06-16-2020 - AGENDA ITEM 04 CONSIDER ADOPTION OF VEHICLE MILES TRAVELED ("VMT") AND THRESHOLDS OF SIGNIFICANCE FOR PURPOSES OF ANALYZING TRANSPORTATION IMPACTS UNDER THE CALIFORNIA ENVIRONMENTAL QUALITY ACTAGENDA ITEM NO.4
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AGENDA STAFF REPORT
City of West Covina I Office of the City Manager
DATE: June 16, 2020
TO: Mayor and City Council
FROM: David Carmany
City Manager
SUBJECT: CONSIDER ADOPTION OF VEHICLE MILES TRAVELED ("VMT") AND THRESHOLDS
OF SIGNIFICANCE FOR PURPOSES OF ANALYZING TRANSPORTATION IMPACTS
UNDER THE CALIFORNIA ENVIRONMENTAL QUALITY ACT
RECOMMENDATION:
It is recommended that the City Council adopt the following resolution:
RESOLUTION NO.2020-57 — A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF
WEST COVINA, CALIFORNIA, ADOPTING "VEHICLE MILES TRAVELED" THRESHOLDS OF
SIGNIFICANCE FOR PURPOSES OF ANALYZING TRANSPORTATION IMPACTS UNDER THE
CALIFORNIA ENVIRONMENTAL QUALITY ACT
BACKGROUND:
On September 27, 2013, Governor Brown signed SB 743 into law and started a process intended to fundamentally
change how transportation impact analysis is conducted as part of the California Environmental Quality Act
(CEQA) review of projects. SB 743 eliminates Level of Service (LOS) as the basis for determining transportation
impacts under CEQA and requires the use of Vehicle Miles Traveled (VMT) instead. The state is shifting the focus
of CEQA traffic analysis from measuring a project's impact on automobile delay (LOS) to measuring the amount
and distance of automobile travel that is attributable to a project (VMT). The State's goal in changing the metric
used to determine a significant transportation impact is to encourage land use and transportation decisions that
reduce greenhouse gas emissions, encourage infill development, and improve public health through active
transportation.
DISCUSSION:
Changes in state law require that cities adopt new CEQA thresholds of environmental significance for
transportation impacts. For the purposes of CEQA, these changes will modify how cities evaluate projects for
transportation impacts. Under the new legislation cities are required to use Vehicle Miles Traveled (VMT) instead
of Level of Service (LOS) as the metric to evaluate transportation impacts in CEQA documents such as
Environmental Impact Reports (EIRs). However, outside the CEQA process cities may choose to continue to
evaluate projects using the LOS metric.
The City of West Covina joined with other cities in the San Gabriel Valley to pool resources and take a regional
approach to complying with the new legislation. A regional approach reduced the cost to individual cities and
allowed for the development of a more uniform approach to complying with the new CEQA requirements.
Home -Based VMT per Capita Comparison O Transit Priority Area (TPA) Land Use • Hotel
CD 15% or more below SGVCOG Average Q City Boundary • Mixed Use • Medical
0 to 15% below SGVCOG Average • Multi -Family Residential • Industrial
Higher than SGVCOG Average • Single -Family Residential
CD No Residents
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Home -Based Work VMT per Employee Comparison Q City Boundary Land Use • Hotel
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0 0 to 15% below SGVCOG Average • Multi -Family Residential • Industrial
0 Higher than SGVCOG Average • Single -Family Residential
Daily Home -Based Work VMT per Employee for West Covina (2012)
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VMT per Service Population Comparison O City Boundary Land Use • Hotel
CD 15% or more below SGVCOG Average E) Transit Priority Area (TPA) • Mixed Use • Medical
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Daily VMT per Service Population for West Covina (2012)
San Gabriel Valley Council of Governments Implementation Process
After receiving consent from the majority of the San Gabriel Valley cities to develop a regional approach to
addressing traffic issues, the San Gabriel Valley Council of Governments (SGVCOG) retained the traffic consultant
Fehr and Peers based upon a competitive bidding process. The consultant analyzed existing traffic conditions in the
region to arrive at a baseline standard from which to determine significance thresholds for future land use and
transportation projects. The result defines recommendations for establishing methodology, thresholds, and technical
tools and procedures for CEQA analysis and transportation impacts of land use and transportation projects and
plans in the local jurisdictions within the San Gabriel Valley.
Staff is recommending that the City follow the guidelines established by the Governor's Office of Planning and
Research ("OPR") in all the areas listed below. Following OPR guidelines allows the City to be consistent with
surrounding jurisdictions, which makes the City economically competitive.
Analysis of CEQA Transportation Thresholds
Which projects should be exemptjrom VMTAnalysis?
• Project Type Screening
The City staff recommendation is to be consistent with OPR guidance to screen out retail projects up to
50,000 SF in floor area and projects generating less than 110 daily trips.
• Low VMT Screening
The City staff recommendation is to be consistent with OPR guidance to screen out residential and office
projects located in low VMT areas. Low VMT is defined as 15% below the Baseline VMT metrics. Low
VMT areas are shown in Attachment No. 3.
• Transit Priority Area (TPA) Screening
The City staff recommendation is to be consistent with OPR guidance to screen out projects in Transit
Priority Areas be defined as locations within /z mile of a transit stop/station with a minimum of 15-minute
headways during peak commute hours. Transit Priority Areas are also shown in Attachment No. 3.
• Affordable Housing Screening
The City staff recommendation is to be consistent with OPR guidance to screen out affordable housing
developments or affordable housing units within mixed -use developments.
A complete list of projects that can be Screened Out based on type is shown on Attachment No. 2.
How does the City define its Baseline VMT?
The Baseline VMT is defined as the average VMT for the area represented by the San Gabriel Valley
Council of Governments, as measured by VMT per capita, VMT per employee, or VMT per service
population. A project's VMT will be compared to the Baseline VMT when determining potential significant
impacts.
What is an appropriate VMT significant impact threshold?
• Land Use Plans: To be consistent with OPR guidance, significant impacts would occur if the VMT per
service population for the land use plan exceeds 15% below the Baseline VMT.
• Land Use Projects: To be consistent with OPR guidance, significant impacts would occur if a project
generates VMT (per capita, per employee, or per service population) higher than 15% below the Baseline
VMT.
• Transportation Projects: To be consistent with OPR guidance, significant impacts would occur if the projects
results in a net increase in VMT.
Existing Thresholds of Significance
The City's existing thresholds of significance rely on the LOS criteria. Staff believes that this approach is
still valid for analyzing local impacts to intersections in proximity to proposed projects. While the LOS
analysis cannot be used for CEQA anymore, the City can choose to continue to use these thresholds outside
the CEQA process. Therefore, staff is recommending that these thresholds be adopted as an official policy by
the City Council.
GENERAL PLAN CONSISTENCY
The new CEQA transportation impact thresholds are consistent with the objectives, principles, and standards of the
West Covina General Plan. The Circulation and Land Use Elements have a number of actions and policies relevant
to the new CEQA transportation impact thresholds, including the following:
"Our Natural Community" Policy 1.3- Minimize the adverse impact of growth and development on air
quality and climate.
"Our Well -Planned Community" Policy 2.6 - Reduce West Covina's production of greenhouse gas emissions
and contribution to climate change, and adapt to the effects of climate change.
Action 2.6a - Key land use adaptation strategies to reduce greenhouse gas emissions are: promoting
transit -oriented infill development, and providing incentives for high-performance buildings and
infrastructure.
"Our Accessible Community" Policy 4.2- Accommodate multimodal mobility, accessibility and safety needs
when planning, designing, and implementing transportation improvements, improving access and circulation
for all users of City streets.
Action 4.2c - Accommodate the needs of all travelers through a Complete Streets approach to
designing new transportation improvements. Complete streets are roadways designed to facilitate safe,
comfortable, and efficient travel for all roadway users.
"Our Accessible Community" Policy 4.4 - Allocate street space equitably among all modes.
Action 4.4a - Ensure that pedestrians, bicyclists, transit vehicles and automobiles each have space in
the right-of-way that is consistent with the street's designated mobility function and land use context
per street typologies and modal -priority overlays as defined in the Thoroughfares Plan.
"Our Accessible Community" Policy 4.6 - Work with transit providers to develop high -quality facilities for
transit users, including access facilities.
"Our Resilient Community" Policy 5.1 (Circulation) - Promote fine-grained network of complete streets in
new and redevelopment projects.
Action 5.1 -Adjust development regulations and review processes to require new development and
redevelopment projects to provide a fine-grained, interconnected, multimodal transportation network
with a balance of motor vehicle, pedestrian, bike, and transit amenities.
"Our Resilient Community" Policy 5.5 (Transportation)- Implement a Complete Streets Policy for the city to
ensure that the right of way will provide safe access for all users.
Action 5.5 - Publish a Complete Streets Manual that provides engineering and design guidelines for
different street typologies to better accommodate a mix of modes, including cars, public transportation,
cyclists, and pedestrians; apply the standards in the manual to projects whenever possible.
"Our Healthy and Safe Community" Policy 6.1 - Promote and support transportation decisions that reduce
driving and increase rates of transit use, walking, and biking.
Action 6 la - Review and revise street standards to promote walking, transit use, and biking.
"Our Healthy and Safe Community" Policy 6.4 - Implement a Complete Streets Policy for the city to ensure
that the right of way will provide safe access for all users.
Following adoption of the VMT standards, the San Gabriel Valley Council of Governments (SGVCOG)
recommends that individual cities prepare new CEQA transportation impact thresholds for consideration by the
City Council. Staff will begin drafting new thresholds following City Council adoption of the new VMT standards
LEGAL REVIEW:
The City Attorney's Office has reviewed the resolution and approved it as to form.
OPTIONS:
The City Council has the following options:
1. Approve staffs recommendation; or
2. Provide alternative direction.
ENVIRONMENTAL REVIEW:
This Ordinance has been assessed in accordance with the authority and criteria contained in the California
Environmental Quality Act (CEQA), the State CEQA Guidelines, and the environmental regulations of the City.
The adoption of new local CEQA thresholds of significance for transportation impacts and the adoption of new
Local Transportation Assessment Guidelines will not have a significant environmental impact and are exempt from
the CEQA pursuant to Section 15308 of Title 14 of the California Code of Regulations because the two actions are
undertaken by the City for the protection of the environment. The revised CEQA thresholds will be compliant with
a State mandate (SB 743) and will be used in a regulatory process (CEQA process) that involves procedures for the
protection of the environment. Accordingly, the City Council will consider the recommendation to find the
Resolution exempt from the environmental review requirements of CEQA pursuant to Section 15308 of Title 14 of
the California Code of Regulations.
Prepared by: Jo -Anne Burns, Planning Manager
Attachments
Attachment No. 1 - Resolution No. 2020-57
Attachment No. 2 - List of Projects that Can Be Screened
Attachment No. 3 - Low VMT Areas (3 Maps)
CITY COUNCIL GOALS & OBJECTIVES: Enhance City Facilities and Infrastructure
Engage in Proactive Economic Development
ATTACHMENT NO.1
RESOLUTION NO. 2020-57
A RESOLUTION OF THE CITY COUNCIL OF THE CITY
OF WEST COVINA, CALIFORNIA, ADOPTING "VEHICLE
MILES TRAVELED" THRESHOLDS OF SIGNIFICANCE
FOR PURPOSES OF ANALYZING TRANSPORTATION
IMPACTS UNDER THE CALIFORNIA ENVIRONMENTAL
QUALITY ACT
WHEREAS, the California Environmental Quality Act Guidelines ("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 orperformance level ofaparticular 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 regulation, 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 detemrining
the significance of transportation impacts of projects; and
WHEREAS, in 2018, the Governor's Office ofPhrining and Research ("OPR') proposed,
and the California Natural Resources Agency certified and adopted, new CEQA Guidelines section
15064.3 that identifies vehicle miles traveled ('VW) — 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, 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
WHEREAS, the City's project review process will retain "Level of Service" analysis to
ensure consistency with the General Plan; and
WHEREAS, CEQA Guidelines section 15064.3 goes into effect on July 1, 2020, though
public agencies may elect to be governed by this section immediately; and
WHEREAS, the City of West Covina, following a public review process consisting of a
staff presentation before the City Council, wishes to adopt the VMT thresholds of significance for
determining the significance of transportation impacts.
NOW, THEREFORE, THE CITY COUNCIL OF THE CITY OF WEST COVINA,
CALIFORNIA DOES HEREBY RESOLVE AS FOLLOWS:
SECTION 1. The City Council finds that the adoption of new local CEQA thresholds of
significance for transportation impacts and the adoption of new Local Transportation Assessment
Guidelines will not have a significant environmental impact and are exempt from the CEQA
pursuant to Section 15308 of Title 14 of the California Code of Regulations because the two actions
are undertaken by the City for the protection of the environment. The revised CEQA thresholds
will be compliant with a State mandate (SB 743) and will be used in a regulatory process (CEQA
process) that involves procedures for the protection of the environment. Accordingly, the City
Council finds that adoption of this resolution is exempt from the environmental review
requirements of CEQA pursuant to Section 15308 of Title 14 of the California Code of
Regulations.
SECTION 2. The City Council hereby adopts the VMT thresholds of significance
attached hereto as Exhibit A.
SECTION 3. The City Clerk shall certify to the adoption of this resolution and shall enter
the same in the book of original resolutions and it shall become effective immediately.
APPROVED AND ADOPTED this 16th day of June, 2020.
Tony Wu
Mayor
APPROVED AS TO FORM: ATTEST:
Thomas P. Duarte Lisa Sherrick
City Attorney Assistant City Clerk
ATTACHMENT NO.1
I, LISA SHERRICK, Assistant City Clerk of the City of West Covina, California, do
hereby certify that the foregoing Resolution No. 2020-57 was duly adopted by the City Council of
the City of West Covina, California, at a regular meeting thereof held on the 16th day of June,
2020, by the following vote of the City Council:
AYES:
NOES:
ABSENT:
ABSTAIN:
Lisa Sherrick
Assistant City Clerk
Exhibit A
VMT Baselines and Thresholds of Significance
Consistent with State CEQA Guidelines section 15064.3, the City of West Covina has adopted
the project baselines and thresholds of significance set forth in Table 1 to guide in determining
when a project will have a significant transportation impact.
TABLE 1
Project Type
Thresholds
Land Use Plan
1) Project Impact: A significant impact would occur if the
VMT rate for the plan would exceed the applicable
baseline VMT rate.
2) Cumulative Project Effect: A significant impact would
occur if the project increases total regional VMT
compared to cumulative no project conditions.
Land Use Project
1) Project Impact: A significant impact would occur if the
VMT rate for the project would exceed the applicable
baseline VMT rate.
2) Cumulative Project Effect:
A significant impact would occur if the project
increases total regional VMT compared to cumulative
no project conditions.
Retail Project (over
1) Project Impact: A significant impact would occur if the
50,000 square feet)
VMT rate for the project would exceed the applicable
baseline VMT.
2) Cumulative Project Effect: A significant impact would
occur if the project increases total VMT in the study
area compared to baseline conditions.
Transportation
A significant impact would occur if the project causes a net
Project
increase in total regional VMT compared to baseline conditions,
opening year no project conditions, or cumulative no project
conditions.
All land use and
A significant impact would occur if the project is inconsistent
transportation
with the RTP/SCS (Regional Transportation Plan/Sustainable
projects
Comnimities Strategy).
Note: Baseline VMT rate is defined as the rate for SGVCOG, per applicable service population.
The baseline VMT may be changed pending updates to the SCAG's RTP model
/:U W F.T01 lu I 0 llL[IIF
List of Projects that Can Be Screened Out
Based on Type
OPR identified local serving project types that may be presumed to have a less than
significant impact absent substantial evidence to the contrary. Local serving retail projects
(less than 50,000 square feet) generally improve the convenience of shopping close to home
and has the effect of reducing vehicle travel The City of West Covina will screen out the
following projects.
The following uses are presumed to have a less than significant impact (absent substantial
evidence to the contrary) as their uses are local serving in nature:
• Local serving retail (retail establishments less than 50,000 square feet in size)
• Local -serving K-12 schools
• Local parks
• Day care centers
• Local -serving retail uses less than 50,000 square feet, including:
o Gas stations
o Banks
o Restaurants
o Shopping Center
• 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, free 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 RTP/SCS (Regional Transportation Plan/Sustainable Communities Strategy)
• Projects generating less than 110 daily vehicle trips. This generally corresponds to
the following "typical" development potentials:
0 11 single family housing units
0 16 multi family, condominiums, or townhouse housing units
0 10,000 sq. ft. of office
0 15,000 sq. ft. of light industrial
0 63,000 sq. ft. of warehousing
0 79,000 sq. ft. of high -cube transload and short-term storage warehouse
• Public parking garages and public parking lots