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HomeMy WebLinkAboutCity Council Resolution 25-045, Adopting VMT PolicyRESOLUTION NO. 25-045 A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF SARATOGA ADOPTING GUIDELINES FOR EVALUATING VEHICLE MILES TRAVELLED WHEREAS, Senate Bill (SB) 743, enacted in 2013 and codified in Public Resources Code section 21099, requires changes to the California Environmental Quality Act (CEQA) Guidelines regarding the criteria for determining the significance of transportation impacts of projects; and WHEREAS, section 15064.7(b) of the State Guidelines implementing CEQA, Title 14, Section 15000 et seq. (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, in 2018, the Governor’s Office of Planning and Research (OPR) proposed, and the California Natural Resources Agency certified and adopted, new CEQA Guideline section 15064.3 that identifies Vehicle Miles Traveled (VMT) – 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, CEQA Guidelines section 15064.7(a) defines a threshold of significance as “an identifiable quantitative, qualitative or performance level of a particular 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 regulations, 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, 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 Docusign Envelope ID: 9AA64F3A-EA76-4208-96E9-81F8D8F30470 Resolution No. 25-045 Page 2 WHEREAS, this resolution is not a project under the requirements of the California Environmental Quality Act (CEQA), Public Resources Code section 21000 et. seq. and the State CEQA Guidelines (collectively, “CEQA”) because the adoption of a new transportation threshold of significance under the CEQA in accordance with CEQA Guidelines Section 15064.7 does not require environmental review and is not a “project” pursuant to State CEQA Guidelines Sections 15060(c)(3) and 15378 because it does not involve commitment to any particular project. The use of VMT in CEQA review is required under SB 743 and Section 15064.3 of the CEQA Guidelines. The foregoing determination is made by the City Council in its independent judgment. NOW, THEREFORE BE IT RESOLVED, that the City Council of the City of Saratoga does hereby adopt the Senate Bill (SB) 743 and Vehicle Miles Traveled Analysis Guidelines (June 2025) as set forth in Attachment A. The above and foregoing resolution was passed and adopted at a regular meeting of the Saratoga City Council held on the 2nd day of July 2025 by the following vote: AYES: COUNCIL MEMBERS FITZSIMMONS, WALIA, ZHAO, VICE MAYOR PAGE, MAYOR AFTAB NOES: NONE ABSENT: NONE ABSTAIN: NONE Belal Y. Aftab, Mayor ATTEST: Britt Avrit, MMC, City Clerk 1926714.1 Docusign Envelope ID: 9AA64F3A-EA76-4208-96E9-81F8D8F30470 City of Saratoga Senate Bill (SB) 743 and Vehicle Miles Traveled Analysis Guidelines JUNE 2025 SB 743 and VMT Background SB 743 requires lead agencies preparing documents pursuant to the California Environmental Policy Act (CEQA) to replace intersection level of service (LOS) analysis with vehicle miles traveled (VMT) analysis to promote the reduction of greenhouse gas emissions, the development of multimodal transportation networks, and a diversity of land uses. In 2018, CEQA guidelines (Section 15064.3) were updated to include VMT as the most appropriate measure of transportation impacts. The Governor’s Office of Planning and Research (OPR) recommends that jurisdictions replace LOS with VMT based metrics and provided guidance on how to accomplish this. To implement SB 743 and the CEQA guidelines, lead agencies must still make their own specific decisions about VMT methodology, thresholds, and mitigation. The implementation of CEQA guidance in the City of Saratoga is outlined in this document and illustrated on Figure 1. In 2022 and 2023 the City worked with the Metropolitan Transportation Commission’s (MTC) SB 743 Policy Adoption Technical Assistance Program to begin to formulate the City’s VMT approach. Information from MTC’s Technical Assistance Program and Fehr & Peers’ previous work with the City informed the City of Saratoga’s Senate Bill (SB) 743 and Vehicle Miles Traveled Analysis Guidelines presented in this document. Resolution 25-045 Page 3Docusign Envelope ID: 9AA64F3A-EA76-4208-96E9-81F8D8F30470 City of Saratoga SB 743 Guidelines| 2 Figure 1: City of Saratoga Transportation Analysis Process Yes No Yes No Yes No Transportation Analysis (CEQA) Does this project require a General Plan Amendment? Conduct Project Generated VMT Analysis FRQGXFP3URMHFPµV Effect on VMT Analysis Does your project exceed the VMT impact criteria? Identify VMT Mitigation for Significant Impacts Document Findings Is this project exempt from VMT analysis? x Transit Priority Area (TPA) x Low VMT Area x Affordable housing x Local serving retail project x Locally serving public facility Document Findings Conduct Project Generated VMT Analysis Document Findings Resolution 25-045 Page 4 Docusign Envelope ID: 9AA64F3A-EA76-4208-96E9-81F8D8F30470 City of Saratoga SB 743 Guidelines| 3 VMT Screening Criteria Table 1 outlines the VMT screening criteria for land use projects within the City of Saratoga. Projects that meet at least one of the specified screening criteria are not required to conduct a detailed VMT analysis. Even if a project is exempt from VMT analysis, however, it may still be required to evaluate the following CEQA requirements: •Conflicts with a plan, ordinance, or policy addressing the circulation system, including transit, roadways, bicycle lanes, and pedestrian paths; or •Increases hazards due to a geometric design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment); or •Results in inadequate emergency access. Projects may also need to conduct transportation analysis for the City’s development application review process, which include site-access and circulation review and potential intersection operations analyses. The screening criteria are consistent with OPR recommendations, though they are refined for the local context of the City of Saratoga. VMT Analysis Projects that are not screened out and require a VMT analysis should follow the guidelines outlined below for VMT metrics, significance thresholds, screening criteria, and calculation method options. VMT Analysis Scenarios The following four scenarios shall be considered when evaluating VMT in the City of Saratoga. BASELINE WITHOUT PROJECT For compliance with CEQA Section 15125(a), the transportation impact analysis must include a description of the physical environmental conditions near the project, as they exist at the time the notice of preparation is published, or if no notice of preparation is published, at the time environmental analysis is commenced, from both a local and regional perspective. Baseline VMT estimates will be prepared based on the most recent base year of the appropriate VMT calculation tool. BASELINE WITH PROJECT Projects are required to estimate project generated VMT for each land use type under Baseline Plus Project conditions. The project’s land use characteristics will be entered into the model in the appropriate location, a model run will be completed, and the relevant VMT values will be generated. Resolution 25-045 Page 5 Docusign Envelope ID: 9AA64F3A-EA76-4208-96E9-81F8D8F30470 City of Saratoga SB 743 Guidelines| 4 Table 1: VMT Screening Thresholds Screening Type VMT Screening Thresholds Transit Priority Areas (TPA) Project is located within one half-mile of high-quality transit service (defined as a rail station or a bus stop with a line providing service at least every 15 minutes during peak hours) and one quarter-mile walking distance of a high-quality bus stop. TPA areas that meet the high-quality transit service/corridor definitions based on June 2025 VTA bus schedules are illustrated in Figure 2. Each project will need to verify VTA bus schedules at the time of analysis to verify if they qualify for a TPA. TPA screening would not apply if a project meets any of the following criteria: •Provides more parking than required by code •Is less than 0.75 floor area ratio (FAR) •Is inconsistent with Plan Bay Area •Replaces affordable units with a smaller number of market rate units •If project-specific or location-specific information indicates that the project will still generate significant levels of VMT1 Low VMT Area Project is in a TAZ for which existing VMT per capita (for the appropriate metric as discussed in Table 2) is at least 15% below the county average.2 Low VMT Area screening would not apply if a project meets any of the following criteria: •Provides more parking than required by code •Is less than 0.75 FAR •Is inconsistent with Plan Bay Area •Replaces affordable units with a smaller number of market rate units Affordable Housing Projects that include at least 100% affordable housing in infill locations (i.e., development within unused and underutilized lands within existing development patterns). Affordable housing includes those affordable to households making at or below 80 percent of the area median income. Small Projects Residential projects of three or fewer lots, multi-family residential projects of seven units or less, and commercial projects designed for an occupancy load of less than 30 persons are considered to not require a VMT analysis, absent substantial evidence indicating that a project would generate a potentially significant level of VMT. Local Serving Retail Project consists of local-serving retail (grocery store, drug store, bank, gym, etc.) not exceeding 20,000 square feet and can demonstrate they are local serving. Examples that are not considered local serving retail projects include new or unique retail establishments or regional/national retail chains that do not have a physical retail presence within three miles. Local Serving Public Facilities Projects that are government, civic, cultural, health, and infrastructure uses and activity which contribute to and support community needs. Locally serving public facilities include police stations, fire stations, passive parks (parks designed for use in an informal way and typically less developed), libraries, community centers, public utilities, and public schools. Notes: 1.Currently, most areas within the City's TPAs have location-specific information indicating that the project would still generate significant levels of VMT. Individual projects will need to verify if a TPA screening would apply. 2. This threshold does not currently apply to the City of Saratoga, as all TAZ are above the 15% county threshold. Source: Fehr & Peers 2025. Resolution 25-045 Page 6 Docusign Envelope ID: 9AA64F3A-EA76-4208-96E9-81F8D8F30470 Resolution 25-045 Page 7 Docusign Envelope ID: 9AA64F3A-EA76-4208-96E9-81F8D8F30470 City of Saratoga SB 743 Guidelines| 6 YEAR 2040 CUMULATIVE WITHOUT PROJECT Projects requiring a General Plan Amendment or that otherwise propose uses not contemplated by the General Plan are also required to evaluate the project’s effect on VMT under Year 2040 Cumulative Conditions. This scenario assumes buildout of the region’s land use and transportation system without the project and also provides a long-range view of future travel patterns. Cumulative without Project VMT estimates should be based on the horizon year of the most recent VTA Travel Model, ensuring the model does not already contain the land uses or transportation improvements associated with the project. YEAR 2040 CUMULATIVE WITH PROJECT The environmental analysis also must evaluate a project’s effect on VMT (CEQA Guidelines Section 21100(b)(5)). The project-generated VMT analysis considers all trips as new trips and does not consider how the project influences travel within the City of Saratoga. The project’s effect on VMT under Year 2040 Cumulative Conditions considers the project’s influence on the VMT generation of surrounding land uses. The cumulative project effect on VMT shall be estimated using the city limit boundary and extracting the total link-level VMT for both the no project and with project conditions. Types of VMT VMT analysis includes two types of VMT: 1.Total project generated VMT per service population. The project generated VMT method relies on tracking trips to/from an individual project. In simple terms, it looks at the total number and distance each trip travels divided by the service population (i.e., residents, employees, etc., as appropriate). 2.Project effect on VMT compares how the project changes VMT on the network considering total citywide VMT per service population. This VMT applies what is known as the boundary method, which captures all VMT on a network within a defined boundary (i.e., City of Saratoga). This VMT captures the project’s overall influence on the VMT generation of surrounding land uses. Generally, a project generated VMT will be required by all projects for project-level analysis. Project effect is typically only required for cumulative impact analyses for projects that are not consistent with the City’s General Plan VMT Metrics Table 2 outlines the VMT metrics for specified land uses. For other land uses not identified in Table 2 the analyst should confer with City staff to determine the appropriate VMT metric that addresses the unique characteristics of such land uses in the context of VMT generation. Resolution 25-045 Page 8 Docusign Envelope ID: 9AA64F3A-EA76-4208-96E9-81F8D8F30470 City of Saratoga SB 743 Guidelines| 7 Table 2: VMT Metric Project Type VMT Metric Office, R&D, Light Industrial Home-based work VMT per employee Residential Home-based VMT per resident Retail and Hotels Project effect on total regional VMT Schools Home-based work VMT per employee Home-based school VMT per student Other Land Uses Project effect on total regional VMT or appropriate per capita metric to be determined in consideration with City staff Mixed-Use Evaluate each component of a mixed-use development independently and apply the significance criteria for each project type Source: Fehr & Peers 2025. VMT Calculation Methods Projects in the City of Saratoga should apply one of two calculation tools developed and maintained by the Santa Clara Valley Transportation Authority (VTA) when evaluating VMT: •Santa Clara Countywide VMT Evaluation Tool (“VTA VMT Tool”): The VTA VMT Tool is available on VTA’s website. The tool calculates baseline VMT and can measure the effectiveness of Transportation Demand Management (TDM) measures. •VTA Travel Demand Model (“VTA Travel Model”): CUBE software travel demand model. The model can calculate baselined VMT and measure the projects-generated and projects’ effect on VMT. In some cases, off-model tools, such as manual accounting, can be most appropriate. This can include VMT calculations for land uses not well represented in either tool, such as wineries, event venues, private schools, or other special uses. Tools shall be applied to projects as follows: •Consistent with City’s General Plan: •Employment and residential projects consistent with the City’s General Plan can apply the VTA VMT Tool. However, complex projects should run the VTA Travel Model to determine VMT impacts. Generally, complex projects require a higher level of technical analysis due to unique characteristics, large-scale developments that influence travel across a broader region, or specialized employment or residential use not well represented by standard ITE categories. •Retail projects or projects evaluating the project’s effect on VMT should use and run the VTA Travel Model. •Inconsistent with City’s General Plan . Use and run the VTA Travel Model. In all cases, analysts should confirm appropriate VMT calculation methods with the City prior to commencing VMT analysis. Resolution 25-045 Page 9 Docusign Envelope ID: 9AA64F3A-EA76-4208-96E9-81F8D8F30470 City of Saratoga SB 743 Guidelines| 8 Regardless of the approach used, the VMT Travel Model run may still be appropriate to calculate total VMT and VMT on local roadways for use in the greenhouse gas and air quality CEQA topic areas. VMT Impact Thresholds Table 3 outlines the VMT impact thresholds. Table 3: Criteria for Significant VMT Impacts Element of Impact Significant VMT Impact Metric Threshold: VMT Reduction from Baseline 15% below baseline VMT per capita Threshold: Project Effect on VMT No net new countywide VMT Baseline 2015 County Average (or appropriate base year model available from VTA) Office, R&D, Light Industrial 15% below countywide baseline home-based work VMT per employee Residential 15% below countywide baseline home-based VMT per resident Retail and Hotels No net increase in citywide VMT per capita Schools 15% below baseline home-based work VMT per employee 15% below baseline home-based school VMT per student Other Land Uses To be determined at project level Source: MTC 2021 and Fehr & Peers 2025. The countywide baseline VMT per capita should be determined based on the appropriate calculation tool for the project (VTA VMT Tool or VTA Travel Model). VMT Mitigation When VMT impacts are identified, there are currently two project-based mitigation measures to consider: •Physical Design (land use or transportation) •Transportation Demand Management (TDM) Project-based features consider whether modifying the project in some way could reduce VMT. The two basic modifications include changing the physical land use or transportation network design of the project or transportation demand management (TDM) strategies such that site residents, workers, or visitors could make fewer or shorter vehicle trips. The following examples of TDM strategies included in the VTA Tool have substantial evidence of their effectiveness in reducing VMT: •Multimodal infrastructure, such as bicycle network or traffic calming improvements beyond project frontage, •Parking strategies, such unbundle parking or reduce parking supply, •TDM programs, such as bike or car share programs, transit subsidies, or employee parking cash-out programs. Resolution 25-045 Page 10 Docusign Envelope ID: 9AA64F3A-EA76-4208-96E9-81F8D8F30470 City of Saratoga SB 743 Guidelines| 9 Project Type VMT Mitigation Tool Other Available Tools and Resources Land Use: Residential and Employment Uses VTA VMT Tool Countywide tool Statewide tools (e.g., CAPCOA, TDM+) Land Use: Other projects Statewide tools in collaboration with City staff Statewide tools (e.g., CAPCOA, TDM+) Transportation projects: Capacity increasing (vehicle capacity reducing projects are generally screened out) Caltrans guidance Caltrans guidance Source: Fehr & Peers 2025. The City of Saratoga is mostly in a high-VMT area where full VMT mitigation to less-than-significant levels will not be likely in many projects. In all cases, development should incorporate all reasonable measures to reduce VMT to the extent feasible even less-than-significant levels cannot be achieved. 1 Available: https://www.airquality.org/ClimateChange/Documents/Final%20Handbook_AB434.pdf Resolution 25-045 Page 11 When VMT impacts are identified, applicants shall coordinate with the City on the most appropriate VMT mitigation measures. To reduce an impact to less-than-significant levels the applicant would need to demonstrate, through substantial evidence, that the VMT would be reduced to the City’s identified thresholds. The VTA VMT Tool includes a list of selected VMT reduction measures that can be applied to a project to reduce project VMT. Another option is TDM+, which is a tool developed by Fehr & Peers to assist in calculating VMT reductions from the strategies presented in the 2021 CAPCOA Report Handbook for Analyzing Greenhouse Gas Emission Reductions, Assessing Climate Vulnerabilities, and Advancing Health and Equity.1 Project applicants should coordinate with City staff to determine if the VTA VMT Tool or TDM+ is suitable for the project. Table 4 outlines the recommended tools that development and transportation projects should use to mitigate VMT impacts. Table 4: VMT Mitigation Approach Docusign Envelope ID: 9AA64F3A-EA76-4208-96E9-81F8D8F30470