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Administrative Draft Environmental Impact Report Gill Medical Center Project City of Stockton Significance Thresholds The County of San Joaquin is the CEQA lead agency for the Project. The County considers it appropriate to use a City's significance thresholds in a traffic impact study for a project within that City's sphere of influence (Levers pers. comm.) The County considers this approach to be consistent with the County General Plan. The Project site is shown in the San Joaquin County Local Agency Formation Commission (LAFCO) Stockton Sphere of Influence map (San Joaquin County LAFCO 2020) in an "Area of Interest". The Project site is also shown in the Envision Stockton 2040 General Plan as being in the City"General Plan Planning Area" (City of Stockton 2018b). Because of the LAFCO and City of Stockton designations, it is considered appropriate to apply the City's significance threshold. While the Project site is not strictly in the City sphere of influence, it would be inappropriate to ignore the LAFCO designation as an Area of Interest and the City designation of the Project site being in the General Plan Planning Area. The City of Stockton Traffic Impact Analysis Guidelines (City of Stockton 2003) presents the methods, assumptions and significance thresholds specified by the City of Stockton for use in preparing traffic impact studies. In general, the methods, assumptions and significance threshold presented in the guidelines are applied in the Traffic Study. It is important to note the significance thresholds specified in the guidelines are based on policies presented in the City General Plan. More specifically, the General Plan policies define ranges of LOS considered to be acceptable and unacceptable. The guidelines then use the General Plan policy ranges of LOS to identify whether a project impact is consistent or inconsistent with applicable policy. Level of Service and Vehicle Miles Traveled In the City of Stockton Traffic Impact Analysis Guidelines, the impacts of a project on LOS is an important factor in determining whether a project has a significant impact. However, recent changes to CEQA have changed how lead agencies use LOS in determining whether a project has a significant impact on transportation. As noted in the California Governor's Office of Planning and Research (OPR) document Technical Advisory on Evaluating Transportation Impacts in CEQA (OPR 2018), "Senate Bill 743 (Steinberg 2013), which was codified in Public Resources Code section 21099, required changes to the guidelines implementing CEQA (CEQA Guidelines) (Cal. Code Regs., Title 14, Div. 6, Ch. 3, § 15000 et seq.) regarding the analysis of transportation impacts. . . OPR has proposed, and the California Natural Resources Agency (Agency) has certified and adopted, changes to the CEQA Guidelines that identify vehicle miles traveled (VMT) as the most appropriate metric to evaluate a project's transportation impacts. With the California Natural Resources Agency's certification and adoption of the changes to the CEQA Guidelines, automobile delay, as measured by"level of service" and other similar metrics, generally no longer constitutes a significant environmental effect under CEQA. (Pub. Resources Code, § 21099, subd. (b)(3).)„ Notably, the City of Stockton Traffic Impact Analysis Guidelines was prepared before the recent changes to CEQA due to Senate Bill 743 (KD Anderson 2021). As a result, the City guidelines specify use of LOS in determining whether a project has a significant impact. Consistent with the approach described in the OPR Technical Advisory on Evaluating Transportation Impacts in CEQA, LOS is not used in the Traffic Study or this draft EIR as a basis for identifying significant impacts. Rather, the methods, assumptions and Transportation 4.19-15 October 2021