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cc16_162

STAFF REPORT

MEETING

DATE:

October 25, 2016

TO:

City Council

FROM:

Robert Brown, Community Development Director

PRESENTER: Robert Brown, Community Development Director

SUBJECT:

TRANSPORTATION IMPACT ANALYSIS WHITE PAPER

REQUEST

Consider providing direction to staff on transportation impact analysis policy and program

options for inclusion in the Draft General Plan and associated Environmental Impact Report.

RECOMMENDATION

Provide direction to staff.

SUMMARY

The Transportation Impact Analysis White Paper is the tenth in a series of white papers being

prepared to assist in updating the Novato General Plan. The purpose of the white paper process is

to provide initial direction on key policy issues, which will aid staff in crafting policies for the

draft General Plan and then eventual evaluation in an environmental impact report (EIR). As

such, Planning Commission recommendations and City Council direction are preliminary and

will be reconsidered upon review of the draft General Plan and its accompanying EIR.

The Transportation Impact Analysis White Paper provides background information on Senate

Bill 743 which was adopted by the state on September 27, 2013 and mandates changes to the

California Environmental Quality Act (CEQA) on the criteria used for analysis of traffic impacts

from new development and transportation improvements. The legislation specifically calls for

discontinuing use of Level of Service (LOS) calculations in assessing traffic impacts in CEQA

analysis. The Governor’s Office of Planning and Research (OPR) was charged with preparing

modifications to the CEQA Guidelines, which have been in preparation and public discussion for

over two years. The legislative change to CEQA analysis will be effect in 2019.

The draft OPR guidance recommends use of Vehicle Miles Travelled (VMT) as a preferable

metric to assess traffic impacts and provides a recommended threshold of significance for VMT

decrease for determining CEQA impacts, but allows for establishment by local government of an

alternative local threshold standard.

922 Machin Avenue Novato, CA 94945 415/ 899-8900 FAX 415/ 899-8213 www.novato.org

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The White Paper discusses the requirements of SB 743, the differences between LOS and VMT

calculations, potential thresholds of significance and implications on environmental review of

new development and transportation projects in a suburban community like Novato.

POLICY OPTIONS

Although implementation of SB 743 will not occur until 2019, the City’s General Plan update

process provides an opportunity to consider the impending changes in traffic analysis and how it

will affect future development approvals and planned transportation improvements. The primary

options discussed in the White Paper are:

1. Whether to use the OPR-recommended VMT reduction for analysis of the new General

Plan update in the EIR under preparation, or adopt a Novato-specific threshold, or to

simply analyze the state-recommended VMT and a locally-derived VMT reduction for

informational purposes in the General Plan EIR, but without adopting a threshold in the

General Plan at this time.

2. Whether to use the OPR-recommended VMT reduction as the CEQA threshold for future

evaluations of development and transportation projects, or adopt a locally-derived

threshold as part of the new General Plan, or to include a program in the new General

Plan to subsequently prepare and consider for Council adoption a local CEQA threshold.

3. Whether to retain LOS criteria in the new General Plan and require individual project

analysis for LOS impacts (outside of the CEQA analysis of VMT) or retain LOS criteria

in the General Plan but apply project mitigation only through payment of a citywide

traffic impact fee for

ENVIRONMENTAL ASSESSMENT

No environmental assessment is necessary for the policy white papers being prepared for the

update of the General Plan. However, an environmental impact report will be prepared for the

draft General Plan, which will include an analysis of the preliminary policy direction and

alternatives developed through the white paper process.

ALTERNATIVES

1. Direct staff to incorporate desired policy options into the Draft General Plan; or

2. Direct staff to provide additional analysis and recommendations.

ATTACHMENTS

1.

Transportation Impact Analysis Plan White Paper

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City of Novato

General Plan 2035 Policy White Paper

THE EVOLUTION OF TRANSPORTATION IMPACT ANALYSIS:

Understanding the Implications of Senate Bill (SB) 743

October 2016

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THE EVOLUTION OF TRANSPORTATION IMPACT ANALYSIS

Understanding the Transportation Analysis Implications of Senate Bill (SB) 743

THE ISSUE

On September 27, 2013, Governor Jerry Brown signed SB 743 into law and started a process intended to fundamentally change transportation impact analysis as part of CEQA compliance. These changes include elimination of auto delay, level of service (LOS), and other similar measures of vehicular capacity or traffic congestion as a basis for determining significant impacts. The Governor’s Office of Planning and Research (OPR) has issued draft guidance for these updates to the CEQA guidelines, and recommends use of Vehicle Miles Traveled, or VMT, as the preferred CEQA transportation metric, along with the elimination of auto delay for CEQA purposes. As such, the City should set new thresholds for transportation impacts based on VMT.

WHITE PAPER PURPOSE

The purpose of the General Plan White Papers is to assist the City Council in providing initial direction on certain policy questions to aid staff in the preparation of the Draft General Plan, which will then be evaluated in the environmental impact report (EIR) prepared for the General Plan. This white paper requests guidance on:

a. Setting a VMT threshold for use in assessing transportation impacts of the level of development contemplated in the draft Novato General Plan; b. Establishing VMT thresholds for project-level CEQA

reviews; and

c. Determining whether LOS will be retained as a project review metric outside of the CEQA review process.

BACKGROUND

SB 743 includes the following two legislative intent statements:

1) Ensure that the environmental impacts of traffic, such as noise, air pollution, and safety concerns, continue to be properly addressed and mitigated through the California Environmental Quality Act.

CEQA refers to the California

Environmental Quality Act. This statute requires identification of any significant environmental impacts of state or local action including approval of new development or infrastructure projects. The process of identifying these impacts is typically referred to as the environmental review process.

LOS refers to “Level of Service,” a metric

that assigns a letter grade to network performance. The typical application in cities is to measure the average amount of delay experienced by vehicle drivers at an intersection during the most congested time of day and assign a report card range from LOS A (fewer than 10 seconds of delay) to LOS F (more than 80 seconds of delay). The amount of delay is calculated relative to the amount of time to traverse the intersection if a vehicle is the sole vehicle on the road, and it arrives at a green light.

VMT refers to “Vehicle Miles Traveled,” a

metric that accounts for the number of vehicle trips generated plus the length or distance of those trips. For transportation impact analysis, VMT is generally

expressed as VMT per capita for a typical weekday. For instance, the 2012 average daily VMT per capita for the nine county Bay Area region was 15.3 miles per person per day.

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2) Balance the needs of congestion management with statewide goals related to infill development, promotion of public health through active transportation, and reduction of greenhouse gas emissions.

These statements are important because they provide direction to OPR and to lead agencies. For OPR, the direction is largely about what new metrics should achieve. For lead agencies, the direction is about expected changes in transportation analysis (and related technical areas) plus what factors to consider for significance thresholds.

To implement this intent, SB 743 contains amendments to current congestion management law that allows cities and counties to effectively opt-out of the LOS standards that would otherwise apply. Further, SB 743 requires the Governor’s Office of Planning and Research (OPR) to update the CEQA Guidelines and establish, “... criteria for determining the significance of transportation impacts of projects within transit priority areas.” The new criteria, “… shall promote the reduction of greenhouse gas emissions, the

development of multimodal transportation networks, and a diversity of land uses.” Once the Secretary of the Natural Resources Agency certifies the new guidelines,

then “…automobile delay, as described solely by level of service or similar measures of vehicular capacity or traffic congestion shall not be considered a significant impact on the

environment…, except in locations specifically identified in the guidelines, if any.”

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), fee programs, or on-going network monitoring, but these metrics will no longer constitute the sole basis for CEQA impacts. Cities or counties that feel that continued use of vehicle LOS is an important part of their transportation analysis process can still use vehicle LOS outside of the CEQA process. The most common applications will likely occur for jurisdictions wanting to use vehicle LOS to size roadways in their general plan to determine nexus relationships for their impact fee programs or to require installation of

improvements or contribution thereto where delay in excess of the LOS standard set forth in the General Plan is expected to occur. Jurisdictions can continue to condition projects to build transportation improvements through the entitlement process in a variety of ways, such as using general plan consistency findings.

OPR plans to submit new guidelines to the Resources Agency during the fall of 2016 and is recommending Vehicle Miles Traveled (VMT) as the preferred CEQA transportation metric

Congestion Management Plans

(CMPs), also called Congestion

Management Programs, are

required under state law. Each

urban county in California may

choose to develop a CMP, which

requires a biennially update.

CMPs identify certain roadway

and highway segments as part of

the CMP network; these facilities

are then monitored for

congestion levels on a periodic

basis.

The CMP also sets performance

standards for these networks,

which have typically been based

on designating an acceptable

level of service. These standards

and modeled future traffic are

used to develop a capital

improvement program to

promote the CMP’s designated

goals.

The Transportation Authority of

Marin manages

the Marin County

CMP.

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and the elimination of auto delay and LOS Statewide. The latest draft of the new guidelines includes specifications for VMT methodology and recommendations for significance thresholds. As noted above, SB 743 requires impacts to transportation network performance to be viewed through a filter that promotes the reduction of greenhouse gas emissions, the development of multimodal transportation networks, and a diversity of land uses. VMT can help identify how projects (land development and infrastructure) influence accessibility (i.e., access to places and people) and emissions so its selection is aligned with the objectives of SB 743. Accessibility is an important planning objective in many

communities but so is travel time or delay experienced by users.

While the final implementation steps for SB 743 have not yet been completed by OPR, enough information is available to inform lead agencies about how to prepare for the upcoming transition to VMT. In some cases, this transition may need to be accelerated in response to actions of Caltrans since they routinely review CEQA documents for local agency development projects. In this role, Caltrans is either a commenting agency or a responsible agency under CEQA (see CEQA § 21069) and sets

expectations for adequate analysis of the State highway system. Caltrans has already started their SB 743 transition and is requesting VMT impact analysis in new transportation impact studies. OPR is expected to complete their implementation process in mid- to late 2017, which is likely to include a two-year grace period for lead agencies to adjust to the new VMT requirements. However, the Caltrans expectations may shrink or eliminate this grace period for projects.

Based on the background context outlined above, the remainder of this document addresses the following key implementation issues identified by City of Novato staff.

 Impact Analysis and Measurement: VMT vs LOS  Setting VMT Significance Thresholds

 Mitigation Options for Land Use Plans, Land Use Development Projects, and Transportation Projects

 Likely Effects of VMT analysis on Land Use Development Projects and Transportation Projects  Continued Use of LOS after SB 743

 Policy Choices for the City Council

Readers should note that this document is a brief overview of SB 743. More details are available at

http://www.fehrandpeers.com/sb743/.

IMPACT ANALYSIS AND MEASUREMENT: LOS VS VMT Level of Service (LOS)

Until SB 743, transportation impact analysis performed to comply with CEQA commonly focused on the perspective of automobile drivers when measuring potential impacts, specifically by measuring the level of delay for drivers traveling through certain intersections or on certain roadway segments. This

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The City of Novato currently sets

its LOS standard at LOS D for

signalized intersections and

all-way stop controlled intersections,

and LOS E at intersections with

stop signs on side streets only.

Projects that would cause LOS to

degrade below those levels are

currently found to have a

significant transportation impact.

perspective reflects general traffic engineering practices and how traffic operations are measured based on quantitative metrics such as vehicle speeds or amount of delay.

Since LOS is directly related to driving convenience (e.g., measurement of delay), it generally found acceptance by public agencies needing to measure roadway network performance and assessing how that performance may change as a result of a land use development or transportation project. Part of the acceptance was the ability to communicate network performance in a form that was directly relevant to drivers and generally understood by the public and decision makers. The current practice, however, does have limitations and consequences that contributed to the SB 743 shift away from vehicle LOS.

1) Vehicle LOS does not fully capture potential effects on transit, bicycle, and pedestrian modes.

Current practice does not provide a methodology to measure roadway or intersection LOS for all users. Methodology does exist to measure LOS or similar metrics for transit, bicycle, and

pedestrian modes, but the performance measures are unique to the mode and do not address the competition for roadway space or traffic signal time at intersections between different modes. Further, basing vehicle LOS only on vehicle delay or speeds means that a vehicle with one

occupant receives just as much influence as a vehicle with 50 occupants, such as a bus (although a bus will be recognized for being the equivalent of approximately two passenger cars due to its physical size). Therefore, an improvement that benefits 50 single-occupant vehicles would be shown to be 50 times more effective in reducing average vehicular delay than one that benefits a single bus with 50 occupants by the same amount.

2) Conventional vehicle LOS analysis does not describe network-wide performance.

Vehicle LOS is typically measured at individual locations such as intersections or freeway ramp junctions. While useful for identifying localized changes in vehicle speeds or vehicle congestion, this isolated focus may result in mitigation recommendations that could worsen network-wide performance because upstream and downstream effects on both the local and regional roadway network are not fully considered. Further, expanding the roadway network may induce more

vehicle travel and create land use patterns that are

dependent on vehicle travel, which in turn generates more vehicle demand, and can lead to similar levels of congestion even on a facility with increased capacity. Conventional LOS analysis also may not fully reflect the cumulative effects of multiple developments on regional roadways, due to its focus on individual intersections, ramps, or roadway segments.

3) LOS thresholds are established without

recognizing the influence on air pollution, greenhouse gases (GHG), and energy consumption.

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The exclusive use of delay-based vehicle LOS does not provide information about the potential effect on air pollutant emissions, GHG generation, or energy consumption which are all important impact analysis topics under CEQA. This problem is exacerbated by the fact that many public agencies have established vehicle LOS thresholds without recognizing the important role speed plays in generating emissions. GHGs and air pollutants are emitted from vehicles at different rates depending on the traveling speeds of the vehicles because speed influences fuel

consumption (i.e., high speeds above 55 miles per hour or low speeds stemming from stop and go traffic conditions burn the most fuel per mile). Since an LOS threshold will influence roadway design and therefore the prevailing travel speeds of automobiles, it will also influence the amount of GHGs and air pollutants that are generated. The LOS threshold that generates the least amount of GHGs or air pollution may not be the same as that desired to minimize delay. 4) LOS thresholds are used to determine roadway sizes and speeds, which influences land use

form and traffic safety.

Many jurisdictional LOS policies require that transportation facilities be designed to achieve a specific vehicle LOS often without recognizing how the size of roadways influences land use form. Multi-lane roadways can create physical barriers between land uses and result in large

intersections that are not conducive to a quality walking and bicycling environment because they create longer distances between land uses and result in lower density development (refer to Exhibit 1 below).

Exhibit 1 - This exhibit illustrates the consequences to pedestrian and bicycle crossing distances

of widening an intersection to improve vehicle LOS.

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Wide multi-lane roadways typically have higher travel speeds that can result in more severe collisions as displayed in Exhibit 2 below. Hence, mitigation designed to improve vehicle LOS may have offsetting impacts on traffic safety because the severity of collisions also increases with speed.

Exhibit 2 – Influence of Speeds on Pedestrian Collision Severity

5) LOS thresholds discourage infill development where higher traffic levels exist and encourage development in outlying areas with minimal traffic.

Another important land use form effect is related to the location of new land use development. Infill development is often accompanied by significant traffic mitigation because existing roadways are already heavily utilized and nearing the locally established LOS thresholds. Any additional trips are likely to trigger vehicle LOS impacts, which often cannot be mitigated due to constrained right-of-way. Suburban or rural development sites are more attractive because projects can avoid potential vehicle LOS-related impacts and the associated mitigation costs because the local roadway network is typically operating under capacity. However, these same suburban or rural developments may have the effect of increasing traffic on regional roadways, and leading to an overall increase in GHGs and emissions affecting air quality. The effects on regional roadways is exacerbated since LOS mitigation often occurs for local streets and intersections, but there is no funding mechanism and limited CEQA analysis for the impacts on regional roadways.

Most of the limitations of vehicle LOS noted above are related to its use in environmental impact analysis. Cities and counties still have the discretion to use vehicle LOS in transportation planning

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to help determine the size and extent of the roadway network. Use of vehicle LOS for this purpose should consider whether recommended roadway changes are compatible with the community’s values related to desired land use patterns, quality of the walking and bicycling network, transit utilization, and environmental resource protection.

Vehicle Miles Travelled (VMT)

VMT does not directly measure traffic operations but instead is a measure of network use or efficiency, especially if expressed as a function of population or employment (i.e., average daily vehicle miles travelled per capita). However, one way to use VMT to help assess traffic operations is to measure VMT that occurs during peak periods or on congested roadways (i.e., congested VMT). Congested VMT is commonly measured by accumulating VMT on roadway links with volume to capacity ratios greater than 1.0 while peak period VMT tends to isolate the portion of daily VMT occurring during the morning and evening commute periods (e.g., 6-9 AM and 4-7 PM). Efforts to reduce peak period or congested VMT can have the co-benefit of reducing travel delays presuming the level of improvement does not induce new vehicle travel.

Also, VMT is directly related to fuel consumption and is routinely used in CEQA analysis to estimate air pollution emissions, greenhouse gases (GHGs), and energy consumption. VMT is typically calculated using travel demand models, which estimate the total number and length of vehicle trips for a given area. VMT can also be calculated using spreadsheet models especially for land use development projects. These calculations are based on vehicle trip generation estimates multiplied by trip lengths. Trip rates and trip lengths should come from locally validated sources such as household travel surveys, mobile device data, and local trip generation studies. In absence of those data sources, statewide or national data can be substituted such as using the ITE Trip Generation Manual for vehicle trip rates.

These models use a combination of transportation engineering methods, validation based on certain conditions, and assumptions regarding current and future land use to make these estimates. Exhibit 3 shows the MTC travel demand model estimates for total VMT generated by both Bay Area and Marin County residents, separated by jurisdiction, in 2015. VMT tends to increase as land use density decreases and travel becomes more reliant on the use of automobiles due to the long distances between origins and destinations. Income also influences the use of vehicles. People with higher incomes tend to make more vehicle trips and travel further distances. The results in Exhibit 3 generally align with these tendencies.

Novato’s average daily VMT per capita as shown in Exhibit 3 is 20% higher than the Bay Area average, but comparable to other Marin communities. These VMT patterns are largely due to lower densities and higher income levels which make driving more affordable.

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Exhibit 3: Average Daily VMT Per Capita (Generated by Residents), from MTC Travel Model

The shift to VMT for environmental impact analysis does require lead agencies to consider multiple steps as part of the implementation process depending on the type of project under analysis.

Generally, a VMT analysis for CEQA purposes includes the following steps1:

1. Establishing baseline VMT levels (based on observed data or travel forecasting models) 2. Setting VMT thresholds for project and cumulative conditions

3. Estimating and forecasting project and cumulative VMT effects

4. Comparing project and cumulative VMT estimates/forecasts to the VMT thresholds to determine significant impacts.

Setting thresholds is one of the more challenging steps in the process and deserves special attention from lead agencies given the role that VMT plays in other environmental impact topics as explained in the next section.

1

More detailed annotated flowcharts showing these steps for a general plan, a land use project, and a

transportation project are included in Appendix A to this memorandum. 0.0 5.0 10.0 15.0 20.0 25.0

Average Daily VMT Generated by Residents Bay Area Average

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SETTING VMT SIGNIFICANCE THRESHOLDS

Since SB 743 introduces a new mandatory metric for use in transportation impact analysis, lead agencies will be required to determine what constitutes acceptable versus unacceptable levels of VMT for CEQA analysis. Specific effects and outcomes from the shift to VMT analysis will depend on the VMT thresholds a jurisdiction establishes for land use and transportation projects. These thresholds will define what constitutes an acceptable level of VMT and what requires mitigation actions. This process is generally referred to as establishing significance thresholds and is governed by CEQA Section 15064.7, which states the following.

15064.7. THRESHOLDS OF SIGNIFICANCE. (a) Each public agency is encouraged to develop and publish thresholds of significance that the agency uses in the determination of the significance of environmental effects. A threshold of significance is an identifiable quantitative, qualitative 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. (b) Thresholds of significance to be adopted for general use as part of the lead agency’s environmental review process must be adopted by ordinance, resolution, rule, or regulation, and developed through a public review process and be supported by substantial evidence. (c) When adopting thresholds of significance, a lead agency may consider thresholds of significance previously adopted or recommended by other public agencies or recommended by experts, provided the decision of the lead agency to adopt such thresholds is supported by substantial evidence.

Following these recommendations are useful in establishing clarity and consistency in environmental impact analysis. With regards to SB 743 and establishing thresholds for VMT, lead agencies will have at least two options:

1) Rely on VMT threshold recommendations developed by OPR.

In absence of lead agency specific thresholds, VMT impact analysis may rely on the thresholds contained in the OPR SB 743 recommendations once they are final. The current OPR threshold guidance is contained in Technical Advisory on Evaluating Transportation Impacts in CEQA, OPR, January 20, 2016. OPR recommendations for land use project VMT thresholds are set at fifteen

percent below baseline VMT/capita for the city or region in suburban areas; the current

average Novato VMT is around 20 percent higher than the regional average. To achieve a VMT reduction equivalent to 15% below Novato’s baseline average, a typical new suburban

development project located further than a half-mile from a transit facility (such as a SMART station) would likely have to incorporate project changes and/or transportation demand management (TDM) measures, which will be discussed in more detail in the next section of this report. For projects not able to reach this maximum level of reduction, VMT impacts would remain significant and unavoidable, and preparation of an environmental impact report (EIR) would be necessary, with approval of impact override findings for project approval.

2) Develop jurisdiction-specific VMT thresholds.

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Jurisdictions will need VMT thresholds for land use plans, development projects, and

transportation projects. Determining when a VMT change represents an unacceptable condition as part of setting a threshold is difficult to establish without linking VMT to other environmental resources and considering its relationship to the built environment and economic factors. VMT by itself is a composite metric that measures the vehicle travel effect associated with land use patterns, amount of growth, and transportation network changes. Further, VMT also varies over time as a function of economic activity and travel cost. VMT tends to increase with economic activity and decline with higher costs for vehicle travel (i.e., higher gas prices).

VMT with respect to other environmental resources is best understood for its relationship to air pollution and GHGs as well as other effects such as energy consumption and public health. While all of these topics should be addressed in other sections of the environmental document, SB 743 requires the analysis of VMT as a transportation impact and lead agencies will need to adopt VMT thresholds to comply with the law. These thresholds should be supported by substantial evidence as specified in CEQA Guidelines Section 15064.7 and consider all three objectives in SB 743: reduce GHGs, encourage infill development and promote active transportation.

If a lead agency decides to set their own thresholds, those thresholds should be consistent with key regional transportation planning documents, such as Plan Bay Area, this region’s Regional Transportation Plan/Sustainable Community Strategy contains regional and local projections of VMT growth associated with anticipated changes in population, employment, and the regional transportation network. Additional VMT reduction may be achieved at the project level especially through TDM strategies and active transportation network expansion, which are not fully

accounted for in regional level travel forecasting models.

In the case of Novato, a VMT threshold that is consistent with Plan Bay Area could be based on the modeled VMT for both 2015 and 2040, as shown in Exhibits 4 and 5 below (based on the latest Preferred Scenario projections). While the regional change in average daily VMT per capita is expected to be around 10 percent lower, the change in average VMT per capita for Novato is expected to be only three percent lower. These modeled VMT estimates reflect the land use and transportation changes expected in the Bay Area through 2040, and may be used to help establish rationale for a local VMT impact threshold. For example, Novato’s current average daily VMT/capita is 19.0 miles. If Novato adopts the OPR

recommended land use project threshold (a 15 percent reduction), then individual development projects would be expected to generate VMT per capita levels that are no higher than 16.2 VMT (19 x .85) per capita per weekday or risk generating a significant impact. If instead, the City relied on MTC’s Plan Bay Area modeling to justify its threshold, then the threshold would be 18.4 VMT per capita per weekday (a three percent reduction from the current citywide average of 19.0 VMT per capita).

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Exhibit 4: Plan Bay Area Projected Change in Average Daily Home VMT Generated by Residents, 2015 to 2040

Exhibit 5: Plan Bay Area Projected Change in Average Daily Work VMT Generated by Workers, 2015 to 2040 Bay

Area Marin County Novato

2015 15.3 19.0 19.0 2040 13.8 18.4 18.6 2015 2015 2015 2040 2040 2040 0.0 2.0 4.0 6.0 8.0 10.0 12.0 14.0 16.0 18.0 20.0 A ve rag e D ai ly VM T p e r Cap ita (R e si d e n ts) Bay

Area Marin County Novato

2015 22.7 31.4 30.4 2040 20.3 29.3 29.2 2015 2015 2015 2040 2040 2040 0.0 5.0 10.0 15.0 20.0 25.0 30.0 35.0 A ve rag e D ai ly Wor k VM T p e r Wor ke r

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As shown in the above charts, VMT is typically calculated based on one of two groups: vehicle trips made by residents to and from their homes (Exhibit 4) and vehicle trips made by workers to and from their jobs, as well as trips made while at work (Exhibit 5). In many cases, work VMT generated by workers may also be counted as home VMT generated by residents in another city or jurisdiction. This illustrates that it’s important to consider that most local land use development projects do not affect the region’s total population or employment levels; VMT analysis indicates a shifting in travel patterns to different areas of the region, rather than the generation of new trips. In almost all land use decisions, a change in general plan land use and underlying zoning will only affect the allocation of future growth within a region rather than the total level of growth. VMT increases or decreases due to a change in auto mode share or average trip length when development occurs in different contexts.

MITIGATION OPTIONS FOR LAND USE PLANS, LAND USE DEVELOPMENT PROJECTS, AND TRANSPORTATION PROJECTS

VMT mitigation typically involves modifying the project to reduce its VMT generation or VMT effect (such as inducing additional vehicle trips through an expanded roadway). This is a different focus compared to current transportation impact practice where the use of vehicle LOS usually involves modification of the external roadway network to increase capacity. This traditional form of mitigation may lead to induced vehicle travel leading to even more VMT, due to roads with increased capacity inducing higher speeds and more vehicle travel.

Mitigation Options for Land Use Plans and Development Projects

As explained above, the use of VMT changes the focus of transportation impact analysis and mitigation. In some cases, this change could be substantial for jurisdictions and developers comfortable with current practice where transportation impacts and mitigation largely affect the external roadway network. With the impact spotlight shining on VMT, more attention will center on the project’s physical design and whether it incorporates strategies to reduce vehicle use and encourage active (pedestrian and bicycle) transportation and transit use.

To reduce VMT for mitigation purposes, the type of project matters. For large area land use plans such as general plans and specific plans, mitigation will typically focus on physical design elements related to the ultimate built environment, which includes the density and mix of land uses in and around the project area plus the availability and quality of the transportation network related to transit, walking, and

bicycling. This will encourage infill development near transit facilities, as well as improvements in the local bicycle and pedestrian network. As project scale shrinks, transportation demand management (TDM) strategies become more relevant especially when they can be tied directly to the ultimate project occupants or tenants. Key references describing various VMT reduction strategies as well as their effectiveness at reducing VMT are listed below:

Quantifying Greenhouse Gas Mitigation Measures, CAPCOA, 2010

 SB 375 Research on Impacts of Transportation and Land Use-Related Policies, California Air Resources Board - https://arb.ca.gov/cc/sb375/policies/policies.htm

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 Integrating Demand Management into the Transportation Planning Process: A Desk Reference, FHWA, 2013 - http://ops.fhwa.dot.gov/publications/fhwahop12035/fhwahop12035.pdf The commonly used guidance document prepared by the California Air Pollution Control Officers Association (CAPCOA) document contains the following matrix that organizes various VMT reduction strategies into groups. Part of this organization is to help identify the maximum level of expected reduction based on project location (community type). However, the CAPCOA guidance offers a

maximum VMT reduction potential of only 10% from the totality of these measures for projects located in suburban settings, and up to 15% for projects in a “suburban center” such as downtown Novato or areas within a half mile of a major transit facility or corridor (which includes sites in designated “Priority Transit Areas”). Therefore, new development projects not within a Priority Transit Area would struggle to mitigate VMT increases to the 15% reduction level recommended by the OPR guidelines.

The CAPCOA document generally presents VMT reduction strategies for development projects as one of three basic intervention types:

 Project Type and Location (such as increased density, location near transit and services, adding mixed-use components to a project, including affordable housing units, , or providing enhanced pedestrian access),

 Transportation programs (such as shuttle service to SMART, providing transit pass subsidies and parking cash-outs, marketing, alternative work schedules and carshare provision), and

 Public amenities (including improvements to the bicycle and pedestrian network, or funding transit service expansion).

The CAPCOA matrix below identifies assumed percent VMT reductions from many of these strategies. Strategies without identified percentages are not quantifiable or require additional study, but may still help to encourage use of non-auto modes.

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Mitigation Options for Transportation Projects

The California Air Resource Board website noted above also contains transportation-related policy options, which can be used as mitigation for land use or transportation projects. Based on the current OPR guidance, the only transportation projects likely to have VMT impacts are larger roadway capacity expansion projects. Transit, bicycle, pedestrian, and smaller roadway modifications would be presumed to have a less than significant impact because they would either help to reduce VMT or cause negligible VMT

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increases. Mitigation for larger roadway projects may need to consider potential modifications to the project that would minimize VMT increases possibly through managed lane operation (i.e., construction of high-occupancy vehicle lanes instead of general purpose lanes) or integration of transit, bicycle, or pedestrian facilities into a project that increases non-auto travel.

LIKELY EFFECTS OF VMT ANALYSIS ON LAND USE AND TRANSPORTATION PROJECTS

The currently proposed modifications to the CEQA Guidelines from OPR would generally not require a comprehensive VMT analysis for development projects located within one-half mile of either a major transit stop, such as a SMART station, or a stop along an existing high quality transit corridor (15-minute or less headways) as having a less than significant transportation impact, provided they also have a floor-area ratio of at least 0.75. CEQA already provides statutory exemptions for most projects within such a Transit Priority Area. In addition, the draft CEQA Guidelines suggest additional potential criteria for the types of projects that may warrant analysis; projects which have a minimal impact on transportation, which is defined as generating 100 or more additional vehicle trips per day may not require a full impact analysis. Examples of developments that typically generate around 100 daily vehicle trips include a 15-unit apartment building, ten detached single family homes, or 9,000 square feet of office space.

For a suburban community like Novato, new development projects located beyond a half-mile from a SMART station will be affected by the change in CEQA transportation analysis and thresholds. Single-family or low-density multi-Single-family projects which are not close to transit and services generally will be unable to meet the 15% VMT reduction recommended by the OPR guidelines. Moderate density housing projects in areas with a diversity of land uses will likely be able to achieve the prescribed VMT reductions. For non-residential projects there are more options for reducing employee-based work trips through transportation demand management (TDM) techniques such as flexible work hours, funding employee car/van pools, subsidizing transit tickets, providing shuttles to SMART stations, etc. Imposition of such TDM mitigation measures will also require that cities provide long-term monitoring of businesses to assure that these programs and measures remain active.

Finally, transportation projects generally would not require a VMT impact analysis unless they were considered large enough to produce an increase in overall vehicle trips on the roadway segment being studied. In the case of Novato, small projects such as the gap closure on Novato Boulevard would be unlikely to require analysis; however, adding capacity at the San Marin / Redwood / US-101 interchange may require consideration of potential induced vehicle travel.

CONTINUED USE OF LOS AFTER SB 743

As noted above, cities and counties can continue to use vehicle LOS as part of their transportation planning and entitlement review. The only restriction will be its use as the basis for determining significant environmental impacts. The loss of vehicle LOS in CEQA could reinforce the importance of general plans and supporting implementation methods (such as impact fee programs) as the primary means for defining a jurisdiction’s policy approach to transportation.

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POLICY CHOICES

The City Council can consider several approaches to setting VMT thresholds in compliance with SB743, as well as for establishing the community’s transportation and circulation expectations through the General Plan.

1. OPTIONS FOR ADOPTING VMT THRESHOLDS FOR GENERAL PLAN UPDATE CEQA STUDY The General Plan Update will undergo environmental review prior to full adoption of SB743, which is anticipated to be fully implemented by 2019. However, Caltrans has recently adopted the OPR draft guidelines, and, as a commenting agency, may request VMT analysis be included in the general plan. Therefore, a VMT analysis for the General Plan may need to be completed during the environmental impact assessment stage.

a. Use OPR Plan-Level VMT Thresholds for General Plan environmental review process. Pros: Provides simple guidance for thresholds that are known to be consistent with

most up-to-date state-level guidance; Caltrans is likely to refer to these thresholds in their review of transportation impacts of land use plans and land use projects in absence of locally established thresholds.

Cons: OPR Thresholds may not fully reflect the local transportation context. They also may present unrealistic mitigation goals for new development projects in Novato. b. Adopt (i.e., through resolution or ordinance) jurisdiction-specific VMT thresholds.

Pros: Allows for locally-based determination of what constitutes an environmental impact. Also allows for adjustments to realistic TDM-based and project-based mitigation goals.

Cons: City staff would need to establish substantial evidence for the specific adopted thresholds. This is particularly important if the thresholds deviate from the OPR recommendations or are inconsistent with the RTP/SCS developed by MTC. Such an effort would require the assistance of a CEQA attorney and transportation consultant with experience in VMT modeling and corresponding mitigation measures. Such a study to create justification for a local threshold and adoption by the City Council would take a number of months and would delay completion of the General Plan EIR and adoption of the new General Plan. In addition, the currently available VMT models would be those created by Caltrans or MTC, which are not highly refined for use at the local level.

c. Perform a VMT analysis as part of the General Plan EIR for informational purposes

only.

Pros: Allows for a comparison of the General Plan’s compliance with both the recommended OPR significance threshold (15% reduction) and a

locally-proposed alternative threshold, well in advance of actually having to adopt a local threshold prior to implementation of the CEQA change in 2017. Such a local

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alternative might be based on the rationale discussed above, utilizing the VMT reduction assumed in Plan Bay Area for Novato between 2010 and 2040. Cons: None, other than this is not legally mandated analysis until the CEQA change

goes into effect.

2. OPTIONS FOR ADOPTING VMT THRESHOLDS FOR FUTURE DEVELOPMENT AND TRANSPORTATION PROJECT CEQA STUDIES

a. Use OPR VMT thresholds for all future projects requiring environmental review. Pros: Provides simple guidance for thresholds that are known to be consistent with

most up-to-date state-level guidance; Caltrans is likely to refer to these

thresholds in absence of locally established thresholds. The City may have few if any transportation project significant impacts since the OPR guidance tends to presume that small roadway expansions, all transit, and all bicycle and pedestrian projects have less than significant VMT impacts.

Cons: OPR thresholds may not fully reflect the local transportation context, or present realistic mitigation goals for development in Novato. Individual land use projects would need to achieve VMT levels that are 15 percent below baseline conditions, which exceeds the maximum reduction potential of 10 percent for a suburban area based on research and guidance from the California Air Pollution Control Officers Association (CAPCOA).

b. Develop project level VMT thresholds through General Plan Update process and

include in adopted General Plan.

Pros: Allows for locally-based determination of what constitutes an environmental impact, and can be informed by technical investigation and public outreach during the General Plan Update process. Also allows for adjustments to realistic TDM-based and project-based mitigation goals. Documentation of consistency with RTP and SCS can be achieved as part of the General Plan review process. Cons: City staff would need to establish substantial evidence for the specific adopted

thresholds. Such an effort would require the assistance of a CEQA attorney and transportation consultant with experience in VMT modeling and corresponding mitigation measures. Such a study to create justification for a local threshold and adoption by the City Council would take a number of months and would delay completion of the General Plan EIR and adoption of the new General Plan. In addition, the currently available VMT models would be those created by Caltrans or MTC, which are not highly refined for use at the local level.

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c. Add a program to the Draft General Plan calling for preparation of a project level

VMT threshold subsequent to adoption of the new General Plan.

Pros: Allows for locally-based determination of what constitutes an environmental impact. Also allows for a more deliberative process to study and adopt such a threshold, including use of a more refined transportation model for VMT analysis being developed by the Transportation Authority of Marin (completion estimated in one year) and would benefit from the General Plan EIR informational analysis of VMT suggested in Option 1c above.

Cons: Not necessary if there is intent to simply utilize the OPR recommended threshold.

3. OPTIONS FOR GENERAL PLAN LEVEL OF SERVICE POLICY

a. Retain LOS criteria in General Plan and require project-level LOS analysis and

compliance

Pros: Continues to provide a detailed assessment of the effects of individual land use projects on traffic operations and an opportunity to require improvements from projects due to impacts on local roadway capacity and delay.

Cons: Requires substantial staff time and developer cost to prepare and review individual Traffic Impact Analysis reports even for land use projects consistent with the General Plan.

b. Retain LOS criteria in General Plan, for use as a metric in preparing transportation

plans and revenue programs but not CEQA documents for projects consistent with the General Plan, and implement a traffic impact fee program plus any

supplemental funding mechanisms to fully fund the general plan circulation improvements designed to meet future LOS expectations under the general plan horizon year.

Pros: Provides a streamlined review and permitting process for land use projects included in the General Plan. Provides clarity to developers regarding the

assessment of traffic impact fees. Still allows for additional review of traffic effects for projects not included in General Plan.

Cons: May provide a less detailed picture of transportation network effects of any given project, or projects which differ substantially from assumptions made in setting the impact fee, thereby not requiring additional and sufficient mitigation of localized LOS impacts. Requires resources to develop and implement the fee program and any supplemental funding mechanisms that may not be available.

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c. Eliminate LOS criteria from General Plan and rely only on VMT analysis in CEQA

reviews

Pros: Further streamlines project review and permitting process for all projects (both those included in the General Plan and those not included in the General Plan). Cons The development and environmental review processes would no longer provide

traffic operations or network performance information related to delay or travel

time. These measures are generally important to residents, workers, business

owners, and visitors.

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P a g e | 20 APPENDIX A

SB 743 General Plan Flowchart

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SB 743 Land Use Project Flowchart

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SB 743 Transportation Project Flowchart

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