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.
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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. . . “
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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.
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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.
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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)
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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.
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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
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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,
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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.
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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.
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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
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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
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(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.