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HomeMy WebLinkAboutCD Traffic Methodologies for GP 2040____________________________________________________________________________________ FOR CITY CLERK ONLY Council Meeting: 06/03/2019 Disposition: Accepted Report Agenda Item No: 6.a Meeting Date: June 3, 2019 SAN RAFAEL CITY COUNCIL AGENDA REPORT Department: COMMUNITY DEVELOPMENT & PUBLIC WORKS Prepared by: Paul Jensen, Comm Dev Director Bill Guerin, Public Works Director City Manager Approval: ______________ TOPIC: TRAFFIC METHODOLOGIES FOR GENERAL PLAN 2040 SUBJECT: INFORMATIONAL REPORT ON TRAFFIC METHODOLOGIES FOR GENERAL PLAN 2040 RECOMMENDATION: Accept report and provide comments and direction to staff. EXECUTIVE SUMMARY: This informational report focuses on traffic methodologies being planned and considered for the upcoming General Plan 2040. Historically, the City has used the level of service (LOS) methodology to: a) manage vehicle traffic movement and gauge intersection and road arterial operations; b) coordinate planning for future growth; and c) assess environmental impacts associated with vehicle movement (CEQA/environmental review). In 2013, Senate Bill 743 was signed by the Governor, establishing new legislation which mandates a major change in the California Environmental Quality Act (CEQA) Guidelines. Effective in 2020, the SB 743 legislation requires that local jurisdictions shift from use of LOS for CEQA/environmental review of vehicle movement impacts (delay) to a method that assesses the distance of vehicle travel attributed to a project or use. This shift focuses review on regional traffic and reducing greenhouse gas (GHG) emissions, rather than vehicle impacts on the local roadway network. The most common method used to assess distance of vehicle travel is “vehicle miles traveled” (VMT). A “white paper” on VMT is currently being prepared by Fehr & Peers, transportation consultants. The white paper, which will present an in-depth discussion of the VMT methodology and technical thresholds, is expected to be completed for public review within the next month. For now, this informational report has been prepared to introduce this topic and provide a broad discussion of VMT and the SB 743 legislation. Further, as the City has managed the local roadway network performance through use of LOS for over 35 years, this informational report includes several options to address continued management of this network performance. As an informational report, there is no recommendation for formal City Council action other than to accept the report. However, as outlined in the Analysis section below, comments and feedback from the City Council and public will guide staff in the next steps. When the white paper is completed, staff will return to the City Council with recommended draft policy for City Council consideration. SAN RAFAEL CITY COUNCIL AGENDA REPORT / Page: 2 BACKGROUND: History Transportation planning in its current, technical form and practices was first instituted by the City in the early 1980’s. In 1983, the City adopted the Northgate Activity Center Plan for the North San Rafael area, which linked land use planning for property development with vehicle transportation networking, operations and needed improvements. It was with this Plan that the City introduced level of service (LOS) as a method of gaging intersection and road arterial operations. Essentially, LOS “grades” signalized intersections and selected arterials based on operations and delay time during selected peak periods during the day. The grades range from LOS A (free flowing traffic; 10 seconds of delay) to LOS F (extreme delays and/or gridlock; 80+ seconds of delay). By the late 1980s, the use of LOS was applied in the three, most traffic sensitive areas of the City: North San Rafael; Southeast San Rafael; and Downtown. The adoption of the San Rafael General Plan 2000 in 1987-1988 memorialized LOS as the standard tool for managing local traffic performance and assessing vehicle traffic associated with new land development. By this point, the state-mandated General Plan Guidelines required that local jurisdictions adopt both a “Land Use Element” and “Circulation Element,” and that both elements be internally consistent. Further, since General Plans are subject to environmental review, LOS was adopted as the standard measure for determining the “threshold” of a significant transportation and circulation impact associated with vehicle movement. A traffic mitigation fee was adopted as the mitigation measure for new land development that triggered a significant transportation and circulation impact. With the adoption of the current San Rafael General Plan 2020 and General Plan Environmental Impact Report (EIR) in 2004, LOS was applied citywide, which included the adoption of our current citywide traffic mitigation fee program. Since the 1980s, LOS has been the primary tool used for managing local traffic performance and assessing transportation and circulation impacts statewide in CEQA-required environmental documents. Through this period, the California Environmental Quality Act Guidelines (CEQA Guidelines) have been structured to require the assessment of a project’s impacts on the performance of a circulation system with focus on impacts associated with motorized (vehicle) travel. The CEQA Guidelines “Initial Study Checklist,” which is used as the starting point for environmental review, clearly requires that a project’s impacts to an adopted congestion management program (CMP) or LOS standard be determined. Mitigation for exceeding LOS standards has historically been in the form of physical transportation improvements such as intersection widening and signalization, which are intended to improve vehicle movement and increase roadway capacity. Current Level of Service (LOS) Methodology & Policies The current San Rafael General Plan 2020 Circulation Element includes specific policies and programs that are directed at maintaining citywide LOS standards. To accommodate planned growth citywide and to maintain the adopted LOS standards, the Circulation Element currently includes a list of planned transportation improvements. These planned transportation improvements represent the “mitigation measure” required to address local traffic impacts associated with growth and are funded (in whole or part) by an adopted Traffic Mitigation Fee. A summary of key LOS policies and programs is provided as follows:  Policy C-5. Traffic Level of Service. A. Intersection LOS. In order to ensure an effective roadway network, maintain traffic levels of service (LOS) consistent with the standards for signalized intersections in the AM and PM peak hours. . . “ SAN RAFAEL CITY COUNCIL AGENDA REPORT / Page: 3 LOS D is the citywide standard, with exception of: a) a LOS E standard for Downtown San Rafael and certain, select intersections in the Southeast San Rafael, North San Rafael and 3rd/Union Street intersection; and b) a LOS F permitted condition at the Mission Avenue/Irwin Street intersection. B. Arterial LOS. The City Traffic Engineer may apply an arterial LOS as the primary method of analysis for any proposed development project. . . LOS D is the citywide standard except for: a) a LOS E standard for Downtown San Rafael; and b) a LOS F condition is permitted for arterials that are located outside of Downtown and are currently operating at LOS E.  Policy C-6. Proposed Improvements. The proposed improvements in [General Plan 2020] Exhibit 21 have been identified as potentially needed to improve and relieve congestion in San Rafael over the next 20 years. . . The planned transportation improvements in Exhibit 21 are major intersection and roadway improvements needed to accommodate the growth. Examples include, among others, intersection signalization and widening improvements at Lucas Valley Road/Los Gamos Drive.  Policy C-7. Circulation Improvements Funding. Take a strong advocacy role in securing funding for planned circulation improvements. Continue to seek comprehensive funding that includes Federal, State, County, Local Traffic Mitigation Fees and Assessment Districts. Consistent with Program C-7a, a citywide Traffic Mitigation Fee is charged for all new development that results in new building square footage. A fee is charged for all new AM and PM peak hour trips generated by a development project. The adopted fee is $4,246.00 per peak hour trip. At present, there is $2.7 million in the Traffic Mitigation Fee Fund. Senate Bill 743 (SB 743) In 2006, Governor Schwarzenegger signed Senate Bill 32 (SB 32), the California Global Warming Solutions Act. SB 32 established legislation requiring a statewide reduction in greenhouse gas (GHG) emissions by specific, future milestone dates. SB 32 required statewide implementation of numerous strategies to reduce GHG emissions by the goal dates. GHG emissions reduction strategies include, among others, the requirement to develop a Sustainable Communities Strategy (SCS). Plan Bay Area is the Bay region’s SCS, which promotes more concentrated growth within the inner region, in urban centers and around transit. In 2013, Governor Brown signed Senate Bill 743 (SB 743), which requires dramatic changes to the CEQA Guidelines to facilitate a reduction in GHG emissions by promoting an increase in infill development. Referred to as the “Congestion Management Law,” this legislation requires that the State Office of Planning and Research (OPR) make changes to the CEQA Guidelines to address SB 743. When the bill was signed, the law was to go into effect in January 2015. However, OPR’s task of updating the CEQA Guidelines to address SB 743 took five years to complete as it involved stakeholder-driven involvement and the development of a “Technical Advisory” (guidelines for local jurisdiction implementation). The CEQA Guidelines updates were completed in late 2018. The SB 743 CEQA Guidelines updates have two parts, which are summarized as follows: 1. Phase-out use of LOS for analyzing traffic and circulation impacts. SAN RAFAEL CITY COUNCIL AGENDA REPORT / Page: 4 The law creates a process that changes the way transportation impacts are analyzed under CEQA. Vehicle delay will no longer be considered a significant impact under CEQA. Specifically, the law prescribes that the CEQA Guidelines be amended to phase-out the use of and provide an alternative to LOS for analyzing transportation impacts (as its purpose and function is to assess vehicle delay). Further, the law prescribes that within areas served by transit, the alternative method or approach must promote: a) the reduction of GHG emissions; b) the development of multi-modal transportation network; and c) a diversity of land uses. Acceptable methods of measuring transportation impacts may include “vehicle miles traveled” (VMT), vehicle miles traveled per capita, vehicle trips generated. The VMT method is being employed throughout the Bay Area region and by the Transportation Authority of Marin (TAM). VMT is discussed in more detail, below. 2. Transit Oriented Development (TOD) CEQA exemption covered by an adopted Specific Plan. The law creates a new CEQA exemption for certain projects that are consistent with an adopted Specific Plan and, in some circumstances eliminates the need to evaluate aesthetic and parking impacts of a project. The exemption applies if a TOD project meets all of the following criteria: a) it is a residential use in an employment center or is a mixed-use project; b) it is located within a transit priority area 1 (TPA); c) it is consistent with an adopted Specific Plan for which an EIR was certified; and d) it is consistent with an adopted Sustainable Communities Strategy (e.g., Plan Bay Area) or an alternative planning strategy. San Rafael has two TPAs, Downtown and Civic Center. The center point for each TPA is the SMART rail station. The law requires that local jurisdictions develop and adopt an acceptable, alternative method of measuring transportation impacts (e.g., VMT method and model) by July 2020 to comply with the CEQA Guidelines. This timing coincides with the preparation and completion of San Rafael 2040, which will necessitate a major revision to the Plan Circulation Element. The following are several important factors that the SB 743 law does not do:  The law does not affect existing, local General Plan policies and the application of such policies related to transportation and circulation. Specifically, the local jurisdiction can continue to use LOS as a method of managing local roadway network performance and development project review. However, LOS (including a LOS study) cannot be used or required for completing CEQA/environmental review or the preparation of an environmental document for a specific development project;  The law does not affect existing fee programs adopted by local jurisdictions. Specifically, local jurisdictions can continue to require a developer to pay into an adopted traffic improvement fee, provided that the fee is: a) linked to needed, planned transportation improvements listed in General Plan; and b) supported by a “nexus” study; and  The law does not prevent local jurisdictions from considering capacity and congestion issues in TPAs. A link to the OPR webpage of “Frequently Asked Questions” about the SB 743 legislation can be accessed here. 1 A Transit Priority Area (TPA) is an area within ½-mile of a major transit stop (existing or planned). A major transit stop is a site containing an existing rail transit station, ferry terminal served by either a bus or rail transit service, or the intersection of two bus routes with a frequency of service interval or 15 minutes or less during the morning and afternoon peak commute periods. SAN RAFAEL CITY COUNCIL AGENDA REPORT / Page: 5 Vehicle Miles Traveled (VMT) Methodology In simple terms, VMT measures the amount and distance of vehicle travel attributed to a project or use. Specifically, VMT focuses on determining the origin and destination of travel patterns. Unlike LOS, VMT does not assess the local vehicle trips from a project or the project’s traffic impacts on a local intersection or road/highway segment. Rather, VMT assesses the effects of the project on regional traffic and use of transit and non-motorized travel. VMT is not a new methodology; it has been used for many years in CEQA/environmental documents in estimating pollution (air quality impacts), GHG emissions and energy consumption. VMT is typically calculated using a travel demand model, which estimates the total number and length of vehicle trips to and from a given geographic area. A VMT model (travel demand model) uses a combination of transportation engineering methods, which are validated based on certain, specific community conditions (e.g., developed conditions, access/availability to transit), as well as assumptions regarding current and future land use/growth. Because VMT is focused on travel distance, i.e., the greater the distance for one to drive from home to work (and vice versa), the greater the impact, it is directly related to fuel consumption and resulting GHG emissions. The metric tends to increase as land use density decreases and travel becomes more reliant on the use of personal vehicles, particularly in areas with limited transit. Also, people with higher income tend to make more vehicle trips and travel further distances. Given these factors, San Rafael’s average daily VMT per capita is 15-16% higher than the Bay Area average but is comparable to the other Marin communities.2 The City Council recently adopted the Climate Change Action Plan 2030 (CCAP) and an updated GHG Emissions Reduction Strategy. The CCAP proposes to comply with the State-adopted targets of reducing GHG emissions by 40% below 1990 emissions by 2030 through implementation of 49 specific measures. Among the measures to reach these targets is LCT -C9 (Smart Growth Development), which is to prioritize infill, higher density, transit-oriented, and mixed-use development. The City has hired Fehr & Peers, Transportation Consultants to assist in addressing compliance with SB 743 and to provide technical transportation engineering services for the General Plan 2040. Fehr & Peers is preparing a “white paper” on VMT, which will be completed within the next month. A brief fact sheet is provided in Attachment 1 of this report. The white paper will cover the following information and required steps to comply with the SB 743 legislation: 1. Selecting the appropriate VMT methodology and developing a travel demand model for the San Rafael General Plan 2040. Ultimately, the travel demand model will be used in the General Plan 2040 EIR to assess future, cumulative growth and development. As the Marin County Congestion Management Agency, the Transportation Authority of Marin (TAM) is required to maintain a travel demand model and in April 2019 the TAM Board of Commissioners accepted an updated model referred to as the TAM travel demand model or TAMDM. The travel model is used to estimate demand on the transportation system from regional growth, new transportation projects, new land use/development projects or large planning efforts like general plans. The travel model provides an estimation of volumes, vehicle to capacity ratios, VMT, and other metrics for use in detailed traffic studies and for development of transportation plans. TAM wi ll keep the TAMDM current and make it available to and for use by all Marin jurisdictions. TAM will charge the Marin jurisdictions for local data input and requests for a “model run.” For consistency and simplicity, San Rafael will use the TAMDM for the General Plan 2040 and future land development review. 2. Adopting a VMT significance threshold. 2 Source: City of Novato General Plan 2035 Policy White Paper (SB 743) SAN RAFAEL CITY COUNCIL AGENDA REPORT / Page: 6 As VMT is the new replacement to LOS for CEQA/environmental review, SB 743 requires that each local jurisdiction establish and adopt a VMT significance threshold3 for land use planning/development and transportation projects. SB 743 offers two options for establishing VMT thresholds: a. Relying on and using the VMT thresholds developed by the State of California Office of Planning & Research (OPR). For land use projects, OPR recommends setting a VMT significance threshold at 15% below baseline VMT per capita for a City or region within a suburban area. As noted above, San Rafael’s average daily VMT per capita is 15-16% higher than the regional average. b. Developing and utilizing a jurisdiction-specific VMT threshold. A local jurisdiction-specific threshold can be developed, this threshold must be consistent with the regional transportation planning documents, such as the region’s Sustainable Communities Strategy (Plan Bay Area). 3. Completing the VMT Analysis for General Plan 2040 Shifting to VMT for CEQA/environmental review (compliance with SB 743) will require an analysis that includes the following steps:  Establishing baseline VMT levels (based on observed data or travel forecasting models);  Setting VMT thresholds for development project review and planning for cumulative (long-term) conditions and growth;  Estimating and forecasting project and cumulative VMT effects; and  Comparing project and cumulative VMT estimates/forecasts to the VMT threshold to determine significant impacts. 4. Mitigation Measures for VMT Impacts Unlike the traditional mitigation measures for LOS that often involve street widening and intersection improvements to improve vehicle travel and road capacity, mitigation measures for VMT impacts focus on revising the project (e.g., increasing density and mixed uses near transit) and/or reducing the distance of vehicle travel (trip reductions), thus reducing GHG emissions. VMT mitigation measures typically involve adoption of a Transportation Demand Management (TDM) Program that includes a mix of the following strategies:  Concentrating and promoting growth, particularly higher density development near or around transit.  Promoting mixed use so that housing is built near employment.  Requiring larger employers to incorporate housing (for their workforce) into commercial development projects.  Mandating compliance with the TDM Program.  Requiring multi-model connection improvements such as installation of bicycle and pedestrian paths and systems. ANALYSIS: VMT Methodology – Recommendations 3 Per CEQA Guidelines Section 15064.7, a threshold of significance is used to determine the significance of environmental effects. A threshold of significance is an identifiable, quantitative, qualitative or performance level of an environmental effect. SAN RAFAEL CITY COUNCIL AGENDA REPORT / Page: 7 When the VMT white paper is completed, staff will confirm the VMT methodology and develop a recommended VMT significance threshold for the General Plan 2040 EIR. The recommended VMT methodology and significance threshold will be presented to the City Council for review and policy direction. LOS Methodology – Options As noted above, SB 743 does not prohibit a local jurisdiction’s ability to continue use of LOS for managing local traffic and roadway performance. Therefore, the City has the option to maintain the current LOS review, scale back its use, or eliminate it. Over time, the City leaders and public have grown accustomed to and become knowledgeable of LOS as a means of understanding local traffic conditions and how new development impacts these conditions. Therefore, the options must be carefully considered. The following are some key observations and points about LOS, which are both positive and negative:  LOS has been a tool in regulating and managing conditions and performance of the local street network, specifically at intersections and along arterials. However, for it to be accurate and effective, it has required the City to maintain a current and accurate modeling system.  Since the 1980s, LOS has been closely aligned with land use and City land development review; it has been used as a tool to control and manage growth throughout the City.  LOS focuses on managing the movement of vehicles through intersections and along the roadway network. It does not look at other modes of travel (e.g., transit, bicycle, pedestrian) nor does it analyze network-wide performance. Therefore, all solutions or mitigation for land development that reduce LOS conditions are intended to increase capacity for better vehicle movement, which: a) promotes more vehicles; and b) increases pollutants and greenhouse gas (GHG) emissions. So, LOS is contrary to achieving some environmental goals as it strongly favors auto traffic over transit, bikes, and peds by solely focusing on increasing capacity for autos.  The LOS approach makes it easier and cheaper to build in the outlying areas where individual intersections would show less delay resulting from new development. In this way, it can encourage sprawl. At the same time, use of LOS makes it much harder and more expensive to build in dense, developed areas (like San Rafael) where there is already a lot of traffic and where current LOS conditions are near or at capacity.  Some areas of the City are currently at or close to LOS capacity (e.g., Downtown, Bellam Boulevard corridor), which, under current General Plan policy requires a moratorium on new development or requires the decision-makers to make controversial findings of significant, unavoidable impacts to approve a development project. Maintaining use of LOS will likely require re-visiting the current, adopted LOS standards in the traffic impacted areas such as Downtown and Southeast San Rafael (Bellam Blvd. corridor).  The current LOS policies require that new development be carefully reviewed for potential traffic impacts. Therefore, project applicants are required to fund individual, technical traffic studies that are costly and time consuming. In many cases, the results of the individual traffic study merely confirm what is already known. Further, the cost and time to prepare such studies is a potential barrier to housing and/or other development that could benefit the City.  The current LOS policies are fairly static in that they do not consider changing technologies or consumer preferences (e.g., increase in autonomous vehicles over time). Therefore, the policies tend to artificially limit development that may be beneficial to the City’s future by not providing a comprehensive analysis. SAN RAFAEL CITY COUNCIL AGENDA REPORT / Page: 8  The current LOS policies mandate a traffic impact fee, which serves as mitigation for new development. The current traffic mitigation fee ($4,246 per AM and PM peak hour trip generated by the project) is costly and can discourage smaller development projects and new businesses. Further, the traffic mitigation fees that are collected are intended to fund major transportation projects/improvements listed in Circulation Element Exhibit 21 referenced above. Some of the planned transportation improvements listed in Exhibit 21 require significant funding; full funding would require subsidies from other sources (federal, state funding). Some of these funding sources have dwindled over time. Given the high cost of some of these improvements, it is possible that they would never be implemented/built. Staff concludes that, independent of administering VMT for required CEQA/environmental review, the City should continue to manage and monitor the performance of the local transportation network. The suggested approach for moving forward is discussed below, along with several local traffic performance options for consideration: 1. Criteria for Successful Management of Local Traffic The goal is to establish a successful local traffic system performance that is: a) easy to measure and monitor by the City and the development community; b) easy to understand by the City decision makers and all stakeholders; c) logical, equitable and nexus driven; and d) supported by a well-funded multi-modal improvement program. 2. Requirements for an Individual Traffic Study It is recommended that the City establish a threshold for when a traffic study is required to assess a new development project’s impacts on the local transportation network. The requirement for individual traffic studies should be reserved for larger development projects that generate a specific number of new AM and PM peak hour trips (a minimum of 150 net new AM and PM peak hour trips is suggested) and projects necessitating a rezoning or General Plan Amendment. The intent is to exclude infill projects from such studies when they have been modeled within the General Plan 2040 forecast. 3. Three Local Traffic Threshold Options to Consider The following three, local traffic threshold options are intended to explore alternatives to our current LOS policies and practices. In considering all three options, the goal is to develop a system to monitor traffic growth, which can be incorporated into the General Plan 2040 and administered along with the CEQA-required VMT system. The three options are summarized as follows: • OPTION A – Arterial Delay Index (DI) This option would eliminate the current, intersection LOS system and replace it with an arterial operations system at pre-defined arterials (e.g., 2nd Street). A performance standard would be established for the arterial, which would be measured by travel speed. A simple performance standard to use would be the “ratio of uncongested speed divided by congested speed” along the arterial and setting the standard by a delay index (DI). As an example, assume a delay index (DI) of “2.0” along 2nd Street, which is established as the performance standard. So, if the uncongested speed is 30 miles per hour, the arterial would be operating within the standard and below the threshold of significance if the congested, peak hour speed does not fall below 15 miles per hour. If a development project causes the arterial speed to go below 15 miles per hour during the peak hour, then a significant impact is triggered, which would require further study and/or mitigation. • OPTION B – Trip Monitoring Within Traffic Zones SAN RAFAEL CITY COUNCIL AGENDA REPORT / Page: 9 This option would eliminate the current, intersection LOS system and replace it with the Arterial Delay Index (Option A) coupled with monitoring trip generation. The trip generation monitoring component would compare the development project’s trip generation with the growth assumptions (converted to trips) presented in the General Plan 2040. This option presents an additional level of traffic scrutiny and conservatism to Option A. This option would rely on the utilization of and monitoring “traffic attraction zones” (TAZ). A TAZ is defined as a geographic area that contains land use data assumptions for new/future development (through 2040) and corresponding assumptions on vehicle trips within this TAZ that are generated from the development. For the TAZ, a threshold of significance could be established and adopted that would monitor land development through 2040. The significance threshold could be a defined percentile of the total assumed growth for the TAZ (see graphic demonstrating a 75th percentile threshold). Therefore, if an individual development project exceeds the threshold, a traffic study would be required. Overall, the approach requires a proactive monitoring of the growth by staff. If the threshold is exceeded because growth within the TAZ is occurring at a faster pace than assumed, it could provide the City with a tool to take a pause and address the issue. • OPTION C – Status Quo: Maintaining LOS Thresholds This option maintains the status quo. It would incorporate all the current LOS policies and programs into the new General Plan 2040. The sole difference would be that the LOS threshold system would no longer be linked to CEQA and therefore not included in the General Plan 2040 Environmental Impact Report (EIR). This option would require the City to maintain and periodically update the LOS traffic model and would continue to require developers to fund the preparation of individual traffic studies that are costly and time consuming. Please note that eliminating LOS review for land development projects would not do away with using LOS as a monitoring tool. City staff would continue to utilize LOS as a tool gauge when warrants are met for local intersection and arterial improvements. • OPTION D- Eliminate LOS and Monitoring Local Network Performance This option would: 1) eliminate the current, intersection LOS system; and 2) discontinue monitoring local network performance. Traffic management would focus on VMT only. Large, SAN RAFAEL CITY COUNCIL AGENDA REPORT / Page: 10 urban cities such as San Francisco, have eliminated LOS and monitoring local network performance with focus solely on traffic management through VMT. In larger, urban cities, signalized intersections are closely spaced and as intersection capacity is reached, monitoring these intersections becomes a futile exercise. This approach may not be best for San Rafael as it is a mid-size city and except for Downtown, the road network and intersections are suburban in character and widely spaced making it easier to monitor performance. Staff finds that Option A (Arterial Delay Index) is the preferred approach as it best meets the criteria for successful management of local traffic. The Arterial DI method is simpler to administer, easier to understand, and less onerous and costly to the applicant/developer. However, a formal recommendation by staff will be developed and presented to the City Council at a future meeting for review and policy direction. Recommendations for Traffic Fees As discussed above, the City has been administering a Traffic Mitigation Fee program since the 1980s. The current fee program structure is linked to LOS impacts and planned transportation improvements for intersections and arterials. The fees that have been collected have been used to fully fund or subsidize needed local road network improvements. Given that new development contributes traffic to the local street network and the need for implementing improvements, there is a clear nexus to continue the fee program. It is prudent for the City to continue a fee program to fully or partially fund needed, local intersection and arterial improvements. As part of their scope of work for General Plan 2040, Fehr & Peers will be completing a fee study, which will consider: a) projected traffic conditions for General Plan 2040 build- out; b) an update of the planned transportation improvements inventory (General Plan 2020 Exhibit 21 referenced above); and c) the other funding sources that are expected to be available. COMMUNITY OUTREACH: A public notice of this meeting was mailed to stakeholders, agencies and special interest groups 15 days prior to this meeting (Attachment 2). Those noticed included, among others, the members of the General Plan 2040 Steering Committee, all neighborhood associations, the Federation of San Rafael Neighborhoods, local developers, local commercial real estate companies, and the San Rafael Chamber of Commerce. FISCAL IMPACT: There is no fiscal impact associated with this item. The VMT “white paper,” analysis and modeling are part of the technical consultant work that has been commissioned for the General Plan 2040 and EIR. All transportation and traffic studies and consultant services for this effort are covered by the General Plan Implementation Fund (Fund no. 218) and have been appropriated. OPTIONS: The City Council has the following options to consider on this matter: 1. Accept report and provide direction to staff. 2. Direct staff to return with more information. 3. Do not accept report. RECOMMENDED ACTION: Accept report and provide comments and direction to staff. SAN RAFAEL CITY COUNCIL AGENDA REPORT / Page: 11 ATTACHMENTS: 1. Fact Sheet – San Rafael General Plan Transportation Performance Policies and Evaluating CEQA Impacts Based on SB 743, Fehr & Peers, Transportation Consultants 2. Public Meeting Notice San Rafael General Plan Transportation Performance Policies and Evaluating CEQA Impacts Based on SB 743 P a g e | 1 The purpose of this document is to seek policy guidance from the City Council on (1) whether to retain a policy to monitor and manage local congestion in the General Plan Update and (2) local priorities for applying VMT as the CEQA transportation metric. Based on Council guidance, staff will return at a later date with detailed recommendations on implementation of Senate Bill (SB) 743 including VMT thresholds, methodology, and mitigation options for use in future CEQA studies. SB 743 changed how transportation impacts are measured under CEQA from using vehicle LOS to using VMT. These changes must be implemented no later than July 1, 2020. The legislature mandated these changes so that CEQA would be more aligned with state goals to reduce greenhouse gas emissions, increase infill development, and improve public health through active transportation. Policy C-5 in the San Rafael 2020 General Plan Circulation Element establishes traffic LOS standards for intersections and arterial segments. This is a policy for measuring, monitoring, and responding to traffic performance. The purpose of the standards is “to ensure an effective roadway network” and as a “primary method of analysis for any proposed development project” to determine consistency with the General Plan. The policy includes exemptions for certain intersections and a process for considering community benefits, particularly for affordable housing projects, where LOS standards are not met. Policy C-5.1 calls for developing a methodology to apply VMT rather than LOS as the metric for analyzing transportation impacts under CEQA as required by SB 743. While LOS can no longer be used as a basis for determining transportation impacts under CEQA after the July 2020 deadline, the City of San Rafael may retain LOS or some other measure of local traffic congestion in the General Plan Update and apply that as part of future land use entitlement reviews. The first question is thus whether to retain a local traffic performance policy in the General Plan, which would mean that projects would be assessed from two transportation perspectives in the future. ➢ General Plan Local Traffic Performance Policy – to inform entitlement review as well as the ongoing monitoring and management of street and intersection operations ➢ General Plan CEQA VMT Policy – basis for determination of CEQA transportation environmental effects caused by future development and infrastructure projects CEQA refers to the California Environmental Quality Act. This statute requires identification of any significant environmental impacts of state or local action including approval of new development or infrastructure projects. The process of identifying these impacts is typically referred to as the environmental review process. LOS refers to “Level of Service,” a metric that assigns a letter grade as a measure of operations for an intersection or arterial segment. The typical application in San Rafael is to evaluate the average amount of delay experienced by vehicle drivers at an intersection during the most congested time of day and assign a report card range from LOS A (fewer than 10 seconds of delay) to LOS F (more than 80 seconds of delay). VMT refers to “Vehicle Miles Traveled,” a measure of network use or efficiency that accounts for the number of vehicle trips generated times the length or distance of those trips. VMT is generally expressed as VMT per capita for a typical weekday. For instance, the 2013 average daily VMT generated by residents living and working in the nine county Bay Area region was 15.3 miles per person per day. San Rafael General Plan Transportation Performance Policies and Evaluating CEQA Impacts Based on SB 743 P a g e | 2 Local Traffic Performance Considerations There are several options should the City of San Rafael wish to retain a local traffic performance measure in the General Plan. This measure and the threshold associated with it would establish performance expectations. The City would be expected to monitor performance using the metric and to make modifications to the network to maintain an adequate level of performance. This could be done as part of direct City actions or implementation programs and as part of entitlement review. A local traffic performance policy and the resulting monitoring process should be easy to understand, intuitive, easy to measure, nexus driven, logical, and equitable. The two most commonly used measures, both of which are mandated in the current General Plan, involve evaluating intersection or arterial performance. Intersection performance is determined by using formulas to calculate LOS based on vehicle delay. This requires documentation of intersection lane configurations, volume data for all movements, and signal operations data. As an alternative, speed data can be used to quantify arterial performance. This is available at a relatively low cost either from technology data providers or count firms. The City may also elect to implement a combination of these performance measures. The following table provides a comparison of these two different local traffic performance measures. FACTORS INTERSECTION PERFORMANCE ARTERIAL PERFORMANCE Metric Level of Service Speed Index Defined by? Peak Hour Vehicle Delay Peak versus Off-Peak Vehicle Speeds Intuitive? No Yes Easy to Measure? No Yes Cost to Evaluate? High Low Pros ▪ Directly related to driving comfort and convenience ▪ LOS is a commonly used metric to measure traffic performance ▪ Easy to understand ▪ Easily calculated ▪ Speed data is available at relatively low cost Cons ▪ Requires significant data and resources to calculate existing intersection vehicle delay ▪ Cost to forecast future delays at intersections is high and subject to a higher margin of error ▪ Does not address network performance unless sophisticated network simulation models are used ▪ Does not reflect the benefits of improvements that increase automobile delay but enhance travel by other modes or improve safety ▪ Cost to forecast future speeds for roadway segments is moderate and subject to a moderate margin of error ▪ Does not capture potential effects on transit, bicycle, and pedestrian modes San Rafael General Plan Transportation Performance Policies and Evaluating CEQA Impacts Based on SB 743 P a g e | 3 VMT Policy Considerations The state legislature mandated the change to how transportation impacts are evaluated through SB 743, the aforementioned shift from LOS to VMT, so that CEQA would be more aligned with state goals related to the reduction of greenhouse gases, infill development, and public health through active transportation. The City of San Rafael, as lead agency for CEQA documents within its jurisdiction, has the discretion to choose the most appropriate methodology and thresholds to evaluate a project’s VMT, and may take into account both its own local policy goals and context in doing so. The Governor’s Office of Planning and Research (OPR) prepared a Technical Advisory on evaluating transportation impacts in CEQA (December 2018). The advisory contains technical recommendations regarding assessment of VMT, thresholds of significance, and mitigation measures. OPR indicates that the purpose of the document is “to provide advice and recommendations, which agencies and other entities may use at their discretion”. Lead agencies throughout the state are in the process of determining whether to follow OPR’s technical recommendations. The benefits of adopting the OPR recommendations are that they align with state goals, create VMT impact screening opportunities, and include specific thresholds. Lead agencies that have decided to develop a different VMT approach have done so for several reasons, including the following. ▪ The recommendations do not consider the local general plan role in setting threshold expectations. ▪ Projects in their jurisdiction are not likely to meet the recommended VMT threshold (e.g., exceeding a level of 15 percent below existing regional VMT per capita or employee) even with mitigation. As such, direct application of the Technical Advisory would result in significant and unavoidable VMT impacts for projects with limited transit service and located in low land use densities even when those projects are consistent with the local general plan. Data extracted from MTC’s regional travel model indicate that the current average daily VMT per capita for San Rafael’s residents that work in the MTC region is about 6 percent higher than the Bay Area average, while the current average daily VMT per employee for San Rafael’s workers that reside in the MTC region is about 33 percent higher than the Bay Area average. In April 2019, the City of San Rafael adopted Climate Change Action Plan 2030, an updated version of the 2009 plan. The Climate Change Action Plan establishes targets similar to the State’s goals to reduce emissions to 40% below 1990 levels by 2030 and 80% below 1990 levels by 2050. The Plan lays out measures that will exceed the 2030 target and put the City on a trajectory to meet the 2050 goal. The first GHG emission reduction strategy, which would comprise the largest share of all reduction strategies at 38 percent, involves reducing carbon emissions from the transportation sector. Key actions related to this strategy include increasing the zero electric vehicle (ZEV) adoption rate, incentivizing public transit use, and enabling better biking and walking opportunities. While mitigation measures for LOS impacts often involve widening streets or intersections, mitigation measures for projects that have a VMT impact focus on changing the project description (i.e., increasing project density, mix of uses, etc.) and/or requiring adoption of a Transportation Demand Management San Rafael General Plan Transportation Performance Policies and Evaluating CEQA Impacts Based on SB 743 P a g e | 4 (TDM) program with vehicle trip reduction strategies. Changing a project’s built-environment characteristics may result in the analysis of a ‘different project’ from what is being proposed. This may create a number of feasibility issues. To conclude that vehicle trip reduction strategies will reduce VMT impacts to a less-than-significant level, they would need to be monitored and adjusted over time since they are dependent on the performance of building tenants, requiring an ongoing investment both in City staff time and from property owners. The final question is whether the City of San Rafael wishes to implement a VMT policy that requires future development projects to commit to a TDM program that would comply with state air quality and GHG reduction goals. The required level of reduction may range from a low of 15 percent to over 25 percent depending on analysis parameters. This would be a costly requirement for future development, particularly for any projects that are either employment-oriented and/or outside the walk shed of the San Rafael SMART station. As an alternative, the City could require a lower reduction in VMT and/or vary reductions by areas within the City according to a reasonable expectation for VMT reduction based on factors such as planned land use types, transit service levels, and walkability. Traffic Impact Fee Considerations The General Plan Update work program includes an update of the City’s traffic impact fee program. This will occur later in the process. There are several options that exist, including a traditional trip-based fee program, a VMT-based fee program, or a flexible fee program based on the existing inventory of transportation assets. We will return to the City Council at a later time for policy direction on this issue. NOTICE OF PUBLIC MEETING – CITY COUNCIL You are invited to attend the City Council meeting on the following proposed project: PROJECT: REPORT ON TRAFFIC METHODOLOGIES FOR SAN RAFAEL GENERAL PLAN 2040- An informational report will be presented to the City Council that will cover State-mandated changes (effective mid-2020) in how traffic and circulation is to be analyzed in environmental documents (California Environmental Quality Act) and the General Plan 2040 Environmental Impact Report (EIR). The State law requires that local jurisdictions phase-out the use of the current “Level of Service” (LOS) method of review in environmental documents, replacing it with a “Vehicle Miles Traveled” (VMT) method. The informational report will explain the difference between the two traffic methodologies and the options that can be considered by the City for preparing the General Plan 2040 EIR. Case Nos.GPA16-001 & P16-013. State law (California Environmental Quality Act) requires that this project be reviewed to determine if a study of potential environmental effects is required. It has been determined that this project, which is an informational report, will have no physical impact on the environment . This informational report is classified as a planning study, which qualifies for a Statutory Exemption from the provisions of the California Environmental Quality Act Guidelines under 14 CRR Section 15262. MEETING DATE/TIME/LOCATION: Monday, June 3, 2019, 7:00 p.m. City Council Chambers, 1400 Fifth Ave at D St, San Rafael, CA FOR MORE INFORMATION: Contact Paul Jensen, Project Planner, Community Development Department at (415) 485-5064 or paul.jensen@cityofsanrafael.org. The Community Development Department office is open from 8:30 a.m. to 4:30 p.m. on Monday, Tuesday and Thursday and 8:30 a.m. to 1:30 p.m. on Wednesday and Friday. You can also view the staff report after 5:00 p.m. on the Friday before the meeting at http://www.cityofsanrafael.org/meetings. WHAT WILL HAPPEN: You can comment on the informational report and options presented in the report. The City Council will consider all public testimony. However, as this item is an informational report, no formal action will be taken by the City Council. The City Council will be requested to provide comments and direction to staff on proceeding with the next steps. IF YOU WANT TO COMMENT: You can send written correspondence by email to the address above, or by mail/hand delivery to the Community Development Department, Planning Division, City of San Rafael, 1400 5 th Avenue, San Rafael, CA 94901. At the above time and place, all written correspondence received will be noted and all interested parties will be heard. If you challenge in court the matter described above, you may be limited to raising only those issues you or someone else raised at the public hearing described in this notice, or in written correspondence delivered at, or prior to, the above referenced public hearing (Government Code Section 65009 (b) (2)). Judicial review of an administrative decision of the City Council must be filed with the Court not later than the 90th day following the date of the Council’s decision. (Code of Civil Procedure Section 1094.6) Sign Language and interpretation and assistive listening devices may be requested by calling (415) 485-3085 (voice) or (415) 485-3198 (TDD) at least 72 hours in advance. Copies of documents are available in accessible formats upon request. Public transportation to City Hall is available through Golden Gate Transit, Line 22 or 23. Para-transit is available by calling Whistlestop Wheels at (415) 454-0964. To allow individuals with environmental illness or multiple chemical sensitivity to attend the meeting/hearing, individuals are requested to refrain from wearing scented products.