HomeMy WebLinkAboutAppendix D1 - Vehicle Miles Traveled Screening Analysis
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April 14, 2021
Mr. John Condas
Allen Matkins
1900 Main Street
Irvine, CA 92614
SUBJECT: UPDATED WEST VALLEY LOGISTICS CENTER VEHICLE MILES TRAVELED (VMT) SCREENING
ANALYSIS
Dear Mr. John Condas:
The following Vehicle Miles Traveled (VMT) Screening Analysis has been prepared for the West Valley
Logistics Center (Project), which is located south of Jurupa Avenue, west of Locust Avenue, and bisected
by Armstrong Road, in the City of Fontana. IDI has requested us to prepare this analysis, even though
the Project may not need to have a VMT analysis prepared, because the Project EIR was certified before
VMT analyses were required to be prepared. A Local & Regional Monitor v. City of Los Angeles (1993)
12 Cal.App.4th 1773, 1801. Also, because at the time the EIR was certified, VMT impacts were known
or should have been known, adoption of the requirement to analyze VMT does not constitute
significant new information, requiring preparation of a subsequent or supplemental EIR. Concerned
Dublin Citizens v. City of Dublin (2013) 214 Cal.App.4th 1301, 1320.
PROJECT OVERVIEW
The Project is proposed to consist of the development of 3,473,690 square feet (sf) of High‐Cube
Fulfillment Center (Non‐Sort) Warehouse use. Trips generated by the Project’s proposed land uses have
been estimated based on trip generation rates collected by the Institute of Transportation Engineers
(ITE) Trip Generation Manual, 10th Edition, 2017. [1] The proposed Project is anticipated to generate a
total of 6,292 vehicle trip‐ends per day (in actual vehicles) (See Attachment A). The site is currently
designated as Public Facilities and Light Industrial in the City’s General Plan, which does allow for the
proposed industrial use.
BACKGROUND
To aid in the transition of lead agencies to adopt VMT as a replacement for automobile delay‐based
level of service (LOS), the Governor’s Office of Planning and Research (OPR) released a Technical
Advisory on Evaluating Transportation Impacts in CEQA (December of 2018) (Technical Advisory). [2]
Using the Technical Advisory as a reference document, the City of Fontana adopted the Traffic Impact
Analysis (TIA) Guidelines for Vehicle Miles Traveled (VMT) and Level of Service Assessment (City
Guidelines). [3] These guidelines have been used to conduct this analysis.
Mr. John Condas
Allen Matkins
April 14, 2021
Page 2 of 5
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It is our understanding that the City of Fontana utilizes the San Bernardino County Transportation
Authority (SBCTA) VMT Screening Tool (Screening Tool). The Screening Tool allows users to input an
assessor’s parcel number (APN) to determine if a project’s location meets one or more of the screening
thresholds for land use projects identified in the Technical Advisory. The focus of this memorandum is
to more thoroughly evaluate each of the applicable screening thresholds to determine if the proposed
Project would be expected to cause a less‐than‐significant impact to VMT without requiring a more
detailed VMT analysis.
PROJECT SCREENING
The City Guidelines provides details on appropriate “screening thresholds” that can be used to identify
when a proposed land use project is anticipated to result in a less‐than‐significant impact without
conducting a more detailed analysis. Screening thresholds are broken into the following three types:
• Transit Priority Area (TPA) Screening
• Low VMT Area Screening
• Low Project Type Screening
A land use project need only to meet one of the above screening thresholds to result in a less‐than‐
significant impact.
TPA SCREENING
Consistent with guidance identified in the Technical Advisory, City Guidelines note that projects located
within a Transit Priority Area (TPA) (i.e., within ½ mile of an existing “major transit stop”1 or an existing
stop along a “high‐quality transit corridor”2) may be presumed to have a less than significant impact
absent substantial evidence to the contrary. However, the presumption may not be appropriate if a
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 Sustainable Communities Strategy (as determined by the lead
agency, with input from the Metropolitan Planning Organization); or
• Replaces affordable residential units with a smaller number of moderate‐ or high‐income
residential units.
Based on the Screening Tool results presented in Attachment A, the Project site is not located within ½
mile of an existing major transit stop, or along a high‐quality transit corridor.
Mr. John Condas
Allen Matkins
April 14, 2021
Page 3 of 5
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The TPA screening threshold is not met.
LOW VMT AREA SCREENING
As noted in the City Guidelines, “residential and office projects located within a low VMT‐ generating
area may be presumed to have a less than significant impact absent substantial evidence to the contrary.
In addition, other employment‐related and mixed‐use land use projects may qualify for the use of
screening if the project can reasonably be expected to generate VMT per resident, per worker, or per
service population that is similar to the existing land uses in the low VMT area.” [3]
The Screening Tool uses the sub‐regional San Bernardino Transportation Analysis Model (SBTAM) to
measure VMT performance within individual traffic analysis zones (TAZ’s) within the region. The Project’s
physical location is selected in the Screening Tool to determine project generated VMT. The Project is
located in TAZs 53753101 and 53733401. The parcels containing the proposed Project was selected and
the Screening Tool was run for Origin‐Destination (OD) Total VMT per Service Population measure of
VMT.
The SBCTA Screening Results are provided in Attachment B. Based on the OD VMT per Service Population
Screening Tool results, it would appear that the Project is partially located in a low VMT area. The Project
TAZ 53733401 is not located in a low VMT area and the Project TAZ 53753101 is located in a low VMT
area. After further review of the socioeconomic data in Project TAZs, the baseline model land uses are
not consistent with the proposed Project. As such, the low VMT areas cannot be applied to this VMT
analysis.
The Low VMT Area screening threshold is not met.
LOW PROJECT TYPE SCREENING
The City Guidelines identifies that local serving retail projects less than 50,000 square feet may be
presumed to have a less than significant impact absent substantial evidence to the contrary. In addition
to local serving retail, other types of local serving uses (e.g., day care centers, non‐destination hotels,
affordable housing, places of worship, etc.) may also be presumed to have a less than significant impact
as their uses are local serving in nature and would tend to shorten vehicle trips.
The proposed Project is anticipated generate more that 110 daily vehicle trips and is not presumed to
have a less than significant impact.
The Low Project Type screening threshold is not met.
Mr. John Condas
Allen Matkins
April 14, 2021
Page 4 of 5
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CONCLUSION
Based on our review of applicable VMT screening thresholds, the Project does not meet any of the
screening thresholds listed in the City Guidelines.
If you have any questions, please contact me directly at aevatt@urbanxroads.com.
Respectfully submitted,
URBAN CROSSROADS, INC.
Aric Evatt, PTP Robert Vu, PE
President Transportation Engineer
Mr. John Condas
Allen Matkins
April 14, 2021
Page 5 of 5
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REFERENCES
[1] Institute of Transportation Engineers, Trip Generation Manual, 10th Edition ed., 2017.
[2] Governor's Office of Planning and Research (OPR), "Technical Advisory on Evaluating Tranpsortation
Impacts in CEQA," December 2018.
[3] City of Fontana, "Traffic Impact Analysis (TIA) Guidelines for Vehicles Miles Traveled (VMT) and Level
of Service Assessment," June 2020.
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ATTACHMENT A:
PROJECT TRIP GENERATION
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ATTACHMENT B:
SCREENING TOOL
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