HomeMy WebLinkAboutCD General Plan 2040 - Downtown Precise Plan____________________________________________________________________________________
FOR CITY CLERK ONLY
Council Meeting: April 5, 2021
Disposition: Accepted report
Agenda Item No: 8.a
Meeting Date: April 5, 2021
SAN RAFAEL CITY COUNCIL AGENDA REPORT
Department: Community Development
Prepared by: Paul A. Jensen
Community Development Director
Barry Miller, Consulting Project Mgr.
City Manager Approval: ____________
TOPIC: GENERAL PLAN 2040 / DOWNTOWN PRECISE PLAN
SUBJECT: GENERAL PLAN 2040 PROGRESS REPORT #6
RECOMMENDATION:
Accept Report.
BACKGROUND:
Staff is providing the sixth and final Progress Report (Progress Report #6) to the City Council on the San
Rafael General Plan 2040 and Downtown Precise Plan. The Progress Report provides an opportunity to
brief the City Council on the status of the project prior to the Council’s receipt of the Draft documents and
Final Environmental Impact Report (FEIR) for adoption. It also provides an opportunity to present new
Traffic Impact Analysis (TIA) Guidelines that implement recent California Environmental Quality Act
(CEQA) requirements, specifically, Senate Bill 743 (SB743), which requires replacement of the Level of
Service (LOS) methodology with the Vehicle Miles Traveled (VMT) methodology for environmental
review.
Links to the five previous Progress Reports are provided below:
•Progress Report #1 (March 4, 2019)
•Progress Report #2 (July 15, 2019)
•Progress Report #3 (December 2, 2019)
•Progress Report #4 (July 6, 2020)
•Progress Report #5 (October 19, 2020)
This report covers activities since October 2020, including a summary of the major issues raised since
publication of the Draft General Plan 2040, Downtown Precise Plan, and EIR. The final section of the
report covers the TIA Guidelines. A PowerPoint presentation on the Guidelines will be provided by the
City’s transportation consultants at the Council meeting.
ANALYSIS:
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1. General Plan 2040
General Plan 2040 was launched in December 2017. The updated Plan moves the time horizon from
2020 to 2040. The Plan has been comprehensively revised to reflect current issues and forecasts, and
to address changes in state law. While the update is primarily a “refresh” of the existing plan rather than
a brand-new plan, changes to the document address the evolving state of the City and region, and cover
issues such as climate change, social equity, and emerging transportation technology. The three-year
planning process gathered and analyzed data; audited each goal, policy, and action in the existing
General Plan; and added new and updated policies. A 24-member Steering Committee was appointed
by the City Council to guide the process. The Committee convened 25 meetings between January 2018
and June 2020.
The October 19 Progress Report included more detail on the Plan, including a summary of each chapter
and highlights of the changes made from General Plan 2020 to General Plan 2040. It also included a
description of adjustments to the community engagement program resulting from the COVID-19
pandemic, and a summary of Land Use Map changes.
Chapters 1-9 of General Plan 2040 were published on October 2, 2020. Chapters 10-14 were published
on November 4, 2020. The published chapters can be accessed here.
The Planning Commission convened public hearings on General Plan 2040 on October 27 and November
12, 2020. In addition to taking public testimony at these hearings, the Commission discussed each
chapter of the document individually, soliciting comments from Commissioners. Following the November
12 hearing, staff prepared a matrix listing all written and oral comments, including a response indicating
how the comment would be addressed in the revised Plan. A third hearing was convened on December
15, 2020 to review the matrix, solicit additional comments, and confirm that the Commission concurred
with staff’s responses to comments.
Key Issues
Approximately 20 comment letters were received on General Plan 2040 between October 2020 and
January 2021. Another 26 public comments were received verbally via YouTube Live and Zoom during
the Planning Commission’s hearings. The Commission also spent approximately six hours discussing
the Plan at its three hearings. Major issues are highlighted below:
• Eleven of the 20 written comments requested stronger language in the Specific Plan regarding tree
preservation, particularly protection of redwood trees.
• The Marin Audubon Society submitted written comments on the Plan’s policies for wetlands
protection. This includes a request to replace conditional statements (i.e., those with caveats such
as “where feasible”) with stronger and more obligatory language. They also asked that the language
on the 85-acre Canalways site focus more strongly on open space and resource conservation, and
that references to future land uses being “economically viable” for the property owners be removed.
The City also received correspondence from the property owner supporting the Plan’s language as
shown and asking that the Plan be more proactive regarding the site’s future development.
• Specific revisions and edits to the Plan were suggested by Terra Linda Homeowners Association,
Hillside Neighbors, West End Neighborhood Association, San Rafael Heritage, and several residents.
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• A number of comment letters and oral testimony requested text changes to the description of
Northgate Mall in the Neighborhoods Element. Specifically, it was requested that the Plan delete
references to “expansion” of the Mall as well as references to “strengthening its role as a revenue
generator.” The Commission generally concurred with these recommendations, pointing out that the
General Plan should not pre-determine the outcome of future planning for the Northgate area.
• Some of those that commented suggested using terms such as “shall” instead of “should” in policy
statements. Similarly, it was suggested that words such as “encourage,” “support” and “consider”
should be changed to more directive words such as “require,” “mandate,” and “establish.” Given the
importance of balancing competing goals in the General Plan and the long-range, aspirational nature
of the Plan, staff would not support these changes in most cases. There are a few instances
(especially in the programs) where it may be appropriate to require actions rather than recommend
them. The General Plan is not a regulatory document. Mandatory or directive words are more
common to regulatory documents such as a zoning ordinance.
• Responsible Growth Marin submitted separate comment letters on the Mobility Element and the
Economic Vitality Element. The Mobility comments related to parking, the viability of transit-oriented
development, and uncertainties about future mobility trends after the pandemic. The Economic
Vitality comments likewise related to unknowns about the future of the retail and office markets, and
clarification of some of the data and policies in that Element.
• Representatives of the arts community spoke in support of the Draft Arts and Culture Element and
emphasized the need for more pro-active and decisive measures to fund arts and cultural programs
in the future.
• Marin Conservation League (MCL) provided comments on the Land Use Element. The Sierra Club
endorsed these comments in its own comments.
• The Planning Commission requested that metrics (measurable objectives and standards) be added
to the Plan where feasible, both to evaluate progress and to help inform future programs and resource
allocation. Staff has prepared implementation tables for each Element and suggested a number of
new metrics in response to this request.
• The Planning Commission noted potential conflicts in the Plan’s focus on equity and higher wage jobs
at the same time it emphasizes the importance of retail to the local economy, and the desire to sustain
sales tax as a revenue source. The Commission suggested that greater attention be given to the
future of the City’s economy and suggested adding a “Call to Action” to re-think how the City’s
economic and equity goals might be better aligned. The Commission also raised issues around how
the City’s economy may need to evolve in response to the pandemic and broader changes in the
retail, office, industrial, health care, and technology sectors.
2. Downtown Precise Plan
In 2018, the City of San Rafael received a grant to prepare a Precise Plan for Downtown San Rafael.
The intent was to update the 1993 Downtown Vision and incorporate more recent plans and programs
for Downtown (including the 2012 Downtown SMART Station Area Plan). The grant created “collateral”
opportunities, such as updating the inventory of Downtown’s historic resources and strategies for making
Downtown more pedestrian-friendly and resilient to climate change. The City retained Opticos Design,
Inc. in January 2019 as the prime consultant for the project. The General Plan Steering Committee
served as the vetting body for the Plan and convened meetings throughout 2019 to provide input.
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The Draft Precise Plan includes a new “form-based code” for Downtown. This code will replace many of
the existing zoning regulations for Downtown with a new method of zoning focused on building form
(height, setbacks, bulk, etc.) rather than the uses that occur within buildings. In some respects, the code
is more flexible than the existing code, particularly with respect to uses. In other respects, it is more
prescriptive, as it identifies specific requirements for building frontages, step backs (recessing of upper
floors), and treatment of historic properties. The trade-off for the prescriptive requirements is a
streamlined review process for conforming projects, and a more pedestrian-friendly building form.
A working draft of the Precise Plan was completed in May 2020. The draft was further vetted through a
subcommittee of the General Plan Steering Committee during summer 2020. A revised Plan was
developed in November 2020. Further revisions followed, and a Public Review Draft was released on
December 21, 2020. Prior to releasing the Draft, Opticos prepared a six-part video tutorial on Form
Based Codes, which is available on YouTube. More recently, staff and Opticos also prepared a video for
Downtown property owners and businesses on how to use the Form Based Code.
The Planning Commission convened public hearings on the Downtown Precise Plan on January 12 and
January 26, 2021. The January 12 hearing focused on the policy and design recommendations of the
Plan, while the January 26 hearing focused on the Form Based Code. A third hearing was held on
February 9 to review staff’s responses and proposed revisions in response to the comments made in
January. This included comments from the public hearings as well as written comments from residents,
businesses, and stakeholder groups.
Key Issues
Comments on the Draft Downtown Precise Plan have focused on historic preservation, density bonuses,
proposed height limits, potential redesign of Fourth Street, other urban design improvements, and the
transition to the Form Based Code. A summary of comments and issues is provided below:
• The greatest number of comments have addressed historic resources. These comments fall into two
general categories: (a) the inventory of proposed historic resources (and eligible districts) and (b) the
Plan’s development standards and policy recommendations for the treatment of historic resources.
o On the first issue, the Precise Plan work scope included an update of the City’s 1978/ 1986
inventory of historic resources. That inventory identified 88 historic resources in Downtown. The
2019/20 inventory revisited these properties, along with nearly 500 other Downtown properties.
The 2019/20 inventory was prepared by Garavaglia Associates with assistance from San Rafael
Heritage. After several rounds of screening, a shortlist of roughly 100 properties was identified
as having historic importance. There were 24 buildings removed from the 1978/1986 list,
including seven that have been demolished and 17 with diminished historic integrity. There were
36 properties added to the list, including a number of buildings from the 1930s, 40s, and 50s that
did not meet eligibility criteria at the time of the 1978 survey.
o San Rafael Heritage (SRH) has reviewed the 2019-20 inventory and provided detailed comments.
SRH has also recommended changes to the areas identified in the Downtown Precise Plan as
eligible historic districts. Staff is reviewing their comments with the assistance of a third-party
historic preservation consultant through the EIR Response to Comments process.
o On the second issue, San Rafael Heritage suggests that the Precise Plan’s standards for historic
buildings may be overly prescriptive on some cases and not prescriptive enough in others. They
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have suggested the removal of specific height and setback requirements for new development
adjacent to historic buildings, along with incentives for restoring facades of buildings with historic
value. San Rafael Heritage has also proposed that a five-member Historic Resources Advisory
Committee be created to advise the Planning Commission on applications impacting historic
resources.
At least one participant in the public hearings expressed concerns about the impacts of new historic
preservation regulations (and property designations) on development costs and opportunities. Staff
has met with the Chamber of Commerce and Business Improvement District to discuss these issues
and concerns. In response, post card notices were sent to the owners of all properties identified as
being potential historic resources and three one-hour webinars were convened the week of February
22 to apprise property owners of what was proposed and discuss their concerns. A recording of the
webinar presentation (including audio) is available here.
• Applicability of the City’s Density Bonus regulations in the Precise Plan area has been raised as an
issue, given that the proposed new Downtown zoning regulations do not include density standards.
Recent changes to State laws allow density bonuses of up to 50 percent for projects meeting certain
criteria, and 80 percent for projects that are 100 percent affordable. Since the Precise Plan relies
solely on height limits and setbacks to determine allowable building envelopes, it is unclear how these
rules would apply. Staff has been developing an alternative approach modeled after Santa Rosa,
Santa Cruz, El Cerrito, and San Francisco, which also have non-density-based zoning districts.
• Comments on the Precise Plan also have raised issues about proposed height limits and height
bonuses. This includes questions about how “affordable housing” is defined, what community
benefits may be required to qualify for bonuses, and how local bonuses align with State density bonus
programs. The Planning Commission and members of the public have also discussed the height
limits themselves. Some Commissioners and members of the public have expressed that the limits
are too high in a few locations, while others have expressed that they are not high enough.
• The Precise Plan recommends redesigning a portion of Fourth Street as a “shared street” that is more
pedestrian-oriented and bicycle-friendly. The Planning Commission discussed the possibility of
further limiting or even eliminating vehicles from parts of Fourth Street, either on a permanent or
temporary basis.
• Sustainable San Rafael has submitted a list of additional urban design improvements to be included
in the Precise Plan, including additional plazas, pedestrian crossing improvements, and bike lane
improvements. Their recommendations also recommend additional solar access standards to protect
sunlight and limit shadowing of public space along Fourth Street.
3. Environmental Impact Report.
A Draft Environmental Impact Report (DEIR) for General Plan 2040 and Downtown Precise Plan was
published on January 7, 2021. The document is a “Program EIR,” meaning it evaluates the impacts of
the General Plan’s policies and maps rather than the impacts of a specific development project or
capital improvement. The “Program” in this case translates to the addition of 4,400 housing units and
4,100 jobs in the San Rafael Planning Area over a 20-year period. Roughly half of this increase will
occur within the Downtown Precise Plan boundaries. Accordingly, each section of the EIR includes an
evaluation of citywide impacts and then an evaluation of Downtown impacts.
Upon publication of the DEIR, a Notice of Availability was prepared. Post cards and email notifications
were sent to a mailing list of several hundred recipients, including public agencies. A 61-day period
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was provided for public review, exceeding the required 45-day review time. The review period closed
on March 9, 2021 and the Planning Commission held a public hearing on that date.
All required CEQA topics are addressed in the EIR. Where the EIR found potential significant impacts,
mitigation measures were identified. In most cases, these measures required new General Plan
programs or edits to existing programs. A few impacts were found to be significant and unavoidable
even after mitigation (air quality, cultural resources, greenhouse gas emissions, and transportation). A
Statement of Overriding Considerations will need to be adopted as part of EIR certification.
Key Issues
Fourteen DEIR comment letters were received, and six persons testified at the Planning Commission
hearing on March 9, 2021. A summary of the comment letters and public hearing testimony is provided
below.
• Golden Gate Bridge, Highway, and Transportation District requested minor clarifications to the
Precise Plan.
• Ragghianti & Freitas law firm requested a minor change to the Precise Plan boundary (on behalf of a
property owner) to allow three parcels under contiguous ownership to be included. Two of the parcels
are already within the boundary.
• Ragghianti & Freitas law firm requested an increase to the height limit for a property on C Street
between Mission and Fifth Avenue (on behalf of a property owner).
• A resident requested that 930 Tamalpais be listed as a resource in the historic inventory.
• The Transportation Authority of Marin (TAM) asked that the EIR address the consistency of the
General Plan/ Downtown Plan with the Congestion Management Program.
• San Rafael Heritage submitted comments on the Precise Plan and the historic resources Inventory
(described in the previous section of this report), along with supplemental comments on the Cultural
Resources Appendix to the Precise Plan.
• A property owner appealed the inclusion of their property on the list of historic resources.
• A resident submitted proposed edits to the Aesthetics section, the Biological Resources section, the
Geology and Soils section, and the appendix annotating Land Use Map changes.
• A resident submitted a request to address impacts on the Northern Spotted Owl and additional
measures to protect sensitive upland plant communities.
• Caltrans acknowledged receipt of the DEIR and expressed their support for the Plan alternative that
accommodated more housing growth.
• Sustainable San Rafael submitted comments on the Greenhouse Gas section and recommended
strengthening several Conservation/Climate Change Element programs to mitigate impacts.
• The San Rafael Rock Quarry submitted comments on the Mineral Resources section, including
clarifications and corrections.
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• The California Department of Fish and Wildlife submitted comments on the Biological Resources
section, referencing additional species and edits to proposed mitigation measures.
• Marin Audubon Society submitted comments referencing General Plan Conservation policies that are
cited as mitigating biological impacts, particularly those relating to wetlands, creeks, and special
status species.
4. Transportation-Focused Initiatives
The Draft General Plan 2040 includes two concurrent transportation initiatives:
• Update of the Traffic Mitigation Fee to reflect General Plan 2040
• Updated “Traffic Impact Analysis” (TIA) Guidelines for proposed development projects. These
Guidelines implement SB743, which discontinues the use of Level of Service (LOS) standards
for environmental review and includes new requirements and procedures for implementing the
Vehicle Miles Traveled (VMT) methodology.
Transportation fees were discussed in Progress Report #5 and will be covered in a future City Council
meeting. The discussion below focuses on the TIA Guidelines.
As required by State law, the City has shifted to a new method of measuring the transportation impacts
of new development under the California Environmental Quality Act (CEQA). Pursuant to SB743, the
impact of a project on transportation is evaluated based on the total number of vehicle miles (e.g., the
amount of driving) it may induce once it is completed, rather than the level of traffic congestion it may
generate. This legislation permits the continued use and application of LOS as a tool for local jurisdiction
planning and development review; however, it can no longer be required for CEQA analysis.
The VMT methodology is complex, as it departs from the classic approach at assessing intersection and
road operations, which focus on vehicle movement and operational capacity. Given the complexity of
VMT, the topic was subject to informational reports that were presented to the City Council on June 3,
2019 and December 2, 2019. Following initial feedback from the City Council, staff prepared a third
informational report outlining recommended standards for VMT and LOS. This third report was presented
to the City Council on July 6, 2020. The City Council provided direction to staff for formulating General
Plan 2040 policy on VMT thresholds and screening criteria and retaining LOS as a planning and
development review tool. The Council also recommended that the General Plan 2040 include a program
to develop clear and easy to understand guidelines addressing the application of VMT and LOS.
As directed by the City Council, General Plan 2040 establishes compliant VMT standards for CEQA
purposes but retains Level of Service (LOS) as a planning and development review tool. Given the
complexity of the new requirements and their potential to increase development costs, staff (through its
consultant) has prepared TIA Guidelines. The intent of the Guidelines is to clearly lay out the City’s
expectations and requirements for both VMT analysis and LOS analysis. One of the objectives of the
Guidelines is to ensure that the new requirements do not create a cost burden for desirable future
development projects. The Draft Guidelines are attached to this staff report and are available on the City’s
website at www.sanrafael2040.org.
The Guidelines describe the City’s approach for determining the need for a transportation analysis, the
contents of that analysis, and the transportation improvements that may be necessary. They provide
essential information for the public and decision-makers, including a tool for evaluating a project’s
SAN RAFAEL CITY COUNCIL AGENDA REPORT / Page: 8
consistency with the General Plan and the County’s Congestion Management Program, mitigation
measures under CEQA, and non-CEQA related improvements that may be necessary to maintain
adopted Level of Service (LOS) standards.
The TIA Guidelines lay out different approaches to traffic studies based on the size, location, and
characteristics of the project. Three tiers have been identified based on the number of trips a project
may generate. Projects in all three tiers are required to provide a basic site access and circulation
analysis, including an evaluation of ingress and egress, parking supply, and loading areas. This is
referred to as a Local Traffic Assessment (or LTA). Projects in Tiers 2 and 3 are subject to additional
requirements, potentially including level of service assessments, additional intersection evaluation, and
an evaluation of cumulative trips. Projects meeting certain criteria may also be required to evaluate their
impact on vehicle miles traveled (VMT). A flow chart in the TIA Guidelines (page 7) indicates the level of
analysis required.
The Guidelines indicate the types of projects that would be exempt from VMT analysis. In addition, maps
have been developed (see pages 10 and 11 of the Guidelines) showing where residential and job-
generating projects would be exempt from VMT analysis based on the characteristics of these areas.
For instance, areas near SMART stations are exempt from the VMT analysis requirements due to
opportunities for transit and non-motorized trips.
The recommended process for conducting a TIA is included in the Guidelines (page 13). This includes
determining the scope of the analysis, assessing existing conditions (including traffic counts), assessing
conditions without the project, calculating the project’s impacts, and identifying appropriate improvement
measures. Provisions for coordinating with other jurisdictions also are included.
Specific direction is provided on how to estimate the number of “person trips” and “vehicle trips” a project
will generate, including guidance for projects with atypical peak hours. Direction is also provided to adjust
trip rates to account for activities that may already be present on a project site (i.e., “credits”) and to allow
for reduced trip rates in areas where a high percentage of trips can be made by walking, bicycling, and
transit. The Guidelines also address ways to reduce the number of trips a project may generate through
transportation demand management (TDM) programs.
The second half of the Guidelines focuses specifically on how to conduct a “non-CEQA Transportation
Impact Analysis” (page 21) and a “CEQA Transportation Analysis.” Guidelines for the non-CEQA studies
address the Local Traffic Assessments (LTAs) that are required for small projects and the Traffic Impact
Analysis (TIAs) required for larger projects.
Every LTA and TIA must address General Plan consistency, parking, loading, on-site circulation,
pedestrian/bike and transit provisions, trip reduction measures, safety issues, truck trips, and impacts on
nearby intersections. An analysis of access and internal circulation also is required. The Guidelines
provide direction on the time periods to analyze, the number of scenarios to evaluate, acceptable ways
to collect data, the software to use, and the method for evaluating traffic operations, including signals and
stop-sign controlled intersections. Special provisions are included for congested conditions,
roundabouts, and potential impacts on Congestion Management Program road segments. The LTA
ultimately should identify any deficiencies, as well as improvements and fees that may be incorporated
as a condition of approval to address deficiencies. A menu of “example improvements” is included (page
33).
The Guidelines for CEQA-related traffic analyses are focused on VMT. The Guidelines first cover land
use projects (for instance, residential and commercial developments), and then transportation projects
SAN RAFAEL CITY COUNCIL AGENDA REPORT / Page: 9
(for instance, road widening or bicycle lane projects). A detailed methodology is spelled out for both
types of projects. The initial step is to “screen out” projects that do not need to prepare a VMT analysis,
such as those near SMART or those below defined thresholds.
Non-screened projects must evaluate VMT generated by the project, as well as the ways the project
could change VMT on the greater regional road network. The analysis must address the baseline year,
plus Year 2040 conditions. The Guidelines includes qualitative and quantitative thresholds for
determining if an impact is “significant” under CEQA, as well as mitigation measures that may be used to
reduce impacts. These measures include design changes, changes to parking, improvements to non-
vehicular travel modes, and TDM programs.
The TIA Guidelines do not require formal adoption by the City Council and may be modified in the coming
months based on public comment and real-time experience. Public comment is invited and encouraged
during the initial roll-out period. An opportunity for public comment and questions will be provided
following the Progress Report presentation on April 5.
COMMUNITY OUTREACH:
A public notice of this meeting was mailed to stakeholders, agencies, and special interest groups 15 days
prior to this meeting. Those noticed included, among others, all neighborhood associations in the city,
the San Rafael Chamber of Commerce, and members of the General Plan 2040 Steering Committee.
Notice of this report was also provided on the General Plan 2040 meetings and events webpage.
FISCAL IMPACT:
This progress report is informational and has no fiscal impact on the City budget.
RECOMMENDED ACTION:
Accept Report
ATTACHMENTS:
1. Transportation Impact Analysis (TIA) Guidelines
1
City of San Rafael Transportation Impact Analysis Guidelines
Prepared for:
City of San Rafael
March 2021
SF20-1125
FEHR ,1 PEERS
Table of Contents
Introduction ................................................................................................................................... 1
Intent of the Guidelines ............................................................................................................................................................. 1
Environmental Evaluation ......................................................................................................................................................... 2
Who can Conduct a TIA? ........................................................................................................................................................... 2
Project Types .................................................................................................................................................................................. 2
CEQA and Non-CEQA Terminology ...................................................................................................................................... 3
Determining the Level of Transportation Analysis .................................................................... 4
Trip Generation Screening ........................................................................................................................................................ 4
CEQA VMT Screening ................................................................................................................................................................. 5
Land Use Project Screening ............................................................................................................................................. 8
Recommended Process and Documentation .................................................................................................................12
Role of City Staff ................................................................................................................................................................12
Consultation with Other Jurisdictions ........................................................................................................................14
Trip Generation and Forecasting Tools ..................................................................................... 15
Project Trip Generation ............................................................................................................................................................15
Vehicle Trips .........................................................................................................................................................................15
Person Trips .........................................................................................................................................................................16
Establishing Trip Generation Rates for an Unknown or Unique Use .............................................................16
Trip Rate Credits for Existing Uses ..............................................................................................................................16
Trip Rate Reductions for ITE Rates ..............................................................................................................................17
VMT Estimation and Cumulative Travel Forecasts ........................................................................................................20
Transportation Impact Analysis and Circulation Studies (non-CEQA) .................................. 21
Scope of Analysis .......................................................................................................................................................................21
Study Area (Key: 1B) .........................................................................................................................................................21
Key Study Elements ...........................................................................................................................................................22
Multimodal Site Access and Circulation ...................................................................................................................23
Analysis Time Periods.......................................................................................................................................................24
Scenarios for Local Transportation Analysis (non-CEQA) ..................................................................................25
Data Collection ............................................................................................................................................................................26
Traffic Operations Analysis .....................................................................................................................................................27
Traffic Signal Parameters ................................................................................................................................................27
Evaluation of Side Street Stop-Controlled Intersections ...................................................................................28
3
Methodology and Software ...........................................................................................................................................29
Mobility Deficiency Criteria ............................................................................................................................................30
CMP Deficiency Criteria ...................................................................................................................................................31
Improvements .....................................................................................................................................................................31
Multimodal Analysis Methods ..............................................................................................................................................34
Transportation Analysis (CEQA) for Land Use Projects ........................................................... 35
Methodology ...............................................................................................................................................................................35
Initial Screening ..................................................................................................................................................................35
Assessment for Non-Screened Projects ...................................................................................................................36
Scenarios for Transportation Analysis (CEQA) ................................................................................................................36
Baseline Conditions...........................................................................................................................................................36
Year 2040 Cumulative Conditions ...............................................................................................................................37
VMT Impact Criteria for Land Use Projects ......................................................................................................................37
Project Generated VMT Impact Thresholds (Baseline Conditions) ................................................................37
Projects Effect VMT Impact Threshold (Year 2040 Cumulative Conditions) .............................................37
CEQA Thresholds of Significance .........................................................................................................................................38
Mitigation Measures .................................................................................................................................................................39
Transportation Analysis (CEQA) for Transportation Projects ................................................. 41
Methodology ...............................................................................................................................................................................41
Screening Criteria ..............................................................................................................................................................41
Assessment for Non-Screened Projects ...................................................................................................................42
Mitigation Measures .................................................................................................................................................................42
Attachments
Attachment A: Site Access and Circulation Plan Review
Attachment B: Transportation Impact Analysis Report Outline
Attachment C: List of Transportation Projects Exempt from Environmental Analysis (CEQA)
List of Figures
Figure 1: Determining Level of Transportation Analysis and Initial VMT Screening.................................................. 7
Figure 2: San Rafael VMT Screening Map (Residential) ..................................................................................................... 10
Figure 3: San Rafael VMT Screening Map (Employment) .................................................................................................. 11
Figure 4: Flow Chart for Transportation Analysis and Documentation....................................................................... 13
List of Tables
Table 1: Comparison of Select Non-CEQA and CEQA Terms ............................................................................................. 3
Table 2: Local Transportation Analysis – Key Study Elements and Evaluation Criteria .......................................... 22
Table 3: Traffic Signal Parameters ............................................................................................................................................... 28
Table 4: Software Analysis Options ............................................................................................................................................ 29
Table 5: Mobility Deficiency Criteria .......................................................................................................................................... 31
Table 6: Example Improvements ................................................................................................................................................. 33
Table 7: VMT Impact Criteria for Land Use Projects under Baseline Conditions...................................................... 40
City of San Rafael Transportation Impact Analysis Guidelines: DRAFT March 2021
1
Introduction
The Transportation Impact Analysis (TIA) Guidelines provide a clear
and consistent technical approach for projects that could have
transportation effects (adverse or beneficial) on the City’s
transportation system and services.
A transportation impact analysis provides essential information for
decision-makers and the public when evaluating individual
development, small- and large-scale area plans, and transportation
infrastructure projects. A transportation impact analysis for projects
in San Rafael serves three primary purposes:
• Evaluate a project’s consistency with the City’s General Plan.
• Evaluate a project’s consistency with the Transportation
Authority of Marin Congestion Management Program (CMP).
• Provide an evaluation of significant impacts and mitigation
measures per the California Environmental Quality Act (CEQA).
Outcomes of the transportation impact analysis process include
conditions of approval and/or mitigation measures under the
California Environmental Quality Act (CEQA) that result in changes to
the project site plan or program, or the implementation of off-site
transportation system improvements.
Intent of the Guidelines
The Mobility Element in San Rafael General Plan 2040 seeks to improve multimodal access to key
destinations in ways that are safe, efficient, and affordable yet also support the City’s climate action
and environmental quality goals, economic vitality goals, and social equity goals. The TIA Guidelines
support these goals by evaluating new projects against the policies of the General Plan and other
relevant documents, including but not limited to the Downtown Precise Plan (2021), the Climate
Change Action Plan 2030 (2019), the Bicycle and Pedestrian Master Plan (2018), and the Downtown
Parking/Wayfinding Study (2017).
For environmental analysis, the TIA Guidelines incorporate California’s Senate Bill 743 (SB 743) and
subsequent changes to CEQA Guidelines where vehicle delay is replaced with vehicle miles
traveled (VMT).
Transportation
Impact Analysis
(TIA) Guidelines
The TIA guidelines define how to evaluate a
project’s effect on
transportation access and
circulation for all travel
modes. The analysis may focus solely on the project
site and access points and
may also include an
evaluation of the nearby
transportation system to ensure infrastructure supports the
traveling public.
2
The TIA Guidelines outline the City’s approach for determining the need for a transportation analysis,
its content, and identifying acceptable transportation improvements for land use and transportation
projects proposed within San Rafael. The TIA Guidelines establish protocols for performing
the following:
• Local Traffic Assessments (LTA) for projects
• Transportation Impact Analysis (non-CEQA) for City’s General Plan and CMP
consistency analysis.
• Transportation Impact Analysis for analyzing and determining impacts under CEQA.
City staff will review transportation studies and reports based on the process presented in these
guidelines. However, each project is unique, and the TIA Guidelines are not intended to be
prescriptive beyond practical limits. Not all criteria and analyses described in these guidelines
will apply to every project. Early and consistent communication with the Community
Development Department and Public Works Department staff is encouraged to confirm the type
and level of analysis required for each study.
The resulting TIA document is intended to provide decision-makers with information about the
transportation system impacts of a project and, when appropriate, recommend conditions of
approval, or identify mitigation measures under CEQA.
Environmental Evaluation
SB 743 changed some of the transportation significance criteria used in CEQA analyses. Specifically,
vehicle level of service (LOS) is no longer used as a determinant of significant environmental impacts,
and a VMT analysis is required. These guidelines outline the required methodology and thresholds
with which to evaluate projects consistent with the latest CEQA Guidelines (Governor’s Office of
Planning and Research, December 2018). Future updates in guidance by OPR on this topic are
assumed to be incorporated herein.
Who can Conduct a TIA?
Only a Professional Civil Engineer or Traffic Engineer, currently registered and in good standing with
the California State Board of Professional Engineers and Land Surveyors, may prepare a TIA for the
City of San Rafael. The City of San Rafael may choose in the future to develop a pre-qualification
process to identify consultants that may conduct traffic studies. The purpose would be to provide
project applicants with a list of qualified consultants that have demonstrated knowledge of the
guidelines and the ability to perform the multi-modal transportation analysis required.
Project Types
A transportation analysis is typically prepared for projects before a discretionary action is taken. The
following types of projects, which involve development activity in and around San Rafael and affect
the adjacent transportation system, may require a transportation analysis.
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• Land use entitlements requiring discretionary approval by San Rafael, which includes
General Plan amendments, precise roadway plans and specific plans (and related
amendments), zoning changes, use permits, planned developments, site plan review
committee approval, and tentative subdivision maps.
• Land use activity advanced by agencies other than San Rafael that is subject to jurisdictional
review under state and federal law such as school districts, or advanced within San Rafael by
agencies other than the City that is inconsistent with the City’s General Plan.
• Transportation infrastructure modification or expansion, including proposed
improvement projects on City roads, county roads and state highways that may impact City
facilities and services. Roadway improvement projects that are identified in the General Plan
and evaluated in the General Plan EIR are subject to tiering for CEQA purposes. Such
transportation projects would not require a TIA. Capital improvement projects (CIP) would
address CEQA as required but would not prepare a TIA. Certain projects fall under the
purview of the state, whereby comments are typically received from Caltrans will require a
level of impact analysis upon state facilities such highways, freeways, ramps and intersections.
• Controversial projects, including projects that may present controversial comments and
concerns as driven by adjacent communities or organizational groups.
• Subsequent phased projects are projects that were phased with no future plans of
implementation or projects that remained stagnant for more than seven years.
The Determining the Need for a Transportation Analysis chapter identifies specific project parameters
that may necessitate a transportation analysis.
CEQA and Non-CEQA Terminology
To distinguish the CEQA analysis from the non-CEQA analysis, the analyses apply different
terminologies as summarized below in Table 1.
Table 1: Comparison of Select Non-CEQA and CEQA Terms
Non-CEQA Term CEQA Term
Local Transportation/Operational Analysis CEQA Transportation Analysis
Threshold or performance standard (LOS) Significance criteria (VMT)
Substantial effect or deficiency Significant impact
Required improvement Mitigation measure
Existing Conditions Baseline Conditions
Background Conditions Not applicable
4
Determining the Level of
Transportation Analysis
The need for a transportation analysis may stem from General Plan
consistency, CMP consistency, CEQA compliance requirements, projects
that are controversial in nature, or some combination thereof. The scope of
the content will vary based on the type and scale of the project per the
City’s established screening criteria.
The applied screening criteria varies by the type of analysis being
completed. This section outlines the different screening thresholds for General Plan consistency, CMP
consistency, and CEQA impacts. All projects need to document and justify the applied screening
criteria for City review and concurrence. The process used to determine the level and type of analysis
required is discussed below and illustrated in Figure 1, which helps determine if projects are a)
subject to CEQA analysis and b) required to prepare a TIA or a simpler LTA. This screening is to be
performed by Traffic Engineering staff in the Public Works Department, Planners in the Community
Development Department, and/or consultants retained to assist City staff. Forms, see attached, are
filled out by the planner with the project applicant or proponent.
Trip Generation Screening
The level of transportation analysis required for projects is generally based on the expected level of
daily vehicle trip generation; however, there may be exceptions based on the project location, such as
in close proximity to a school, or project characteristics, such as a high level of truck trip generation.
For purposes of trip generation screening, estimates should be made using the most recent edition of
the ITE Trip Generation Manual and should apply an existing use credit only for currently active uses.
Additional internalization or mode adjustments may be considered by City staff in scoping the
analysis but should not be included in initial assignment of a project tier. Phased projects should be
assessed based on build-out conditions.
• Tier 1: Less than 110 daily trips: The transportation study focuses on site plan review and
assessment of site integration within the existing transportation system. For most projects,
this review would likely be conducted at the staff level. A threshold of 110 daily trips is the
level under which no VMT analysis is required. The 110 daily trip threshold equates to
approximately 10 single-family units, 15 multi-family units, office developments of up to
10,000 square feet, and retail uses up to 3,000 square feet. However, if the project is
controversial in nature, level of analysis will be determined relevant to the expressed
concerns. Projects of this size do not require a TIA or an LTA.
• Tier 2: Between 110 and 1,000 daily trips and less than 100 peak hour trips: The
transportation study includes site plan review, site access assessment for all travel modes, and
What level of transportation
analysis is required?
City of San Rafael Transportation Impact Analysis Guidelines: DRAFT March 2021
5
may include intersection evaluation including level of service, vehicle queues, signal warrants
and collision assessment for two to four intersections immediately surrounding the Project
site. Most development projects in San Rafael are expected to fall within the Tier 1 or Tier 2
threshold. The 1,000 daily trip threshold equates to approximately 100 peak hour trips. Multi-
family home developments up to 165 units, office developments up to 100,000 square-feet,
and retail uses up to 25,000 square feet (not accounting for pass-by trips) would fall into the
Tier 2 level of analysis category. Projects of this size require an LTA and may require a TIA;
projects of this size are also required to undergo additional assessment for
CEQA applicability.
◦ Tier 2A: Between 110 and 250 daily trips and less than 25 peak hour trips: In most
cases, projects of this size will require an LTA only, as the addition of fewer than 25
vehicles to the roadway network across the peak hour is unlikely to lead to congestion or
other traffic issues more than two blocks away from the project as traffic disperses, and
the project is unlikely to add more than 20 vehicles to any single intersection.
◦ Tier 2B: Between 251 and 1,000 daily trips: In most cases, projects of this size will
prepare a TIA with additional intersection analysis, although they may not need to
prepare cumulative operational forecasts.
• Tier 3: Greater than 1,000 daily trips or 100 peak hour trips: The transportation study
includes the elements discussed above, as well as additional intersection evaluation based on
the expected influence of project trips. In addition, the study should discuss cumulative /
long-term effects, and incorporate changes based on reasonably expected land use and
transportation projects. This level of trip generation also meets the requirements for
additional study in compliance with the Marin County CMP, and requires a TIA and
CEQA review.
All projects are required to provide a site access and circulation analysis, including parking supply and
loading evaluation to demonstrate that the project conforms to City policies and development
standards as defined in the San Rafael Municipal Code. Key elements of this assessment are included
in the checklist in Attachment A: Site Access and Circulation Plan Review.
CEQA VMT Screening
Projects that meet certain screening criteria may be exempt from the preparation of a vehicle miles of
travel assessment for CEQA transportation assessment purposes (VMT calculations may still be
needed for air quality, noise and climate change evaluations). However, even if a project is exempt
from VMT analysis, it may still be required to evaluate the following CEQA requirements:
• Conflicts with a program, plan, ordinance, or policy addressing the circulation system,
including transit, roadways, bicycle and pedestrian facilities
• Substantially 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.
6
CEQA screening criteria for land use and transportation projects are listed below. Projects that do not
meet the screening criteria must conduct a VMT analysis [see Transportation Analysis (CEQA) for Land
Use Projects and Transportation Analysis (CEQA) for Transportation Projects chapters].
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Figure 1: Determining Level of Transportation Analysis and Initial VMT Screening
8
Land Use Project VMT Screening
Based on guidance from the State of California’s Office of Planning and Research (OPR) Technical
Advisory (December 2018, pages 13-15), land use projects that meet at least one of the following
screening criteria are presumed to not require CEQA VMT analysis:
• Transit Priority Areas (TPA): Projects located within ½ mile walkshed around major transit
stops 1 (i.e., the Downtown San Rafael and Civic Center SMART Stations) in San Rafael as
shown on Figure 2. However, TPA screening will not apply if the project meets any of the
following criteria:
◦ The project has a Floor Area Ratio (FAR) of 0.75 or less;
◦ The proposed parking exceeds the minimum required by the Zoning Code or
applicable plan;
◦ The Project is inconsistent with the City’s General Plan, applicable Specific Plan, or
applicable Sustainable Communities Strategy (as determined by the lead agency, with
input from ABAG and MTC);
◦ The Project removes or reduces the number of existing on-site affordable
residential units; or,
◦ Significant levels of VMT are projected through project-specific or
location-specific information.
• Affordable Housing: 100% restricted affordable residential projects in infill locations (i.e.,
development within unused and underutilized lands within existing development patterns).
• Small Projects: Projects defined as generating 110 or fewer average daily vehicle trips, absent
substantial evidence indicating that a project would generate a potentially significant level of
VMT. Examples of projects that may generate less than 110 average daily trips include:
◦ ~10 units of single-family residential
◦ ~15 units of multifamily residential
◦ ~10,000 square-feet office
◦ ~15,000 square-feet industrial
• Each project is required to document the estimated number of trips it will generate.
• Locally Serving Public Facility: Locally serving public facilities that encompasses
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), branch
libraries, community centers, public utilities, and neighborhood public schools.
1 “Major transit stop” is defined in Public Resources Code 21064.3 as a site containing an existing rail transit station, a ferry terminal served by either a bus or rail transit service, or the intersection of two or more major
bus routes with a frequency of service interval of 15 minutes or less during the morning and afternoon peak
commute periods.
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• Neighborhood-Serving Retail Project: Neighborhood-serving retail projects that are less
than 50,000 square feet, which serve the immediate neighborhoods. Examples include dry
cleaners, coffee shops, convenience markets, tutoring centers and daycare centers.2
• Location in a Low VMT Area: The project is located within a low VMT area for its land use, or
a transit priority area, as shown in Figure 2 or Figure 3. Based on information from the TAM
model, certain areas of San Rafael have lower rates of VMT generation than others. In existing
locations where VMT per capita is below the thresholds, projects may be screened from
further VMT analysis. Figures 2 and 3, which show the ½ walking distance screening area for
the Downtown San Rafael SMART Station and adjacent San Rafael Transit Center, will be
updated if the future location of the San Rafael Transit Center when relocated differs
substantially from its present location.
Each component of a mixed-use project is considered separately; therefore, each of the project’s
individual land uses should be compared to the screening criteria. It is possible for some of the mixed-
use project’s land uses to be screened out and some to require further analysis. In addition, projects
that do not require CEQA VMT analysis may still require a transportation study to assess other CEQA
considerations such as emergency access, design hazards, and consistency with plans and policies.
2 Daycare centers of 7,500 square feet or less would apply to the screening criteria.
10
Figure 2: San Rafael VMT Screening Map (Residential)
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Figure 3: San Rafael VMT Screening Map (Employment)
12
Recommended TIA Process and Documentation
The project applicant shall retain a professional transportation consultant to conduct the required
transportation analysis; the City may seek to develop a list of qualified firms and it is the applicant’s
responsibility to ensure that the selected firm is acceptable to the City. The firm shall be licensed to
perform such work in the State of California, and its preparation shall be overseen by a licensed
Professional Engineer or Traffic Engineer. The applicant’s consultant should seek City acceptance of
the scope of work before initiation. In some cases, review by other affected jurisdictions will be
required. Attachment B: Transportation Analysis Report Outline contains a recommended outline
for the transportation analysis documentation, while the overall process for analysis is outlined in
Figure 4 through a simplified flow chart. The process for each individual project will be unique and
based on the judgment of Community Development Department and Public Works staff; in particular,
phased projects or large projects may evaluate a greater number of scenarios than shown in Figure 4.
Each transportation analysis will begin by preparing a scope of work that describes the project, site
location, analysis methods, area-wide assumptions, study elements, study time periods, and
transportation data collection methods. The transportation analysis scope of work along with initial
estimates of the project trip generation, trip distribution, and VMT screening evaluation should be
submitted to City staff for review and approval. Detailed guidance on selecting elements for inclusion
in the analysis is presented in the Scope of Analysis section, beginning on page 21 of this document.
Role of City Staff
The transportation analysis will be prepared at the direction of City Public Works and Community
Development Department staff. This will ensure that potential transportation improvements and
environmental impacts are considered as early as possible in the planning process. Development of a
transportation analysis should include:
• Pre-application coordination, which will include a discussion of the TIA requirements.
• Approval of the scope of work, which includes field reconnaissance, trip generation, study
area, analysis scenarios and parameters, data requirements, and provisions for pedestrian,
bicycle and transit modes.
• Approval of the project trip generation (person and vehicle), trip distribution, and VMT
approach and results.
• Review of all assumptions and the results of Existing Conditions analysis.
• Review of the administrative draft report, with adequate time for comments.
• Review of a draft report, with adequate time for comments.
If information from a transportation analysis will be incorporated into the transportation and
circulation section of an environmental document (e.g., Initial Study, Mitigated Negative Declaration
or Environmental Impact Report), the format of the transportation analysis report should be
coordinated with the environmental consultant and City staff.
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Figure 4: Flow Chart for Transportation Analysis and Documentation
14
Coordination with Other Jurisdictions
The need for coordination with other jurisdictions is a determination to be made by City staff based
on a project location, size, and potential for impacting transportation facilities managed by other
agencies. In general, coordination efforts would be limited to Tier 3 projects that generate more than
100 peak hour vehicle trips.
Section 15086 of the CEQA Guidelines 3 shall be followed as the basis for satisfying coordination
requirements for environmental studies. In most cases, overlap will occur for roadway system analysis
(i.e., not VMT) but may also include impact analysis of active transportation modes (bicycling and
walking), as well as transit system facilities and services. If the study area overlaps with other
jurisdictions, staff from those jurisdictions must be consulted to verify study locations, analysis
methodologies, and the substantial effect thresholds. As appropriate, adjacent jurisdictions should be
contacted to provide current development applications. Caltrans should be consulted for Tier 3
projects that have the potential to affect the state highway system, including US-101 and I-580.
Roadway crossings of rail lines are another overlap area that may require coordination with the
California Public Utilities Commission (CPUC), particularly for large projects with parking facility
driveways located in close proximity to at-grade rail crossings. The focus of any analysis related to rail
crossings should be on whether the current crossing complies with current design standards and if
the project has the potential to result in vehicle queue spillback across an active crossing.
3 The California Environmental Quality Act Guidelines, California, 2019.
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Trip Generation and
Forecasting Tools
The local transportation analysis for General Plan and CMP consistency is based on vehicle trip
generation, while CEQA analysis is based on VMT generation. This section describes how vehicle trip
generation and VMT are estimated, and how cumulative traffic forecasts are developed.
Project Trip Generation
Person and vehicle trip generation rates are a way to estimate the number
of expected pedestrian, bicycle, transit, and vehicle trips a proposed
development will generate. These rates establish the basis of analysis for a
proposed project and its effect on the transportation network. Person trip
generation should be reported for walking, bicycle, and pedestrian trips;
and vehicle trip generation should be reported for single-occupant,
carpool, and transportation network company (TNC) (i.e., Uber/Lyft) trips.
Vehicle Trips
The state-of-the-practice is deriving vehicle trip generation rates from local empirical data, as this will
provide the most accurate forecast for future land use vehicle trip-making. This typically requires
surveying a similar existing land use at three unique locations to quantify the number of daily and
morning, mid-day, and evening peak period person and vehicle trips generated.
The City understands that conducting new trip generation surveys may not be practical in all cases
and that the latest Institute of Transportation Engineers’ (ITE) Trip Generation Manual is a reasonable
alternative when local data is not available. In the absence of empirical studies, the most recent
vehicle rates published by ITE in the Trip Generation Manual 4 or other relevant sources may be used
for trip rate estimation. When using ITE rates, the time period selected should reflect peak travel
periods on adjacent streets and care shall be exercised in utilizing rates developed from a small study
size (fewer than 20 studies) or containing a low R2 value (less than 0.75).5
In some cases, the peak hour of the generator may occur outside the typical peak commute hours
and may require additional analysis (e.g., a regional shopping center on a Saturday or a school during
the afternoon pick-up period).
4 Trip Generation Manual (10th Edition), Institute of Transportation Engineers, 2017.
5 R2 is the coefficient of determination defined as the percent of variance in the dependent variable (number of vehicle trips) associated from the independent variable (size of the project).
How do I
Estimate the Project’s Trip
Generation Characteristics?
16
The City reserves the right to require the project applicant to conduct local trip generation surveys for
select projects depending on project characteristics as well as land use and travel conditions in
the field.
Person Trips
If a project is located in an area where significant levels of walking, bicycling and/or transit use are
expected, person trip generation should be presented for single occupant vehicles (SOV), carpool,
rideshare, transit, bicycle, and pedestrian trips. Person trip generation rates should be developed from
empirical studies, person travel survey data, or conversion of vehicle trip rates to person trip rates
using a vehicle occupancy factor and adjustments based on travel behavior at the study location. In
addition, person trip generation by mode may be derived using an approved analysis tool that
incorporates data from the above sources. Either method may be used to apply a vehicle trip credit to
the previously calculated vehicle trip generation totals using the processes discussed below.
Establishing Trip Generation Rates for an Unknown or Unique Use
For projects where the ultimate land-use is not certain (for example, a large subdivision of flexible
commercial-industrial parcels), there are two options for establishing the trip generation rates:
• Option 1: City staff will recommend the use of the highest traffic intensity among all
permitted uses to establish transportation impacts.
• Option 2: Estimates can be made using a lower intensity use if the City and developer
establish a maximum trip allowance. Once a proposed land use has been identified, then 1)
the subdivision trip generation allowance must be monitored by the City as development
occurs; and 2) the transportation analysis may need to be updated.
Trip Rate Credits for Existing Uses
For trip generation estimates and subsequent level of service analysis, the estimate of new trips
generated by the proposed development project may include credit for trips associated with existing
uses on the site. Uses are considered as existing if they are actively present on the project site at the
time data is gathered for the transportation impact analysis. Additionally, if a planned (but not
constructed) use was already permitted for the site, the baseline for analysis may be the permitted use
if all mitigation measures from the approved use remains applicable, subject to City staff approval.
For the evaluation of vehicle miles of travel, VMT credit for the prior use may be considered if that use
was active within the past three years, and if a similar type use could reoccupy the building without
needing to obtain a conditional use permit. However, this credit should only be applied to total
project-generated VMT, and should not be included when calculating VMT per capita.
For the calculation of transportation fees, the net peak hour trips generated by a project would be
determined by applying a credit for existing uses if that use was active within the past three years.
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Multi-modal and Other Trip Rate Reductions for Standard ITE Rates
Standard rates published by ITE are generally developed for suburban sites where access is primarily
made via personal automobile. The City of San Rafael recognizes that the rates may overstate the
traffic impact for developments that contain a mix of uses (and “capture” some vehicle trips internally)
or are in denser areas such as downtown San Rafael. Additionally, certain commercial land uses attract
vehicles on the roadway, rather than generating new trips. This section discusses reductions that may
be taken under these circumstances.
Internalization / Walking, Bicycling or Transit Trips
Internal or captured trips are trips that do not enter or leave the driveways of a project within a
mixed-use development. They are similar to active transportation trips (e.g., walking or bicycling) or
transit trips in a setting like San Rafael, where destinations may be reached on foot (a “park once”
environment). These trips do not add vehicle traffic to the local roadway system. Trip rate reductions
are allowed for internalization for internal trips at mixed-use sites or in downtown San Rafael.
Specifically, trip generation estimates may use trip adjustments due to land use variables such as
Density, Diversity, Design and Destination to enhance its sensitivity to the built environment. These
four most commonly discussed built environment factors and their effects on vehicle trips are
summarized below:
• Net Residential and Employment Density – A wide body of research suggests that, all else
being equal, denser developments generate fewer vehicle trips per unit than less
dense developments.
• Jobs/Housing Diversity – Research suggests that having residences and jobs in close
proximity will reduce the vehicle-trips generated by each land use by allowing some trips to
be made on foot or by bicycle.
• Walkable/Bikeable Design – Many pedestrian and bicycle improvement projects assume
(supported by research findings) that improving the walking/biking environment will result in
more active travel trips (e.g., walking, bicycling, etc.) and a resulting reduction in
vehicle travel.
• Destination Accessibility – Research shows that, all else being equal, households situated near
regional centers of activity generate fewer vehicle trips and VMT.
Other built environment factors such as demographics, distance to transit, and employment within 30
minutes by transit also affect vehicle trip-making. Reductions shall be based on empirical and peer-
reviewed data, and quantitatively supported in the transportation analysis report. If trip rates are
derived from a local survey of a similar land use or derived by a mixed-use trip generation estimator,
additional trip reductions may be permitted based on location and other factors. Tools are available
from ITE and other sources to estimate these reductions. City staff may provide direction on which
analysis tools are most appropriate for a project’s transportation analysis.
18
Pass-by / Diverted Link
Restaurants, convenience stores, gas stations, banks, and similar commercial land uses often locate on
high traffic volume roads to attract motorists already on the street. These attracted trips are not new
traffic to the adjacent street system, but simply access a new use as part of their current travel path.
These trips are known as pass-by trips. For commercial land uses on arterial or collector streets, a
reduction for pass-by trips supported by analysis may be used. Analysis resources may include the ITE
Trip Generation Handbook Chapter 10 or a documented and relevant study. To ensure adequacy of
project driveways, the access analysis at these locations should reflect total site-generated trips, and
not include any pass-by or similar reductions.
Diverted link trips are similar to pass-by trips in that they are vehicle trips already on the roadway
network. However, the key difference is that diverted link (link meaning roadway) trips pull traffic from
other roadways (not adjacent to the project site) onto the roadway(s) serving the development. Thus,
these trips do add traffic to adjacent streets serving the site and should not be included as a reduction
for the assessment of site access and circulation, but could be included as a reduction in the
preparation of new vehicle trip estimates as inputs to air and noise analyses, and could also be
considered in the VMT assessment.
As an example, a new gas station is proposed on a minor street one block away from a major arterial
street. The trips that are attracted to the station site from existing traffic on the major arterial are
diverted link trips. Those trips attracted to the site from existing traffic on the minor street in front of
the new gas station are defined as pass-by trips. In both cases, these are not new trips to the overall
network but come from existing volumes on adjacent or nearby roadways.
Transportation Demand Management Reductions
In addition to project characteristics that can reduce trip generation, transportation demand
management (TDM) strategies can further reduce the vehicle trips from a project site such as:
• Neighborhood / Site Enhancement – Bicycle and pedestrian network, car sharing programs,
traffic calming, and site design to support other travel modes;
• Parking Policy / Pricing – Parking supply limits, unbundled parking cost from property cost,
and public parking pricing;
• Transit System Improvements – Built environment and access transit stop
improvements; and,
• Commute Trip Reduction – Transit fare subsidy, employee parking cash-out, alternative
work schedules, priced workplace parking, shuttles, and employer sponsored vanpools.
TDM strategies committed to by a project in their application and project description should be
included in the analysis, with the corresponding recommended reduction in vehicle trip generation for
each element clearly stated. Any trip rate reductions claimed for a TDM strategy are subject to
approval by City staff and should be substantiated with either industry standard publications/tools
(such as the CAPCOA Guide to Mitigating Greenhouse Gas Emissions, CalEEMod, etc) or local data. Trip
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rate reductions associated with a TDM strategy are also subject to a monitoring plan, to be developed
by the project applicant and modified based on review and comment provided by City staff.
20
VMT Estimation and Cumulative Travel Forecasts
To conduct transportation forecasts and VMT analysis that meets environmental regulatory conditions
and provides a high level of confidence in the analysis results, analysts should follow state-of-the-
practice or best practice methods for transportation forecasting.
For consistency, analysts are required to use the TAM Travel Demand Model or other model as
approved by City staff, for large plans or projects 6 that require a quantitative VMT assessment, and
conduct checks to ensure it is sufficiently accurate and sensitive within the study area and for the
types of land use and transportation changes associated with the project.
• Conduct sub-area validation of the community being studied, if necessary
• Prepare the following model runs
◦ Baseline without Project
◦ Baseline with Project
◦ Cumulative without Project
◦ Cumulative with Project
Consultants should contact TAM staff directly to coordinate the process and identify any related costs
for obtaining VMT forecasts for large plans or projects using the TAM Travel Demand Model.
Depending on the specific year represented by “base year” conditions, model output may need to be
adjusted to represent “baseline” conditions for CEQA purposes.
For small projects that require a quantitative VMT assessment or large projects where a travel demand
model may not be appropriate, alternative methods for quantifying VMT may be used including
applying daily trip generation forecasts, trip length data for comparable uses from the TAM travel
model or other applicable data sources, and project population estimates.
6 Large plans or projects would generally include General Plan Updates, major General Plan Amendments, Specific Plans, and employment uses of 100,000 gross square feet or more.
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Transportation Impact Analysis and
Circulation Studies (non-CEQA)
The contents and extent of a transportation impact analysis depend on the
location and size of the proposed development, the prevailing transportation
conditions in the surrounding area, and the technical responses to address
questions being asked by decision-makers and the public. In general,
projects will prepare either:
a. A Local Traffic Assessment (Tier 1 projects, Tier 2A projects, and Tier 2B
projects in Downtown San Rafael); or,
b. A Transportation Impact Analysis (Tier 2B projects outside of Downtown
San Rafael and Tier 3 projects)
The City is committed to a balanced level of analysis for all modes of travel. The methods presented in
this chapter include robust data collection and analysis techniques for pedestrian, bicycle and transit
networks, in addition to vehicle circulation.
Scope of Analysis
Study Area
The study area can be thought of as the area of influence of a project and is determined by evaluating
the project location and how it may affect all transportation modes and facilities. It is not simply a
map showing where the project is located. Each local transportation analysis will consider the adjacent
transportation system for site access and circulation of land development projects and street
modifications for transportation projects.
Local Traffic Assessment
The study area for small projects should consist of, at a minimum, the roadways providing immediate
access to the Project site, including any pedestrian, bicycle, or transit facilities. For most projects in
this tier, analysis will focus on project driveways, and identify 2-4 intersections near the project to
assess the effects on site access. This level of analysis is also appropriate for many projects located
within Downtown San Rafael.
Transportation Impact Analysis
In addition to the level of study required for a Local Traffic Assessment, the City may require
additional off-site intersection analysis or other multimodal analysis. Generally, intersections within a
one-mile radius that are known to currently operate at LOS D or worse based on previous studies, and
where the project adds at least ten or more peak hour trips per lane to any movement should be
What is included in
a local transportation
analysis?
22
considered for analysis. The study area should include the nearest CMP facility or CMP-monitored
intersection to evaluate the proposed project’s conformity with the CMP.
Applicants should consult with the City early regarding the study area and need for off-site
multimodal analysis based on local or site-specific issues, especially those related to pedestrians,
bicycles, rail crossings, and transit. The City requires the consultant to perform field reviews to
completely assess existing conditions.
Key Study Elements
The extent and complexity of a transportation analysis can vary greatly. Table 2 summarizes the
potential study elements to be considered for every project that requires a complete transportation
analysis, including both Site Access and Circulation Memoranda and Transportation Impact Analyses.
Specific significance criteria for each of the listed elements are described in further detail in the
Transportation Analysis (CEQA) for Land Use Projects and Transportation Analysis (CEQA) for
Transportation Projects chapters. To avoid the potential for identification of substantial off-site
improvements or changes to the project site plan/description after the transportation analysis is
completed, a preliminary site-plan shall be included for a “fatal flaw” evaluation.
Table 2: Local Transportation Analysis – Potential Study Elements and Evaluation Criteria
Study Element Evaluation Criteria
General Plan Consistency Evaluate the project against goals, policies, and actions set forth in the General Plan
Parking
(if required)
A parking assessment would only be required if a new use or a change in use is
requested by the applicant as determined by City staff.
Compare the project parking plan with City standards and expected demand and discuss how the proposed supply will affect demand for walking, bicycling, and
transit modes. If a mix of land uses is proposed on-site, or complements adjacent
land uses, justify how the development will make use of shared on-site parking.
On-Site Circulation
Review and evaluate site access locations, turning radii, truck loading areas, emergency access, and other site characteristics with respect to operations and safety for all modes of transportation. Projects with a drive-through component are
required to evaluate vehicle queues at the drive-through. Projects with a gas station component are required to evaluate how fuel delivery trucks would access the site. The City may require other analyses based on specific uses. School TIAs will require on-site circulation plan integral to their preferred routes to school. Include on-site drop off / pick up plan.
Pedestrian Facilities
Identify any existing or planned pedestrian facilities that may be affected by the
project. Document how the project will affect local pedestrian circulation (e.g., disclose how widening a road or adding a driveway will affect pedestrian safety and comfort).
Bicycle Facilities Identify any existing or planned facilities (per Bike Plan) that may be affected by the project.
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Table 2: Local Transportation Analysis – Potential Study Elements and Evaluation Criteria
Study Element Evaluation Criteria
Transit
Identify any existing or planned transit facilities that may be affected by the project.
If appropriate, document how the project improves access to or utilization
of transit.
Trip Reduction Ordinance (TRO) Evaluate project against trip reduction requirements of City of San Rafael Trip Reduction Ordinance.
Safety Assessment TBD See attached
Trucks (or Other Large Vehicles)
For relevant industrial projects, identify the number of truck trips that will be generated, including STAA trucks, and design facilities necessary to accommodate these trucks.
Passenger Loading and Pick-up/Drop-Off
For projects that may have a large concentration of pick-up/drop-off activity, the project site circulation and pick-up/drop-off areas must be reviewed to identify opportunities and constraints of the project site. Modifications to the site circulation and/or pick-up/drop-off may be recommended. This analysis should include a discussion of TNC activity as appropriate.
Off-Site Traffic Operations
Vehicle Level of Service analysis should be conducted for all roadway segments and
intersections included in the study area for Tier 2B projects outside of Downtown San Rafael and Tier 3 projects as determined by City staff. The City reserves the right to define the study area. All roadway facility analysis should be conducted using the latest version of the Highway Capacity Manual (HCM) unless other methods or tools that are more applicable to the study area or project context are approved by City staff.
Intersection Traffic Control
Evaluate unsignalized intersections located within the study area to determine appropriate traffic control. Analysis should consider the appropriateness of roundabouts as an alternative to traffic signals. See attached
Other Issues Consider other issues on a case-by-case basis (e.g., construction deficiencies, queuing between closely spaced intersections, emergency access, special event traffic)
Other Jurisdictional Requirements
In situations where several agencies must approve a development or are responsible for affected roadways, the applicant must contact lead and responsible agencies to determine issues to be addressed, scope of study, etc. In general, the
applicant will be responsible for analyzing project impacts against appropriate
jurisdictional thresholds; however, the analysis method will be determined by the City in compliance with CEQA and the impacts will be mitigated consistent with City standards.
Multimodal Site Access and Circulation
A detailed multimodal site access and circulation plan review is required for all projects. The
transportation analysis should include a review and summary of findings of the following qualitative
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and quantitative features included in the checklist in Attachment A: Site Access and Circulation
Plan Review.
An important aspect of a transportation analysis is to provide sufficient information for the City to
determine if a project is consistent with the General Plan, other applicable City plans, and relevant
design standards. Individual projects must be reviewed against relevant policies contained in the
General Plan and other plans, policies, and standards. Applicants should review the full policy
statements in the latest General Plan Circulation Element.
If the study area extends into an adjacent jurisdiction, the applicant may be responsible for analyzing
project-generated operational impacts in these jurisdictions. These include intersection or segment
locations in any other jurisdiction, including Caltrans-maintained facilities. The applicant shall refer to
current policies in the respective jurisdiction to identify the appropriate significance criteria.
Details on how intersection and roadway segment LOS will be analyzed, and operations addressed,
are discussed in the deficiency sections toward the end of this chapter. Per the General Plan, physical
improvements focus on operational efficiencies (i.e., signal coordination, modified timings) and
enhancements to improve bicycle and pedestrian travel as needed. Roadway expansions are
considered in the developing areas of the City, consistent with major planned mobility improvements
identified in the General Plan.
Analysis Time Periods
Based on the land use of the proposed project and upon consultation with
City staff, the study should typically analyze traffic operations during the
peak one-hour of the following time periods:
• Weekday morning peak (7:00 – 9:00 AM)
• Weekday evening peak (4:00 – 6:00 PM)
For some projects, the City may substitute or require additional peak hour analysis for the following
time periods.
• Weekday afternoon peak (2:00 – 4:00 PM)
• Friday evening peak (4:00 – 7:00 PM)
• Weekend mid-day peak (11:00 AM – 1:00 PM)
• Sunday or holiday evening peak (4:00 – 7:00 PM)
For example, retail commercial projects that are 100,000 square feet or larger should evaluate
operations for Saturday mid-day peak hour conditions, in addition to the standard weekday morning
and evening peak periods. The determination of study time periods should be made separately for
each proposed project based upon the peaking characteristics of the project-generated traffic and
peaking characteristics of the adjacent street system and land uses.
What time periods need to
be analyzed?
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Scenarios for Local Transportation Analysis (non-CEQA)
When a LOS analysis is required, the range of analysis scenarios is
dependent on several factors:
• Project size and complexity
• Planned construction schedule (i.e., phasing)
• Location and potential impact relative to other
approved development
• Consistency with the General Plan
• Consistency with the CMP
The range of scenarios includes Existing Conditions (typically for projects that generate between 110
and 2,000 daily trips), Background Conditions (potentially some that generate between 110 and 2,000
daily trips, and all projects that generate more than 2,000 daily trips), and Cumulative Conditions (all
projects that generate more than 2,000 daily trips). Projects consistent with the General Plan will only
be required to complete the Existing and Background conditions analysis; where Existing Conditions
looks at the effect of the proposed project on the existing system within the next year or two, and
Background Conditions typically looks at a longer time frame of about three to five years. Inclusion of
all three analysis conditions (e.g., Existing, Background, and Cumulative), would typically occur for
large development projects, General Plan Amendments, Precise Plans, and Specific Plans (and related
amendments), with Cumulative Conditions having a time horizon of 15 to 20 years.
The following analysis scenarios will document existing or future conditions, any deficiencies, and
identify deficiencies that will result from the addition of the project. Each scenario will include a
qualitative description of transportation facilities for all modes (and any planned enhancements),
traffic volumes, and a quantitative analysis of intersection LOS. Key study elements are identified in
the Multimodal Analysis Methods section of this chapter. Details regarding each transportation
analysis scenario are presented below.
Existing Conditions
Existing without Project
These conditions are based on recent field observations and recent (less than two years old) traffic
count data.
Existing with Project
Traffic volume forecasts for roadway analysis reflecting Existing Conditions with traffic generated by
the proposed project. For re-use or conversion projects, this will involve accounting for any existing
use of the site that remains or will be removed. It should also qualitatively describe how the project
will affect transportation for other modes including compliance or relation to other City documents.
For phased projects, this will likely incorporate only the first phase, with later phases assessed against
background conditions.
How many local transportation
analysis scenarios are required?
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Background Conditions
Background without Project
Traffic volume forecasts for roadway segment and intersection analysis should reflect Existing
Conditions with growth due to approved development that is expected to be operational before or
concurrently with the proposed project. This scenario may not be needed if the study area has limited
or no approved developments. A list of approved and pending projects can be obtained from City of
San Rafael Community Development Department.
Background with Project
This scenario represents the Background Conditions with vehicle trips added by the proposed project.
This scenario provides decision-makers and the public with a view of conditions with all recently
approved development and physical improvements including the proposed project. For phased
projects, there may be multiple Background plus Project scenarios representing individual phases.
Cumulative Conditions (General Plan Amendments and Specific Plans)
Cumulative without Project
Transportation conditions for all travel modes in the study area reflecting all approved projects,
pending projects, or expected development of other areas of San Rafael designated for growth under
the General Plan. In most cases, the project site will likely be vacant under this scenario. In some
cases, this scenario may need to account for any existing uses on the site that could continue, and
potential increases in development allowed by ministerial approvals.
Cumulative with Project
This scenario represents the cumulative future transportation conditions with anticipated changes to
the transportation system and the additions of project trips and provides the long-range view of
future traffic operations. For phased projects, this should reflect project build-out.
Data Collection
Accurate data is essential to achieve a high level of confidence in transportation analysis results.
Existing transportation data shall be collected using the requirements set forth below. Data should be
presented on maps or figures where appropriate. To address the specific needs of each project, the
extent of data collected shall be at the discretion of City staff.
• Pedestrian/Bicycle Facilities – The report will document the existing pedestrian and bicycle
facilities serving the project site. Elements will include presence and width of sidewalks, curb
ramps, crosswalks or other pedestrian facilities within ½-mile walking distance of the project
site, and bicycle facilities (e.g., routes, lanes or shared use paths) within a two-mile bicycling
distance of the project site. Document barriers, deficiencies and high-pedestrian demand land
uses including schools, parking, senior housing facilities, and transit stops or centers. Consider
using evaluation tools such as www.walkscore.com or similar tools to quantify walkability. The
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report will note any deficiencies or enhancements planned or recommended in the Bicycle
Master Plan or other planning documents.
• Transit Analysis – The report will document transit lines that serve the project site (e.g.,
within ½-mile walking distance), including stop locations, frequency of service, and any
capacity issues. It will also describe transit stop amenities (e.g., benches, shelters, etc.).
• Multimodal Peak-Period Turning Movement Counts – Turning movement counts,
including vehicles, heavy vehicles, bicycles, and pedestrians, will be collected for each study
time period at all study intersections. The following parameters will be followed:
◦ Data collection will cover at least two hours to ensure the peak hour is observed.
◦ Traffic volumes should not be influenced by a holiday, weather, construction, or other
temporary change, and should occur when area schools are in typical session.
◦ The percent of traffic that consists of heavy trucks will be noted/estimated during
data collection.
◦ Some projects may require vehicle classification or occupancy counts. Consult with City
staff on a case-by-case basis.
◦ Traffic counts that are older than two years at study initiation will not be used without
consultation and approval by City staff. These counts may need to be re-counted or
adjusted to reflect current year traffic volumes.
• Roadway Geometry – Document existing roadway and intersection geometries and lane
configurations. Information from aerial photography and street views should be verified
based on a site visit(s).
• Intersection Controls, and Signal Timings – For use in intersection analysis, intersection
control types and signal timings and phasing should be based on signal timing sheets
(available from City of San Rafael or Caltrans) and verified during site visits.
Traffic Operations Analysis
Traffic operational deficiencies shall be analyzed using standard or state-of-the-practice professional
procedures. The main issues related to traffic operations analysis are the method, input data, and
assumptions. These three items influence the level of confidence and the associated level of
defensibility of the transportation analysis. For traffic operations, this requires following the
procedures and techniques published in the most recent Highway Capacity Manual (HCM).
Traffic Signal Parameters
Traffic signal parameters are as important as accurate turning moving counts for determining
intersection LOS. As summarized in Table 3, the following intersection data should be collected
and/or calculated along with the traffic counts. Traffic signal timing information should be collected
from City, County, or Caltrans staff, and verified by field observations.
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Table 3: Traffic Signal Parameters
Parameter Recommendation
Peak Hour Factor (PHF)
PHF for Existing Conditions should be collected and calculated from the traffic count data. It should be calculated individually for each isolated intersection and grouped for closely spaced intersections. For cumulative scenarios or Existing Conditions where the PHF is not available,
refer to the most recent Highway Capacity Manual (HCM) and maintain consistency throughout
the analysis periods. If a simulation model is used for analysis, the PHF should be applied over
more than a 15-minute period.
Saturation Flow Rate
A field measurement of the saturation flow rate is recommended in accordance with procedure
in the HCM, Chapter 31, Signalized Intersections: Supplemental.
For Cumulative Conditions, use the value recommended in the most recent HCM unless physical conditions and traffic controls warrant a change.
Yellow Phase
Ranges from three to six seconds, with longer values in this range used with phases serving high-speed movements. If a traffic signal is present under Existing Conditions, use existing yellow phase (HCM, Chapter 19).
All Red Phase One second per phase (if a traffic signal is present under Existing Conditions, use existing length of all red phase). This phase may be greater on high-speed roadways.
Pedestrian and Bicycle Conflicts
Pedestrian and bicycle signal calls and crossing conflicts at intersections can increase delay for vehicles. Outside of dedicated phases, they generally conflict with right-turning motorists and motorists making permitted left turns. The volume of each should be collected during traffic counts and used in the analysis. Otherwise refer to the most current version of the HCM.
Cycle Lengths
Replicate existing cycle length and phasing (e.g., leading left turns) when possible. For new signalized locations, use the cycle lengths of the following three categories unless other cycle lengths can be justified through the traffic operations analysis.
• In and around downtown – limit signal cycle lengths to 60 seconds or less.
• In and around suburban areas – limit signal cycle lengths to 90 seconds or less.
• Near freeway interchanges/regional commercial – limit signal cycle lengths to 120 seconds or less.
Ensure that minimum pedestrian crossing times and bicycle clearance intervals are satisfied.
Heavy Truck Percentages
Based on the existing heavy-truck percentage and adjusted to account for future planned development. In general, heavy-truck percentages should be greater on truck routes and main thoroughfares than on local streets. Minimum recommended value is 2%.
Lane Utilization Factor If applicable, adjust lane utilization factors based on field observations.
Evaluation of Side Street Stop-Controlled Intersections
In addition to reporting the worst individual approach delay, the delay for the overall intersection
shall be calculated and reported. This information will allow reviewers to gauge potential impacts to
individual approaches against those for the entire intersection.
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Methodology and Software
Intersection operations shall be analyzed using Synchro unless an alternative analysis methodology is
identified through consultation with City staff. Table 4 provides a matrix of software options for
analysis. Special conditions related to congested conditions, state highway facilities, and roundabouts
are discussed in more detail below.
Table 4: Software Analysis Options
Software/
Method1
Traffic Studies Roundabouts Arterial/ Interchange Operations Microsimulation Analysis4
Operations2 Signal Coor-dination3 Planning Design Unique Geometrics
Heavily Congested Conditions
Multi-modal
Synchro/SimTraffic X X X X X
VISTRO/TRAFFIX X X
HCS X X
SIDRA for Roundabouts X X
Microsimulation5 X X X X X X
Notes: 1. The most current version of analysis software (with updated software patches) should be used. 2. Appropriate for isolated intersection operations or for signal systems that are not coordinated. 3. Mandatory for coordinated signal systems to maximize vehicle progression. 4. Should be applied to analyzing operations of congested conditions or non-standard conditions where traditional analytical approaches may not be appropriate. 5. Specific software program selection should be conducted in consultation with the City and consider the types of technical questions being asked in the study and the modes to be included.
Congested Conditions
Analysts should note that the HCM recommends the use of simulation models to analyze congested
conditions or closely spaced intersections. Because simulation tools (e.g., VISSIM, SimTraffic, etc.) can
simultaneously evaluate vehicle interactions across a complete network (including the interaction of
multiple modes), they can provide a more complete understanding of traffic operating conditions
during peak congested periods and what may happen when a specific bottleneck is modified or
eliminated. Specifically, care should be taken in analyzing intersection LOS at closely spaced
intersections. In such cases, standard intersection analysis does not adequately show the compound
effects of intersection delay.
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State Highway Analysis
The analysis of state highways, including freeways and on- and off-ramps, should be conducted
consistent with CMP Guidelines.
Roundabout Analysis
Typically, roundabout operations are analyzed in conjunction
with a conceptual roundabout design. Different roundabout
analysis methods (FHWA, Australian Gap Acceptance, UK
Empirical, HCM 2010, and microsimulation) provide different
delay results and corresponding capacities. The deterministic
roundabout analysis methods described in the HCM can be
used for roundabouts operating under low volume and
isolated conditions (without influence from nearby
intersections). HCM methods allow the use of calibration
factors to reflect regional differences in roundabout capacity.
Calibration factors specific to California are available in the report Roundabout Geometric Design
Guidance, 2007, California Department of Transportation Division of Research and Innovation.
Roundabout queue lengths should also be reviewed to ensure they do not spill beyond available
storage or interfere with overall operations of the roundabout and/or transportation system.
As described in the HCM, the use of alternative analysis methods is needed for complex multi-lane
roundabout designs, roundabouts operating near or at capacity, high pedestrian and/or bicycle
volume, and at roundabout locations where upstream or downstream operation may interact with
adjacent roundabouts or signals. Microsimulation of the roundabout and surrounding intersections
may also be useful. Care must be taken in coding and calibrating the microsimulation models to
accurately reflect the proposed roundabout design and operational characteristics.
When comparing roundabout versus signal control at a given location, long-term maintenance costs
should be estimated and considered in the evaluation.
Mobility Deficiency Criteria
Transportation analyses evaluate intersection operations focused on specific traffic issues such as
queuing and safety. An emphasis is placed on pedestrian, bicycle, and transit facilities and services, in
part to reduce traffic congestion and air quality impacts associated with automobile use. Table 5
outlines deficiency criteria for each mode, with local analysis thresholds presented below. The mobility
deficiency criteria can be used to identify conflicts with existing or planned multimodal facilities.
Table 5 also notes if the criteria is applicable for CEQA review or for local transportation analysis
review only. Level of Service (LOS) consistency determinations shall be made based on General Plan
Policy M-2.5 that identifies thresholds and a process for locations that exceed the thresholds.
Transportation Analysis Deficiencies
A transportation analysis
evaluates all modes of
transportation and includes
analysis of elements such as
parking and traffic operations
that are not considered
environmental impacts.
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CMP Deficiency Criteria
To determine consistency with the CMP, off-site intersection analysis may be needed. The analyst
should refer to the most current TAM Congestion Management Program policy document.
Improvements
When deficiencies are identified, improvements should be incorporated into projects either as
conditions of approval or CEQA mitigation, presuming that they are deemed feasible and consistent
with the General Plan. Applicants will also be required to pay all applicable local and regional
transportation impact fees. To the extent a project is conditioned to construct an improvement
project that is included within the local or regional fee program, a reimbursement agreement may be
sought for a portion of the improvement project.
All project deficiencies should be addressed consistent with the policies of the General Plan. Under
these circumstances, the applicant should meet with City staff to identify transportation
improvements that address the deficiencies. Table 6 shows example types of improvements to
address transportation deficiencies. Potential improvements may require a more detailed review,
often including traffic operations, to demonstrate how they address a specific deficiency. This list is
not intended to be an all-inclusive list but provide some options to consider. All improvements are
subject to review and approval by City staff.
Selected improvements should be identified whether they will be implemented under Existing
Conditions, Background Conditions or Cumulative Conditions. Background Conditions generally
reflect conditions at the time of full occupancy of a project.
If a transportation improvement is selected to address a deficiency, it should include a description of
how the improvement contributes to the multimodal transportation system in San Rafael. In addition,
all transportation improvements need to consider whether they have secondary effects to VMT [i.e.,
whether the improvement is VMT inducing per guidance in Attachment C: List of Transportation
Projects Exempt from Environmental Analysis (CEQA)].
Table 5: Mobility Deficiency Criteria
Study Element Deficiency Determination Applicability
Parking Project increases off-site parking demand above a level required by the City Zoning Code or estimated demand. Local
On-Site Circulation
Project designs for on-street circulation, access, and parking fail to meet City design guidelines. Where City standards are not defined, industry standards (Highway Design Manual, MUTCD, etc.) should be referenced, as appropriate. Failure to provide adequate access for service and delivery trucks on-site, including access to loading areas. Project will result in a hazard or potentially
unsafe conditions without improvements.
Local and CEQA
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Table 5: Mobility Deficiency Criteria
Study Element Deficiency Determination Applicability
Pedestrian Facilities
Project fails to provide safe and accessible pedestrian connections between project buildings and adjacent streets, trails, and transit facilities. Project adds trips to an existing facility along the project frontage that does not meet current pedestrian design standards.
Local and CEQA
Bicycle Facilities
Project disrupts existing or planned bicycle facilities or is otherwise inconsistent with the Bicycle Master Plan or future plans. Project adds bicycle trips along project frontage to an existing facility that does not meet current bicycle design standards.
Local and
CEQA
Transit Project disrupts existing or planned transit facilities and services or conflicts with City adopted plans, guidelines, policies, or standards. Local and CEQA
TDM Program A project does not comply with the City’s Trip Reduction Ordinance. Local and CEQA
Heavy Vehicles (Trucks and Buses)
A project fails to provide adequate accommodation of forecasted heavy traffic or temporary construction-related truck traffic consistent with City or industry standards (Highway Design Manual, MUTCD, etc.).
Local and CEQA
Off-Site Traffic Operations
95th percentile vehicle queues exceed the existing or planned length of a turn pocket or freeway off-ramp, resulting in a speed differential with the adjacent lane of travel; or where a queue exceeds the available storage without the project, project traffic increases the queue by more than 50-feet. The proposed project introduces a design feature that substantially increases safety hazards.
Local and CEQA
Intersection Traffic Control
Addition of project traffic causes an intersection to fail to maintain LOS Standards as specified in General Plan Policy M-2.5. If the intersection is already failing to maintain LOS standards under No Project conditions, a deficiency occurs if the project causes an increase in delay of five seconds or more at the intersection.
Local
General Plan
Consistency
Evaluate the project against mobility, safety, and other related goals, policies,
and actions set forth in the General Plan. CEQA
Other Subject Areas
Consider other areas on a case-by-case basis (e.g., construction impacts, queuing between closely spaced intersections, emergency access, special event traffic, etc.).
Local and CEQA
Requirements for Other Jurisdictions
The project exceeds established deficiency thresholds for transportation facilities and services under the jurisdiction of other agencies. CEQA
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Table 6: Example Improvements
Study Element Improvement
Project Modifications and Transportation
Demand
Management
• Alter density or diversity of project uses
• Encourage flexible employee working hours
• Allow parking “cash out” or require employee paid parking
• Institute preferential parking for carpools
• Encourage employees to use carpools and public transportation
• Provide employee walk/bike incentives
Pedestrian and Bicycle Facilities
• Provide for access to, from, and through the development for pedestrians
and bicyclist
• Construct Class I bicycle paths, Class II bicycle lanes, and other facilities
• Provide secure bicycle parking and shower amenities
• Reduce travel lanes on a street to install a two-way left-turn lane and Class II bicycle lanes
• Add corner bulbouts, reduce curb radii, add pedestrian refuges or implement other walking-related improvements
• Dedicate right-of-way to provide bicycle or pedestrian facilities
Transit Facilities
• Provide bus turnouts, bus shelters, additional bus stops, and park-and-ride lots
• Fund increases in transit service
Parking Facilities
• Design parking facilities to allow free-flow access to and from the street
• Provide off-street parking per City standards or recommendations
• Implement shared parking among complementary land uses
Traffic Control Modifications
• Provide for yield or stop control
• Evaluate unsignalized intersections with substandard LOS for conversion to roundabout intersection control or for signalization.
• Provide coordination/synchronization of traffic signals along a corridor
• Provide turn-lane channelization through raised islands
• Restrict selected turning movements
Street Operations Modifications
• Optimize location of access driveway(s)
• Provide improvements to traffic signal phasing, or lengthen existing turning pocket
• Provide additional through traffic lane(s), right-turn lane(s), and left-turn lane(s) if they do not adversely impact other modes or induce additional vehicle travel
• Reduce travel lanes on a street to install a two-way left-turn lane
• Congestion pricing on roads or within a specific area
• Install a roundabout
• Signalize an intersection, or replace a signalized intersection with a roundabout
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Multimodal Analysis Methods
The report should provide a qualitative evaluation of the project’s potential adverse or beneficial effects
on transportation facilities and services related to pedestrians, bicycles, transit, and rail crossings.
For some projects, more detailed multimodal analysis may be required. Such analysis shall be decided
upon in consultation with City staff and consider new tools, methods, and performance measures such
as those listed below.
• Multimodal LOS – The Highway Capacity Manual (6th Edition) contains methods for
multimodal LOS. Alternatively, simulation models can be used to measure performance (i.e.,
person-delay) for all modes within a transportation network.
• Level of Stress (LTS) – There are several methodologies for evaluating LTS for bicycle
facilities. These methodologies generally rely on street widths/number of vehicle lanes,
vehicle speeds, daily volumes, and type of bicycle facility to evaluate “low stress”
bike networks.
• Transit Capacity – The project’s person trip estimates can be used to forecast transit demand
and evaluated against available transit capacity.
• Activity Connectedness – Travel time for each mode (e.g., walking, bicycles, transit, and
vehicles) between the project and surrounding land uses can be used to gauge the degree of
accessibility for a project. The City desires to minimize travel time to necessary destinations
while minimizing unnecessary vehicle travel.
Tools such as geographic information systems or online tools (e.g., Index and Walk Score) can be used
to gauge this measure specifically for walking. The main idea is to evaluate activity centers and
destinations around projects to ensure that walk times to necessary destinations are minimized and
the walking experience is comfortable.
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Transportation Analysis (CEQA) for
Land Use Projects
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.
Specifically, SB 743 removes the use of automobile delay, LOS,
and other similar measures of vehicular capacity or traffic
congestion for determining transportation impacts in
environmental review. According to the legislative intent
contained in SB 743, the move away from LOS is necessary to more appropriately 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.
The legislation also directed the State of California’s Office of Planning and Research (OPR) to look at
different metrics for identifying transportation impacts and make corresponding revisions to the
CEQA Guidelines. OPR selected VMT as the preferred metric for assessing passenger vehicle-related
impacts and issued revised CEQA Guidelines in December 2018, along with a Technical Advisory: On
Evaluating Transportation Impacts in CEQA (December 2018) to assist practitioners in implementing
the CEQA Guidelines revisions to use VMT as the new metric. The VMT methodology and thresholds
are consistent with OPR’s Guidelines and Technical Advisory.
Methodology
The following section provides details on if and how a VMT analysis should be conducted for land use
plans and projects.
Initial Screening
San Rafael’s VMT screening process for projects that can be presumed to cause a less-than-significant
impact without conducting a detailed study is discussed on page 5. However, even if a project is
exempt from VMT analysis, it may still be required to evaluate the following CEQA requirements:
• Conflicts with a program, plan, ordinance, or policy addressing the circulation system,
including transit, roadways, bicycle lanes, and pedestrian paths;
• 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.
Additionally, other non-CEQA analysis may be required based on the project type, location, and level
of daily trip generation. All projects need to document and justify the applied VMT screening criteria.
Does my land use project result in an
environmental impact?
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Assessment for Non-Screened Projects
Projects not screened out through the criteria listed in the Determining the Level of Transportation
Analysis section are required to complete a VMT analysis using the City of San Rafael General Plan
Model to determine if there would be a significant VMT impact. The impact analysis includes two
types of VMT:
1. 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). As an example:
a. Residential projects should present home-based VMT per resident
b. Office, R&D, and Industrial projects should present work-based VMT per employee
c. Retail projects should present Total VMT per employee
d. Mixed Use projects and Land Use Plans should present Total VMT per service
population and/or VMT metrics for each land use type evaluated individually against the
above residential, office, and/or retail thresholds
e. Other Land Use projects may apply an ad hoc threshold as developed by City staff
f. All other projects should present total VMT per service population (where the service
population is the sum of residents, employees, and students)
2. Project effect on VMT compares how the project changes VMT on the network looking at
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., Marin County
or the Bay Area region). This VMT captures the project’s overall influence on the VMT
generation of surrounding land uses.
The types of VMT analysis should be evaluated for the following scenarios:
• Baseline Conditions evaluates project generated VMT. For the project scenarios the VMT
generation by land use is compared to the regional average.
• Year 2040 7 Cumulative Conditions evaluates project effect on VMT. The citywide total VMT
per service population is compared between the “no project” and “plus project” scenarios.
The model output should also include total VMT, which includes all vehicle trips and trip purposes.
Scenarios for Transportation Analysis (CEQA)
Baseline Conditions
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
7 The TAM Travel Demand model currently has a 2040 horizon year. The cumulative horizon year shall be updated to reflect the horizon year of the current version of the TAM model when a study is initiated.
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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 using the TAM travel demand model.
Baseline with Project
All projects that do not meet the VMT screening criteria 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.
Year 2040 Cumulative Conditions
Year 2040 Cumulative without Project
Projects requiring a General Plan Amendment are also required to evaluate the project effect on VMT
under Year 2040 Cumulative Conditions. This scenario buildout of the region’s land use and
transportation system also provides the long-range view of future travel patterns. Cumulative without
Project VMT estimates should be based on the horizon year of the San Rafael 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 San Rafael. 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 Marin County limit boundary and
extracting the total link-level VMT for both the no project and with project conditions.
VMT Impact Criteria for Land Use Projects
The following outlines the VMT impact criteria for land use projects that do not meet the City’s VMT
screening criteria.
Project Generated VMT Impact Thresholds (Baseline Conditions)
Listed in Table 7 are the land use project-level impact criteria under the Baseline scenarios.
Projects Effect VMT Impact Threshold (Year 2040 Cumulative Conditions)
The cumulative threshold for the project effect on VMT is no change to the City’s per capita VMT
applying the boundary method.
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CEQA Thresholds of Significance
Based on the updated Appendix G Environmental Checklist Form and City of San Rafael policies, a
significant transportation-related impact could occur if a project would:
A. Conflict with a program, plan, ordinance, or policy addressing the circulation system,
including roadway, transit, bicycle and pedestrian facilities.
Roadway System – The project would create a significant impact related to the roadway
system if any of the following criteria are met:
1. At unsignalized intersections, the project results in any of the traffic signal warrants
included in the CA Manual on Uniform Traffic Control Devices (MUTCD) to be
satisfied, or for a location where any of the warrants are satisfied prior to the project,
the project increases overall travel through the intersection by more than 1 percent.
2. The project creates the potential for excessive vehicle queue spillback that could
periodically block or interfere with pedestrian, bicycle or transit facilities.
Transit System - The project would create a significant impact related to transit service if the
following criterion is met:
1. The project interferes with existing transit facilities or precludes the construction of
planned transit facilities.
Bicycle System - The project would create a significant impact related to the bicycle system if
any of the following criteria are met:
1. Disrupt existing bicycle facilities;
2. Interfere with planned bicycle facilities; or,
3. Create inconsistencies with adopted bicycle system plans, guidelines, policies,
or standards.
Pedestrian System - The project would create a significant impact related to the pedestrian
system if any of the following criteria are met:
1. Disrupt existing pedestrian facilities; or
2. Interfere with planned pedestrian facilities; or
3. Create inconsistencies with adopted pedestrian system plans, guidelines, policies,
or standards.
B. Conflict or be inconsistent with CEQA Guidelines section 15064.3, subdivision (b).8
8 This section of the CEQA Guidelines relates to the evaluation of vehicle miles of travel (VMT).
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C. Substantially increase hazards due to a geometric design feature (e.g., sharp curves or
dangerous intersections) or incompatible uses (e.g., farm equipment)
D. Result in inadequate emergency access
These criteria should be cross-referenced with the information presented in Table 5 as additional
specific criteria may need to be evaluated depending on the project.
Mitigation Measures
When VMT impacts are identified, there are currently two types of project-based mitigation measures
to consider:
• Physical Design at the project site (land use or transportation);
• Changes in project parking supply (relative to standard parking demand);
• Regional programs or facilities improvements (such as bicycle and pedestrian facilities); and,
• Transportation Demand Management (TDM).
Project-based features consider whether modifying the project in some way could reduce VMT. The
four basic modifications include changing the physical land use or transportation network design of
the project, reducing the project’s parking supply relative to industry standard rates, contributing to
regional programs and facilities, or implementing transportation demand management (TDM)
strategies such that residents, workers, or visitors of the site could make fewer or shorter vehicle trips.
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. Methods for calculating a VMT reduction based on parking reduction or the
introduction of TDM measures should be substantiated through external sources such as the CAPCOA
Guide to Mitigating Greenhouse Gas Emissions and CalEEMod, or through reliable local data and case
studies.
It should be noted that program-based mitigation measures such as VMT impact fees, exchanges, and
banks, are an emerging concept that will likely evolve over the next few years; this includes mitigation
through contribution to regional programs or infrastructure. Since these are newer concepts and the
City and/or County has not implemented such program-based mitigation measures, these are
currently not valid options for consideration in San Rafael. The City will update these guidelines to
incorporate program-based mitigations measures as they become available.
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Table 7: VMT Impact Criteria for Land Use Projects under Baseline Conditions
Project Type Significance Criteria Current Level Impact Threshold
Residential A project exceeds existing regional home-based VMT per capita minus 15 percent.
13.4 Home-based VMT per Capita
(Average)
11.4 Home-based VMT per Capita
Office A project exceeds regional home-based work
VMT per employee minus 15 percent.
16.9 Home-based work VMT per Employee (Average)
14.35
Home-based work VMT per Employee
Retail Project Total VMT rate exceeds 15 percent below existing Regional average rate (per employee)
Mixed-Use
• Aggregate metric (VMT per service population) rate exceeds 15 percent below existing regional average rate
• Each land use type evaluated individually against residential, office, and retail thresholds above
Other Land Use Types City to develop ad hoc (i.e., project specific) VMT threshold
Redevelopment If a redevelopment project leads to a net overall increase in VMT, based on evaluation of individual land uses, project exceeds respective thresholds above for applicable land-use types
Land Use Plans
• Aggregate metric (VMT per service population) exceeds 15 percent below regional average rate
• Each land use type evaluated individually against residential, office, and retail thresholds above
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Transportation Analysis (CEQA) for
Transportation Projects
Transportation projects have the potential to change travel patterns and may lead to additional
vehicle travel on the roadway network, also referenced as induced vehicle travel. This is particularly
true for roadway capacity expansion projects.
Project types that would likely lead to a measurable and substantial
increase in vehicle travel generally include addition of through
lanes on existing or new highways, including general purpose
lanes, HOV lanes, peak period lanes, auxiliary lanes, or grade
separated interchanges. For transportation projects that increase
roadway capacity, the VMT estimates and forecasts will also need
to include induced travel effects. However, not all roadway projects
lead to induced travel.
Methodology
The following sections provides details on if and how a VMT analysis should be conducted for
transportation projects.
Screening Criteria
OPR’s Technical Advisory identifies specific types of transportation projects that would likely lead to
an increase in VMT, and, therefore, should undergo analysis. Transportation projects relevant to the
City of San Rafael include:
• Added travel lanes;
• New roadway connections, including new roads or freeway overpasses; and,
• Lanes through grade-separated interchanges.
The General Plan 2040 EIR includes a Road Network VMT impact assessment for the 3.8 new lane
miles of added roadway capacity that would result from the construction of new road improvements
listed in Table 10-1 (Major Planned Mobility Improvements, 2020-2040) of the Mobility Element of the
San Rafael General Plan 2040. The EIR analysis addresses the induced vehicle travel effect due to
roadway system expansion that is not fully accounted for in travel demand models, estimating that
the new lane miles of added road capacity would induce approximately 15.2 million additional VMT
per year, or about 50,500 VMT on a daily basis. The EIR identifies a significant impact due to road
network expansion, a mitigation measure, and a conclusion that the impact would be significant and
unavoidable with the mitigation measure. CEQA analysis conducted for specific projects would tier off
the analysis in the General Plan EIR and only need to address issues specific to the later project.
Does my
transportation project result in an
environmental impact?
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Specific types of transportation projects are presumed to have a less-than-significant transportation
impact because they “would not likely lead to a substantial measurable increase in VMT.” Projects that
would not require a VMT analysis fall into four categories:
• Transit project (except for on-demand transit);
• Bicycle projects, such as bike lanes, projected bike lanes, or bike paths;
• Pedestrian projects, such as added sidewalks, crosswalks, or new trails; and,
• Roadway reconfigurations that are not intended to add vehicle capacity or substantially
reduce vehicle delay, such as signal modifications, traffic calming projects, or intelligent
transportation system (ITS) improvements.
Attachment C: List of Transportation Projects Exempt from Environmental Analysis (CEQA)
includes a complete list provided in the OPR Technical Advisory for transportation projects that would
not likely lead to a substantial or measurable increase in vehicle travel, and therefore generally should
not require an induced travel analysis and are presumed to have a less-than-significant impact
on VMT.
However, even if a project is exempt from VMT analysis, it may still be required to evaluate the
following CEQA requirements:
• Conflicts with a program, plan, ordinance, or policy addressing the circulation system,
including transit, roadways, bicycle lanes, and pedestrian paths;
• Substantially 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.
All projects need to document and justify the applied VMT screening criteria.
Assessment for Non-Screened Projects
Projects not screened out through the criteria outlined above are required to complete a VMT
analysis. Analysis methods and thresholds to evaluate the VMT effect of roadway projects will be
assessed on a case-by-case basis, since the appropriate tool and methodology will vary based on the
type and scope of transportation project proposed. Transportation projects that result in a net
increase in total VMT may indicate a significant transportation impact.
Mitigation Measures
When VMT impacts are identified for roadway expansion projects, mitigation measure should
consider and evaluate the reduction in scope of the capacity increase and/or enhancement to active
transportation components.
Attachment A: Site Access and Circulation Plan Review
A detailed site plan review is required for all projects. The transportation analysis should include a review
and summary of findings of the following qualitative and quantitative features, in addition to the site-plan
criteria identified in Table 2. See attached for more…
• Existence of any current traffic problems in the local area such as a high-collision location, non-
standard intersection or roadway, or an intersection in need of a traffic signal.
• Applicability of context-sensitive design practices compatible with adjacent neighborhoods or
other areas that may be impacted by the project traffic.
• Proximity of proposed site driveway(s) to other driveways or intersections.
• Adequacy of the project site design to convey all vehicle types.
• Number and type of parking provided, including vehicle and bicycle parking.
• On- and off-street loading requirements.
• Adequacy of site access and circulation for vehicles, bicycle, and pedestrian and provision of
direct pedestrian paths from residential areas to school sites, public streets to commercial and
residential areas, and the project site to nearby transit facilities. Delivery vehicle access and
circulation, and the potential for vehicle queues at drive-through windows should be considered.
Attachment B: Transportation Impact Analysis Report Outline
Sections for All Transportation Impact Analysis
The preparer has the discretion to use the most appropriate documentation format depending on the
complexity of the analysis, including memorandum and formal reports, so long as the required
information is provided. Not all information noted below is appropriate for all studies, nor is the list
inclusive of everything that may be required to fully analyze a project.
1. Introductory Items
• Front Cover/Title Page
• Table of Contents, List of Figures, and List of Tables
• Executive Summary
2. Introduction/Background
• Project description
• Type and size of development
• Site plan (include proposed driveways, roadways, traffic control, parking facilities, emergency
vehicle access, and internal circulation for vehicles, bicyclists, and pedestrians)
• Location map (include major streets, study intersections, and neighboring zoning and land uses)
• Scope of transportation analysis
3. Project Screening
• Description of whether the project meets General Plan Consistency screening criteria
• Description of whether the project meets CMP Consistency screening criteria
• Description of whether the project meets VMT screening criteria
4. Current Conditions
• Description of existing street system within project site and surrounding area
• Location and routes of nearest public transit system serving the project
• Location and routes of nearest pedestrian and bicycle facilities serving the project
• Off-site intersection analysis for site access and circulation evaluation and CMP evaluation
(if applicable)
◦ Figure of study intersections with peak hour turning movement counts, lane geometries, and
traffic control (if applicable)
◦ Map of study area showing average daily traffic (ADT) of study roadways (if applicable)
◦ Table of existing peak hour average vehicle delay and level of service (LOS)
• Environmental Analysis (if VMT screening criteria are not met)
◦ Description of baseline VMT estimates (may include site and regional VMT estimates)
5. Project Trip Generation and Vehicle Miles Traveled
• Table of project generated trip estimates
• Figure/map of trip distribution (in percent)
• Table of project generated vehicle miles traveled estimates
6. Project Site Access and Circulation Evaluation
• Summary of a detailed site review for all modes of travel
• Mobility deficiency analysis for vehicle, transit, bicycle and pedestrian facilities (under Existing,
Background, and Cumulative Conditions)
• Summary of transportation improvements
• Other Technical Analysis discussion: LOS, Queueing, Signal Warrants, Traffic Share Analysis,
Schools, Transit, Bicycles, Pedestrians, Trucks, Parking, Traffic Calming, Access Management, Sight
Distance, Park & Ride, Compliance with Policies.
CEQA Transportation Analysis Report Section
7. VMT Analysis (For projects not meeting VMT screening criteria)
• Summary of project generated VMT under Baseline Conditions
• Summary of project’s effect on VMT under Year 2040 Cumulative Conditions
• Identification of significant impacts
• Discussion of mitigation measures
• Evaluation of impacts of mitigation measures
8. Other CEQA Requirements
• Summary of conflicts with a program, plan, ordinance, or policy addressing the circulation system,
including transit, roadways, bicycle lanes, and pedestrian paths. Present mitigation measures,
as needed.
• Evaluation of hazards due to a geometric design feature (e.g., sharp curves or dangerous
intersections) or incompatible uses (e.g., farm equipment). Present mitigation measures,
as needed.
• Emergency access evaluation. Present mitigation measures, as needed.
Local Transportation Analysis Report Section (Project Requiring
Off-Site Analysis)
9. Existing with Project Conditions
• Maps of study area with applicable peak hour turning movements (Project Only and Existing
with Project)
• Table of Existing and Existing with Project intersection peak hour average vehicle delay and LOS
(or other multimodal performance measure)
• Traffic signal and other warrants
• Changes/Deficiencies to bike, pedestrian, and transit networks
• Findings of project deficiencies
• Improvements for project deficiencies (include a map showing physical improvements)
• Scheduling and implementation responsibility of improvements
• Deficiencies of proposed improvements
10. Baseline without Project Conditions
• Table of trip generation for approved project(s)
• Figure and/or table of approved projects trip distribution (in percent)
• Map of study area with applicable peak hour turning movements (Baseline without Project)
• Table of intersection peak hour average vehicle delay and LOS (or other multimodal
performance measure)
• Changes/deficiencies to bike, pedestrian, and transit networks
• Traffic signal and other warrants
11. Baseline with Project Conditions
• Similar content to Existing with Project Conditions
12. Cumulative without and with Project Conditions
• Map of study area with Cumulative without Project peak hour turning movements
• Map of study area with Cumulative with Project peak hour turning movements
• Table of Cumulative without Project and Cumulative with Project intersection peak hour average
vehicle delay and LOS (or other multimodal performance measure)
• Changes/Deficiencies to bike, pedestrian, and transit networks
• Traffic signal and other warrants
• Findings of project deficiencies
• Improvements for project deficiencies (include a map showing physical improvements)
• Scheduling and implementation responsibility of improvements
• Deficiencies of proposed improvements
As Needed Sections for Transportation Analysis Reports
13. Construction Deficiencies
• Trips due to construction workers
• Truck trips and truck access routes
14. Phasing Deficiencies (For Large Projects Only)
15. Appendices
• List of references
• List of authors
• Pedestrian, bicycle, and vehicle counts
• Technical calculations for all analyses
Attachment C: List of Transportation Projects Exempt from Environmental Analysis (CEQA)
The following complete list is provided in the OPR Technical Advisory (December 2018, Pages 20-21) for
transportation projects that “would not likely lead to a substantial or measurable increase in vehicle travel,
and therefore generally should not require an induced travel analysis:”
• Rehabilitation, maintenance, replacement, safety, and repair projects designed to improve the
condition of existing transportation assets (e.g., highways; roadways; bridges; culverts;
Transportation Management System field elements such as cameras, message signs, detection, or
signals; tunnels; transit systems; and assets that serve bicycle and pedestrian facilities) and that do
not add additional motor vehicle capacity.
• Roadside safety devices or hardware installation such as median barriers and guard rails
• Roadway shoulder enhancements to provide “breakdown space,” dedicated space for use only by
transit vehicles, to provide bicycle access, or to otherwise improve safety, but which will not be
used as automobile vehicle travel lanes.
• Addition of an auxiliary lane of less than one mile in length designed to improve roadway safety
• Installation, removal, or reconfiguration of traffic lanes that are not for through traffic such as left,
right, and U-turn pockets, two-way left turn lanes, or emergency breakdown lanes that are not
utilized as through lanes.
• Addition of roadway capacity on local or collector streets provided the project also substantially
improves conditions for pedestrians, cyclists, and, if applicable, transit.
• Conversion of existing general purpose lanes (including ramps) to managed lanes or transit lanes,
or changing lane management in a manner that would not substantially increase vehicle travel.
• Addition of a new lane that is permanently restricted to use only by transit vehicles.
• Reduction in number of through lanes.
• Grade separation to separate vehicles from rail, transit, pedestrians or bicycles, or to replace a
lane in order to separate preferential vehicles (e.g., HOV, HOT, or trucks) from general vehicles.
• Installation, removal, or reconfiguration of traffic control devices, including Transit Signal Priority
(TSP) features.
• Installation of traffic metering systems, detection systems, cameras, changeable message signs
and other electronics designed to optimize vehicle, bicycle, or pedestrian flow.
• Timing of signals to optimize vehicle, bicycle, or pedestrian flow.
• Installation of roundabouts or traffic circles.
• Installation or reconfiguration of traffic calming devices.
• Adoption of or increase in tolls.
• Addition of tolled lanes, where tolls are sufficient to mitigate VMT increase.
• Initiation of new transit service.
• Conversion of streets from one-way to two-way operation with no net increase in number of
traffic lanes.
• Removal or relocation of off-street or on-street parking spaces.
• Adoption or modification of on-street parking or loading restrictions (including meters, time
limits, accessible spaces, and preferential/reserved parking permit programs).
• Addition of traffic wayfinding signage.
• Rehabilitation and maintenance projects that do not add motor vehicle capacity.
• Addition of new or enhanced bike or pedestrian facilities on existing streets/highways or within
existing public rights-of-way.
• Addition of Class I bike paths, trails, multi-use paths, or other off-road facilities that serve non-
motorized travel.
• Installation of publicly available alternative fuel/charging infrastructure.
• Addition of passing lanes, truck climbing lanes, or truck brake-check lanes in rural areas that do
not increase overall vehicle capacity along the corridor.