STAFF REPORT - CITY COUNCIL/SUCCESSOR AGENCY/PUBLIC FINANCE AUTHORITY

Staff recommends that the City Council Review and Consider Adoption of a Resolution Adopting the Fresno County SB 743 Implementation Regional Guidelines for Vehicle Miles Traveled (VMT) and setting 13% percent less VMT per capita than existing average VMT for Fresno County as the threshold for the City of Coalinga as its California Environmental Quality Act (CEQA) threshold as detailed within the Fresno County SB 743 Implementation Regional Guidelines.

Senate Bill 743 (SB 743), signed in 2013 and effective as of July 1, 2020, changes the mandated way transportation impacts are analyzed in the California Environmental Quality Act (CEQA) process. VMT has replaced level of service (LOS) as CEQA’s transportation impact determination.

CEQA Regional Guidelines: Transportation is the single largest sector contributing to the State’s greenhouse gas (GHG) emissions, with more than 40 percent of the GHG emissions coming from the transportation sector (primarily passenger cars and light-duty trucks), reducing the number and/or length of vehicle trips are expected to result in reduced GHG emissions. As such, vehicle miles traveled (VMT) now replaces auto delay and Level of Service (LOS) as the metric for transportation impact determination within CEQA. The City of Coalinga has traditionally used the LOS as the method to determine transportation impact determination. As a result of SB 743, the City of Coalinga, as the lead agency, is required to analyze VMT instead of LOS in its CEQA documents. LOS can still be used to assess projects but is no longer a CEQA impact. In collaboration with the Fresno Council of Governments (FCOG), the City has identified VMT thresholds that would define a significant CEQA impact for land use development projects and associated VMT analysis for transportation projects. Even though LOS will no longer be considered a significant impact under CEQA, the lead agency can still require projects to meet the LOS standards as designated in its zoning code or general plan, but not as part of the CEQA analysis.

CEQA Regional Guideline Analysis: Within the constructs of SB 743, the analysis for impacts of transportation has shifted from congestion to climate change, and the purpose of the CEQA analysis is to disclose and ultimately reduce GHG emissions by reducing the number and length of automobile trips.  VMT is a regional effect not defined by roadway, intersection, or pathway. In other words, CEQA documents prepared by the City of Coalinga are no longer required to analyze intersections and road segments. Instead, they have to analyze regional trips within Fresno County.

On July 26, 2022, the Planning Commission adopted Resolution 022P-006 recommending approval by the City Council, of the VMT thresholds.  

The VMT baseline reduction set by the State Office of Planning and Research (OPR) is 15 percent less than current VMT.  However, an individual jurisdiction may adopt a lower threshold with substantial evidence and data to show that a lower threshold can still achieve the State’s overall reduction goal; with such analysis supported or accepted by OPR. With the technical assistance of FCOG, the entire Fresno County Region worked together to identify a 13 percent threshold, as detailed within the Fresno County SB 743 Implementation Regional Guidelines, which is included in Attachment A. As such, the City of Coalinga will establish a threshold for land use developments, specifically residential and office, of exceeding 13 percent below the existing regional VMT per capita as indicative of a significant environmental impact. Additionally, threshold changes will likely take place over time, as VMT trends and data change over time.

Under the proposed guidelines, project screening is conducted as the initial step. If the project meets any one of the screening criteria, the project may be presumed to create a less than significant impact and no further VMT analysis is necessary. If the project does not screen out, the next step is to assess a project as to whether or not their VMT impact would be less than significant. This process is detailed in the guidelines. The third step is to screen a project using the FCOG VMT Assessment Tool. The FCOG VMT assessment tool is available online for the City’s use. For bigger projects with higher VMT that do not screen out as less than significant, FCOG’s online VMT calculator can be used to determine project VMT and then apply mitigation as needed to reduce VMT to at or below the 13 percent baseline. If this cannot be achieved, an Environmental Impact Report would need to be prepared to allow for a Statement of Overriding Consideration as required by CEQA. Alternatively, an applicant can revise their project to reduce VMT. FCOG is currently working on developing a VMT mitigation bank or other type of program to assist with identifying VMT mitigation which can assist with mitigation on bigger projects.

California Environmental Quality Act: The establishment and implementation of a VMT threshold is a state-mandated requirement under SB 743, and Section 15064.3 of the CEQA Guidelines. While adoption of the regional implementation guidelines and setting of the 13% threshold does not require environmental analysis, these actions will impact the environmental analysis for all land use and capital development projects moving forward, in accordance with amended CEQA regulations as mandated under SB 743. As a result, this action is categorically exempt under the California Environmental Quality Act (CEQA), Section 15308 (Actions by Regulatory Agencies for Protection of the Environment).

VMT and Future Development Projects

For land use development projects, VMT is simply the product of the daily trips generated by new development and the distance those trips travel to their destinations. Land use projects that decrease vehicle miles traveled in the project area compared to existing conditions should be presumed to have a less than significant transportation impact.

For capital projects, impacts are identified as the new VMT attributable to the added capital project, both from the installation of the facility and the induced growth – a new term in the CEQA lexicon – generated as a result of induced land use. Transportation projects that reduce, or have no impact on, vehicle miles traveled should be presumed to cause a less than significant transportation impact. Bicycle and pedestrian infrastructure projects generally reduce VMT and, therefore, may be presumed to cause a less than significant impact on transportation. In addition, rehabilitation and maintenance projects designed to improve the condition of existing transportation assets that do not add motor vehicle capacity may be presumed to cause a less than significant impact on transportation

• The City can prepare its own VMT analysis however, staff does not recommended as it is not expected to prove more beneficial to the City. This is a state mandated action the Council must adopt. 

There is no negative financial impact to the City associated with this action, as the technical analysis and resulting Regional Guidelines document were funded by Fresno COG and made available to COG’s member agencies for use as they deemed appropriate for their agency. Future actions to address increased costs will be delivered to the Planning Commission for their recommendation, and City Council for formal action, and should be expected as VMT analysis becomes more established.