The California Environmental Quality Act (CEQA) requires public agencies to evaluate the environmental effects of a project before an action is taken. CEQA also aims to prevent significant environmental effects from occurring as a result of agency actions by requiring agencies to avoid or reduce, when feasible, the significant environmental impacts of their decisions.
On September 27, 2013, Senate Bill No. 743 (SB 743) declared that new methodologies were needed for evaluating transportation impacts to promote the State’s goals of reducing greenhouse gas emissions and traffic-related air pollution, promoting the development of a multimodal transportation system, and providing clean, efficient access to destinations. As a result, SB 743 directed the Office of Planning and Research (OPR) to develop proposed revisions to the CEQA Guidelines that established criteria for determining the significance of transportation impacts, developed metrics to measure transportation impacts, and established criteria for models used to analyze transportation impacts. Finally, SB 743 declared that upon certification of the CEQA Guidelines by the Secretary of the Natural Resources Agency, automobile delay shall not be considered a significant impact on the environment under CEQA.
In December of 2018, the OPR released the “Technical Advisory on Evaluating Transportation Impacts in CEQA” that found that in order to achieve the State’s long-term climate goals relating to the reduction of greenhouse gas (GHG) emissions, California needed to reduce per capita VMT, and recommended that this could occur under CEQA through VMT mitigation. The OPR technical advisory contained technical recommendations that ultimately noted that lead agencies have the discretion to develop and adopt their own thresholds or rely on the thresholds recommended by other agencies provided that the decision of the lead agency is supported by substantial evidence. On December 28, 2018, the Natural Resources Agency modified the CEQA Guidelines, declaring that vehicle miles traveled is the most appropriate measure of transportation impacts, that a project’s effect on automobile delay shall not constitute a significant environmental impact under CEQA, and that this legislation applied statewide starting July 1, 2020.
In anticipation of the updates to the CEQA Guidelines regarding transportation impacts, the City of Brea joined the cities of Fullerton, La Habra, Buena Park, Orange, Placentia, and Yorba Linda in a study lead by Fehr & Peers, a transportation consulting firm, that analyzed the methodology, thresholds, and mitigation approaches associated with the implementation of VMT impact analysis for each of the seven North Orange County Cities (NOCC). Following this study, City staff continued to work with Fehr & Peers to develop the local, City of Brea VMT thresholds for CEQA compliance regarding transportation analysis.
VMT thresholds that are to be applied to determine potential VMT impacts are as provided below:
- A project would result in a significant project generated VMT impact if the baseline, or cumulative, project-generated VMT per service population exceeds the City of Brea General Plan Buildout VMT per service population.
- A project’s effect on VMT would be considered significant if it resulted in the baseline, or cumulative, link-level boundary Citywide VMT per service population increase under the plus project condition compared to the no project condition.
Note that the cumulative no project condition shall reflect the adopted Regional Transportation Plan/Sustainable Community Strategy (RTP/SCS); as such, if a project is consistent with the Southern California Association of Governments (SCAG) RTP/SCS, then the cumulative impacts (project effect on VMT) shall be considered less than significant subject to the consideration of other substantial evidence.
On July 1, 2020, the updates to the CEQA Guidelines were applied statewide. All projects that had not circulated CEQA documents prior to this date have been, or will be, required to prepare a VMT Analysis as part of the CEQA environmental review process.
As a result of the updates to the CEQA Guidelines, Level of Service (LOS) no longer constitutes a significant environmental effect under CEQA. As such, Vehicle Miles Traveled thresholds for the City of Brea have been developed to meet CEQA Guideline requirements. Adopting VMT thresholds however, does not preclude the City from using LOS analysis to be consistent with the City General Plan requirements in setting operational goals which are to be attained and maintained as the City grows and develops.
In addition to developing the VMT thresholds, City staff is working to develop local, City of Brea Transportation Impact Assessment (TIA) Guidelines. These guidelines will serve to provide direction on VMT thresholds and the preparation of a Transportation Impact Analysis, that uses VMT Analysis as the method of impact analysis per CEQA Guidelines, and the preparation of Traffic Assessments, that use LOS Analysis to measure vehicle delay and traffic congestion for consistency with the guidance provided in the City General Plan. The City of Brea TIA Guidelines will become effective upon completion and will be adjusted on occasion administratively to align with current best practices and court decisions regarding VMT thresholds, Transportation Impact Analysis utilizing VMT Analysis, and Traffic Assessments utilizing LOS Analysis.
Additional Information:
At the September 15, 2020, City Council Meeting, City Council asked staff to provide clarification on which projects had been, or will be, impacted based on the updates to the CEQA Guidelines regarding VMT becoming effective as of July 1, 2020. In short, current development projects that have been, or will be, impacted by the updated CEQA Guidelines include the Brea 265, Brea Plaza, and Brea Mall Expansion developments. All projects that had not circulated CEQA documents prior to this date have been, or will be, required to prepare a VMT Analysis as part of the CEQA environmental review process. |