2020-06-20 VMT Policy1
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
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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
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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.
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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
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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.
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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.
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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
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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
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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
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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.
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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.
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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”.
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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.
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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.
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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.