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Traffic Impact Study Griffith Energy Storage Project 5.0 CONCLUSIONS 5.1 SIGNIFICANCE OF IMPACTS 5.1.1 Vehicle Miles Traveled As noted in Section 1.3.1, there is no established threshold of significance for VMT in San Joaquin County. Since no quantitative, qualitative, or performance level is identified, the significance of 847,667 additional miles traveled must be evaluated based on the three guidance criteria from the CEQA Technical Advisory, and based on the following CEQA criteria, the Project is a less than significant impact for VMT: Reduction of GHG Emissions. The Project is a battery energy storage system facility and the chief aim of constructing such facilities is to increase local energy storage capacity. This Project would support the state policies necessary to meet the California renewable energy standards. California has proceeded to advance energy storage uses to support the grid, including the passage of AB 2514, as well as the resulting California Public Utilities Commission decision for energy procurement targets for each of the investor-owned utilities. The proposed Project would address the limitations of the electrical grid by the increasing demand for renewable energy. Layering energy storage systems into the energy grid improves grid reliability and makes it more resilient to disturbances and peaks in energy demand. The Project and other energy storage systems are used to supply power during brief disturbances, reduce outages and associated impacts to the community, and substitute for certain large footprint transmission and disruption upgrades. Additionally, Griffith conducted an Air Quality and Greenhouse Gas Technical Report for San Joaquin County which concluded a "less than significant impact"for both construction and operations emissions. The GHG technical report identified a quantitative threshold of significance for GHG emissions. The analysis included in that report accounted for construction traffic emissions to determine the total emissions for the Project. Using this definitive quantitative metric yielded a "less than significant impact." Based on this conclusion a threshold value for VMT would likely be much higher than the Project generated VMT. This assertion is in line with the fact that the guidance for conducting VMT analysis originated with GHG emissions reduction regulations and goals and the guidance states "OPR recommends using quantitative VMT thresholds linked to GHG reduction targets when methods exist to do so." Diversity of Land Use. Diversity of land use is a more difficult criteria to quantify for a comparative analysis. According to CEQA(2018), "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." The Project would diversify land use by changing the current use from undeveloped cropland grazing land to renewable energy storage. While the Project would increase the VMT from undeveloped to developed conditions, nearly all of the VMT are added during a relatively short construction time window. The expected facility maintenance would generate infrequent and light traffic during operations, and it is anticipated that eventually maintenance visits would be reduced to once a month or less and not impact peak hour traffic. Development of the Project would therefore support California's statutory energy goals—reduction of GHGs through development of a storage facility for renewable energy, development of multimodal transportation networks, and a diversity of land uses. Development of Multimodal Transportation networks. This CEQA guidance criteria is not relevant to the Project. NTETRA TECH 10 February 2023