HomeMy WebLinkAbout4.4 Establishing the California Environmental Quality Act (CEQA) TransportationSTAFF REPORT
CITY COUNCIL
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Agenda Item 4.4
DATE:April 20, 2021
TO:Honorable Mayor and City Councilmembers
FROM:Linda Smith, City Manager
SUBJECT:Establishing the California Environmental Quality Act (CEQA)Transportation
Thresholds of Significance for Vehicle Miles Traveled (VMT) Pursuant to
Senate Bill 743
Prepared by: Pratyush Bhatia, Transportation and Operations Manager, and
Sai Midididdi, Associate Civil Engineer (Traffic)
EXECUTIVE SUMMARY:
The City Council will consider establishing the California Environmental Quality Act (CEQA)
Transportation Thresholds of Significance for Vehicle Miles Traveled (VMT) Pursuant to Senate
Bill 743.
STAFF RECOMMENDATION:
Adopt the Resolution Establishing the California Environmental Quality Act (CEQA)
Transportation Thresholds of Significance for Vehicle Miles Traveled (VMT) Pursuant to Senate
Bill 743.
FINANCIAL IMPACT:
Staff does not anticipate financial impacts resulting from establishing the CEQA Transportation
Thresholds of Significance.
DESCRIPTION:
In September 2013, the California Legislature passed Senate Bill 743 (Steinberg) that shifts the
focus of transportation analysis from driver delay to reduction of greenhouse gas emissions,
creation of multi-modal networks, and promotion of a mix of land uses.
Historically, transportation analysis under California Environmental Quality Act (CEQA) was
based on Level of Service (LOS), as measured by roadway capacity or congestion and vehicle
delay. SB 743 eliminates LOS as the metric to assess significant transportation impacts under
CEQA.
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To align transportation analysis with state goals for climate change and active transportation, the
Governor’s Office of Policy and Research (OPR) developed guidelines for new metrics to use in
CEQA transportation analyses. In December 2018, OPR published a technical advisory document,
based on stakeholder engagement and feedback, which identified Vehicle Miles Traveled (VMT) as
the new required metric. Starting July 1, 2020, VMT became the required metric for all new CEQA
analyses.
VMT counts the number of miles traveled by vehicles that are generated by or attracted to the
project. It captures motorized trip generation rates, thereby accounting for the effects of project
features and its surroundings, such as proximity to mass transit. VMT analysis also captures trip
length, and so can account for regional location, which is the most important single determinant of
vehicle travel. Although VMT is based on the number of auto trips only and not on the number of
trips by other modes, a lower VMT is indicative of areas in which other modes, such as public
transit and bicycling, are more utilized.
In addition to setting VMT as the official metric for CEQA analyses, OPR developed
recommendations on metrics, significance thresholds, and geographic areas over which to apply
them. OPR recommendations are not mandatory requirements on local agencies. Therefore, the
City can adopt its own thresholds based on local conditions and supported by substantial
evidence. OPR recommendations for metrics and thresholds for various project types include:
1. Residential Projects: OPR recommendsaverage existing VMT per capita (total VMT divided
by the residential population of the region) as the metric for residential uses. It also
recommends that the threshold of significance should be defined as 15 percent below the
regional average. In other words, a project that generates a VMT per capita that is more
than 85 percent of existing VMT may result in a significant impact.
2. Office Projects: OPR recommends existing average VMT per employee (total VMT divided
by the total worker population of a region) as the metric for office projects. Like residential
projects, OPR recommends that the threshold of significance should be defined as 15
percent below the regional average for office projects. An office or employment project
would have a significant impact if its average VMT per employee is more than 85 percent of
the existing regional average.
3. Retail Projects: OPR recommends estimating total VMT in an area as the metric to assess
retail projects. A determination of a significant impact would be based on measuring the
net decrease or increase in VMT in the study area with and without the project. An impact
may occur if there would be an increase in total VMT resulting from the project.
Staff performed a detailed review of the OPR’s recommendations for the VMT metrics and
thresholds of significance and concluded they are generally appropriate for use in Dublin.
However, Staff determined that the geographic area against which these thresholds should be
applied to or compared to, should be modified based on local conditions. Staff reviewed four
different geographic areas to use for the region over which to apply the metrics. These regions and
the Staff’s conclusions are as follows:
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1. Nine-County Bay Area – The diversity of travel patterns and development, large size, and
minimal policy and planning applicability at the local level make the Nine-County Bay Area
unsuitable as the regional VMT comparison.
2. Alameda County – Cities in eastern Alameda County have significantly different travel
patterns, diversity, and topographic features than areas in the inner County communities.
As such, using the entire County is not representative of conditions in the Tri-Valley.
3. City of Dublin – A review of trip characteristics in the City of Dublin show that fewer than
20% of residential and commercial trips produced within the City of Dublin stay within City
boundaries. Therefore, this geographic area is too small to be selected as representing
regional VMT for Dublin.
4. Planning Area 4 (East Planning Area) – This geographic area represents the eastern
planning area for Alameda County Transportation Commission (ACTC) and includes
Dublin, Livermore, and Pleasanton. The overlap that Planning Area 4 provides between the
County’s planning efforts and ACTC’s travel demand modeling makes Planning Area 4 Staff’s
recommended geographic area for assessing VMT.This region as the recommended option
would also facilitate effective Transportation Demand Management measures and
implementation by providing the opportunity to coordinate with other cities in Planning
Area 4.
In conclusion, Staff recommends establishing the following metrics, thresholds of significance, and
geographic area when assessing potential VMT impacts under CEQA for projects within the City of
Dublin:
1. Residential Projects: A significant impact occurs if a Proposed Project average VMT per
capita is greater than 15 percent below the existing Planning Area 4 average.
2. Office Projects: A significant impact occurs if a Proposed Project average VMT per
employee is greater than 15 percent below the existing Planning Area 4 average.
3. Retail Projects: A significant impact occurs if a Proposed Project causes a net increase in
total VMT. The total VMT for Planning Area 4 with and without the Proposed Project is
calculated. The difference between the two scenarios is the net change in total VMT that is
attributable to the Proposed Project.
4. Other Development Projects: Staff will determine the applicable thresholds on a case-by-
case basis based on the land use type, project description, and setting. Other Development
Projects may include schools, institutional uses, medical facilities, hotels, etc. Generally,
these projects will be analyzed based on how similar they are to residential, office, or retail
projects.
Residential and Office Land Use VMT maps (Attachment 2) show which parts of the City fall under
the thresholds and which fall above the thresholds based on the current land uses at these
properties.
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SB 743 does not preclude the use of LOS for operational analysis, but LOS may no longer be used
as a method for evaluating a project's potential transportation impacts under CEQA. Dublin’s
General Plan Section 5.2.2.A.6 will continue to require LOS-based analysis outside of CEQA to
assess traffic impacts.
Next Steps
Staff will finalize the draft Transportation Impact Analysis Guidelines (Attachment 3), which are
currently updated based on the recommended thresholds and metrics. The TIA Guidelines
document provides direction to Staff, applicants, and consultants on the requirements to evaluate
transportation impacts for projects in the City. It is intended to:
1. Promote conformance with applicable City and state regulations.
2. Provide evaluation consistent with the California Environmental Quality Act (CEQA).
3. Ensure consistency in preparation of studies by applicants and consultants.
4. Provide predictability in content for Staff and the public in reviewing studies.
STRATEGIC PLAN INITIATIVE:
None.
NOTICING REQUIREMENTS/PUBLIC OUTREACH:
The City Council Agenda was posted, and a public notice was published in the East Bay Times.
ATTACHMENTS:
1) Resolution Establishing the California Environmental Quality Act (CEQA) Transportation
Thresholds of Significance for Vehicle Miles Traveled (VMT) Pursuant to Senate Bill 743
2) Residential and Office Land Use VMT Maps
3) Draft Transportation Impact Analysis (TIA) Guidelines
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Reso. No. XX-21, Item X.X, Adopted XX/XX/21 Page 1 of 2
Attachment 1
RESOLUTION NO. XX – 21
A RESOLUTION OF THE CITY COUNCIL
OF THE CITY OF DUBLIN
ESTABLISHING THE CALIFORNIA ENVIRONMENTAL QUALITY ACT (CEQA)
TRANSPORTATION THRESHOLDS OF SIGNIFICANCE FOR VEHICLE MILES TRAVELED
(VMT) PURSUANT TO SENATE BILL 743
WHEREAS,In September 2013, the California Legislature passed Senate Bill 743
(Steinberg) that shifts the focus of transportation analysis from driver delay to reduction of
greenhouse gas emissions, creation of multi-modal networks, and promotion of a mix of land
uses; and
WHEREAS,historically, transportation analysis under California Environmental Quality
Act (CEQA) was based on Level of Service (LOS), as measured by roadway capacity or
congestion and vehicle delay, and SB 743 eliminates LOS as the metric to assess significant
transportation impacts under CEQA; and
WHEREAS,in December 2018, to align transportation analysis with state goals for
climate change and active transportation, the Governor’s Office of Policy and Research (OPR)
developed guidelines for new metrics to use in CEQA transportation analyses; and
WHEREAS,OPR recommendations are not mandatory requirements on local agencies;
therefore, the City can adopt its own thresholds based on local conditions if supported by
substantial evidence; and
WHEREAS,Staff evaluated and determined that Vehicle Miles Traveled (VMT), an
estimate of the amount and distance people drive by vehicle to reach a destination, is an
appropriate metric for evaluating transportation impacts under CEQA analysis per OPR’s
guidelines; and
WHEREAS,Staff evaluated and determined that Planning Area 4, representing the
eastern geographic planning area that includes cities of Dublin, Livermore, and Pleasanton for
Alameda County Transportation Commission (ACTC), is the appropriate geographic planning
area that VMT thresholds should apply to, as it also overlaps with the ACTC’s planning efforts in
this region and travel demand modeling; and
WHEREAS,Staff evaluated and determined that the appropriate thresholds of
significance for residential projects and office projects is at 15% below the existing Planning
Area 4 VMT averages and is at no net increase in VMT for retail projects per OPR’s guidelines;
and
WHEREAS,Staff evaluated and determined that the appropriate thresholds of
significance for other development projects will be decided by Staff on a case-by-case basis
depending on how close the proposed land use is to residential, office, or retail projects.
NOW, THEREFORE, BE IT RESOLVED that the City Council of the City of Dublin
establishes VMT as the metric to measure transportation impacts under CEQA analysis.
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Reso. No. XX-21, Item X.X, Adopted XX/XX/21 Page 2 of 2
Attachment 1
BE IT FURTHER RESOLVED that the City Council of the City of Dublin establishes the
following thresholds of significance and geographic area when assessing potential VMT impacts
under CEQA.
1.Residential Projects: A significant impact occurs if a Proposed Project average VMT per
capita is greater than 15% below the existing Planning Area 4 average.
2.Office Projects: A significant impact occurs if a Proposed Project average VMT per
employee is greater than 15% below the existing Planning Area 4 average.
3.Retail Projects: A significant impact occurs if a Proposed Project causes a net increase in
total VMT. The total VMT for Planning Area 4 with and without the Proposed Project is
calculated. The difference between the two scenarios is the net change in total VMT that
is attributable to the Proposed Project.
4.Other Development Projects: Staff will determine the applicable thresholds on a case-by-
case basis based on the land use type, project description, and setting. Other
Development Projects may include, but are not limited to schools, institutional uses,
medical facilities, hotels, etc. Generally, these projects will be analyzed based on how
similar they are to residential, office, or retail projects.
PASSED, APPROVED AND ADOPTED this 20th day of April 2021, by the following vote:
AYES:
NOES:
ABSENT:
ABSTAIN:
______________________________
Mayor
ATTEST:
_________________________________
City Clerk
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Planning Area 4 - Residential
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Planning Area 4 - Office
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TRANSPORTATION IMPACT
ANALYSIS GUIDELINES
City of Dublin, CA
February 16, 2021
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Table of Contents
1. Introduction ................................................................................................................................... 1
1.1. Which Projects Require a Transportation Impact Analysis? .................................................. 1
1.2. Developing the Scope of Work ............................................................................................... 1
2. Project Summary ............................................................................................................................ 2
2.1. Project Description ................................................................................................................. 2
2.2. Study Area Description ........................................................................................................... 2
3. Local Transportation Analysis ........................................................................................................ 3
3.1. TRIP GENERATION and Distribution Documentation ............................................................. 4
3.1.1. Identification of Potential Study Locations ..................................................................... 4
3.1.2. Trip Generation ............................................................................................................... 4
3.1.3. Trip Distribution .............................................................................................................. 5
3.2. Site Plan Review ...................................................................................................................... 5
3.3. Operations Analysis ................................................................................................................ 7
3.3.1. Data Collection and Study Periods .................................................................................. 7
3.3.2. Study Scenarios ............................................................................................................... 7
3.3.3. Future Traffic Volume Forecasting Methodology ........................................................... 8
3.3.4. Operations Analysis Methodology .................................................................................. 8
3.3.5. Level of Service Standards .............................................................................................. 8
3.3.6. Other Analysis Requirements ....................................................................................... 10
3.3.7. Cross-Jurisdictional Analysis ......................................................................................... 11
3.3.8. Analysis Discussion ........................................................................................................ 11
4. CEQA Transportation Analysis ..................................................................................................... 12
4.1. Consistency with Adopted Plans .......................................................................................... 14
4.2. VMT Screening ...................................................................................................................... 14
4.2.1. Small Projects ................................................................................................................ 17
4.2.2. Affordable Housing ....................................................................................................... 17
4.2.3. Local Serving Retail and Public Services ........................................................................ 17
4.2.4. High-Quality Transit Area (HQTA) ................................................................................. 18
4.2.5. Project Located in Low VMT Areas ............................................................................... 19
4.2.6. Consistency with RTP/ SCS ............................................................................................ 19
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4.3. Detailed VMT Analysis .......................................................................................................... 19
4.3.1. Efficiency Metrics (VMT per Capita and VMT per Employee)....................................... 20
4.3.2. Total VMT ...................................................................................................................... 20
4.3.3. Exclusion of Truck VMT ................................................................................................. 20
4.3.4. Thresholds of Significance ............................................................................................. 21
4.3.5. Redevelopment Projects ............................................................................................... 21
4.3.6. Land Use Plans .............................................................................................................. 22
4.3.7. Cumulative Impacts....................................................................................................... 22
4.4. Mitigation ............................................................................................................................. 22
4.5. Transportation Projects ........................................................................................................ 24
4.5.1. Determining Need for Detailed VMT Analysis .............................................................. 24
4.5.2. VMT Analysis for General Plan or RTP/SCS Projects ..................................................... 24
4.5.3. VMT Analysis Methodology and Tools .......................................................................... 25
4.5.4. Mitigation for Transportation Projects ......................................................................... 25
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1. INTRODUCTION
This Transportation Impact Analysis Guidelines document provides guidance to City staff,
applicants, and consultants on the requirements to evaluate transportation impacts for projects in
the City of Dublin (City). It is intended to:
Promote conformance with applicable City and state regulations;
Provide evaluation consistent with the California Environmental Quality Act (CEQA);
Ensure consistency in preparation of studies by applicants and consultants; and
Provide predictability in content for staff and the public in reviewing studies.
Although these guidelines are intended to be comprehensive, not all aspects of every
transportation analysis can be addressed in this framework. City staff reserve the right to use
judgement to request exemptions and/or to modify requirements for specific projects at the time of
the review application.
1.1. WHICH PROJECTS REQUIRE A TRANSPORTATION IMPACT ANALYSIS?
A Transportation Impact Analysis (TIA) prepared by a qualified consultant, working at the direction
of the City, is required for most projects. For projects subject to CEQA, the TIA must include an
evaluation that addresses the CEQA statute. In addition, the TIA must include a local operational
evaluation. The level of analysis will vary based on the size, type and location of the project. A TIA
for a simple project may include trip generation estimates, brief documentation of VMT for CEQA
compliance, and a site plan review. More complex projects may require a detailed VMT analysis,
and an intersection operations analysis documenting the project’s effect on the local transportation
infrastructure.
1.2. DEVELOPING THE SCOPE OF WORK
Table 1 shows the top-level elements to include in a scope of work. For all projects, a pre-
application/transportation scoping meeting should be scheduled between City staff and the
transportation consultant to address how these guidelines are applied to the proposed project. This
is required for projects generating more than 50 trips in a peak hour. Following the scoping
meeting, the transportation consultant should prepare a draft scoping memorandum for review and
approval by City staff. Key items required in a scoping memorandum include:
• Identify travel demand model to be used if performing a detailed VMT analysis.
• Selected study intersections based on guidance provided in this document.
• Trip generation assumptions including any proposed reductions for pass-by, internal
capture, and travel demand management.
• Trip distribution and assignment assumptions and brief justification.
• Proposed time periods for transportation counts.
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• Proposed intersection analysis tool (Vistro, Synchro, etc.).
• Project vicinity maps showing traffic assignment, location of the project, and proposed
study intersections.
Table 1: Typical Study Components
Topic Subtopics
Passes CEQA Screen Does
Not Pass
CEQA
Screen
TIA
Section
<= 50 Peak
Hour Trip
Generation
> 50 Peak
Hour Trip
Generation
Project Summary
Project Description x x x 2.1
Study Area Description x x x 2.2
Local
Transportation
Analysis
Trip Generation x x x 3.1
Site Plan Review x x x 3.2
Operations Analysis x x 3.3
CEQA
Transportation
Analysis
Consistency with Plans x x x 4.1
CEQA VMT Screening x x x 4.2
Detailed VMT Analysis x 4.3
Mitigations (if applicable) x 4.4
City staff will make reasonable, good faith efforts to review the draft scope within 10 business days
of receipt and request revisions as needed.
2. PROJECT SUMMARY
All transportation impact analyses will include a project summary including a project description
and a study area description.
2.1. PROJECT DESCRIPTION
All transportation impact analyses must include a project description with the following
information:
• Site plan including address and cross streets.
• Existing and proposed total gross square footage for each land use type and number of
residential units and hotels rooms.
2.2. STUDY AREA DESCRIPTION
The transportation review should provide a brief but complete description of existing
transportation infrastructure and conditions in the vicinity of the project. The study area selected
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and covered in this description must be justified such that the reasoning can be easily understood.
Key elements include but are not limited to:
• Roadway description of key roadways in the study area including:
o Number and width of lanes;
o Average daily traffic volumes (where known from studies performed within the past
three years);
o Traffic calming devices (e.g., traffic circles, bulb-outs and speed bumps),
o Sidewalk characteristics;
o Presence of bicycle facilities; and
o On-street parking.
• Map showing current transit routes in the study area and the closest transit stop to the
project.
• Map showing existing and proposed bicycle facilities in the study area.
• If the project is anticipated to generate truck traffic, a map of existing truck routes in the
study area.
3. LOCAL TRANSPORTATION ANALYSIS
A local transportation analysis is required for development projects to evaluate potential impacts
on the circulation network, primarily on local access and circulation in the proximity of a project
site. This analysis is required for conditions of approval and is outside the CEQA review process.
Traffic impacts caused by a development project are considered to be unacceptable and warrant
improvements if the addition of project traffic results in intersection level of service exceeding the
acceptable level established in the General Plan1; where there may be safety hazards created; or
where there may be other substantial effects on the circulation system. This analysis would address
traffic operations, safety issues and needed project design features related to a proposed
development project, as well as site access and internal circulation.
The level of local transportation analysis is dependent on the proposed project. Project’s generating
less than 50 vehicle trips during a peak hour are only required to submit trip generation and
distribution documentation. Projects larger than 50 trips must also include operational analyses at
the identified study locations.
1 The City strives to phase development and roadway improvements so that the operating Level of Service (LOS)
for intersections in Dublin does not exceed LOS D. However, intersections within the Downtown Dublin Specific
Plan area (including the intersections of Dublin Boulevard/San Ramon Road and Village Parkway/Interstate 680 on-
ramp) are excluded from this requirement and may operate at LOS E or worse as long as the safety for pedestrians
and bicyclists is maintained and impacts to transit travel speeds are minimized .
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3.1. TRIP GENERATION AND DISTRIBUTION DOCUMENTATION
Trip generation and distribution documentation must be provided for all projects proposed for
development in Dublin. Details of the requirements for this documentation are described in this
section.
3.1.1. Identification of Potential Study Locations
The first step in the trip generation and distribution documentation is to identify potential locations
where the project may affect the transportation infrastructure. At a minimum, signalized and
unsignalized intersections that fall into the following categories should be identified:
• Project driveways
• All intersections of streets adjacent to the project site
• Major intersections of collector or higher classified streets where the project traffic could
significantly affect operations
The study should also examine any other locations necessary as determined by City staff.
3.1.2. Trip Generation
Trip generation should be based on one or more of the following:
Institute of Transportation Engineers (ITE) Trip Generation Manual (most current edition)
o When the land use has a limited number of studies to support the trip generation rates
or when the Coefficient of Determination (R2) is below 0.75, consultation with the City
and those preparing the analysis is recommended.
Local trip generation rates are acceptable if appropriate validation is provided to support
them.
Mixed-use trip reductions are allowed but must follow methods from approved sources
such as ITE or NCHRP.
Pass-by trip2 reductions must be justified from approved sources and are only considered
for retail-oriented development. Determination of pass-by trips will be based on the ITE
procedures and will be approved by the City’s Traffic Engineer. The justification for
exceeding a five percent reduction should be discussed in the documentation.
2 Pass-By - Traffic already on the way from an origin to a primary trip destination that will make an intermediate
stop at the site being studied without a route diversion.
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Internal capture3 trip reductions are allowed and will be based on the ITE procedures and
will be approved by the City’s Traffic Engineer. The justification for exceeding a five percent
reduction should be discussed in the documentation.
Diverted4 trips require consultation with the City.
All trip reductions may be capped by the City Traffic Engineer.
All assumptions shall have proper citation and justification for their use in the local
transportation analysis and must be approved by the City Engineer.
Projected daily and AM and PM peak hour trips for the proposed project shall be summarized in a
table. Trip generation rates, factors and source should be provided. The totals for the inbound and
outbound trips shall be provided in the table.
3.1.3. Trip Distribution
Trip distribution should be developed, and project trips assigned to the study intersections using
either existing travel patterns and relative locations of complementary land uses, or a travel
demand model select zone run (in consultation with City staff).
A figure illustrating the percentage of peak hour traffic going to and from various destinations along
the transportation network shall be provided. A figure illustrating peak hour project only trips at the
study intersections (including project driveways) shall be provided based on the trip distribution.
3.2. SITE PLAN REVIEW
A site plan review is required for all development projects and as requested by the City Traffic
Engineer. It is essential to have a transportation professional review the proposed site plan and
make recommendations on how site circulation and access for all modes can be improved. Key
elements of a site plan review that need to be discussed include:
Vehicle Parking – Identify and compare the project’s:
o Proposed parking supply;
o Parking requirements from the Dublin Municipal Code (DMC) (including ADA
requirements);
o Bicycle parking supply will also be compared to code requirements; and
o Parking stall depth and length in relation to code requirements.
3 Internal Capture - Traffic associated with multi-use developments where trips among various land uses can be
made on the site being studied without using the major street system. These trips can be made either by walking
or by vehicles using internal roadways
4 Diverted - Traffic attracted to the site being studied from adjacent facilities without direct access to the site. A
diverted trip example is a through trip on a freeway that diverts to an exit and a development, adding traffic to the
local road but removing traffic from the freeway.
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Bicycle Parking – Identify and compare the project’s short-term and long-term bicycle
parking against requirements in the DMC. (This is per Green Building code and if any
requirements that are/may be proposed in Bicycle and Pedestrian Master Plan). The
location of the bicycle parking on the site and its accessibility should also be assessed.
Vehicle Site Circulation – Identify any potential vehicle conflict points when accessing or
circulating within the site.
Pedestrian and Bicycle Site Circulation – Identify any potential pedestrian and bicycle
conflict points accessing or circulating within the site. Pedestrian routes between the
project and the closest bus stop should also be assessed to determine if adequate
pedestrian facilities are provided.
Large Vehicle Site Circulation – Create turn templates showing site access and circulation for
the largest of either emergency, garbage, service, or delivery vehicles.
Drop Off and Loading Zones – Evaluate the adequacy of drop off or loading zones as
applicable to the project.
Sight Distance – Review the available sight distance at the proposed project access points.
This review should include visibility triangles on landscape plans.
Attachment E provides a high-level checklist of items to consider when reviewing site plans.
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3.3. OPERATIONS ANALYSIS
Projects anticipated to generate more than 50 vehicle trips in the peak hour are required to
perform an operations analysis of access points to a project site and at key intersections where
traffic created by a project may affect operations. This operations analysis is in addition to the trip
generation and distribution documentation and the site plan review. The requirements of this
operations analysis are included in this section.
3.3.1. Data Collection and Study Periods
Traffic counts should be collected and included in the Appendix. Available existing counts can be
used if they are less than two years old and the traffic volumes have not been significantly changed
due to more recent development in the vicinity. The City may allow the use of older data or
alternative data collection sources due to atypical conditions that may be causing a substantial
disruption of traffic patterns or volumes such as long-term roadway construction or closures, severe
disruptions of economic, employment activity and widespread mandated closures of public and
private institutions. The City Traffic Engineer or their designee shall approve all requests to use
other available traffic counts.
Common rules for conducting traffic counts include but are not limited to:
Peak hour turning movement volumes shall be conducted on Tuesdays, Wednesdays, or
Thursdays during weeks not containing a holiday. Counts shall be conducted in favorable
weather conditions.
Counts shall be collected when schools and colleges are in ses sion, but not during the first
two weeks that the schools and colleges are in session. Counts collected when schools and
colleges are not in session shall be approved by the City Engineer, including a methodology
for adding historical school traffic volumes into the analysis.
Two-hour peak period vehicular, bicycle, and pedestrian volumes shall be collected for all
study intersections for the weekday AM and weekday PM periods, or unless otherwise
specified (such as midday or weekend peak periods). To eliminate unnecessary analysis,
consultation between the City, and those preparing the TIA is required during the early
planning stages of a project to determine the exact time periods for data collection.
3.3.2. Study Scenarios
Intersection levels of service should be analyzed for the following scenarios:
• Existing Conditions
• Opening Year Conditions
• Opening Year Plus Project Conditions (project-generated traffic added to Opening Year
volumes)
• Cumulative Conditions (based on the current cumulative year travel demand model)
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• Cumulative Plus Project Conditions (project-generated traffic added to cumulative traffic
volumes)
For projects anticipated to be completed in phases, an interim year analysis for the opening of each
phase may be required. Please consult with the City Traffic Engineer for determination of interim
years if the project is phased.
3.3.3. Future Traffic Volume Forecasting Methodology
The local or regional travel demand model should reflect the most current land use and planned
improvements (i.e., where programming or funding is secured). When a general plan build-out
model is not available, the closest forecast model year to build-out should be used. Any changes
made to the model to accommodate the proposed project should be clearly identified in the TIA.
If a travel demand model is not available, historical growth rates and current trends can be used to
project future traffic volumes. City staff must approve alternative methods to develop future
volumes such as general growth rates.
3.3.4. Operations Analysis Methodology
Existing, Opening Year, Opening Year Plus Project, Cumulative, and Cumulative Plus Project
intersection levels of service must be evaluated for all study intersections using the most recent
edition of the Highway Capacity Manual (HCM) methodology. The analysis software used to
implement the HCM (Vistro, Synchro, HCS, etc.) should be verified with the City prior to beginning
the analysis.
3.3.5. Level of Service Standards
Level of service (LOS) is a standard performance measurement to describe the operating
characteristics of a street system in terms of the level of congestion or delay experienced by
motorists. Service levels range from A through F, which relate to traffic conditions from least
congested, (free-flowing conditions) to most congested (total breakdown with stop-and-go
operations). The relationship between level of service and delay are described in the HCM.
The performance standard5 for intersections in Dublin is to maintain no worse than LOS D as the
acceptable for most signalized intersections within the City. Intersections within the Downtown
Dublin Specific Plan area (including the intersections of Dublin Boulevard/San Ramon Road and
Village Parkway/Interstate 680 on-ramp) may operate at LOS E or worse as long as the safety for
pedestrians and bicyclists is maintained and negative effects to transit travel speeds are minimized .
5 City of Dublin General Plan Section 5.2.2
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3.3.5.1. Signalized Intersections
The local transportation analysis should note intersections that perform unacceptably under no
project and/or plus project conditions, and necessary improvements that can be applied to increase
performance to acceptable levels. For signalized intersections, an adverse traffic operations issue is
identified if the addition of the traffic generated from the proposed project results in any one of the
following:
At a study, signalized intersection which is located outside the Downtown Dublin Specific
Plan area, the project would cause the motor vehicle LOS to degrade to worse than LOS D
(i.e., LOS E or F);
At a study, signalized intersection which is located within the Downtown Dublin Specific
Plan area, the project would cause the motor vehicle (LOS to degrade to worse than LOS E
(i.e., LOS F);
At a study, signalized intersection which is located outside the Downtown Dublin Specific
Plan area where the motor vehicle level of service is LOS E, the project would cause the total
intersection average vehicle delay to increase by four (4) seconds or more; or
At a study, signalized intersection for all areas where the level of service is LOS F, the project
would cause: (a) the overall volume-to-capacity (V/C) ratio to increase 0.03 or more; or (b)
the critical movement V/C ration to increase by 0.05 or more.
For intersections located along routes of regional significance, the Tri-Valley Transportation
Plan and Action Plan identifies LOS E or better as the standard for the Multimodal
Transportation Service Objective (MTSO) related to intersection LOS.
3.3.5.2. Unsignalized Intersections
Unsignalized intersections should maintain no worse than LOS E in the Downtown Dublin Specific
Plan area and LOS D for all other areas. For unsignalized study intersections, an adverse traffic
operations issue is identified if the addition of the traffic generated from the proposed project
results in any one of the following:
At a study, unsignalized intersection which is located outside the Downtown Dublin Specific
Plan area, the project would cause the motor vehicle LOS to degrade to worse than L OS D
(i.e., LOS E or F) and after project completion satisfy the California Manual on Uniform
Traffic Control Devices (MUTCD) peak hour traffic signal warrant;
At a study, unsignalized intersection which is located within the Downtown Dublin Specific
Plan area, the project would cause the motor vehicle LOS to degrade to worse than LOS E
(i.e., LOS F) and after project completion satisfy the California Manual on Uniform Traffic
Control Devices (MUTCD) peak hour traffic signal warrant; or
At a study, unsignalized intersection where the motor vehicle level of service is operating
below the LOS threshold, the project would add ten (10) or more vehicles to the critical
movement and after project completion satisfy the California Manual on Uniform Traffic
Control Devices (MUTCD) peak hour traffic signal warrant.
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Unsignalized intersections includes all way stop, two way stop, and roundabout controlled
intersections. The delay for unsignalized intersections should be computed as follows:
All-Way Stop and Roundabout Controlled – use overall intersection delay
Two-Way Stop Controlled – use worst approach delay
Improvements to unsignalized intersections may include a change of traffic control, including yield
control, traffic circle/roundabout, or a traffic signal. The City reserves the right to determine if a
warranted signal will be installed.
3.3.6. Other Analysis Requirements
In addition to LOS, the local transportation assessment must include the following analyses and
recommendations for improvement:
• Vehicle Queuing: Examine outbound vehicle queuing at project driveways and note any on-
site deficiencies or conflicts with circulation. Also examine the adequacy of turn pocket
storage length at off-site study intersections based on 95th percentile queues.
• Pedestrian Circulation: Examine potential effects to pedestrian safety and accessibility for
all existing and planned sidewalks, crosswalks, and other pedestrian facilities adjacent to the
project site, within a quarter mile of the project site, or connecting to transit stops or
stations in the vicinity of the project site. A determination should also be made whether the
project conflicts with adopted policies, plans, or programs supporting pedestrian circulation.
• Bicyclist Circulation: Examine potential effects to bicyclist safety and accessibility for all
existing and planned bikeways and other bicycle facilities (including roadways) adjacent to
the project site, within a quarter mile of the project site, or connecting to transit stops or
stations in the vicinity of the project site. A determination should also be made whether the
project conflicts or creates inconsistencies with adopted bicycle system plans, guidelines,
policies or standards; or a project fails to provide on-site parking for bicycles as required by
the City’s municipal code.
• Transit Circulation: Examine potential operational effects to transit routes and facilities and
potential effects to transit user safety and accessibility for all existing and planned transit
stops or stations adjacent to the project site or within a quarter mile of the project site.
• Consistency with Complete Street and Traffic Safety Policies: Determine if the Project
conflicts with the City’s Complete Street or Traffic Safety Policies.
• Metropolitan Transportation Service Objectives (MTSOs): The Tri-Valley Transportation
Council (TVTC) has defined MTSOs that define quality of service that is desired for routes of
regional significance. Projects affecting routes of regional significance must also perform an
analysis of applicable MTSOs per the latest Tri-Valley Transportation Plan and Action Plan
for Routes of Regional Significance.
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The project applicant should conduct any additional analysis that is deemed necessary by City staff,
to be determined through a scoping meeting. This could include passenger loading demand
analyses and freight loading demand analysis.
3.3.7. Cross-Jurisdictional Analysis
If a project will affect another jurisdiction, such as Caltrans, Alameda CTC, County of Alameda, or
adjacent cities, coordination with that jurisdiction may be required. City of Dublin staff can provide
guidance and contact information for other jurisdictions.
3.3.8. Analysis Discussion
The local transportation analysis should discuss conclusions regarding the transportation issues
caused by the proposed project on the roadway system. If the traffic generated by this and other
projects requires improvement measures that are not covered by current impact fees, then the
project’s fair share percentage shall be calculated using peak-hour volumes and provided in the
local transportation analysis.
For all recommendations to increase the number of travel lanes on a street or at an intersection as
an improvement measure, the report must clearly identify the adverse effects associated with such
a change such as whether or not additional right-of-way will be required and whether it is feasible
to acquire the right-of-way based on the level of development of the adjacent land and buildings (if
any). All improvements should be reviewed in the field to make sure that they can be
accommodated. If they cannot be accommodated or are not feasible, those findings need to be
included in the local transportation analysis.
Any proposed roadway widening would need a review of the VMT impacts for transportation
projects, as described the VMT Impact Thresholds section (Section 4.3.4). Any proposed
improvements in response to local transportation analysis that results in increased capacity must
undergo a detailed VMT analysis (Section 4.3).
The local transportation analysis should discuss other possible adverse issues on traffic. Examples of
these are: (1) the limited visibility of access points on curved roadways; (2) the need for pavement
widening to provide left-turn and right-turn lanes at access points into the proposed project; (3) the
effect of increased traffic volumes on local residential streets; and (4) the need for road realignment
to improve sight distance.
Projects which propose to amend a General Plan land use designation and substantially increase
potential traffic generation must provide an analysis of the project at current planned land use
versus proposed land use in the build out condition for the project area, including future cumulative
conditions. The purpose of such analysis is to provide decision makers with the understanding of
the planned circulation networks ability to accommodate additional traffic generation caused by a
General Plan Amendment.
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4. CEQA TRANSPORTATION ANALYSIS
This section discusses the requirements for conducting analyses for projects that are subject to
CEQA, consistent with requirements of SB 743. Under CEQA, a lead agency has the authority to
determine its own significance thresholds and methodologies for technical analysis, taking into
account its own development patterns, policy goals and context. Lead agencies can make their own
specific decisions regarding methodology and thresholds, presuming their choices are supported by
substantial evidence.
Appendix G (Environmental Checklist Form) of the CEQA Guidelines identifies the following four
questions for the assessment of transportation impacts:
a) Would the project conflict with a program, plan, ordinance or policy addressing the
circulation system, including transit, roadway, bicycle and pedestrian facilities?
b) Would the project conflict with or be inconsistent with CEQA Guidelines section 15064.3,
subdivision (b) (requirement to use VMT)?
c) Would the project substantially increase hazards due to a geometric feature or incompatible
uses?
d) Would the project result in inadequate emergency access?
Consistent with CEQA Guidelines Section 15064.3, the City of Dublin has established thresholds of
significance to determine when a project will have a significant transportation impact based on
VMT. The City has also established screening criteria to streamline the analysis for projects that
meet certain criteria, referred to as project screening.
Figure 1 presents a flow chart depicting how a development project would be analyzed under VMT-
based metrics.
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Figure 1: Development Project VMT Analysis Flow Chart
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4.1. CONSISTENCY WITH ADOPTED PLANS
Dublin’s adopted plans shape the framework for transportation planning in the City. These plans
should be consulted for all projects to determine if the project elements are consistent or conflict
with Dublin’s vision of a safe and efficient transportation system. The names of major plans in
Dublin along with their weblinks include:
General Plan Land Use and Circulation Element
o https://dublin.ca.gov/171/General-Plan
Bicycle and Pedestrian Master Plan
o https://dublin.ca.gov/DocumentCenter/View/7738/Bike-and-Ped-Plan-and-
Guidelines-1?bidId=
Downtown Dublin Specific Plan
o https://dublin.ca.gov/DocumentCenter/View/7859/Amended_DDSP_Dec_2019?bid
Id=
Dublin Village Historic Area Specific Plan
o https://dublin.ca.gov/DocumentCenter/View/7780/DVHASP-FULL-PDF-
10714?bidId=
Eastern Dublin Specific Plan
o https://dublin.ca.gov/DocumentCenter/View/7776/EDSP-2016-Update-Full-
PDF?bidId=
Dublin Crossing Specific Plan
o https://dublin.ca.gov/DocumentCenter/View/14502/Dublin-Crossing-SP-
2017?bidId=
Downtown Dublin Streetscape Plan
o https://dublin.ca.gov/1945/Downtown-Dublin-Streetscape-Plan
4.2. VMT SCREENING
A project requires a detailed VMT analysis unless it meets at least one of the City’s five screening
criteria:
1. Small projects
2. Provision of affordable housing
3. Local-serving retail and public services
4. Project located in a High-Quality Transit Area (HQTA)
5. Project located in low VMT area
Figure 2 presents a chart depicting how a development project would be analyzed under the
proposed screening criteria. A project that meets at least one of the screening criteria is assumed to
have a less than significant VMT impact due to project or location characteristics. Projects that meet
one or more of these screening criteria should document the findings in a letter or memorandum
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and submit it to the City for review and approval. Ultimate determination of whether a project
screens out under one of these criteria rests with the City’s Public Works Director or designee.
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Figure 2 - Development Projects Screening Criteria Flow Chart
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4.2.1. Small Projects
Projects that generate or attract fewer than 110 vehicle trips per day are presumed to have a less
than significant transportation impact. Examples of projects that typically generate 110 daily vehicle
trips per day or less are shown in Table 2.
Table 2: Small Projects Examples (less than 110 daily trips)
Land Use Type Number of Units/ Square Feet Corresponding Daily Trips
Single Family Residential 10 Dwelling Units 110
Multi-Family Residential 11 Dwelling Units 104
Office 11,000 SF 107
Trips calculated from the ITE Trip Generation Manual 10th Edition.
4.2.2. Affordable Housing
Residential projects with 100 percent deed restricted affordable housing are presumed to have a
less than significant transportation impact. If a project contains less than 100 percent affordable
housing, the portion that is affordable should be screened out of needing a detailed VMT analysis.
This applies to affordable for-sale and rental housing projects located anywhere in the City.
4.2.3. Local Serving Retail and Public Services
Retail projects that are locally serving are presumed to have a less than significant transportation
impact. The determination of local-serving retail would be based on its location, the characteristics
of the project and the vicinity of the site, as well as the envisioned goods and services the retail
development would provide. Generally, local-serving retail would primarily provide goods and
services that most people need on a regular basis and are purchased close to where people live.
Groceries, medicines, fast food and casual restaurants, fitness and beauty services are typical goods
and services provided by local-serving retail.
Projects proposing to screen out of a detailed VMT analysis due to being local-serving retail will
need to document how the project meets the characteristics of a neighboring retail development
based on the goods and services provided. The City may also require an economic market analysis
to demonstrate the project is local serving based on goods and services provided relative to the
geographic location, customer base, and other nearby retail uses. Final determination of whether
the retail is local serving will be made by the City of Dublin Public Works Director or designee
Public services (e.g., police, fire stations, public utilities, neighborhood parks, public schools)
generally do not increase VMT. Instead, these land uses are often built in response to development
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from other land uses (e.g., office and residential). Therefore, these land uses can be presumed to
have less than significant transportation impacts on VMT. However, this presumption would not
apply if the project is sited in a location that would require employees or visitors to travel
substantial distances and may require a detailed VMT analysis. Additionally, charter and private
schools typically draw students from a much larger geographic area than public schools and would
not screen out of a detailed VMT analysis under this criterion.
4.2.4. High-Quality Transit Area (HQTA)
HQTAs are areas located within one-half mile of an existing major transit stop6 or an existing stop
along a high-quality transit corridor.7 A project is considered to be within one-half mile of a major
transit stop or high-quality transit corridor if all parcels within the project have no more than 25
percent of their area farther than one-half mile from the stop or corridor and if not more than 10
percent of the residential units or 100 units (whichever is lower) in the project are farther than one -
half mile from the stop or corridor.
The City has two major transit stops that qualify including the West Dublin and the
Dublin/Pleasanton BART Stations. Attachment A shows the two BART stations and the one-half mile
area where projects would screen out of a detailed VMT analysis. The City may also have high
quality transit corridors, especially within Priority Development Areas, that have bus service at 15-
minute headways or less. If a project is proposing to screen out because it is along one of these
high-quality bus lines, the TIA should document the route/s and service headways to confirm
location in an HQTA.
The presumption to exempt a project from a detailed VMT analysis under this screening criterion
does not apply if the project:
Has a floor area ratio (FAR) of less than 0.75;
Includes more parking for use by residents, customers, or employees of the project than
required by the jurisdiction (if the jurisdiction requires the project to supply parking);
Is inconsistent with the applicable Metropolitan Transportation Commission’s (MTC)
Sustainable Communities Strategy (SCS), as determined by the City; or
Replaces affordable residential units with a smaller number of moderate- or high-income
residential units.
6 Per Pubic Resources Code, § 21064.3 (“‘Major transit stop’ means a site containing an existing rail transit station,
a ferry terminal served by either a bus or rail transit service, or the intersection of two or more major bus routes
with a frequency of service interval of 15 minutes or less during the morning and afternoon peak commute
periods.”).
7 Per Public Resources Code, § 21155, a high-quality transit corridor means a corridor with fixed route bus service
with service intervals no longer than 15 minutes during peak commute hours.
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4.2.5. Project Located in Low VMT Areas
Residential and employment projects that are proposed in areas that generate VMT below adopted
City thresholds are presumed to have a less than significant transportation impact and, thus, can be
screened out. Attachment B shows the location of low VMT areas in green where projects may be
screened out of a detailed VMT analysis using this criteria:
Residential projects proposed in TAZs with total daily resident based VMT per capita that is
15 percent less than the existing average baseline level for Planning Area 4.
Office or the employment portions of other non-residential uses with total daily employee
based VMT per employee that is 15 percent less than the existing average baseline level for
Planning Area 4.
This screening criterion is only applicable for projects that are substantially similar to the
surrounding land uses in the project area. If the proposed project is an office project while
surrounding land uses are light industrial for example, the project would likely have different trip
length per employee than the surrounding land uses. Therefore, the fact it is in a low VMT area for
light industrial does not mean an office project would have similarly low VMT and a detailed VMT
analysis may be needed.
4.2.6. Consistency with RTP/ SCS
If a proposed project is inconsistent with the adopted MTC Regional Transportation
Plan/Sustainable Communities Strategy (RTP/SCS), the City will evaluate whether that inconsistency
may result in a significant impact on transportation. Therefore, projects that are inconsistent with
the RTP/SCS may not qualify for screening out of a detailed VMT analysis.
4.3. DETAILED VMT ANALYSIS
Projects that do not meet the screening criteria must include a detailed evaluation of the VMT
generated by the project. The level of significance of the project on VMT will be assessed by
comparing the project VMT to the VMT thresholds established by the City.
The City has established three VMT metrics for assessing impacts. These metrics include the VMT
per capita, VMT per employee, and total VMT. The application of these metrics to development
projects includes:
VMT per capita is used to assess residential projects and includes all home-based trips made
by residents, including their trips while away from home, but does not include trips visiting
residences (such as delivery vans).
VMT per employee is used to assess projects providing employment in non-retail settings
and includes trips made by employees to and from their workplaces, including trips to and
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from points other than the employees’ homes, but does not include visitors to the
employment sites.
Total VMT is used to assess retail and other similar projects by estimating the change in the
overall VMT for the region with and without the project.
4.3.1. Efficiency Metrics (VMT per Capita and VMT per Employee)
For residential or employment land uses where VMT/capita or VMT/employee are used to
determine impacts, the following analysis methods are available:
The VMT/capita or VMT/employee may be determined using the latest screening maps
(Attachment B) and the TAZ (or TAZs) containing the project site if the project land use is
similar to surrounding land uses.
If the value for the TAZ is zero due to a lack of land use data in the existing condition for the
project TAZ, the City may allow the VMT/capita or VMT/employee to be based on an
average of surrounding TAZs if they are similar land uses to the proposed Project.
The VMT/capita or VMT/employee may also be directly calculated using data about number
of residents or employees, mode share, and average trip length.
4.3.2. Total VMT
For development projects that use total VMT to determine impacts (such as retail), total VMT may
be calculated using the travel model specified by the City or another method backed by substantial
evidence:
Smaller projects may use the total daily vehicle trip generation (determined using
references such as the most current Institute of Transportation Engineers Trip Generation
Manual) multiplied by an average trip length determined from the travel demand model or
a market research analysis.
If a proposed project would affect the balance of residential and non-residential land uses in
an area and is a relatively large project, it is recommended that the travel demand model be
rerun to include the proposed project. The total regional VMT calculated from the model
would then be compared with and without the project.
4.3.3. Exclusion of Truck VMT
SB 743 does not apply to goods movement (i.e., trucks). CEQA Guidelines Section 15064.3 states
that VMT for transportation impacts refers to “… the amount and distance of automobile travel…”.
Therefore, the VMT associated with trucks and the movement of goods is not required to be
analyzed and mitigated for the evaluation of transportation impacts under CEQA. Projects that
generate a substantial amount of truck traffic also generate automobile trips and, therefore,
project-related automobile trips would be subject to VMT analysis and mitigation. The VMT for all
vehicles including heavy trucks related to a project will still be calculated as input for air quality,
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greenhouse gas (GHG), noise and energy impact analyses to be evaluated in non-transportation
parts of the environmental analysis.
4.3.4. Thresholds of Significance
The City has established the following thresholds of significance for development projects:
• Residential Projects: A significant impact occurs if a Proposed Project VMT/capita is greater
than 15 percent below the existing Planning Area 4.
• Office Projects: A significant impact occurs if a Proposed Project VMT/employee is greater
than 15 percent below the existing Planning Area 4 average.
• Retail Projects: A significant impact occurs if a Proposed Project causes a net increase in
total VMT. The total VMT for Planning Area 4 without and with the project is calculated. The
difference between the two scenarios is the net change in total VMT that is attributable to
the project.
• Other Development Projects: The City will make a determination of the applicable
thresholds on a case-by-case basis based on the land use type, project description and
setting. Generally, these projects will be analyzed based on how similar they are to
residential, office, and retail projects.
o Student housing and senior housing land uses for example should be treated as
residential for screening and detailed VMT analysis.
o Research and development, industrial, medical offices, and hospital projects may be
evaluated as office projects using the VMT/employee metric.
o Projects such as hotels, private schools, religious institutions, and regional parks, should
be treated as retail for detailed VMT analysis.
• Mixed-Use Projects: Evaluate each component of a mixed-use project independently and
apply the significance threshold for each land use type. Alternatively, the evaluation would
apply only to the project’s dominant use if it generates 80 percent of the total daily trips.
Since VMT threshold values may change over time as updated traffic models or new ABAG land uses are
adopted, verify with the City the most current thresholds for each land use type prior to performing an
analysis.
4.3.5. Redevelopment Projects
If a project replaces existing uses and the project results in similar or a net decrease in overall VMT,
it may be presumed that the project would result in a less than significant impact.
If a project replaces existing uses and the project leads to a net overall increase in VMT compared
to the previous uses, then the thresholds for the new land uses should apply. For example, if a
residential project replaces an office project resulting in a net increase in VMT, the project’s
VMT/capita should be compared with the thresholds for residential projects. If the project is a
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mixed-use project, then the recommended approach for analyzing mixed-use projects should be
applied to analyze each individual use.
4.3.6. Land Use Plans
For land use plans such as specific plans, community plans, and general plan updates, the City
requires comparing the applicable VMT thresholds (such as VMT per capita and/or VMT per
employee) under existing conditions with the applicable VMT metrics for the expected horizon year
for the land use plan. If there is a net increase in the applicable VMT metrics under horizon year
conditions, then there may be a potentially significant impact. The VMT calculations should be
conducted for the plan area (in the case of the General Plan, all trips originating or ending in the
City) using the most current travel demand model (Alameda Countywide or City of Dublin).
4.3.7. Cumulative Impacts
Per CEQA Guidelines Section 15064(h)(1), “when assessing whether a cumulative effect requires an
EIR, the lead agency shall consider whether the cumulative impact is significant and whether the
effects of the project are cumulatively considerable.”
An analysis of cumulative impacts generally would fall under two categories:
1. VMT per capita or per employee
2. Total VMT
These are described below.
4.3.7.1. VMT per Capita or per Employee
For land uses evaluated under an efficiency metric (VMT/capita or VMT/employee), a project falling
below the threshold under existing conditions would also result in less than significant cumulative
impacts. In other words, a project that falls below an efficiency-based threshold would have no
cumulative impact distinct from the project impact.
4.3.7.2. Total VMT
For land uses evaluated using total VMT (retail, hotels, etc.), a cumulative VMT analysis should be
assessed to ensure that future travel and VMT patterns are taken into account. A cumulative impact
for total VMT would occur if the project causes the total VMT in the region to increase similar to the
existing conditions analysis.
4.4. MITIGATION
If a project would result in significant impacts, CEQA requires mitigation measures to be
implemented to reduce or mitigate an impact. For VMT impacts, a combination of measures from
several VMT reduction strategies may be implemented – project characteristics, multimodal
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improvements, parking, and transportation demand management (TDM). VMT is reduced by
implementing strategies that reduce the number of automobile trips generated by the project, shift
more trips from automobile to non-automobile modes, and/or reduce the distances that people
drive. Generally, these reductions can be achieved by the implementation of TDM strategies.
Measures to reduce VMT have been documented by several sources such as the California Air
Resources Board (CARB) list of transportation and land use strategies for reducing GHG emissions,
the SB 743 Implementation Project resources, the California Pollution Control Offices Association
(CAPCOA) report on quantifying the greenhouse gas mitigation measures, more recent research for
the West Riverside Council of Governments (WRCOG), and the SANDAG Mobility Management VMT
Reduction Calculator Tool – Design Document. Alameda County also has a VMT Reduction
Calculator for use in all cities in Alameda County including Dublin.
Projects for which impacts are determined to be significant are required develop a TDM plan to
propose a list of VMT reduction measures and document the associated percent reduction in VMT.
Project VMT with the proposed reduction is then compared to the threshold of significance to
evaluate the project’s transportation impact. The City will review and approve the proposed
mitigation and the calculated VMT percentage reductions. A mitigation monitoring program may be
required by the City to ensure the TDM plan is able to meet the required VMT reduction.
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4.5. TRANSPORTATION PROJECTS
This section provides information for analyzing transportation projects on roads within the City’s
jurisdiction.
4.5.1. Determining Need for Detailed VMT Analysis
The City of Dublin requires an analysis of transportation projects if they are expected to increase
VMT, primarily projects that encourage the use of single occupancy automobile such as the addition
of through travel lanes. However, transportation projects that have already been specifically
analyzed in a citywide plan (such as a General Plan) may be exempt from a detailed VMT analysis.
This exemption may be granted if the necessary VMT analysis and potential mitigations would have
already been calculated and identified at the plan level.
Conversely, projects that would likely not lead to an increase in vehicle travel, which promote use
of transit and active transportation should not require a VMT analysis. Project types that would not
likely lead to a substantial or measurable increase in vehicle travel and generally should not require
a VMT analysis include:
Road rehabilitation
Safety projects
Auxiliary lanes less than one mile in length
Turning lanes
Conversion to managed or transit lanes
Road diets
Removal or relocation or parking spaces
Addition of non-motorized, transit, and active transportation facilities.
These projects generally do not increase capacity enough to result in an impact to VMT. A full list is
provided in Attachment C.
This approach is consistent with the intent of SB 743 by promoting that VMT-reducing projects will
be streamlined and projects that have the potential to increase VMT will be thoroughly assessed
and mitigated as appropriate.
4.5.2. VMT Analysis for General Plan or RTP/SCS Projects
For transportation projects that have not been included in the General Plan or RTP/SCS or are
modifications and replacements, any growth in VMT attributable to the transportation project
would result in a significant impact. For example, a transportation project that replaces a project
included in the General Plan and would generate less VMT compared to the project included in the
General Plan would have a less than significant impact. Projects not included in the General Plan or
RTP/SCS would have a significant impact if they cause a net increase in VMT.
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4.5.3. VMT Analysis Methodology and Tools
Projects that have already been included and evaluated in the General Plan or the RTP/SCS would
have a less than significant impact.
For transportation projects that require a detailed VMT analysis (e.g., increasing vehicular
throughput or not included in a citywide plan), the City requires analysis using the most current
travel demand model to estimate changes to citywide VMT due to rerouted trips. To capture long -
term effects, an induced demand assessment is required using the following formula:
[% increase in lane miles] x [existing VMT] x [elasticity] = [VMT resulting from the project]
A National Center for Sustainable Transportation8 tool can be used to determine the elasticity.
The City requires total VMT in the City as the appropriate VMT metric, with the impact threshold
being any increase in total VMT. The analysis should be performed for the long-range horizon year,
normally 20 years out. This approach would discourage induced demand impacts by requiring that a
baseline level of VMT in the City not be exceeded.
4.5.4. Mitigation for Transportation Projects
Mitigation measures for transportation projects generally seek to reduce VMT by discouraging more
single passenger automobile travel or funding TDM measures. Potential mitigation measures for
transportation projects may include implementing or funding off-site travel demand management
programs to incentivize carpooling or implementing Intelligent Transportation Systems (ITS)
strategies that improve passenger throughput rather than vehicle throughput on existing lanes.
8 https://ncst.ucdavis.edu/research/tools
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Attachment A: High Quality Transit Area Map
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Attachment B: VMT Screening Maps
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E P
WDONOHUEDRSAN RAMON RDSIERRA CTFALLON RDTASSAJARA RDNORTHSIDE DRAMADOR VALLEY BLSCHAEFER RANCH RDCOLLIER CANYON RD
8TH STCROMWELLAV BARNET BLCROAK RDRANGERD
FCI
CREEKSIDEDR
HORIZON PW
SCARLETT CT
PERSIM
MONDRALLEY6TH ST
7TH ST SEBILLERDSCARLETT DR PALISA D E S DR
1 2 T H S T
TOWER RD SYRAHDRHILLROSE
D
R
INSPIR ATIONCI ALBROOKDREAGLERDBRODER BL
INSPIRATIONDRCREEKVIEWDRHI
L
LTOPRDDUBLIN BLSTERLING RDCivic Plaza
EmeraldGlen Park
Dougherty HillsOpen Space
FallonSportsPark
Pleasanton Livermore
AlamedaCounty
San Ramon
ContraCostaCounty
H:\22\22865 - Dublin Transp Planning Eng On-Call 2018\004 - SB 743 Implementation\gis\Fig8_VMT Per Capita TAZ_PA4.mxd Date: 10/15/2020Legend
No VMT Generated
<25.9 - Below Target VMT (Planning Area 4 Average - 15%)
25.9 - 30.5 - Target VMT (Planning Area - 15%) to Planning Area 4 Average
>30.5 - Above Planning Area 4 Average
Priority Development Area (PDA)
Dublin City Limits
Figure 8
Residential VMT (VMT per Capita)Dublin, California
[0 1 Mile
128
§¨¦680
§¨¦580
B R I GHTONDR
V
O
MACRDS
T
AGECOACHRDM A D D E N W Y
TA
MARACKDRDA
V
ONAD R
SILVERGATEDRBAN
D
O
N
D
R
SIERR A LNH
A
N
S
E
NDRARNOLD RDCENTRAL PW
GLEASON DR
LOCKHARTSTYORK DRKEEGANSTN DUBLIN RANC
HDRD U B L I N B L DOUGHERTY RDPOSITANOPWVILLA
G
E P
WDONOHUEDRSAN RAMON RDSIERRA CTFALLON RDTASSAJARA RDNORTHSIDEDRAMADOR VALLEY BLSCHAEFER RANCH RDCOLLIER CANYON RD
8TH STCROMWELLAV BARNET BLCROAK RDRANGERD
FCI
CREEKSIDEDR
HORIZON PW
SCARLETT C T
PERSIM
MONDRALLEY6TH ST
7TH ST SEBILLERDSCARLETT DR PALISA D E S DR
1 2 T H S T
TOWER RD SYRAHDRHILLROSE
D
R
INSPIR ATIONCI ALBROOKDREAGLERDBRODER BL
INSPIRATIONDRCREEKVIEWDRHI
L
LTOPRDDUBLIN BLSTERLING RDCivic Plaza
EmeraldGlen Park
Dougherty HillsOpen Space
FallonSportsPark
Pleasanton Livermore
AlamedaCounty
San Ramon
ContraCostaCounty
H:\22\22865 - Dublin Transp Planning Eng On-Call 2018\004 - SB 743 Implementation\gis\Fig9_VMT Per Employee TAZ_PA4.mxd Date: 10/15/2020Legend
No VMT Generated
<12.9 - Below Target VMT (Planning Area 4 Average - 15%)
12.9 - 15.2 - Target VMT (Planning Area 4 - 15% to Planning Area 4 Average)
> 15.2 - Above Planning Area 4 Average
Priority Development Area (PDA)
Dublin City Limits
Figure 9
Employment VMT (VMT per Employee)Dublin, California
[0 1 Mile
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28 | P a g e
Attachment C: Transportation Projects That Generally Do Not
Increase VMT
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Transportation Projects Generally Not Requiring Induced Travel Analysis 9
Projects that would not likely lead to a substantial or measurable increase in vehicle travel, and therefore
generally should not require an induced travel analysis, include:
• Rehabilitation, maintenance, replacement, safety, and repair projects designed to improve the
condition of existing transportation assets (e.g., highways; roadways; bridges; culverts;
Transportation Management System field elements such as cameras, message signs, detection, or
signals; tunnels; transit systems; and assets that serve bicycle and pedestrian facilities) and that do
not add additional motor vehicle capacity
• Roadside safety devices or hardware installation such as median barriers and guardrails
• Roadway shoulder enhancements to provide “breakdown space,” dedicated space for use only by
transit vehicles, to provide bicycle access, or to otherwise improve safety, but which will not be used
as automobile vehicle travel lanes
• Addition of an auxiliary lane of less than one mile in length designed to improve roadway safety
• Installation, removal, or reconfiguration of traffic lanes that are not for through traffic, such as left,
right, and U-turn pockets, two-way left turn lanes, or emergency breakdown lanes that are not
utilized as through lanes
• Addition of roadway capacity on local or collector streets provided the project also substantially
improves conditions for pedestrians, cyclists, and, if applicable, transit
• Conversion of existing general purpose lanes (including ramps) to managed lanes or transit lanes, or
changing lane management in a manner that would not substantially increase vehicle travel
• Addition of a new lane that is permanently restricted to use only by transit vehicles
• Reduction in number of through lanes
• Grade separation to separate vehicles from rail, transit, pedestrians or bicycles, or to replace a lane
in order to separate preferential vehicles (e.g., HOV, HOT, or trucks) from general vehicles
• Installation, removal, or reconfiguration of traffic control devices, including Transit Signal Priority
(TSP) features
• Installation of traffic metering systems, detection systems, cameras, changeable message signs and
other electronics designed to optimize vehicle, bicycle, or pedestrian flow
• Timing of signals to optimize vehicle, bicycle, or pedestrian flow
• Installation of roundabouts or traffic circles
• Installation or reconfiguration of traffic calming devices
• Adoption of or increase in tolls
• Addition of tolled lanes, where tolls are sufficient to mitigate VMT increase
9 California Office of Planning and Research, Technical Advisory on Evaluating Transportation Impacts in CEQA,
December 2018.
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• Initiation of new transit service
• Conversion of streets from one-way to two-way operation with no net increase in number of traffic
lanes
• Removal or relocation of off-street or on-street parking spaces
• Adoption or modification of on-street parking or loading restrictions (including meters, time limits,
accessible spaces, and preferential/reserved parking permit programs)
• Addition of traffic wayfinding signage
• Rehabilitation and maintenance projects that do not add motor vehicle capacity
• Addition of new or enhanced bike or pedestrian facilities on existing streets/highways or within
existing public rights-of-way
• Addition of Class I bike paths, trails, multi-use paths, or other off-road facilities that serve non-
motorized travel
• Installation of publicly available alternative fuel/charging infrastructure
• Addition of passing lanes, truck climbing lanes, or truck brake-check lanes in rural areas that do not
increase overall vehicle capacity along the corridor
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Attachment D: Minimum Contents of a Transportation Impact
Analysis Report
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Page | 32
MINIMUM CONTENTS OF TRAFFIC IMPACT STUDY REPORT
I. EXECUTIVE SUMMARY
II. TABLE OF CONTENTS
A. List of Figures
B. List of Tables
III. PROJECT SUMMARY
A. Description of the proposed project
B. Study Area Description
C. Site plan including all access points to streets (site plan, map)
D. Vicinity map showing all modes of transportation in the study area
E. Land use and zoning
F. Phasing plan including proposed dates of project (phase) completion
G. Project sponsor and contact person(s)
IV. LOCAL TRANSPORTATION ANALYSIS
A. Trip Generation and Distribution
B. Operations Analysis10
• Existing Conditions
• Opening Year Conditions With/Without Project
• Cumulative Conditions With/Without Project
• 95th Percentile Queues for All Scenarios With/Without Project
C. Site Plan Review
V. CEQA ANALYSIS
A. Consistency with Adopted Plans
B. VMT Analysis11
• VMT Screening
• Detailed VMT Analysis
C. Proposed Mitigations (if applicable)
10 An operations analysis is only required for projects generating more than 50 peak hour vehicle trips.
11 Projects that screen out of a detailed VMT analysis only need to present documentation of screening out. Otherwise,
this section should include an overview of the methodology and findings of a detailed VMT analysis.
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Page | 33
VI. CONCLUSIONS AND RECOMMENDATIONS
VII. APPENDICES
A. Collected Multimodal Counts
B. Worksheets Used in Analysis (i.e., signal warrant, LOS data and analysis
sheets, etc.)
C. Provide electronic analysis files (Synchro, Vistro, etc.) to the City.
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Attachment E: Site Plan Review Checklist
136
Page | 35
SITE PLAN REVIEW CHECKLIST
Parking
Verify vehicle parking supply meets municipal code requirements. (8.76.080)
Compact car space substitution does not exceed threshold (8.76.050.A)
Motorcycle space substitution does not exceed threshold (8.76.050.B)
Parking aisles meets or exceeds minimums (8.76.070.A.7)
Parking stall width and depth meets or exceeds minimums (8.76.070.A.7)
Project provides sufficient disabled accessible parking in the correct location (8.76.070.A.8)
Project provides sufficient loading spaces (8.76.090) and when provided, meet the standards
(8.76.070.B)
Bicycle parking confirms with California Green Building Standards Code (8.76.070.A.2)
Vehicle Circulation
Project driveways meet minimum width requirements (8.76.070.A.11)
Project driveways provide adequate sight distance for vehicles exiting.
Site plan has eliminated vehicle/vehicle conflict points or has proposed adequate measures to
reduce the conflicts.
Turn templates have been created showing site access and circulation for the largest of either
emergency, service, or delivery trucks.
Pedestrian and Bicycle Circulation
Site plan provides a clear path of travel between project building/s, parking areas, and public
street sidewalks.
Site plan has eliminated vehicle/pedestrian and vehicle/bicycle conflict points or has proposed
adequate measures to reduce the conflicts.
On site sidewalks provide sufficient width such that vehicle overhang does not reduce the
unencumbered width to less than four feet (8.76.070.A.7a).
137