Concord Naval Weapons Station, Contra Costa County
New Approach to Traffic Impact Assessment
In January of 2016, after 18 months of coordination with stakeholders and public review, the Governor's Office of Planning and Research (OPR) released a revised proposal
for updates to the transportation analysis methodology in the CEQA Guidelines
. If you missed it the first time, take a look at our November 2014 eAlert
for an overview of the original draft and its proposed changes to traffic impact analysis in California. This latest eAlert will summarize the new changes in OPR's revised proposal and highlight the most interesting recommendations that are new or different from the August 2014 preliminary discussion draft.
First, specifications on thresholds, methodology, safety, and mitigation recommendations that OPR originally proposed to include in the Guidelines section now appear in a new draft Technical Advisory section. This change is intended to clarify which elements of the proposal are requirements and which are recommendations, and to outline OPR's technical recommendations and best practices regarding CEQA evaluation of transportation impacts. The Technical Advisory is not regulatory in nature, and agencies may use the information it contains at their discretion. OPR may update this section whenever it is needed, to reflect changes and advances in methodologies and best practices. Notably, a list of suggested mitigation measures and alternatives has been moved to the Technical Advisory section, where it will provide information to agencies while reducing the length and increasing the clarity of the regulatory text itself. The Technical Advisory also contains case studies to help guide agencies through particular scenarios.
San Pablo Reservoir, Contra Costa County
Second, new threshold recommendations are more closely aligned with the State's long-term greenhouse gas emissions reductions goals, and they recognize the diversity of communities in California.
These threshold recommendations come with better access to relevant data, including outputs from Caltrans' Statewide Travel Demand Model
, in an attempt to address concerns around the availability of information like average vehicle miles traveled (VMT) by land type. In the revisions, OPR acknowledges that some variation in thresholds may be appropriate in different regions of California. For example, outside of central urban locations, using a city's average may be appropriate. Or, within unincorporated county areas, using the average of cities in the county may be more appropriate. OPR also acknowledges that to avoid the worst effects of climate change, new development projects must perform significantly better than average on emissions, and the revised threshold recommendations better reflect emissions reductions goals detailed in SB 743, SB 375, and AB 32, among others. Absent any other project-specific information, OPR finds that an estimate of vehicle miles traveled 15 percent below the existing averages for the region or city is reasonable.
OPR updated the methodological recommendations for estimating vehicle miles traveled to include parking as one of several factors that may lead to a determination that a project may have a significant impact on VMT. This change is in response to public comment, and acknowledges that excess parking may indicate higher vehicle miles traveled. As specified in the new
Technical Advisory, if a project includes more parking for resident, customer, or employee use than is required by the jurisdiction, the presumption of a less-than-significant impact for projects near transit stations may not be appropriate. The revised proposal also clarifies which transportation projects could induce additional VMT and which may not.
OPR eliminated transportation safety provisions from the proposed new Guidelines, given the precise nature of that analysis, and has instead described potential considerations, including slower speeds and increasing driver attention, in the Technical Advisory.
Finally the revised proposal recommends a two-year phase-in period during which new procedures would be optional, but allows those agencies ready for the changes to begin implementing them immediately. The two-year phase-in provides a grace period for agencies to adjust and prepare for the transition to the new rules. At the same time, agencies that are already moving ahead and up to speed can opt in to the new rules and make the switch from level of service to vehicle miles traveled immediately. During this time, OPR will monitor implementation and assess whether updates to the Technical Advisory or the Guidelines are needed.
So what hasn't changed from the preliminary discussion draft? Many of the basics. This revised proposal still recommends vehicle miles traveled as the most appropriate measure of a project's transportation impact, and this measure should be used Statewide and not limited to transit priority areas. Bicycle, pedestrian, and transit projects, as well as development projects within one-half mile of a major transit stop, are still considered to have a less-than-significant transportation impact. And the new proposal still recommends that implementation be phased in over time.
OPR accepted comments on the new draft through February 29, 2016. The regulations are expected to go into effect Statewide in 2019.
Springtime on the flanks of Mt. Tamalpais, Marin County
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