50,000 square feet might be considered regional-serving, and so lead agencies should undertake an
analysis to determine whether the project might increase or decrease VMT.
Mixed-Use Projects
Lead agencies can evaluate each component of a mixed-use project independently and apply the
significance threshold for each project type included (e.g., residential and retail). Alternatively, a lead
agency may consider only the project’s dominant use. In the analysis of each use, a project should take
credit for internal capture. Combining different land uses and applying one threshold to those land uses
may result in an inaccurate impact assessment.
Other Project Types
Of land use projects, residential, office, and retail projects tend to have the greatest influence on VMT.
For that reason, OPR recommends the quantified thresholds described above for purposes of analysis
and mitigation. Lead agencies, using more location-specific information, may develop their own more
specific thresholds, which may include other land use types. In developing thresholds for other project
types, or thresholds different from those recommended here, lead agencies should consider the
purposes described in section 21099 of the Public Resources Code and regulations in the CEQA
Guidelines on the development of thresholds of significance (e.g., CEQA Guidelines, § 15064.7).
Strategies and projects that decrease local VMT but increase total VMT should be avoided. Agencies
should consider whether their actions encourage development in a less travel-efficient location by
limiting development in travel-efficient locations.
Redevelopment Projects
Where a project replaces existing VMT-generating land uses, if the replacement leads to a net overall
decrease in VMT, the project would lead to a less-than-significant transportation impact. If the project
leads to a net overall increase in VMT, then the thresholds described above should apply.
As described above, a project or plan near transit which replaces affordable 31 residential units with a
smaller number of moderate- or high-income residential units may increase overall VMT, because
31 Including naturally-occurring affordable residential units.
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displaced residents’ VMT may increase.32 A lead agency should analyze VMT for such a project even if it
otherwise would have been presumed less than significant. The assessment should incorporate an
estimate of the aggregate VMT increase experienced by displaced residents. That additional VMT
should be included in the numerator of the VMT per capita assessed for the project.
If a residential or office project leads to a net increase in VMT, then the project’s VMT per capita
residential) or per employee (office) should be compared to thresholds recommended above. Per
capita and per employee VMT are efficiency metrics, and, as such, apply only to the existing project
without regard to the VMT generated by the previously existing land use.
If the project leads to a net increase in provision of locally-serving retail, transportation impacts from
the retail portion of the development should be presumed to be less than significant. If the project
consists of regionally-serving retail, and increases overall VMT compared to with existing uses, then the
project would lead to a significant transportation impact.
RTP/SCS Consistency (All Land Use Projects)
Section 15125, subdivision (d), of the CEQA Guidelines provides that lead agencies should analyze
impacts resulting from inconsistencies with regional plans, including regional transportation plans. For
this reason, if a project is inconsistent with the Regional Transportation Plan and Sustainable
Communities Strategy (RTP/SCS), the lead agency should evaluate whether that inconsistency indicates
a significant impact on transportation. For example, a development may be inconsistent with an
RTP/SCS if the development is outside the footprint of development or within an area specified as open
space as shown in the SCS.
3. Recommendations Regarding Land Use Plans
As with projects, agencies should analyze VMT outcomes of land use plans across the full area over
which the plan may substantively affect travel patterns, including beyond the boundary of the plan or
jurisdiction’s geography. And as with projects, VMT should be counted in full rather than split between
origin and destination. (Emissions inventories have sometimes spit cross-boundary trips in order to sum
to a regional total, but CEQA requires accounting for the full impact without truncation or discounting).
Analysis of specific plans may employ the same thresholds described above for projects. A general plan,
area plan, or community plan may have a significant impact on transportation if proposed new
residential, office, or retail land uses would in aggregate exceed the respective thresholds
recommended above. Where the lead agency tiers from a general plan EIR pursuant to CEQA Guidelines
sections 15152 and 15166, the lead agency generally focuses on the environmental impacts that are
specific to the later project and were not analyzed as significant impacts in the prior EIR. (Pub. Resources
Code, § 21068.5; Guidelines, § 15152, subd. (a).) Thus, in analyzing the later project, the lead agency
32 Chapple et al. (2017) Developing a New Methodology for Analyzing Potential Displacement, Chapter 4,
pp. 159-160, available at https://www.arb.ca.gov/research/apr/past/13-310.pdf.
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would focus on the VMT impacts that were not adequately addressed in the prior EIR. In the tiered
document, the lead agency should continue to apply the thresholds recommended above.
Thresholds for plans in non-MPO areas may be determined on a case-by-case basis.
4. Other Considerations
Rural Projects Outside of MPOs
In rural areas of non-MPO counties (i.e., areas not near established or incorporated cities or towns),
fewer options may be available for reducing VMT, and significance thresholds may be best determined
on a case-by-case basis. Note, however, that clustered small towns and small town main streets may
have substantial VMT benefits compared to isolated rural development, similar to the transit oriented
development described above.
Impacts to Transit
Because criteria for determining the significance of transportation impacts must promote “the
development of multimodal transportation networks” pursuant to Public Resources Code section 21099,
subd. (b)(1), lead agencies should consider project impacts to transit systems and bicycle and pedestrian
networks. For example, a project that blocks access to a transit stop or blocks a transit route itself may
interfere with transit functions. Lead agencies should consult with transit agencies as early as possible in
the development process, particularly for projects that are located within one half mile of transit stops.
When evaluating impacts to multimodal transportation networks, lead agencies generally should not
treat the addition of new transit users as an adverse impact. An infill development may add riders to
transit systems and the additional boarding and alighting may slow transit vehicles, but it also adds
destinations, improving proximity and accessibility. Such development also improves regional vehicle
flow by adding less vehicle travel onto the regional network.
Increased demand throughout a region may, however, cause a cumulative impact by requiring new or
additional transit infrastructure. Such impacts may be adequately addressed through a fee program that
fairly allocates the cost of improvements not just to projects that happen to locate near transit, but
rather across a region to all projects that impose burdens on the entire transportation system, since
transit can broadly improve the function of the transportation system.
F. Considering the Effects of Transportation Projects on Vehicle Travel
Many transportation projects change travel patterns. A transportation project which leads to additional
vehicle travel on the roadway network, commonly referred to as “induced vehicle travel,” would need to
quantify the amount of additional vehicle travel in order to assess air quality impacts, greenhouse gas
emissions impacts, energy impacts, and noise impacts. Transportation projects also are required to
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examine induced growth impacts under CEQA. (See generally, Pub. Resources Code, §§ 21065 [defining
project” under CEQA as an activity as causing either a direct or reasonably foreseeable indirect physical
change], 21065.3 [defining “project-specific effect” to mean all direct or indirect environmental effects],
21100, subd. (b) [required contents of an EIR].) For any project that increases vehicle travel, explicit
assessment and quantitative reporting of the amount of additional vehicle travel should not be omitted
from the document; such information may be useful and necessary for a full understanding of a project’s
environmental impacts. (See Pub. Resources Code, §§ 21000, 21001, 21001.1, 21002, 21002.1
discussing the policies of CEQA].) A lead agency that uses the VMT metric to assess the transportation
impacts of a transportation project may simply report that change in VMT as the impact. When the lead
agency uses another metric to analyze the transportation impacts of a roadway project, changes in
amount of vehicle travel added to the roadway network should still be analyzed and reported.33
While CEQA does not require perfection, it is important to make a reasonably accurate estimate of
transportation projects’ effects on vehicle travel in order to make reasonably accurate estimates of GHG
emissions, air quality emissions, energy impacts, and noise impacts. (See, e.g., California Clean Energy
Com. v. City of Woodland (2014) 225 Cal.App.4th 173, 210 [EIR failed to consider project’s
transportation energy impacts]; Ukiah Citizens for Safety First v. City of Ukiah (2016) 248 Cal.App.4th
256, 266.) Appendix 2 describes in detail the causes of induced vehicle travel, the robust empirical
evidence of induced vehicle travel, and how models and research can be used in conjunction to
quantitatively assess induced vehicle travel with reasonable accuracy.
If a project would likely lead to a measurable and substantial increase in vehicle travel, the lead agency
should conduct an analysis assessing the amount of vehicle travel the project will induce. Project types
that would likely lead to a measurable and substantial increase in vehicle travel generally include:
Addition of through lanes on existing or new highways, including general purpose lanes, HOV
lanes, peak period lanes, auxiliary lanes, or lanes through grade-separated interchanges
Projects that would not likely lead to a substantial or measurable increase in vehicle travel, and
therefore generally should not require an induced travel analysis, include:
Rehabilitation, maintenance, replacement, safety, and repair projects designed to improve the
condition of existing transportation assets (e.g., highways; roadways; bridges; culverts;
Transportation Management System field elements such as cameras, message signs, detection,
or signals; tunnels; transit systems; and assets that serve bicycle and pedestrian facilities) and
that do not add additional motor vehicle capacity
Roadside safety devices or hardware installation such as median barriers and guardrails
33 See, e.g., California Department of Transportation (2006) Guidance for Preparers of Growth-related,
Indirect Impact Analyses, available at http://www.dot.ca.gov/ser/Growth-
related_IndirectImpactAnalysis/GRI_guidance06May_files/gri_guidance.pdf.
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Roadway shoulder enhancements to provide “breakdown space,” dedicated space for use only
by transit vehicles, to provide bicycle access, or to otherwise improve safety, but which will not
be used as automobile vehicle travel lanes
Addition of an auxiliary lane of less than one mile in length designed to improve roadway safety
Installation, removal, or reconfiguration of traffic lanes that are not for through traffic, such as
left, right, and U-turn pockets, two-way left turn lanes, or emergency breakdown lanes that are
not utilized as through lanes
Addition of roadway capacity on local or collector streets provided the project also substantially
improves conditions for pedestrians, cyclists, and, if applicable, transit
Conversion of existing general purpose lanes (including ramps) to managed lanes or transit
lanes, or changing lane management in a manner that would not substantially increase vehicle
travel
Addition of a new lane that is permanently restricted to use only by transit vehicles
Reduction in number of through lanes
Grade separation to separate vehicles from rail, transit, pedestrians or bicycles, or to replace a
lane in order to separate preferential vehicles (e.g., HOV, HOT, or trucks) from general vehicles
Installation, removal, or reconfiguration of traffic control devices, including Transit Signal
Priority (TSP) features
Installation of traffic metering systems, detection systems, cameras, changeable message signs
and other electronics designed to optimize vehicle, bicycle, or pedestrian flow
Timing of signals to optimize vehicle, bicycle, or pedestrian flow
Installation of roundabouts or traffic circles
Installation or reconfiguration of traffic calming devices
Adoption of or increase in tolls
Addition of tolled lanes, where tolls are sufficient to mitigate VMT increase
Initiation of new transit service
Conversion of streets from one-way to two-way operation with no net increase in number of
traffic lanes
Removal or relocation of off-street or on-street parking spaces
Adoption or modification of on-street parking or loading restrictions (including meters, time
limits, accessible spaces, and preferential/reserved parking permit programs)
Addition of traffic wayfinding signage
Rehabilitation and maintenance projects that do not add motor vehicle capacity
Addition of new or enhanced bike or pedestrian facilities on existing streets/highways or within
existing public rights-of-way
Addition of Class I bike paths, trails, multi-use paths, or other off-road facilities that serve non-
motorized travel
Installation of publicly available alternative fuel/charging infrastructure
Addition of passing lanes, truck climbing lanes, or truck brake-check lanes in rural areas that do
not increase overall vehicle capacity along the corridor
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1. Recommended Significance Threshold for Transportation Projects
As noted in Section 15064.3 of the CEQA Guidelines, lead agencies for roadway capacity projects have
discretion, consistent with CEQA and planning requirements, to choose which metric to use to evaluate
transportation impacts. This section recommends considerations for evaluating impacts using vehicle
miles traveled. Lead agencies have discretion to choose a threshold of significance for transportation
projects as they do for other types of projects. As explained above, Public Resources Code section
21099, subdivision (b)(1), provides that criteria for determining the significance of transportation
impacts must promote the reduction of greenhouse gas emissions, the development of multimodal
transportation networks, and a diversity of land uses. (Id.; see generally, adopted CEQA Guidelines, §
15064.3, subd. (b) [Criteria for Analyzing Transportation Impacts].) With those goals in mind, OPR
prepared and the Agency adopted an appropriate transportation metric.
Whether adopting a threshold of significance, or evaluating transportation impacts on a case-by-case
basis, a lead agency should ensure that the analysis addresses:
Direct, indirect and cumulative effects of the transportation project (CEQA Guidelines, § 15064,
subds. (d), (h))
Near-term and long-term effects of the transportation project (CEQA Guidelines, §§ 15063,
subd. (a)(1), 15126.2, subd. (a))
The transportation project’s consistency with state greenhouse gas reduction goals (Pub.
Resources Code, § 21099)34
The impact of the transportation project on the development of multimodal transportation
networks (Pub. Resources Code, § 21099)
The impact of the transportation project on the development of a diversity of land uses (Pub.
Resources Code, § 21099)
The CARB Scoping Plan and the CARB Mobile Source Strategy delineate VMT levels required to achieve
legally mandated GHG emissions reduction targets. A lead agency should develop a project-level
threshold based on those VMT levels, and may apply the following approach:
1. Propose a fair-share allocation of those budgets to their jurisdiction (e.g., by population);
34 The California Air Resources Board has ascertained the limits of VMT growth compatible with
California containing greenhouse gas emissions to levels research shows would allow for climate
stabilization. (See The 2017 Climate Change Scoping Plan: The Strategy for Achieving California’s 2030
Greenhouse Gas Target (p. 78, p. 101); Mobile Source Strategy (p. 37).) CARB’s Updated Final Staff
Report on Proposed Update to the SB 375 Greenhouse Gas Emission Reduction Targets illustrates that
the current Regional Transportation Plans and Sustainable Communities Strategies will fall short of
achieving the necessary on-road transportation-related GHG emissions reductions called for in the 2017
Scoping Plan (Figure 3, p. 35). Accordingly, OPR recommends not basing GHG emissions or
transportation impact analysis for a transportation project solely on consistency with an RTP/SCS.
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2. Determine the amount of VMT growth likely to result from background population growth, and
subtract that from their “budget”;
3. Allocate their jurisdiction’s share between their various VMT-increasing transportation projects,
using whatever criteria the lead agency prefers.
2. Estimating VMT Impacts from Transportation Projects
CEQA requires analysis of a project’s potential growth-inducing impacts. (Pub. Resources Code, § 21100,
subd. (b)(5); CEQA Guidelines, § 15126.2, subd. (d).) Many agencies are familiar with the analysis of
growth inducing impacts associated with water, sewer, and other infrastructure. This technical advisory
addresses growth that may be expected from roadway expansion projects.
Because a roadway expansion project can induce substantial VMT, incorporating quantitative estimates
of induced VMT is critical to calculating both transportation and other impacts of these projects.
Induced travel also has the potential to reduce or eliminate congestion relief benefits. An accurate
estimate of induced travel is needed to accurately weigh costs and benefits of a highway capacity
expansion project.
The effect of a transportation project on vehicle travel should be estimated using the “change in total
VMT” method described in Appendix 1. This means that an assessment of total VMT without the project
and an assessment with the project should be made; the difference between the two is the amount of
VMT attributable to the project. The assessment should cover the full area in which driving patterns are
expected to change. As with other types of projects, the VMT estimation should not be truncated at a
modeling or jurisdictional boundary for convenience of analysis when travel behavior is substantially
affected beyond that boundary.
Transit and Active Transportation Projects
Transit and active transportation projects generally reduce VMT and therefore are presumed to cause a
less-than-significant impact on transportation. This presumption may apply to all passenger rail projects,
bus and bus rapid transit projects, and bicycle and pedestrian infrastructure projects. Streamlining
transit and active transportation projects aligns with each of the three statutory goals contained in SB
743 by reducing GHG emissions, increasing multimodal transportation networks, and facilitating mixed
use development.
Roadway Projects
Reducing roadway capacity (for example, by removing or repurposing motor vehicle travel lanes) will
generally reduce VMT and therefore is presumed to cause a less-than-significant impact on
transportation. Generally, no transportation analysis is needed for such projects.
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December 2018
Building new roadways, adding roadway capacity in congested areas, or adding roadway capacity to
areas where congestion is expected in the future, typically induces additional vehicle travel. For the
types of projects previously indicated as likely to lead to additional vehicle travel, an estimate should be
made of the change in vehicle travel resulting from the project.
For projects that increase roadway capacity, lead agencies can evaluate induced travel quantitatively by
applying the results of existing studies that examine the magnitude of the increase of VMT resulting
from a given increase in lane miles. These studies estimate the percent change in VMT for every percent
change in miles to the roadway system (i.e., “elasticity”).35 Given that lead agencies have discretion in
choosing their methodology, and the studies on induced travel reveal a range of elasticities, lead
agencies may appropriately apply professional judgment in studying the transportation effects of a
particular project. The most recent major study, estimates an elasticity of 1.0, meaning that every
percent change in lane miles results in a one percent increase in VMT.36
To estimate VMT impacts from roadway expansion projects:
1. Determine the total lane-miles over an area that fully captures travel behavior changes
resulting from the project (generally the region, but for projects affecting interregional travel
look at all affected regions).
2. Determine the percent change in total lane miles that will result from the project.
3. Determine the total existing VMT over that same area.
4. Multiply the percent increase in lane miles by the existing VMT, and then multiply that by the
elasticity from the induced travel literature:
increase in lane miles] x [existing VMT] x [elasticity] = [VMT resulting from the project]
A National Center for Sustainable Transportation tool can be used to apply this method:
https://ncst.ucdavis.edu/research/tools
This method would not be suitable for rural (non-MPO) locations in the state which are neither
congested nor projected to become congested. It also may not be suitable for a new road that provides
new connectivity across a barrier (e.g., a bridge across a river) if it would be expected to substantially
35 See U.C. Davis, Institute for Transportation Studies (Oct. 2015) Increasing Highway Capacity Unlikely
to Relieve Traffic Congestion; Boarnet and Handy (Sept. 2014) Impact of Highway Capacity and Induced
Travel on Passenger Vehicle Use and Greenhouse Gas Emissions, California Air Resources Board Policy
Brief, available at https://www.arb.ca.gov/cc/sb375/policies/hwycapacity/highway_capacity_brief.pdf.
36 See Duranton and Turner (2011) The Fundamental Law of Road Congestion: Evidence from US cities,
available at http://www.nber.org/papers/w15376.
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shorten existing trips. If it is likely to be substantial, the trips-shortening effect should be examined
explicitly.
The effects of roadway capacity on vehicle travel can also be applied at a programmatic level. For
example, in a regional planning process the lead agency can use that program-level analysis to
streamline later project-level analysis. (See CEQA Guidelines, § 15168.) A program-level analysis of VMT
should include effects of the program on land use patterns, and the VMT that results from those land
use effects. In order for a program-level document to adequately analyze potential induced demand
from a project or program of roadway capacity expansion, lead agencies cannot assume a fixed land use
pattern (i.e., a land use pattern that does not vary in response to the provision of roadway capacity). A
proper analysis should account for land use investment and development pattern changes that react in a
reasonable manner to changes in accessibility created by transportation infrastructure investments
whether at the project or program level).
Mitigation and Alternatives
Induced VMT has the potential to reduce or eliminate congestion relief benefits, increase VMT, and
increase other environmental impacts that result from vehicle travel.37 If those effects are significant,
the lead agency will need to consider mitigation or alternatives. In the context of increased travel that is
induced by capacity increases, appropriate mitigation and alternatives that a lead agency might consider
include the following:
Tolling new lanes to encourage carpools and fund transit improvements
Converting existing general purpose lanes to HOV or HOT lanes
Implementing or funding off-site travel demand management
Implementing Intelligent Transportation Systems (ITS) strategies to improve passenger
throughput on existing lanes
Tolling and other management strategies can have the additional benefit of preventing congestion and
maintaining free-flow conditions, conferring substantial benefits to road users as discussed above.
G. Analyzing Other Impacts Related to Transportation
While requiring a change in the methodology of assessing transportation im pacts, Public Resources
Code section 21099 notes that this change “does not relieve a public agency of the requirement to
analyze a project’s potentially significant transportation impacts related to air quality, noise, safety, or
any other impact associated with transportation.” OPR expects that lead agencies will continue to
37 See National Center for Sustainable Transportation (Oct. 2015) Increasing Highway Capacity Unlikely
to Relieve Traffic Congestion, available at
http://www.dot.ca.gov/newtech/researchreports/reports/2015/10-12-2015-
NCST_Brief_InducedTravel_CS6_v3.pdf; see Duranton and Turner (2011) The Fundamental Law of Road
Congestion: Evidence from US cities, available at http://www.nber.org/papers/w15376.
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December 2018
address mobile source emissions in the air quality and noise sections of an environmental document and
the corresponding studies that support the analysis in those sections. Lead agencies should continue to
address environmental impacts of a proposed project pursuant to CEQA’s requirements, using a format
that is appropriate for their particular project.
Because safety concerns result from many different factors, they are best addressed at a programmatic
level (i.e., in a general plan or regional transportation plan) in cooperation with local governments,
metropolitan planning organizations, and, where the state highway system is involved, the California
Department of Transportation. In most cases, such an analysis would not be appropriate on a project-
by-project basis. Increases in traffic volumes at a particular location resulting from a project typically
cannot be estimated with sufficient accuracy or precision to provide useful information for an analysis of
safety concerns. Moreover, an array of factors affect travel demand (e.g., strength of the local economy,
price of gasoline), causing substantial additional uncertainty. Appendix B of OPR’s General Plan
Guidelines summarizes research which could be used to guide a programmatic analysis under CEQA.
Lead agencies should note that automobile congestion or delay does not constitute a significant
environmental impact (Pub. Resources Code, §21099(b)(2)), and safety should not be used as a proxy for
road capacity.
H. VMT Mitigation and Alternatives
When a lead agency identifies a significant impact, it must identify feasible mitigation measures that
could avoid or substantially reduce that impact. (Pub. Resources Code, § 21002.1, subd. (a).)
Additionally, CEQA requires that an environmental impact report identify feasible alternatives that could
avoid or substantially reduce a project’s significant environmental impacts.
Indeed, the California Court of Appeal recently held that a long-term regional transportation plan was
deficient for failing to discuss an alternative which could significantly reduce total vehicle miles traveled.
In Cleveland National Forest Foundation v. San Diego Association of Governments, et al. (2017) 17
Cal.App.5th 413, the court found that omission “inexplicable” given the lead agency’s “acknowledgment
in its Climate Action Strategy that the state’s efforts to reduce greenhouse gas emissions from on-road
transportation will not succeed if the amount of driving, or vehicle miles traveled, is not significantly
reduced.” (Cleveland National Forest Foundation, supra, 17 Cal.App.5th at p. 436.) Additionally, the
court noted that the project alternatives focused primarily on congestion relief even though “the
regional] transportation plan is a long-term and congestion relief is not necessarily an effective long-
term strategy.” (Id. at p. 437.) The court concluded its discussion of the alternatives analysis by stating:
Given the acknowledged long-term drawbacks of congestion relief alternatives, there is not substantial
evidence to support the EIR’s exclusion of an alternative focused primarily on significantly reducing
vehicle trips.” (Ibid.)
Several examples of potential mitigation measures and alternatives to reduce VMT are described below.
However, the selection of particular mitigation measures and alternatives are left to the discretion of
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the lead agency, and mitigation measures may vary, depending on the proposed project and significant
impacts, if any. Further, OPR expects that agencies will continue to innovate and find new ways to
reduce vehicular travel.
Potential measures to reduce vehicle miles traveled include, but are not limited to:
Improve or increase access to transit.
Increase access to common goods and services, such as groceries, schools, and daycare.
Incorporate affordable housing into the project.
Incorporate neighborhood electric vehicle network.
Orient the project toward transit, bicycle and pedestrian facilities.
Improve pedestrian or bicycle networks, or transit service.
Provide traffic calming.
Provide bicycle parking.
Limit or eliminate parking supply.
Unbundle parking costs.
Provide parking cash-out programs.
Implement roadway pricing.
Implement or provide access to a commute reduction program.
Provide car-sharing, bike sharing, and ride-sharing programs.
Provide transit passes.
Shifting single occupancy vehicle trips to carpooling or vanpooling, for example providing ride-
matching services.
Providing telework options.
Providing incentives or subsidies that increase the use of modes other than single-occupancy
vehicle.
Providing on-site amenities at places of work, such as priority parking for carpools and vanpools,
secure bike parking, and showers and locker rooms.
Providing employee transportation coordinators at employment sites.
Providing a guaranteed ride home service to users of non-auto modes.
Notably, because VMT is largely a regional impact, regional VMT-reduction programs may be an
appropriate form of mitigation. In lieu fees have been found to be valid mitigation where there is both a
commitment to pay fees and evidence that mitigation will actually occur. (Save Our Peninsula
Committee v. Monterey County Bd. of Supervisors (2001) 87 Cal.App.4th 99, 140-141; Gentry v. City of
Murrieta (1995) 36 Cal.App.4th 1359; Kings County Farm Bureau v. City of Hanford (1990) 221
Cal.App.3d 692, 727–728.) Fee programs are particularly useful to address cumulative impacts. (CEQA
Guidelines, § 15130, subd. (a)(3) [a “project’s incremental contribution is less than cumulatively
considerable if the project is required to implement or fund its fair share of a mitigation measure or
measures designed to alleviate the cumulative impact”].) The mitigation program must undergo CEQA
evaluation, either on the program as a whole, or the in-lieu fees or other mitigation must be evaluated
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on a project-specific basis. (California Native Plant Society v. County of El Dorado (2009) 170 Cal.App.4th
1026.) That CEQA evaluation could be part of a larger program, such as a regional transportation plan,
analyzed in a Program EIR. (CEQA Guidelines, § 15168.)
Examples of project alternatives that may reduce vehicle miles traveled include, but are not limited to:
Locate the project in an area of the region that already exhibits low VMT.
Locate the project near transit.
Increase project density.
Increase the mix of uses within the project or within the project’s surroundings.
Increase connectivity and/or intersection density on the project site.
Deploy management strategies (e.g., pricing, vehicle occupancy requirements) on roadways or
roadway lanes.
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Appendix 1. Considerations About Which VMT to Count
Consistent with the obligation to make a good faith effort to disclose the environmental consequences
of a project, lead agencies have discretion to choose the most appropriate methodology to evaluate
project impacts.38 A lead agency can evaluate a project’s effect on VMT in numerous ways. The purpose
of this document is to provide technical considerations in determining which methodology may be most
useful for various project types.
Background on Estimating Vehicle Miles Traveled
Before discussing specific methodological recommendations, this section provides a brief overview of
modeling and counting VMT, including some key terminology.
Here is an illustrative example of some methods of estimating vehicle miles traveled. Consider the
following hypothetical travel day (all by automobile):
1. Residence to Coffee Shop
2. Coffee Shop to Work
3. Work to Sandwich Shop
4. Sandwich Shop to Work
5. Work to Residence
6. Residence to Store
7. Store to Residence
Trip-based assessment of a project’s effect on travel behavior counts VMT from individual trips to and
from the project. It is the most basic, and traditionally the most common, method of counting VMT. A
trip-based VMT assessment of the residence in the above example would consider segments 1, 5, 6 and
7. For residential projects, the sum of home-based trips is called home-based VMT.
A tour-based assessment counts the entire home-back-to-home tour that includes the project. A tour-
based VMT assessment of the residence in the above example would consider segments 1, 2, 3, 4, and 5
in one tour, and 6 and 7 in a second tour. A tour-based assessment of the workplace would include
segments 1, 2, 3, 4, and 5. Together, all tours comprise household VMT.
38 The California Supreme Court has explained that when an agency has prepared an environmental
impact report:
T]he issue is not whether the [lead agency’s] studies are irrefutable or whether they
could have been better. The relevant issue is only whether the studies are sufficiently
credible to be considered as part of the total evidence that supports the [lead agency’s]
finding[.]
Laurel Heights Improvement Assn. v. Regents of the University of California (1988) 47 Cal.3d 376, 409;
see also Eureka Citizens for Responsible Gov’t v. City of Eureka (2007) 147 Cal.App.4th 357, 372.)
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Both trip- and tour-based assessments can be used as measures of transportation efficiency, using
denominators such as per capita, per employee, or per person-trip.
Trip- and Tour-based Assessment of VMT
As illustrated above, a tour-based assessment of VMT is a more complete characterization of a project’s
effect on VMT. In many cases, a project affects travel behavior beyond the first destination. The location
and characteristics of the home and workplace will often be the main drivers of VMT. For example, a
residential or office development located near high quality transit will likely lead to some commute trips
utilizing transit, affecting mode choice on the rest of the tour.
Characteristics of an office project can also affect an employee’s VMT beyond the work tour. For
example, a workplace located at the urban periphery, far from transit, can require an employee to own
a car, which in turn affects the entirety of an employee’s travel behavior and VMT. For this reason, when
estimating the effect of an office development on VMT, it may be appropriate to consider total
employee VMT if data and tools, such as tour-based models, are available. This is consistent with CEQA’s
requirement to evaluate both direct and indirect effects of a project. (See CEQA Guidelines, § 15064,
subd. (d)(2).)
Assessing Change in Total VMT
A third method, estimating the change in total VMT with and without the project, can evaluate whether
a project is likely to divert existing trips, and what the effect of those diversions will be on total VMT.
This method answers the question, “What is the net effect of the project on area VMT?” As an
illustration, assessing the total change in VMT for a grocery store built in a food desert that diverts trips
from more distant stores could reveal a net VMT reduction. The analysis should address the full area
over which the project affects travel behavior, even if the effect on travel behavior crosses political
boundaries.
Using Models to Estimate VMT
Travel demand models, sketch models, spreadsheet models, research, and data can all be used to
calculate and estimate VMT (see Appendix F of the preliminary discussion draft). To the extent possible,
lead agencies should choose models that have sensitivity to features of the project that affect VMT.
Those tools and resources can also assist in establishing thresholds of significance and estimating VMT
reduction attributable to mitigation measures and project alternatives. When using models and tools for
those various purposes, agencies should use comparable data and methods, in order to set up an
apples-to-apples” comparison between thresholds, VMT estimates, and VMT mitigation estimates.
Models can work together. For example, agencies can use travel demand models or survey data to
estimate existing trip lengths and input those into sketch models such as CalEEMod to achieve more
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accurate results. Whenever possible, agencies should input localized trip lengths into a sketch model to
tailor the analysis to the project location. However, in doing so, agencies should be careful to avoid
double counting if the sketch model includes other inputs or toggles that are proxies for trip length (e.g.,
distance to city center). Generally, if an agency changes any sketch model defaults, it should record and
report those changes for transparency of analysis. Again, trip length data should come from the same
source as data used to calculate thresholds to be sure of an “apples-to-apples” comparison.
Additional background information regarding travel demand models is available in the California
Transportation Commission’s “2010 Regional Transportation Plan Guidelines,” beginning at page 35.
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Appendix 2. Induced Travel: Mechanisms, Research, and Additional Assessment Approaches
Induced travel occurs where roadway capacity is expanded in an area of present or projected future
congestion. The effect typically manifests over several years. Lower travel times make the modified
facility more attractive to travelers, resulting in the following trip-making changes:
Longer trips. The ability to travel a long distance in a shorter time increases the attractiveness of
destinations that are farther away, increasing trip length and vehicle travel.
Changes in mode choice. When transportation investments are devoted to reducing automobile
travel time, travelers tend to shift toward automobile use from other modes, which increases
vehicle travel.
Route changes. Faster travel times on a route attract more drivers to that route from other
routes, which can increase or decrease vehicle travel depending on whether it shortens or
lengthens trips.
Newly generated trips. Increasing travel speeds can induce additional trips, which increases
vehicle travel. For example, an individual who previously telecommuted or purchased goods on
the internet might choose to accomplish those tasks via automobile trips as a result of increased
speeds.
Land Use Changes. Faster travel times along a corridor lead to land development farther along
that corridor; that new development generates and attracts longer trips, which increases vehicle
travel. Over several years, this induced growth component of induced vehicle travel can be
substantial, making it critical to include in analyses.
Each of these effects has implications for the total amount of vehicle travel. These effects operate over
different time scales. For example, changes in mode choice might occur immediately, while land use
changes typically take a few years or longer. CEQA requires lead agencies to analyze both short-term
and long-term effects.
Evidence of Induced Vehicle Travel. A large number of peer reviewed studies 39 have demonstrated a
causal link between highway capacity increases and VMT increases. Many provide quantitative
estimates of the magnitude of the induced VMT phenomenon. Collectively, they provide high quality
evidence of the existence and magnitude of the induced travel effect.
39 See, e.g., Boarnet and Handy (Sept. 2014) Impact of Highway Capacity and Induced Travel on
Passenger Vehicle Use and Greenhouse Gas Emissions, California Air Resources Board Policy Brief,
available at https://www.arb.ca.gov/cc/sb375/policies/hwycapacity/highway_capacity_brief.pdf;
National Center for Sustainable Transportation (Oct. 2015) Increasing Highway Capacity Unlikely to
Relieve Traffic Congestion, available at
http://www.dot.ca.gov/research/researchreports/reports/2015/10-12-2015-
NCST_Brief_InducedTravel_CS6_v3.pdf.
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Most of these studies express the amount of induced vehicle travel as an “elasticity,” which is a
multiplier that describes the additional vehicle travel resulting from an additional lane mile of roadway
capacity added. For example, an elasticity of 0.6 would signify an 0.6 percent increase in vehicle travel
for every 1.0 percent increase in lane miles. Many of these studies distinguish “short run elasticity”
increase in vehicle travel in the first few years) from “long run elasticity” (increase in vehicle travel
beyond the first few years). Long run elasticity is larger than short run elasticity, because as time passes,
more of the components of induced vehicle travel materialize. Generally, short run elasticity can be
thought of as excluding the effects of land use change, while long run elasticity includes them. Most
studies find a long run elasticity between 0.6 and just over 1.0,40 meaning that every increase in lanes
miles of one percent leads to an increase in vehicle travel of 0.6 to 1.0 percent. The most recent major
study finds the elasticity of vehicle travel by lanes miles added to be 1.03; in other words, each percent
increase in lane miles results in a 1.03 percent increase in vehicle travel.41 (An elasticity greater than 1.0
can occur because new lanes induce vehicle travel that spills beyond the project location.) In CEQA
analysis, the long-run elasticity should be used, as it captures the full effect of the project rather than
just the early-stage effect.
Quantifying Induced Vehicle Travel Using Models. Lead agencies can generally achieve the most accurate
assessment of induced vehicle travel resulting from roadway capacity increasing projects by applying
elasticities from the academic literature, because those estimates include vehicle travel resulting from
induced land use. If a lead agency chooses to use a travel demand model, additional analysis would be
needed to account for induced land use. This section describes some approaches to undertaking that
additional analysis.
Proper use of a travel demand model can capture the following components of induced VMT:
Trip length (generally increases VMT)
Mode shift (generally shifts from other modes toward automobile use, increasing VMT)
Route changes (can act to increase or decrease VMT)
Newly generated trips (generally increases VMT)
o Note that not all travel demand models have sensitivity to this factor, so an off-model
estimate may be necessary if this effect could be substantial.
However, estimating long-run induced VMT also requires an estimate of the project’s effects on land
use. This component of the analysis is important because it has the potential to be a large component of
40 See Boarnet and Handy (Sept. 2014) Impact of Highway Capacity and Induced Travel on Passenger
Vehicle Use and Greenhouse Gas Emissions, California Air Resources Board Policy Brief, p. 2, available at
https://www.arb.ca.gov/cc/sb375/policies/hwycapacity/highway_capacity_brief.pdf.
41 Duranton and Turner (2011) The Fundamental Law of Road Congestion: Evidence from US cities,
available at http://www.nber.org/papers/w15376.
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the overall induced travel effect. Options for estimating and incorporating the VMT effects that are
caused by the subsequent land use changes include:
1. Employ an expert panel. An expert panel could assess changes to land use development that
would likely result from the project. This assessment could then be analyzed by the travel
demand model to assess effects on vehicle travel. Induced vehicle travel assessed via this
approach should be verified using elasticities found in the academic literature.
2. Adjust model results to align with the empirical research. If the travel demand model analysis is
performed without incorporating projected land use changes resulting from the project, the
assessed vehicle travel should be adjusted upward to account for those land use changes. The
assessed VMT after adjustment should fall within the range found in the academic literature.
3. Employ a land use model, running it iteratively with a travel demand model. A land use model
can be used to estimate the land use effects of a roadway capacity increase, and the traffic
patterns that result from the land use change can then be fed back into the travel demand
model. The land use model and travel demand model can be iterated to produce an accurate
result.
A project which provides new connectivity across a barrier, such as a new bridge across a river, may
provide a shortened path between existing origins and destinations, thereby shortening existing trips. In
rare cases, this trip-shortening effect might be substantial enough to reduce the amount of vehicle
travel resulting from the project below the range found in the elasticities in the academic literature, or
even lead a net reduction in vehicle travel overall. In such cases, the trip-shortening effect could be
examined explicitly.
Whenever employing a travel demand model to assess induced vehicle travel, any limitation or known
lack of sensitivity in the analysis that might cause substantial errors in the VMT estimate (for example,
model insensitivity to one of the components of induced VMT described above) should be disclosed and
characterized, and a description should be provided on how it could influence the analysis results. A
discussion of the potential error or bias should be carried into analyses that rely on the VMT analysis,
such as greenhouse gas emissions, air quality, energy, and noise.
TO: Honorable Chair and Members of the Planning Commission
FROM: Cheri Flores, Planning Manager
DATE: June 23, 2020
SUBJECT: PROJECT UPDATES
As of June 17, City Hall has opened with limited access. Telephonic and on-
line services for permits, plan check, application submittals, payments, and
inspection appointments remain as options for conducting business. In-
person consultation is available by appointment only and staff is still on a
staggered schedule to comply with social distancing requirements. Face
coverings are required for anyone entering the building and glass partitions
have been installed at the public counters to limit exposure to COVID-19.
Social distancing of 6 ft. between persons in the lobby and at the counter is
also required. A thermal camera is located at the entrance to monitor the
temperatures of all City employees and members of the public entering the
building. Staff continues to work on existing development projects and an
update of these is summarized below.
Pavilion Palms Shopping Center project
The public hearing was continued to July 7 in light of constraints to site
plan preparation due to COVID-19 orders. At this time, revisions to the
site plan do not require recirculation to the Commission.
Staff Level Approval projects
Dutch Bros Coffee Shop: An application was received in April for a Site
Development Permit to construct a new double-drive through coffee
shop with no indoor dinning, west of Jefferson Street and south of Fred
Warning. The application is currently under design review. The applicant
has submitted construction plans as well.
Update on recently approved projects
Tampico Starbucks: The project is currently in building plan check. Staff
has approved their sign program and landscape plan.
Casa Mendoza: Staff recently approved a Modification by Applicant to
add a canopy to the outdoor patio.
STAFF ITEM NO. 1
2
Upcoming projects for Commission consideration are summarized below.
Jefferson Apartments: Applications were received in early March for a
new 40-unit apartment project located at the southeast corner of
Jefferson Street and Palm Circle Drive, location of the formerly approved
Villas at Indian Springs project. The applicant wishes to change the
residential product from 16 single-family residences to 40 multi-family
apartments. The applications are now under design review and are not
anticipated to come before the Commission for another 6-8 months.
The Wave at Coral Mountain: The project consists of a Specific Plan to
allow for a 15-acre wave pool with an associated hotel/hospitality
component, 600 residential units, a neighborhood commercial center
and a community farm. Staff continues to work with the applicant in
preparing their environmental documentation and special studies. The
applications are still under completeness review at this time. It is
anticipated that the applications will come before the Commission in late
2020.
Travertine: The project consists of a Specific Plan amendment to reduce
the number of residential units from 2,300 to 1,200, reduce hotel rooms
from 500 to 100 and reorganize land use patterns on the site. Staff
continues to work with the applicant in preparing the environmental
documentation for the project. The applications are still under
completeness review at this time. It is anticipated that these
applications will come before the Commission in early 2021.
Highway 111 Cell Tower: An application was received in April for a
Conditional Use Permit to construct an 84’ mono-eucalyptus cell tower
located in the rear of the Extra Space Storage facility, east of Adams
and north of Highway 111. The application is still under completeness
review at this time. Staff does not yet have an estimate when it will
come before the Commission.
Mountain View Country Club Cell Tower: An application was received in
April for a Conditional Use Permit to construct a 70’ monopalm cell tower
within the Mountain View Country Club clubhouse area, east of Jefferson
Street and south of Avenue 50. The application is under completeness
review and staff does not yet have an estimate when it will come before
the Commission.
Hideaway Cell Tower: An application was received in May for a
Conditional Use Permit to construct a roof-top cell facility at the
Hideaway Clubhouse located west of Jefferson Street and south of
Avenue 50. The application is under completeness review and staff does
not yet have an estimate when it will come before the Commission.