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4.7 – Transportation Draft Environmental Impact Report February 2021 14800 W. Schulte Road Logistics Center 4.7-4 recommended by other public agencies, provided the decision to adopt those thresholds is supported by su bstantial evidence” (CEQA Guidelines Section 15064.7[c]). In December 2018, the CEQA Guidelines were updated to add new Section 15064.3, Determining the Significance of Transportation Impacts, that describes specific considerations for evaluating a project’s transportation impacts using the VMT methodology. CEQA Guidelines Section 15064.3(b) is divided into four subdivisions, as follows: (1) Land Use Projects. Vehicle miles traveled exceeding an applicable threshold of significance may indicate a significant impact. Generally, projects within one-half mile of either an existing major transit stop or a stop along an existing high quality transit corridor should be presumed to cause a less than significant transportation impact. Projects that decrease vehicle mi les traveled in the project area compared to existing conditions should be presumed to have a less than significant transportation impact. (2) Transportation Projects. Transportation projects that reduce, or have no impact on, vehicle miles traveled should be presumed to cause a less than significant transportation impact. For roadway capacity projects, agencies have discretion to determine the appropriate measure of transportation impact consistent with CEQA and other applicable requirements. To the extent that such impacts have already been adequately addressed at a programmatic level, such as in a regional transportation plan EIR, a lead agency may tier from that analysis as provided in Section 15152. (3) Qualitative Analysis. If existing models or methods are not available to estimate the vehicle miles traveled for the particular project being considered, a lead agency may analyze the project’s vehicle miles traveled qualitatively. Such a qualitative analysis would evaluate factors such as the availability of transit, proximity to other destinations, etc. For many projects, a qualitative analysis of construction traffic may be appropriate. (4) Methodology. A lead agency has discretion to choose the most appropriate methodology to evaluate a project’s vehicle miles traveled, including whether to express the change in absolute terms, per capita, per household or in any other measure. A lead agency may use models to estimate a project’s vehicle miles traveled and may revise those estimates to reflect professional judgment based on substantial evidence. Any assumptions used to estimate vehicle miles traveled and any revisions to model outputs should be documented and explained in the environmental document prepared for the project. The OPR’s regulatory text indicated that a public agency may immediately commence implementation of the new transportation impact guidelines, and that the guidelines must be implemented statewide by July 1, 2020. However, the OPR Technical Advisory allows local agencies to retain their congestion -based LOS standards in General Plans and for project planning purposes. The County has not adopted VMT analysis thresholds; therefore, use of both LOS and VMT is provided in this analysis for different purposes. The project’s LOS effects related to the County’s Development Title standards have been documented in the TIA prepared for the Project (Appendix F) for informational purposes and to evaluate potential safety impacts associated with vehicle stacking resulting from potential delay. Additionally, a VMT analysis has been provided directly in this Environmental Impact Report, which relies on VMT as the basis for evaluating transportation impacts under CEQA.