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City of San Leandro Proposed Guidelines for Analyzing VMT <br />December 8, 2023 <br />Page 2 of 12 <br />transportation impacts under CEQA. Mitigations of LOS impacts compelled communities to widen <br />roads and incentivized spread out land use patterns resulting over time in more driving, <br />congestion, and pollution. <br />Senate Bill 743 (Steinberg, 2013), codified in Public Resources Code section 21099, requires lead <br />agencies to replace LOS to better align transportation impact criteria with State environmental, <br />economic, and public health goals. The criteria for determining the significance of transportation <br />impacts and setting new thresholds must “promote the reduction of greenhouse gas emissions, <br />the development of multimodal transportation networks, and a diversity of land uses.” <br />The Governor’s Office of Planning and Research (OPR) supports the implementation of SB 743 by <br />providing resources including the Technical Advisory on Evaluating Transportation Impacts in <br />CEQA (2018). OPR recommends that jurisdictions replace LOS with VMT based metrics and <br />provides guidance on how to accomplish this. This shift better aligns transportation impact <br />analysis and mitigation outcomes to reduce greenhouse gas emissions, encourage infill <br />development, and improve public health. Jurisdictions in California are now required to use VMT <br />based metrics to evaluate environmental impacts related to transportation. Jurisdictions may still <br />use LOS within the local development review process to inform site access and traffic operations <br />decisions, but LOS cannot be used to evaluate CEQA impacts or mitigations. Thus, the City of San <br />Leandro intends to continue to use LOS analysis for some purposes, such as evaluating the need <br />for adding or modifying traffic signals, or modifying lane configuration at intersections. Section 6 <br />of this memorandum addresses when a project may require the preparation of a Local <br />Transportation Impact Analysis (LTIA), which would include LOS analysis. <br />VMT measures the amount of driving produced by a project and provides a measure of travel <br />efficiency of a land use project. For most types of projects, VMT-based analysis offers a <br />streamlined analysis that saves jurisdiction staff time and provides clarity for the public and land <br />developers. The shift to VMT policies is intended to help achieve climate commitments, preserve <br />the environment, improve health and safety, create sustainable communities, encourage more <br />efficient use of the transportation network, and provide more travel choices for each jurisdiction, <br />as well as for the region and state. <br />VMT can be measured in several ways. For the purposes of VMT analysis in San Leandro, the City <br />proposes to use the metrics of home-based VMT per resident for residential uses, and home-work <br />VMT per worker for employment-generating uses. Both metrics are “efficiency” metrics, in which <br />the level of VMT is expressed in “per person” terms. This form of the metric speaks to how <br />efficiently the people at a given location travel. A project that contributes to a more efficient use <br />of the transportation system would reduce the VMT per person as compared to a no-project <br />scenario. Some amount of overall VMT growth is always expected to occur when there is overall <br />growth in population and economic activity; many development projects will cause an increase in <br />total VMT, but the VMT per person can decrease if the new residents and/or workers travel in