06 Staff Report.VMT Thresholds
PREPARED BY: Ying Smith
Transportation and Mobility Manager
Reviewed by: Town Manager, Assistant Town Manager, Town Attorney, Community Development
Director, and Parks and Public Works Director
110 E. Main Street Los Gatos, CA 95030 ● 406-354-6832
www.losgatosca.gov
TOWN OF LOS GATOS
COUNCIL AGENDA REPORT
MEETING DATE: 11/17/2020 ITEM NO: 6
DATE: November 13, 2020
TO: Mayor and Town Council
FROM: Laurel Prevetti, Town Manager
SUBJECT: Adopt A Resolution Designating the Use of Vehicle Miles Traveled as the
Metric for Conducting Transportation Analyses Pursuant to the California
Environmental Quality Act and Establishing the Thresholds of Significance to
Comply with California Senate Bill 743
RECOMMENDATION:
Adopt a Resolution (Attachment 1) designating the use of vehicle miles traveled as the metric
for conducting transportation analyses pursuant to the California Environmental Quality Act
and establishing the thresholds of significance to comply with California Senate Bill 743.
BACKGROUND:
On September 27, 2013, Governor Jerry Brown signed Senate Bill (SB) 743 into law which
started a process to change transportation impact analysis for purposes of CEQA compliance.
The new law directed the Governor’s Office of Planning and Research (OPR) to update the CEQA
Guidelines to include new criteria and metrics for determining the significance of transportation
impacts. OPR selected vehicle miles traveled (VMT) as the new transportation impact metric,
recommended its application Statewide, and submitted updates to the CEQA Guidelines that
were certified by the Natural Resources Agency in December 2018.
The Town of Los Gatos is the lead agency for environmental clearance under CEQA for projects
within the Town’s jurisdiction. Fehr & Peers has been hired to assist the Town in preparing its
Transportation Analysis Policy and Guidelines using VMT and any other updates to the Town’s
local transportation policies, as the Council deems appropriate.
The Town Council and Planning Commission held a joint Study Session on October 8, 2019 on
the topic as an introduction to the new requirements, concepts, and other provisions. At its
PAGE 2 OF 9 SUBJECT: Resolution Designating the Use of Vehicle Miles Traveled as the Metric for Conducting Transportation Analyses Pursuant to the California Environmental Quality Act and Establishing the Thresholds of Significance to Comply with California Senate Bill 743 DATE: November 13, 2020
BACKGROUND (continued):
January 21, 2020 meeting, the Town Council discussed how vehicle miles travelled (VMT) and
level of service analysis (LOS) would work together in evaluating future development projects.
A document titled SB 743 Implementation Decisions for the Town of Los Gatos was completed
by Fehr & Peers in July 2020. This document provides background on the changes in the
California Environmental Quality Act (CEQA) Transportation Analysis and technical information
pertaining to decisions the Town Council will need to make. The Executive Summary is included
as Attachment 2 and the entire document is available on the Town’s VMT webpage:
https://www.losgatosca.gov/2563/Vehicle-Miles-Traveled---VMT
DISCUSSION:
The Town of Los Gatos, as a lead agency, is required to make several key policy decisions in
compliance with SB 743 and the CEQA Guidelines expectations, which are grouped by specific
decision categories (1) VMT metrics, (2) VMT calculation methods, (3) VMT significance
thresholds, and (4) VMT mitigation actions. This staff report focuses most of the discussion on
the thresholds and the staff recommendation addresses the first three decisions in the list.
Since SB 743 introduces a new mandatory metric for use in CEQA analysis, lead agencies will
need to determine what constitutes acceptable and unacceptable levels of VMT. This process is
generally referred to as establishing significance thresholds. At the February 18, 2020 meeting,
the Town Council was presented with two threshold setting options and it approved the option
to set thresholds consistent with the General Plan future year Vehicle Miles Traveled
projections.
VMT and the Local Context
VMT is an output of land use and transportation network infrastructure decisions and is most
meaningful when expressed as a Town-wide value for roadways equal or greater in size to
arterial roadways. Statewide goals consider blended major metropolitan areas as well as more
suburban areas like Los Gatos that are on the fringe of more intensely developed areas.
Statewide goals may be more difficult to achieve for jurisdictions like Los Gatos where
significant transit, jobs, and development density do not exist. This makes achieving standards
recommended by agencies like the California Air Resource Board (CARB) stretch goals in and of
themselves.
PAGE 3 OF 9 SUBJECT: Resolution Designating the Use of Vehicle Miles Traveled as the Metric for Conducting Transportation Analyses Pursuant to the California Environmental Quality Act and Establishing the Thresholds of Significance to Comply with California Senate Bill 743 DATE: November 13, 2020
DISCUSSION (continued):
Context for Setting VMT Impact Thresholds
California law states that the criteria for determining the significance of transportation impacts
should promote: (1) reducing of greenhouse gas emissions; (2) encouraging infill development;
and (3) promoting active transportation. SB 743 changes the focus of transportation impact
analysis in CEQA from measuring impacts to drivers, to measuring the impact of driving. The
Town has discretion to set its significance threshold for VMT impacts, provided that the basis
for that threshold is grounded in substantial evidence. To establish VMT impact significance
thresholds for land use projects and land use plans in the Town of Los Gatos, two questions
must be answered:
• What is the VMT impact significance threshold for land use projects and land use plans
under baseline conditions?
• What is the VMT impact significance threshold for land use projects and land use plans
under cumulative conditions?
The SB 743 Implementation Decisions for the Town of Los Gatos document discusses each of
these questions in greater detail.
Methodology Used for Future Year VMT Projections
In coordination with Town staff, Fehr & Peers applied the latest Santa Clara County Valley
Transportation Authority (VTA) travel forecasting model to prepare VMT estimates in 2040
conditions at the Town, the County, and the Bay Area region levels. Fehr & Peers used the
preferred land use alternative framework for the 2040 Los Gatos General Plan approved by the
Town Council on April 7, 2020 as the project description for the VMT assessment. The
transportation network was assumed to be the same as in the VTA model in the 2040 scenario.
The total project generated VMT is the expected VMT growth in all vehicle trips, vehicle types,
and trip purposes for all project land uses, divided by the sum of residents plus employees. The
Town’s total projected VMT growth rate, or “budget,” was established by the Town’s General
Plan transportation network and land use growth assumptions.
As shown in Figure 1 under existing conditions (2015), the Town of Los Gatos has a total VMT
per service population that is greater than both the Santa Clara County and the Bay Area
region. In 2040, the Town’s project generated VMT per service population trends higher than
existing conditions (2015). In comparison, in 2040 Santa Clara County total VMT per service
population is decreasing and the Bay Area region total VMT per service population is remaining
PAGE 4 OF 9 SUBJECT: Resolution Designating the Use of Vehicle Miles Traveled as the Metric for Conducting Transportation Analyses Pursuant to the California Environmental Quality Act and Establishing the Thresholds of Significance to Comply with California Senate Bill 743 DATE: November 13, 2020
DISCUSSION (continued):
constant. This upward trend in the total VMT per service population in Los Gatos is an
important observation that has helped Town staff with recommending a Town specific VMT
threshold and a VMT mitigation action approach that would apply under baseline and
cumulative conditions.
Another way to illustrate the Town’s expected VMT growth is through measuring boundary
VMT. Boundary VMT is a VMT metric that measures the VMT on the jurisdictions roadway
system. As Shown in Figure 2, the boundary VMT in the Town of Los Gatos increases from
1,195,940 in 2015 to 1,321,680 in 2040. The boundary VMT on local streets and freeways is
expected to grow by 10.5 percent within the Town of Los Gatos, which is nearly twice the
amount of boundary VMT growth contained in the State goals.
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DISCUSSION (continued):
Range of Thresholds of Significance Options
The Town’s General Plan includes underlying expectations of how population and employment
will change between the base year and future year scenarios. Because VMT is a composite
metric that is an output of combining long-term population and employment growth
projections with long-term transportation network infrastructure – the Town of Los Gatos
effectively already has a VMT growth budget (i.e., how much VMT growth is anticipated, where
that growth will occur and in what forms) that has already been planned for and determined to
be acceptable in the Los Gatos 2020 General Plan.
With this concept in mind, Table 1 provides a summary of the VMT threshold options with
percent reductions or increases expressed relative to the baseline VMT metrics. The project
team developed four possible VMT threshold options with the possibilities bracketed by a net-
zero Town-wide total project generated VMT per service population rate (option 1) and a net-
zero Town-wide total project generated VMT option (option 4). The options include:
Threshold Option 1: Greatest VMT Growth. This is a zero growth Town-wide total
project generated VMT per service population rate option. This jurisdiction specific
VMT threshold option would be consistent with the existing General Plan and treats
existing and future land development with the same total project generated VMT per
service population rate. This option aligns with the preferred land use alternative
currently under consideration for the General Plan update.
Threshold Option 2: Some VMT Growth. This threshold option supports State goals
pertaining to air quality, greenhouse gases (GHG) reductions, and energy conservation
by only allowing a 6.5% increase in Town-wide project generated VMT. The threshold
would be an 11.3 percent reduction in the total project generated VMT per service
population rate from baseline conditions. This option aligns with CARB targets for total
VMT reductions.
Threshold Option 3: Some VMT Growth. This threshold supports State goals pertaining
to air quality, GHG reductions, and energy conservation by reducing the total project
generated VMT per service population rate by 14.3 percent from baseline conditions.
Threshold Option 4: No (Net Zero) VMT Growth. This is a net-zero Town-wide total
project generated VMT threshold. This “Net Zero VMT Threshold” would establish any
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DISCUSSION (continued):
increase in the Town-wide VMT generated by a new development project in the Town of
Los Gatos would constitute a significant impact. This is similar to Caltrans draft guidance
for State highway projects. The threshold would be a 16.7 percent reduction in the total
project generated VMT per service population rate from baseline conditions.
Table 1 –VMT Threshold Options
Threshold Options
Total Project Generated
VMT per Service
Population
Total Project Generated
VMT
Baseline 33.6 1,888,010
1. Greatest VMT Growth (20%
Increase in Baseline VMT)
33.6
(0% change in baseline
VMT rate)
2,264,980
(20% increase in baseline
VMT)
2. Some VMT Growth (CARB
Capacity for VMT Growth = 6.5%)
29.8
(-11.3% reduction from
baseline VMT rate)
2,010,730
(6.5% increase in baseline
VMT) 3. Some VMT Growth (CARB
14.3% Reduction from Existing
Needed in 2050)
28.8
(-14.3% reduction from
baseline VMT rate)
1,941,410
(2.8% increase in baseline
VMT)
4. No VMT Growth (0% Change
from Baseline VMT)
28.0
(-16.7% reduction from
baseline VMT rate)
1,888,010
(0% increase in baseline
VMT)
DISCUSSION (continued):
Among these threshold options, staff recommends threshold option 2 because it aligns with the
CARB’s Statewide capacity for VMT Growth of 6.5% in total project generated VMT and is
supportive of the State’s goal. Even with robust VMT mitigation actions as discussed in the
following paragraphs, this threshold is still considered a stretch goal in the local setting. It is
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possible that the General Plan update may result in VMT growth that exceed one or more of
the significance thresholds proposed, therefore a significant impact would likely occur.
For all land use and transportation projects, a significant impact would occur if the project is
inconsistent with the Regional Transportation Plan/Sustainable Community Strategy Plan (Plan
Bay Area). Inconsistency with the Plan Bay Area would be evaluated by determining if the VMT
for the project increases or decreases the VMT assumed in the RTP/SCS.
VMT Mitigation Actions
Lead agencies making the transition to VMT are realizing the challenges of trying to mitigate
VMT on a project-by-project basis. Much of this difficulty arises from the regional nature of
VMT impacts, as well as the complexity of underlying factors influencing VMT generation.
For area plans such as general plans and specific plans, mitigation will typically focus on physical
design elements related to the ultimate built environment, such as the density and mix of land
uses as well as the availability and quality of the transportation network related to transit,
walking, and bicycling.
The SB 743 Implementation Decisions for the Town of Los Gatos document describes existing
VMT mitigation programs and emerging VMT mitigation concepts, as well as several
implementation strategies. The recommended path to establish thresholds will support the
Town’s ability to adopt Town-wide mitigation actions in parallel with the General Plan update.
Many of the viable mitigation measures will be identified as a part of the CEQA analysis
conducted for the General Plan update. Through this process, it is unlikely that the Town will
be able to achieve VMT reduction targets through new development alone. Adding efforts,
such as the Connect Los Gatos program that have the potential for reducing VMT on existing
conditions and reliance on regional or statewide regulation may be necessary to achieve
targeted reductions.
CONCLUSION:
In alignment with the approach to set thresholds consistent with the General Plan future year
Vehicle Miles Traveled projections, staff recommends that Town Council establishes VMT
thresholds of significance for both baseline and cumulative conditions consistent with threshold
option 2 (see Table 1) and as defined in Table 2. These proposed thresholds are outlined below
PAGE 8 OF 9 SUBJECT: Resolution Designating the Use of Vehicle Miles Traveled as the Metric for Conducting Transportation Analyses Pursuant to the California Environmental Quality Act and Establishing the Thresholds of Significance to Comply with California Senate Bill 743 DATE: November 13, 2020
and are included in Exhibit A of the Resolution of Adopting VMT Thresholds of Significance
(Attachment 1). Substantial evidence to support the establishment of these thresholds is
included in the SB 743 Implementation Decisions for the Town of Los Gatos document.
Table 2 – Recommended VMT Thresholds of Significance
Baseline Thresholds
A.1. Land Use
Projects
Project Impact: A significant impact would occur if the total VMT per
service population for the project would exceed a level of 11.3% below
the total VMT per service population for the Town of Los Gatos
baseline conditions.
Project Effect: A significant impact would occur if the project increases
total (boundary) County-wide VMT by 6.5% compared to baseline
conditions.
A.2. Land Use Plans
Project Impact: A significant impact would occur if the total VMT per
service population for the plan area would exceed a level of 11.3%
below the total VMT per service population for the Town of Los Gatos
baseline conditions.
Cumulative Thresholds
B.1. Land Use
Projects
Project Effect: A significant impact would occur if the project increases
total (boundary) countywide VMT by 6.5% compared to cumulative no
project conditions.
B.2. Land Use Plans
Project Effect: A significant impact would occur if the project increases
total (boundary) County-wide VMT by 6.5% compared to cumulative no
project conditions.
B.3. All land use
and transportation
projects
A significant impact would occur if the project is inconsistent with the
Regional Transportation Plan/Sustainable Community Strategy Plan
(Plan Bay Area).
NEXT STEPS:
As discussed at the February 18 Town Council meeting, another consideration in setting Los
Gatos specific thresholds is how to address cumulative VMT impacts and whether addressing
them in the General Plan EIR is advantageous for streamlining the review of subsequent land
use and transportation projects given CEQA relief available through CEQA Statute & Guidelines
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Section 15183. This Section relieves a project of additional environmental review if the project-
specific environmental impacts were adequately addressed in the General Plan EIR and the
project is consistent with the General Plan.
In completing the CEQA transition to VMT work, the project team will ensure alignment with
the General Plan update and bring forward potential modifications to other Town
transportation policies, including the vehicle Level of Service (LOS) policy.
The draft Transportation Analysis Policy and Guidelines was completed in July 2020. The
General Plan update CEQA analysis and any modifications to other local transportation policies
will guide the development of the final Transportation Analysis Policy and Guidelines.
COORDINATION:
This report was coordinated with the Community Development Department.
FISCAL IMPACT:
There is no fiscal impact as a result of this report.
ENVIRONMENTAL ASSESSMENT:
This is not a project defined under CEQA, and no further action is required.
Attachments:
1. Resolution Adopting Vehicle Miles Traveled Thresholds of Significance for Purposes of
Analyzing Transportation Impacts Under the California Environmental Quality Act
2. Executive Summary of SB 743 Implementation Decisions for the Town of Los Gatos
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