The Evolving Practice of Travel Forecasting for CEQA Projects

October 17, 2011 By Leave a Comment

A common challenge in preparing forecasts for EIR transportation impact studies is having an adequate travel forecasting model. Part of the problem is getting everyone to agree on what’s adequate. The modeling profession has established guidance on models needing to be calibrated and validated before use in applications. Unfortunately, this guidance has been written for a very technical audience and the information has not been effectively disseminated to lead agencies, CEQA attorneys, developers, or the public. The passage of SB 375 had placed a spotlight on travel forecasting models and resulted in updated forecasting guidance in the form of the California 2010 Regional Transportation Guidelines.

The new guidelines make it clear about what is expected in the development and application of models. Of particular importance are the specific static and dynamic validation tests for establishing model accuracy and sensitivity. These are formal tests that can be applied to any model so that users will understand whether the model is adequate for intended application purposes.

Further, these guidelines extend to sub‐regional applications such as a development project EIR transportation impact study as noted in the excerpt from the guidelines below. In this respect, the new 2010 California Regional Transportation Plan Guidelines have clarified the definition of adequate for model development and application in California.

Section 3.4, Page 51
Consistency of RTP Modeling
Recommendations:

  1. Agencies that use MPO models for purposes other than regional planning should ensure thatthe model provides the appropriate scale and sensitivity for applications at a sub‐regional levelsuch as corridor, sub‐area, or local planning studies. Below the regional level, model refinements are likely necessary to ensure the model meets the validation targets established in these guidelines and is appropriately sensitive to smaller scale changes associated with sub‐regional studies.

Click here for details of Fehr & Peers’ suggested guidance on travel forecasting for CEQA, and/or traffic operations for CEQA.

Filed Under: CEQA, Uncategorized

California MPOs Reveal Results of SB375 Soul-Searching

June 12, 2010 By Leave a Comment

In May, California’s Metropolitan Planning Organizations revealed their self-assessments of their ability to curb climate change.  MPOs representing over 90% of the state’s population went on record with estimates of their “ambitious and achievable” 25-year reductions in greenhouse gas emissions.

The announcements followed more than seven months of public outreach and stakeholder discussions, scenario testing and modeling representing the “bottom up process” within the regions to assess their GHG reduction potential.  The process was prescribed by the State’s SB375 Regional Targets Advisory Committee (RTAC) in its September 2009 report California Air Resources Board. The resulting MPO reports will inform the Board’s deliberations on regional GHG targets required under the California’s landmark SB375 climate legislation.

MPOs representing the state’s four major regions Los Angeles (SCAG), San Francisco (MTC), San Diego (SANDAG) and Sacramento (SACOG) submitted a unified report, though the proposed land use and transportation strategies varied from region to region (as shown in the following table), as did each regions’ estimated performance levels.  The MPOs and Regional Transportation Planning Agencies representing Fresno, Kern, Kings, San Joaquin, San Luis Obispo, Monterey, Santa Cruz, San Benito, Butte, and Shasta counties also presented target-setting proposals.

Based on information provided for the May 25 RTAC meeting, the MPO land use and transportation scenarios identified as “ambitious but achievable” would reduce GHG per capita in 2020 to between 5% and 11% below 2005 levels.  Each MPO estimated that its region could double those reductions by 2020 through much more aggressive land use, demand management and transportation investment strategies that they deemed very ambitious, but not necessarily achievable.

Ambitious Enough?

The reported scenarios and performance levels provoked a full day’s public comment and discussion by the RTAC.  Observations by RTAC member Jerry Walters, along with his opinions on unresolved issues appear here. Questions include whether the MPO scenarios and GHG reductions are ambitious enough, including:

  • whether assumptions on land use respond to anticipated growth in market demand for compact growth
  • whether roadway pricing assumptions were ambitious enough, given the above-mentioned modest escalation in fuel prices projected over the next 25 years
  • the reasons for worsening jobs/housing balances in several regions
  • differences in the estimated effectiveness of travel demand management (TDM)
  • the lack of information on vehicle miles traveled in the MPO reports
  • the fact that the achievable 2020 reduction percentages for the three largest MPOs were actually higher than projected reductions in 2035

Questions Remain

In addition to the specific questions on the MPO scenario analysis above, several substantial issues remain for ARB to address in its deliberations in the coming months:

  • whether ARB should set a uniform statewide target, as suggested in the September 2009 RTAC findings, or allow that regional variations, matching the individual target proposals submitted last week
  • whether to set target ranges, rather than specific targets, that might allow the MPOs to perform within the ranges between “ambitious” and “achievable” as defined by each MPO
  • the extent to which MPOs and others might perform technical reasonableness checks on the MPO modeling analysis , using information on typical effectiveness of land use and TDM strategies that the University of California has been preparing for ARB
  • how to translate the final SB375 GHG reduction targets  into update goals in the AB 32 Scoping Plan which predicted that the land use and associated changes in transportation emphasis could deliver a 4% reduction in GHG (or 5 million metric tons) relative to 2020 trend-line conditions

ARB workshops and Board hearings on the targets begin on June 24 and through July. For more information, visit:  http://arb.ca.gov/cc/sb375/meetings/meetings.htm

Filed Under: CEQA, Greenhouse gases, Health

California MPOs Reveal Results of SB375 Soul-Searching

June 12, 2010 By Leave a Comment

In May, California’s Metropolitan Planning Organizations revealed their self-assessments of their ability to curb climate change.  MPOs representing over 90% of the state’s population went on record with estimates of their “ambitious and achievable” 25-year reductions in greenhouse gas emissions.

The announcements followed more than seven months of public outreach and stakeholder discussions, scenario testing and modeling representing the “bottom up process” within the regions to assess their GHG reduction potential.  The process was prescribed by the State’s SB375 Regional Targets Advisory Committee (RTAC) in its September 2009 report California Air Resources Board. The resulting MPO reports will inform the Board’s deliberations on regional GHG targets required under the California’s landmark SB375 climate legislation.

MPOs representing the state’s four major regions Los Angeles (SCAG), San Francisco (MTC), San Diego (SANDAG) and Sacramento (SACOG) submitted a unified report, though the proposed land use and transportation strategies varied from region to region (as shown in the following table), as did each regions’ estimated performance levels.  The MPOs and Regional Transportation Planning Agencies representing Fresno, Kern, Kings, San Joaquin, San Luis Obispo, Monterey, Santa Cruz, San Benito, Butte, and Shasta counties also presented target-setting proposals.

Based on information provided for the May 25 RTAC meeting, the MPO land use and transportation scenarios identified as “ambitious but achievable” would reduce GHG per capita in 2020 to between 5% and 11% below 2005 levels.  Each MPO estimated that its region could double those reductions by 2020 through much more aggressive land use, demand management and transportation investment strategies that they deemed very ambitious, but not necessarily achievable.

Ambitious Enough?

The reported scenarios and performance levels provoked a full day’s public comment and discussion by the RTAC.  Observations by RTAC member Jerry Walters, along with his opinions on unresolved issues appear here. Questions include whether the MPO scenarios and GHG reductions are ambitious enough, including:

  • whether assumptions on land use respond to anticipated growth in market demand for compact growth
  • whether roadway pricing assumptions were ambitious enough, given the above-mentioned modest escalation in fuel prices projected over the next 25 years
  • the reasons for worsening jobs/housing balances in several regions
  • differences in the estimated effectiveness of travel demand management (TDM)
  • the lack of information on vehicle miles traveled in the MPO reports
  • the fact that the achievable 2020 reduction percentages for the three largest MPOs were actually higher than projected reductions in 2035

Questions Remain

In addition to the specific questions on the MPO scenario analysis above, several substantial issues remain for ARB to address in its deliberations in the coming months:

  • whether ARB should set a uniform statewide target, as suggested in the September 2009 RTAC findings, or allow that regional variations, matching the individual target proposals submitted last week
  • whether to set target ranges, rather than specific targets, that might allow the MPOs to perform within the ranges between “ambitious” and “achievable” as defined by each MPO
  • the extent to which MPOs and others might perform technical reasonableness checks on the MPO modeling analysis , using information on typical effectiveness of land use and TDM strategies that the University of California has been preparing for ARB
  • how to translate the final SB375 GHG reduction targets  into update goals in the AB 32 Scoping Plan which predicted that the land use and associated changes in transportation emphasis could deliver a 4% reduction in GHG (or 5 million metric tons) relative to 2020 trend-line conditions

ARB workshops and Board hearings on the targets begin on June 24 and through July. For more information, visit:  http://arb.ca.gov/cc/sb375/meetings/meetings.htm

Filed Under: CEQA, Greenhouse gases, Health

Proposed VMT Threshold for the Yolo County General Plan Update

May 21, 2009 By Leave a Comment

The County of Yolo, located in the Sacramento, California region, is in the process of updating their General Plan with a horizon year of 2030. The unincorporated area of the County has historically focused on preservation of farmland, open space, and natural resources, while directing residential growth to incorporated cities and in some cases established rural communities. However, with the existing incorporated cities nearing build-out and increased pressure on the county to accommodate additional residential growth, the County has the opportunity to establish a new growth area. As part of the General Plan update, the County has identified the Town of Dunnigan (with less than 400 existing residential units) as a new Specific Plan area that would accommodate up to approximately 8,000 new residential dwelling units. The size of the community was predicated on a desire to fix existing environmental problems such as water contamination due to private septic systems while also creating a sustainable full-service community.

The Draft General Plan includes policies that promote sustainable development in the Dunnigan Specific Plan area, including matching jobs to housing, ensuring that jobs are created concurrently with housing, providing needed services in the community, and promoting walking, biking, and transit. The focus of the policies is to reduce the need for vehicle travel but it is not intended to reduce personal mobility. To further insure that the Dunnigan Specific Plan area achieves lower levels of travel, Fehr & Peers worked closely with the County to develop a daily vehicle miles of travel (VMT) generated per household threshold. The threshold was developed based on the new regional travel demand model for the Sacramento region, called SACSIM, which is a state of the art activity-based travel demand model. This new type of model simulates people and their activity patterns (i.e., why they travel) to estimate regional travel performance measures, such as VMT.

The regional SACSIM model estimates that the incorporated cities of Davis and Woodland, which are mature full service cities, are anticipated to generate 44 miles per household by 2035, while the unincorporated area of the County is estimated to generate 77 miles per household by 2035. The Dunnigan Specific Plan area is envisioned to include a land use pattern and transportation system representative of a mature and sustainable community similar to the Cities of Davis and Woodland. As a result, the following new policy was developed as part to the VMT analysis in the Yolo County General Plan Draft EIR:

  • The Dunnigan Specific Plan shall incorporate a maximum of 44 vehicle miles of travel (VMT) generated per household per weekday through implementation of all feasible actions including but not limited to specifications contained in Policies CC-3.3 through CC-3.6. As part of the specific plan implementation, the VMT performance shall be monitored at each phase.

The specific approach may be applicable elsewhere but it would need to be tailored to the local conditions. Yolo County has unique land use conditions (i.e., Williamson Act properties, strong commitment to agricultural protection, focused growth in cities that no longer want to grow in significant amounts, etc.) that were important considerations in establishing the threshold. Other key factors related to this approach include the following benefits that go beyond just greenhouse gas reductions:

  • Reduces the urban footprint of planned development through higher densities and a mix of land uses with a focus on encouraging transit, bicycling, and walking.
  • Reduces energy use from buildings due to higher densities and from traveling.
  • Reduces air pollutant emissions.

The full VMT discussion is available for public review in the Transportation and Circulation section of the Draft Yolo County General Plan EIR at the Yolo County Web site.

Filed Under: CEQA, General Plans, Greenhouse gases, Local ordinances, VMT

California Proposes Dropping Auto LOS

January 19, 2009 By 1 Comment

In early January, the California Governor’s Office of Planning and Research (OPR) quietly proposed a sweeping change to the way that transportation-specific environmental impacts are evaluated.  In the Preliminary Draft CEQA Guideline Amendments for Greenhouse Gas Emissions recently released, all reference to automobile Level of Service (LOS) has been removed, including related text referring to roadway volume to capacity ratios, automobile congestion, and parking capacity.

Filip Bodgan Pursuant to Senate Bill 97 (2007), OPR is responsible for updating California Environmental Quality Act (CEQA) guidelines to support mitigating greenhouse gas emissions or the effects of greenhouse gas emissions.  The purpose of these guidelines, originally released in preliminary draft form in October 2008 (see related CoolConnections post here), is to help local jurisdictions meet their CEQA obligations.

CEQA itself has no specific Level of Service requirements, but it does encourage the adoption of standards of significance to be used in determining significant impacts. It is the responsibility of the Lead Agency to determine the definition of “significant.”

Typically, standards of significance for transportation impacts in California (and around the nation) are based on automobile LOS.  This is partly due to the fact that current CEQA Guidelines state significance thresholds need to be:

“… an identifiable quantitative, qualitative or performance level of a particular environmental effect, noncompliance with which means the effect will normally be determined to be significant by the agency and compliance with which means the effect normally will be determined to be less than significant.” (CEQA, Section 15064.7)

Standardized LOS policies tend to fit the above description well.  While permissible to use differing significance thresholds, Lead Agencies have so far been reluctant to deviate from the use of LOS.

Part of the reluctance may be due to recent case law generally interpreting the analysis of transportation impacts in light of consistency with the CEQA Checklist, which states that a project will normally have a significant effect on the environment if it will:

“… [c]ause an increase in traffic which is substantial in relation to the existing traffic load and capacity of the street system (i.e. result in a substantial increase in…the volume to capacity ratio on the roads, or congestion at intersections)….” (CEQA Checklist – Appendix G)

This language in the CEQA Checklist was added in 1999 and suggests the use of automobile-based standards of significance as opposed to alternate approaches involving considerations for pedestrians, bicyclists, and transit (some jurisdictions use multimodal significance criteria, but this is always in addition to, not in lieu of, automobile significance criteria).

Which brings us to January 2009.  OPR has released proposed changes to the CEQA checklist which eliminate the above language, replacing it with language relating to the number of automobile trips or vehicle miles traveled (VMT) a particular “project” would generate:

OPR Text - January 2009

This proposal comes on the heels of the City of San Francisco’s proposal in the Fall of 2008 to do just the same thing.  It also follows an LOS Forum on this topic that was held at OPR in December.  If adopted, it would mean that automobile LOS, which describes the level of congestion and delay on a road, would be abandonded in favor of impacts being based on the amount of automobile travel generated, irrespective of roadway capacity.

Workshops to discuss this and other aspects of the Preliminary Draft CEQA Guidelines will be held on January 22 and 26.  We’ll continue to review new developments with this proposal, including its implications, in upcoming posts.

Filed Under: CEQA, Greenhouse gases, Level of Service

CEQA and Greenhouse Gas Emissions

November 4, 2008 By Leave a Comment

California’s recent Senate Bill 97 (2007) states that greenhouse gas emissions and the effects of greenhouse gas emissions are subject to the California Environmental Quality Act (CEQA).  Pursuant to SB 97, the Governor’s Office of Planning and Research (OPR) has developed draft guidelines for mitigating greenhouse gas emissions or the effects of greenhouse gas emissions.  These guidelines are intended to help local jurisdictions and other CEQA-defined lead agencies meet their CEQA obligations.  As part of this process, OPR has asked the California Air Resources Board (ARB) technical staff to recommend statewide interim thresholds of significance for greenhouse gases.

clip_image002

On October 24th, ARB released a set of preliminary concepts for developing CEQA thresholds of significance for greenhouse gases – Preliminary Draft Staff Proposal: Recommended Approaches for Setting Interim Significance Thresholds for Greenhouse Gases under the California Environmental Quality Act (CEQA). ARB hosted a public workshop on October 27th to present these concepts, pose an initial set of questions, and receive public input prior to presenting a final recommended approach to the ARB Board in January 2009.

The Preliminary Draft Staff Proposal includes ARB staff’s initial recommendations for industrial and residential/commercial projects. For these projects, staff has outlined an approach which considers project exemptions, performance standards, and significant impacts – for residential/commercial projects, there is also a “programmatic approach” to streamline projects that comply within the requirements of a previously adopted plan (EIR). While industrial projects have a recommend threshold of 7,000 MTCO2E/year (metric tons carbon dioxide equivalent), the residential/commercial projects’ threshold is yet to be determined. The document notes that staff is still working on a proposal for an interim approach for thresholds for transportation projects and large dairies. Electricity generation is another sector where clarity is needed in the near term. 

ARB staff also recognizes that additional analyses and data are needed to fill in some of the blanks, and to understand how the thresholds will operate in the real world. Comments on all aspects of the Staff Proposal are encouraged. In particular, ARB seeks the active participation of local lead agencies.

Staff has identified a few questions in both their Preliminary Draft Staff Proposal and at ARB’s October 27th public workshop to solicit further comment:

  1. How should the performance standards for transportation, construction, waste, and water be defined?
  2. What are the unintended consequences?
  3. ARB would like additional analyses of categorical exemptions
  4. ARB is concerned that projects that meet thresholds could still have significant climate change impacts

Full Presentation from the October 27th workshop can be viewed here.  Additional information can be found on ARB’s Climate Change Website.

ARB is currently encouraging comments on the Preliminary Draft Staff Proposal.  The proposal has already generated some in-depth discussion and is sure to generate more in the weeks ahead.

- Lauren Hilliard

Filed Under: CEQA, Greenhouse gases

Eliminating Automobile LOS

October 7, 2008 By 5 Comments

Last month, the San Francisco County Transportation Authority released a draft report calling for the elimination of auto levels of service (LOS) as significance criteria under the California Environmental Quality Act (CEQA). Among other things, the report recommends replacing LOS with a new measure of “Automobile Trips Generated.” While San Francisco is not the first City to discuss changes to traditional automobile LOS policies, it may be the first to propose completely eliminating it.

For those not familiar with CEQA, it requires agencies to determine if a given project will have a significant impact on the environment. CEQA also allows agencies to develop specific “thresholds of significance” to determine the level at which an environmental effect is considered significant. Oftentimes, transportation impact analysis performed to comply with CEQA (or NEPA) focuses on only one perspective about potential impacts – the perspective of the automobile driver. Traditional traffic engineering practice has been to use LOS to study the congestion or delay a driver experiences on a roadway, or more frequently, at an intersection. If an LOS threshold is exceeded, a mitigation measure must be crafted to ensure project impacts are not deemed “significant and unavoidable” – which would require an agency override impacts or deny the project. Implementing mitigations to achieve a set LOS threshold can result in oversized intersections that are inconvenient at best and hostile at worst toward anyone but the automobile driver.

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With many communities more concerned about climate change, creating livable communities, and wanting to emphasize transit, walking, and bicycling, the traditional traffic engineering approach to LOS is not effective. Worse, it can result in smart growth projects being denied due to neighborhood opposition associated with worsening LOS and not understanding the other tradeoff benefits of infill and higher density development.

San Francisco has been considering revisiting LOS criteria for several years. In 2003, it released a strategic analysis report investigating options for different LOS methodologies, including some types of multimodal LOS criteria. In 2005, a more detailed study was begun, the product of which is the current proposal to eliminate automobile LOS. As a next step, the City’s Transportation Authority intends to develop a multimodal impact fee that will apply to new automobile trips generated by new development and will seek to mitigate the cumulative effects of additional automobile trips.

san_francisco_van_ness

How smooth will the road to abandoning auto LOS be? The proposal already has support from a number of influential groups in the City, including the San Francisco Bicycle Coalition and the San Francisco Planning + Urban Research Association.

Filed Under: CEQA, Level of Service