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Traffic Impact Study Griffith Energy Storage Project Agency adopted changes to the CEQA identifying VMT as "the most appropriate metric to evaluate a project's transportation impacts...Thus, to achieve the State's long-term climate goals, California needs to reduce per capita VMT."The VMT values calculated should be compared to a jurisdictionally determined threshold of significance that ultimately dictates whether a project's traffic impacts are significant and require mitigation or are a less than significant impact. San Joaquin County has not yet developed a threshold of significance for VMT, so in lieu of that the criteria as stated in the Technical Advisory on Evaluating Transportation Impacts in CEQA(CEQA 2018) would apply: The VMT metric can support the three statutory goals: "the reduction of greenhouse gas emissions, the development of multimodal transportation networks, and a diversity of land uses." (Pub. Resources Code, § 21099, subd. (b)(1)) However, in order for it to promote and support all three, lead agencies should select a significance threshold that aligns with state law on all three. State law concerning the development of multimodal transportation networks and diversity of land uses requires planning for and prioritizing increases in complete streets and infill development but does not mandate a particular depth of implementation that could translate into a particular threshold of significance. Meanwhile, the State has clear quantitative targets for GHG emissions reduction set forth in law and based on scientific consensus, and the depth of VMT reduction needed to achieve those targets has been quantified. Tying VMT thresholds to GHG reduction also supports the two other statutory goals. Therefore, to ensure adequate analysis of transportation impacts, OPR [Office of Planning and Research] recommends using quantitative VMT thresholds linked to GHG reduction targets when methods exist to do so. TETRA TECH 6 February 2023