Vehicle Miles Traveled (VMT)

Background

On September 27, 2013, Governor Jerry Brown signed Senate Bill 743 into law that commenced a process that would change transportation analysis for California Environmental Quality Act (CEQA) compliance.  Specifically, the legislation directed the Office of Planning and Research (OPR) to look at different metrics for identifying transportation impacts under CEQA. The Final OPR guidelines were released in December 2018 and identified Vehicle Miles Traveled (VMT) as the preferred metric moving forward. VMT is the measure of distance in miles that a vehicle travels, with one-mile equivalent to one VMT.  Therefore, projects subject to CEQA evaluation for transportation, would no longer be analyzed measuring Level of Service (LOS), and analyzed using VMT.

The Natural Resources Agency completed the rule making process to modify the CEQA guidelines in December of 2018. The revised CEQA Guidelines identified that, by July of 2020 all lead agencies must use VMT as the new transportation metric for identifying transportation impacts for land use and transportation projects.

Guidelines

As a result, the City of San Dimas (City) established VMT thresholds of significance for purposes of analyzing transportation impacts for projects subject to CEQA review, and adopted Transportation Study Guidelines for Vehicle Miles Traveled and Level of Service Assessment (TS Guidelines). While the revised CEQA guidelines require that projects subject to CEQA are analyzed using VMT, the City has vehicle LOS standards for which local infrastructure will strive to maintain. The LOS standards apply to discretionary approvals of new land use and transportation projects. Therefore, in addition to VMT guidelines, the adopted TS Guidelines also include instructions for vehicle LOS analysis consistent with City requirements.

Application of Guidelines

An applicant seeking project approval will submit the proposed project to the City with a planning and land use application. After a preliminary review of the project by City Staff, the applicant will be notified by the project planner as to whether or not a TS is required. The TS should consider changes in both LOS and VMT.

A TS which includes LOS analysis shall be required for a proposed project when either the AM or PM peak hour trip generation from the proposed development is expected to exceed 50 total trips. (A traffic study may be required for smaller projects based on land use and location per City’s discretion.)

Furthermore, all TS’s must include a VMT assessment that explains either why the project screens out or provides a full VMT impact analysis. A proposed project may screen out of full VMT analysis if it meets one or more of the following project screening criteria:

• Transit Priority Areas Screening
• Low VMT-generating Areas Screening
• Project Type Screening

Project Screening

There are three types of screening that may be applied to effectively screen projects from project-level assessment. These screening steps are summarized below:

1. Transit Priority Area (TPA) Screening
   • Projects located within a TPA, which is defined as a half-mile area around an existing major transit stop or an existing stop along a high-quality transit corridor, 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 City;
     3. Is inconsistent with the applicable Sustainable Communities Strategy (as determined by the lead agency, with input from the Southern California Association of Governments [SCAG]); or
     4. Replaces affordable residential units with a smaller number of moderate- or high-income residential units.
2. 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 (to identify if a project is in a low VMT-generating area, the analyst should use the SGVCOG VMT Evaluation Tool at: https://apps.fehrandpeers.com/SGVCOGVMT/.) 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 generate VMT per resident, per worker, or per service population that is similar to the existing land uses in the low VMT area.
3. Project Type Screening
   • Some project types have been identified as having the presumption of a less than significant impact. The following uses can 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 retail uses less than 50,000 square feet, including
     • Gas stations
     • Banks
     • Restaurants
     • Shopping Centers
   • Local-serving hotels (e.g. non-destination hotels)
   • Student housing projects on or adjacent to a college campus
   • Local-serving assembly uses (places of worship, community organizations)
   • Community institutions (public libraries, fire stations, local government)
   • Affordable, supportive, or transitional housing
   • Assisted living facilities
   • Senior Housing (as defined by HUD)
   • Local serving community colleges that are consistent with the assumptions noted in the Regional Transportation Plan (RTP) and Sustainable Communities Strategy (SCS)
   • Projects generating less than 110 daily vehicle trips. This generally corresponds to the following “typical” development potentials:
     • 11 single family housing units
     • 16 multi-family, condominiums, or townhouse housing units
     • 10,000 sq. ft. of office
     • 15,000 sq. ft. of light industrial
     • 63,000 sq. ft. of warehousing
     • 79,000 sq. ft. of high-cube transload and short-term storage warehouse

For additional information please refer to the TS Guidelines or contact the Planning Division at 909.394.6250.