Agenda Item Wording:
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Adopt Resolution for Updated VMT Thresholds - Request to adopt by Resolution No. 2025-04 an update to Vehicles Miles Traveled Thresholds and Implementation Guidelines pursuant to Senate Bill 743 and the California Environmental Quality Act.
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Deadline for Action: None
Submitting Department: Community Development - Engineering
Contact Name and Phone Number:
Leslie Blair, Senior Civil Engineer, leslie.blair@visalia.city <mailto:leslie.blair@visalia.city> (559) 713-4633
Brandon Smith, Principal Planner, brandon.smith@visalia.city <mailto:Brandon.smith@visalia.city> (559) 713-4636
Chris Crawford, City Engineer, chris.crawford@visalia.city <mailto:chris.crawford@visalia.city> (559) 713-4331
Jason Huckleberry, Engineering and Building Director, jason.huckleberry@visalia.city <mailto:jason.huckleberry@visalia.city> (559) 713-4495
Department Recommendation:
Staff recommends that the City Council adopt Resolution No. 2025-04 approving the update to the numerical thresholds for Vehicle Miles Traveled (VMT) metrics, screening maps, and guidelines, based on the latest edition of Tulare County Association of Government’s (TCAG’s) travel demand model, as contained in the City of Visalia Vehicle Miles Traveled Thresholds and Implementation Guidelines document for purposes of analyzing transportation impacts under Senate Bill 743 and the California Environmental Quality Act.
Background Discussion:
The City adopted in March 2021 the City of Visalia VMT Thresholds and Implementation Guidelines (Guidelines). The purpose was for the City to establish its own VMT policy that was specific to Visalia’s unique needs, and better equip the City to evaluate transportation impacts under CEQA in compliance with SB 743 which mandated a change in the way transportation impacts were evaluated under the California Environmental Quality Act (CEQA). Adoption of VMT into the CEQA process did not eliminate level of service (LOS) analysis since that tool is still a necessary metric for evaluating traffic operations and determining infrastructure needs. Furthermore, the VMT requirement does not preclude the requirement of a traffic impact analysis for developments within the City of Visalia.
Since the adoption of the guidelines, the Tulare County Association of Governments (TCAG) performed an update of its travel demand model. The TCAG travel demand model is the regional travel model which formed the technical basis and provided the substantial evidence for the development of the 2021 City of Visalia’s Guidelines. TCAG’s update of the travel model was conducted for the County’s 2022 Regional Transportation Plan (2022 RTP) update. Moving forward, the updated travel model will be used for transportation analyses of projects.
Consequently, given the update of the regional model and new data, and that the established numerical thresholds for the City’s VMT metrics may change, LSA Associates, Inc. of Riverside, CA, a planning consultant, was hired to perform a corresponding update to the VMT Guidelines for the City of Visalia. LSA, using the updated TCAG 2022 RTP travel model and new data, performed an update to the numerical thresholds for VMT per capita, VMT per employee and VMT per service population metrics, and performed an update to the screening maps for the different VMT metrics in both the guidelines document and the GIS online screening tool.
The 2024 update to the City of Visalia VMT Thresholds and Implementation Guidelines, attached in Exhibit A, is the resulting product and complies with CEQA requirements and closely follows recommendations from the Office of Planning and Research (OPR) Technical Advisory (TA) on Evaluating Transportation Impacts in CEQA, December 2018. The 2024 update has no significant impact and includes no change to the VMT thresholds of significance previously adopted. The update includes only changes to the numerical thresholds for VMT per capita, VMT per employee, and VMT per service population metrics, and the consequent update to the screening maps for the different VMT metrics in both the guidelines document and the GIS online screening tool.
Resolution’s Authorization to Address Reoccurring Update Cycles
An update to the Regional Transportation Plan (RTP) is performed every four years. Consequently, given the four-year update cycle of the regional model and that this data may change every four years when the RTPlan is required to be updated, a review and potential update to the numerical thresholds for VMT metrics, VMT screening maps, and corresponding updates to the guidelines will need to be performed every four years.
Adoption of Resolution 2025-04 therefore also authorizes City staff to conduct subsequent future updates to the numerical thresholds for VMT metrics, screening maps, and amend the City of Visalia VMT Guidelines document based on the latest version of the regional travel demand model and data, without any further adoption of City Council resolutions.
History of Senate Bill 743 and Adoption of City Thresholds
Senate Bill 743, passed by the Legislature and signed into law in 2013, mandated a change in the way transportation impacts were evaluated under CEQA, effective July 1, 2020. The intent of the law was to support the state’s climate and environmental goals in meeting Greenhouse Gas (GHG) reduction targets established by the State of California. Prior to this date, CEQA transportation impacts were evaluated solely by LOS which measures traffic delay and congestion. The metric of VMT is simply the number of trips generated by a project multiplied by the trip distances in miles.
In December 2018, the OPR released a Technical Advisory (TA) providing guidance and technical recommendations regarding the assessment of VMT, thresholds of significance, and mitigations measures. Since the TA serves as a reference document and does not have the weight of law, this guidance was a starting point, and local agencies were given the opportunity to set different thresholds if supported by substantial evidence. As the City of Visalia is rural in nature compared to the larger metropolitan areas of the state such as Southern California and the Bay Area, it was determined to be in the City’s best interest to adopt its own VMT policy tailored to reflect Visalia’s own unique values and local characteristics.
In August 2020, the City of Visalia elected to proceed with formally establishing its own thresholds of significance and hired LSA Associates, Inc. to help develop a VMT policy for the City of Visalia. On March 15, 2021, City Council adopted by Resolution 2021-08 the thresholds of significance, screening criteria and guidelines as contained in the City of Visalia Vehicle Miles Traveled Thresholds and Implementation Guidelines document. The Guidelines contain a detailed description of the City of Visalia significance thresholds and the substantial evidence to support them, screening criteria, as well as a list of potential mitigation measures. This document serves as a detailed guideline for preparing VMT analyses consistent with SB 743 requirements for development projects, transportation projects, and plans. Project applicants are required to follow the guidance provided in this document for preparations of a VMT analysis.
Fiscal Impact:
No fiscal impact to City finances would occur as a result of adopting the update to the Guidelines.
Prior Council Action:
March 15, 2021: Adopted Resolution 2021-08 approving the thresholds of significance, screening criteria, and guidelines as contained in the City of Visalia Vehicles Miles Traveled Thresholds and Implementation Guidelines pursuant to SB 743 and the California Environmental Quality Act.
August 3, 2020: Authorized the City Manager to award the contract for RFP 19-20-55 to LSA Associates, Inc. of Riverside CA in the amount of $89,935.00 (Project number 2410-72000/CP0293).
Other:
None
Alternatives:
1) Not adopt Resolution 2025-04 nor approve the update to the numerical thresholds for VMT metrics, VMT screening maps, and corresponding updates to the Guidelines, and continue to utilize the current Guidelines with outdated TCAG travel demand model data. This alternative may not be defendable under CEQA.
2) Approve the update to the numerical thresholds for VMT metrics, VMT screening maps, and corresponding update to the Guidelines, without adopting Resolution 2025-04. This would mean that every four years when the TCAG travel demand model is updated will require Council approval of corresponding updates to the Guidelines.
Recommended Motion (and Alternative Motions if expected):
recommendation
Recommended Motion - I move to adopt Resolution 2025-04 and approve updates to the City of Visalia Vehicle Miles Traveled Thresholds and Implementation Guidelines pursuant to SB 743 and the California Environmental Quality Act.
Alternative Motion - I move to approve the update to the City of Visalia Vehicle Miles Traveled Thresholds and Implementation Guidelines pursuant to SB 743 and the California Environmental Quality Act.
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Environmental Assessment Status:
None
CEQA Review:
The City Planner has determined that adoption of updates to the numerical thresholds for VMT metrics, screening maps, and guidelines, based on the latest edition of Tulare County Association of Governments travel demand model, as contained in the City of Visalia Vehicle Miles Traveled Thresholds and Implementation Guidelines, is not a project under Guidelines Section 15378(b)(5) because the City is complying with the requirements of CEQA Guidelines Section 15064.7(b), and therefore no CEQA review is required.
Attachments:
VMT Threshold and Implementation Guidelines
Resolution 2025-04