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Administrative Draft Environmental Impact Report Gill Medical Center Project Based on the above discussion, a project's inconsistency with General Plan policies will be considered significant if: the project would result in traffic operating conditions changing from an acceptable LOS to an unacceptable LOS, or when LOS without the project is already unacceptable, the project would result in a substantial degradation of traffic operating conditions (e.g., an increase of more than five seconds of delay at an intersection, an increase of more than five percent in traffic volume on a roadway segment, or an increase of more than five percent in the freeway and ramp volumes for ramps). Vehicle Miles Traveled Significance Threshold The Envision Stockton 2040 General Plan (City of Stockton 2018b) Policy TR-4.3 addresses the topic of VMT as an impact in CEQA documents. The policy states, "Use the threshold recommended by the California Office of Planning and Research for determining whether VMT impacts associated with land uses are considered significant under State environmental analysis requirements." The OPR Technical Advisory on Evaluating Transportation Impacts in CEQA (California Governor's Office of Planning and Research 2018) provides recommended thresholds for determining the significance of VMT impacts associated with land use development projects. Specific thresholds are provided for residential, office, and retail commercial types of development. While a portion of the proposed Project includes office land uses, a specific threshold is not provided for the hospital land use and, therefore, does not provide adequate guidance for the overall project. The City of Stockton General Plan Policy Action TR-4.3A states, "Establish a threshold of 15 percent below baseline VMT per capita to determine a significant transportation impact under the California Environmental Quality Act." The 15 percent threshold in General Plan Action TR-4.3A is similar to thresholds for residential and office land use types recommended by OPR in the Technical Advisory on Evaluating Transportation Impacts in CEQA, and is used in this draft EIR to determine the significance of VMT impacts associated with the Project. Consistent with General Plan Action TR4.3A, if a project would result in a 15 percent or more reduction of vehicle travel, a project is considered to have a less-than-significant impact. A project that would not result in a reduction of 15 percent or more is considered to have a significant impact. The percent change in vehicle travel is determined by comparing project-related travel to the Stockton area average. The unit of measure applied for this comparison in the Envision Stockton 2040 General Plan Update and Utility Master Plan Supplements Draft EIR(City of Stockton 2018c) is "VMT per Service Population". The General Plan Draft EIR defines service population as the "sum of population and employment". Transportation 4.19-20 October 2021