09-17-2020
CITY OF GRAND TERRACE
PLANNING COMMISSION/SITE AND ARCHITECTURAL REVIEW BOARD
AGENDA
Council ChambersRegular Meeting6:30 PM
PUBLIC ADVISORY: THE COUNCIL CHAMBER IS NOW OPEN TO THE PUBLIC!!
Beginning June 15, 2020, the City of Grand Terrace will reopen its public meetings. Therefore, the regular
meeting of the Planning Commission for September 17, 2020, is now open to the public. Please be
advised that face masks are required, social distancing will be practiced, and occupancy limits will be
enforced.
Please note that Pursuant to Section 3 of Executive Order N-29-20, issued by Governor Newsom on
March 17, 2020, the regular meeting of the Planning Commission for September 17, 2020, will also be
COMMENTS FROM THE PUBLIC
The public is encouraged to address the Planning Commission on any matter posted on the agenda or on
any other matter within its jurisdiction. If you wish to address the Planning Commission, you are invited to
provide your name to the City Clerk who will be compiling a list of speakers. Speakers will be called upon
by the Mayor at the appropriate time and each person is allowed three (3) minutes speaking time.
If you would like to participate telephonically and speak on an agenda item, you can access the meeting
by dialing the following telephone number and you will be placed in the waiting room, muted until it is your
turn to speak:
*67 1-669-900-9128
Enter Meeting ID: 865 7902 0126
Password: 115278
The City wants you to know that you can also submit your comments by email to
ccpubliccomment@grandterrace-ca.gov. To give the CityClerk adequate time to print out your comments
for consideration at the meeting, please submit your written comments prior to 5:00 p.m.; or if you are
-6621 x230 by 5:00 p.m.
If you wish to have your comments read to the Planning Commission during the appropriate Public
you wish to comment on. Comments that you want read to the Planning Commission will be subject to the
three (3) minute time limitation (approximately 350 words).
Pursuant to the provisions of the Brown Act, no action may betaken on a matter unless it is listed on the
agenda, or unless certain emergency or special circumstancesexist. The Planning Commission may
direct staff to investigate and/or schedule certain matters for consideration at a future Planning
Commission meeting.
PLEASE NOTE: Copies of staff reports and supporting documentation pertaining to each item on this
agenda are available for public viewing and inspection at City Hall, 1 st Floor Lobby Area and 2 nd Floor
Reception Area during regular business hours anwww.grandterrace-ca.gov. For
further information regarding agenda items, please contact the office of the City Clerk at (909) 824-6621
x230, or via e-mail at dthomas@grandterrace-ca.gov.
Any documents provided to a majority of the Planning Commission regarding any item on this agenda will
City of Grand TerracePage 1
Agenda Grand Terrace Planning Commission/Site and Architectural Review Board September 17, 2020
during normal business hours. In add
www.grandterrace-ca.gov.
AMERICANS WITH DISABILITIES ACT
In compliance with the Americans with Disabilities Act, if you need special assistance to participate in this
-6621 x230 at least 48 hours prior to the
advertised starting time of the meeting. This will enable the City to make reasonable arrangements to
ensure accessibility to this meeting. Later requests will be accommodated to the extent feasible.
CALL TO ORDER
Convene the meeting of the Planning Commission and Site and Architectural Review
Board
PLEDGE OF ALLEGIANCE
ROLL CALL
Attendee Name Present Absent Late Arrived
Chairman Edward A. Giroux
Vice-Chairman Jeremy Briggs
Commissioner Tara Cesena
Commissioner Jeffrey McConnell
Commissioner David Alaniz
APPROVAL OF AGENDA
PUBLIC ADDRESS
Public address to the Commission shall be limited to three minutes unless extended by
the Chairman. Should you desire to make a longer presentation, please make written
request to be agendized to the Director of Planning and Development Services.
This is the opportunity for members of the public to comment on any items not
appearing on the regular agenda. Because of restrictions contained in California Law,
the Planning Commission may not discuss or act on any item not on the agenda, but
may briefly respond to statements made or ask a question for clarification. The
Chairman may also request a brief response from staff to questions raised during public
comment or may request a matter be agendized for a future meeting.
City of Grand Terrace Page 2
Agenda Grand Terrace Planning Commission/Site and Architectural Review Board September 17, 2020
A.CONSENT CALENDAR
1. Approval of Minutes Regular Meeting 08/20/2020
DEPARTMENT: CITY CLERK
B.ACTION ITEMS
None.
C.PUBLIC HEARINGS
None.
D.PRESENTATIONS
1. Presentation on Vehicle Miles Traveled Thresholds for Analysis of Traffic Impacts Under
the California Environmental Quality Act
RECOMMENDATION:
Receive and file
DEPARTMENT: PLANNING COMMISSION/SITE AND ARCHITECTURAL REVIEW
BOARD
E. INFORMATION TO COMMISSIONERS
F. INFORMATION FROM COMMISSIONERS
ADJOURN
Adjourn to the next scheduled meeting of the Site and Architectural Review
Board/Planning Commission to be held on October 1, 2020 at 6:30 p.m.
City of Grand Terrace Page 3
A.1
CITY OF GRAND TERRACE
PLANNING COMMISSION/SITE AND ARCHITECTURAL REVIEW BOARD
MINUTES
Council ChambersRegular Meeting6:30 PM
22795 Barton Road
CALL TO ORDER
Chairman Edward Giroux convened the Regular Meeting of the Planning Commission
and Site and Architectural Review Board for Thursday, August 20, 2020 at 6:30 p.m.
PLEDGE OF ALLEGIANCE
The Pledge of Allegiance was led by Commissioner Tara Ceseña.
Attendee NameTitleStatusArrived
Edward A. GirouxChairmanPresent
Jeremy BriggsVice-ChairmanPresent
Tara CesenaCommissionerPresent
Jeffrey McConnellCommissionerPresent
David AlanizCommissionerPresent
Steven WeissPlanning & Development Services DirectorPresent
Robert KhuuAssistant City AttorneyPresent
Haide AguirreAssistant PlannerPresent
Debra ThomasCity ClerkPresent
APPROVAL OF AGENDA
1.Motion: August 20, 2020 Approval of Agenda
RESULT:ADOPTED \[UNANIMOUS\]
AYES:Giroux, Briggs, Cesena, McConnell, Alaniz
PUBLIC ADDRESS
None.
City of Grand TerracePage 1
Packet Pg. 4
A.1
Minutes Grand Terrace Planning Commission/Site and Architectural Review Board August 20, 2020
A.CONSENT CALENDAR
2. Approval of Minutes Regular Meeting 07/16/2020
RESULT: ACCEPTED \[2 TO 1\]
MOVER: Tara Cesena, Commissioner
SECONDER: David Alaniz, Commissioner
AYES: Tara Cesena, David Alaniz
NAYS: Jeremy Briggs
RECUSED: Edward A. Giroux, Jeffrey McConnell
B.ACTION ITEMS
None.
C.PUBLIC HEARINGS
None.
D.PRESENTATIONS
1. Tentative Project Schedule for the General Plan Update
Steve Weiss, Planning & Development Services Director gave the PowerPoint
presentation for this item.
PUBLIC COMMENT
None.
RECEIVE AND FILE TENTATIVE PROJECT SCHEDULE FOR GENERAL PLAN
UPDATE
RESULT: NO ACTION TAKEN
Minutes Acceptance: Minutes of Aug 20, 2020 6:30 PM (CONSENT CALENDAR)
E. INFORMATION TO COMMISSIONERS
Steve Weiss, Planning & Development Services Director informed the Planning
Commission that there will be more meetings and workshops scheduled throughout the
remainder of the 2020 calendar year.
City of Grand Terrace Page 2
Packet Pg. 5
A.1
Minutes Grand Terrace Planning Commission/Site and Architectural Review Board August 20, 2020
Directo
Engineer, Craig Bradshaw.
F. INFORMATION FROM COMMISSIONERS
Commissioner McConnell requested information from staff on the following:
Assembly bills that may affec
Taco Bell and its building plans
Lewis Group
Greens Group
Commissioner Alaniz urged everyone to get a COVID-19 test.
ADJOURN
Chairman Giroux adjourned the Regular Meeting of the Planning Commission/Site and
Architectural Review Board at 7:00 p.m. The Next Regular Meeting of the Planning
Commission/Site and Architectural Review Board will be held on September 3, 2020 at
6:30 p.m.
_________________________________ _________________________________
Edward Giroux, Chairman of the Grand Debra L. Thomas, City Clerk for the City of
Terrace Planning Commission Grand Terrace
Minutes Acceptance: Minutes of Aug 20, 2020 6:30 PM (CONSENT CALENDAR)
City of Grand Terrace Page 3
Packet Pg. 6
D.1
AGENDA REPORT
MEETING DATE:September 17, 2020
TITLE:Presentation on Vehicle Miles Traveled Thresholds for
Analysis of Traffic Impacts Under the California
Environmental Quality Act
PRESENTED BY:Steven Weiss, Planning & Development Services Director
RECOMMENDATION:Receive and file
BACKGROUND:
At its regular meeting on July 14, 2020, the City Council conducted a public hearing and
adopted Resolution 2020-26 (Exhibit A) establishing Vehicle Miles Traveled (VMT)
thresholds under the California Environmental Quality Act (CEQA).
Senate Bill 743 (SB 743) has changed the focus for preparing a transportation impact
analysis in CEQA documents (e.g. Environmental Impact Reports), replacing Level of
Service (LOS) with VMT and providing streamlined review of land use and
transportation projects that will help reduce future VMT growth. This shift in
transportation impact focus is expected to better align transportation impact analysis
G)
emissions, encourage infill development, and improve public health through more
realistic,active,and safe alternative options to get to desired destinations like walking
and biking.
VMT measures the number of vehicles (trips) multiplied by the distance they travel (trip
lengths). We routinely analyze VMT for air quality and greenhouse gas impact analysis.
SB 743 adds VMT to the transportation impact analysis of CEQA documents.
Transportation impacts under CEQA now focuses on increases in vehicle trips and trip
lengths, rather than delay and capacity at intersections.
The City can still require developments to complete a Traffic Study which includes LOS
assessment to ensure adequate infrastructure is improved through conditions of
approval but is no longer the required metric under CEQA.
DISCUSSION:
proposed project meet a determined threshold, it requires public agencies to evaluate
the environmental effects of a project before action is taken. CEQA also aims to prevent
significant environmental effects from occurring as a result of agency actions by
requiring agencies to avoid or reduce, when feasible, the significant environmental
impacts of their decisions.
Packet Pg. 7
D.1
On December 28,2018, the Office of Administrative Law approved a comprehensive
update to the state CEQA Guidelines which also included implementation metrics for
VMT. Since VMT is a new method in analyzing transportation impacts, a work study
session was held with the City Council on June 16, 2020 to gather input. Following the
meeting, the CEQA guidelines were revised to include thresholds specific to Grand
Terrace.
Vehicle Miles Traveled Thresholds
VMT is the new metric for transportation analysis which focuses on the overall miles
traveled by vehicles within a region, resulting in automobile delay (Level of Service -
LOS) that is no longer used as criteria for determining a significant environmental effect
under CEQA. This approach has an added inherent emphasis on reducing greenhouse
gas emissions. Therefore, Fehr & Peers, an expert firm in VMT analysis, assisted in
review and development of appropriate VMT thresholds for Grand Terrace to be fully
compliant with CEQA law.
City staff participated in a collaborative study led by SBCTA which evaluated the tools,
thresholds, and mitigation options appropriate for the San Bernardino County region.
Staff attended workshops on October 23, 2020, February 3, 2020, and March 30, 2020
on VMT. Vehicle Miles Traveled thresholds for Grand Terrace have been incorporated
within the draft Local CEQA Guidelines.
In the recommendations provided by SBCTA, four (4) VMT methodologies were used
for the purpose of VMT analysis. The methodologies recommended by SBCTA are
based on the guideli
Southern California Association of Governments (SCAG), and California Air Resource
Board (CARB). The four methodologies are as follows and fully discussed in the City of
le Miles Travelled (VMT) Guidelines attached as Exhibit B:
1. Rely on the OPR Technical Advisory Thresholds (15% reduction below existing
baseline conditions).
2. Set Thresholds Consistent with Lead Agency Air Quality, GHG Reduction, and
Energy Conservation Goals.
3. Set Thresholds Consistent with RTP/SCS Future Year VMT Projections by
Jurisdiction or Sub-Region.
4. Set Thresholds Based on Baseline VMT Performance.
As a result, automobile delay, as measured by LOS, generally no longer constitutes a
significant environmental effect under CEQA. Adopting VMT thresholds, however, does
not preclude the City from using LOS analysis to comply with Congestion Management
Plan requirements or to conduct project specific transportation analysis.
City of Grand Terrace Threshold Selection
The City will utilize the San Bernardino County Travel Demand Model (SBTAM) as its
Packet Pg. 8
D.1
impact, and utilize a threshold consistent with Exhibit A, Table 1 of Resolution 2020-26.
This threshold is consistent with how all other resource areas are currently evaluated
under CEQA.
Exhibit A
Table 1 VMT Impact Thresholds
Methods Project Threshold Cumulative Threshold
Land Use Plans (such as General Plans and Specific Plans)
A significant impact would A significant impact would occur
San Bernardino Traffic Analysis
occur if the project VMT/SP if the project caused total daily
Model (SBTAM) forecast of total
(for the land use plan) VMT within the City to be higher
daily VMT/SP. - To capture project
exceeds the Countywide than the no project alternative
effect, the same cumulative year
average. under cumulative conditions.
population and employment
growth totals should be used. The
allocation.
NA A significant impact would occur
Consistency check with SCAG
if the project is determined to be
RTP/SCS. - Is the proposed
inconsistent with the RTP/SCS.
project within the growth
projections in the RTP/SCS?
Land Use Projects
Presumed less than significant Project presumption applies
Transit Priority Area (TPA)
VMT impact for projects under cumulative conditions as
screening.
located in TPAs. long as project is consistent with
SCAG RTP/SCS.
Presumed less than significant Project presumption applies
Low VMT area screening.
VMT impact for projects under cumulative conditions as
located in low VMT generating long as project is consistent with
model traffic analysis zones SCAG RTP/SCS.
(TAZs). These TAZs generate
total daily VMT/SP that is 15%
less than the baseline level for
the County.
Local serving retail projects Project presumption applies
Project type screening.
under cumulative conditions as
Advisory less than 50,000 long as project is consistent with
square feet) and neighborhood SCAG RTP/SCS.
schools are presumed to have
a less than significant VMT
impact. Projects that generate
less than 110 daily trips do not
require VMT analysis.
A significant impact would A significant impact would occur
VMT analysis using SBTAM
occur if the project VMT/SP if the project is determined to be
forecast of total daily VMT/SP.
exceeds the Countywide inconsistent with the RTP/SCS.
average. A significant impact would occur
if the project causes total daily
VMT within the City to be higher
than the no project alternative
under cumulative conditions. This
analysis should be performed
Transportation Projects (thresholds may apply for SB 743 or GHG purposes)
Packet Pg. 9
D.1
A significant impact would A significant impact would occur
SBTAM forecast of total citywide
occur if the project increased if the project caused total daily
daily VMT
the baseline VMT within the VMT within the City to be higher
City. than the no build alternative
under cumulative conditions.
NA A significant impact would occur
Consistency check with SCAG
if the project is determined to be
RTP/SCS
inconsistent with the RTP/SCS.
The intent of SB 743 is to promote infill development and reduce GHGs - promoting
development in VMT-efficient areas (i.e. Cities that have VMT per service population
below the County average). According to data produced by the latest version of the San
Bernardino Transportation Analysis Model (SBTAM, the City of Grand Terrace has an
average existing VMT per service population below the San Bernardino County average
existing VMT per service population.
This threshold is consistent with how all other resource areas are currently evaluated
under CEQA. It should be noted such local serving projects and as schools, childcare
and neighborhood serving retail are exempt from VMT analysis.
Comparing back to the county average would encourage development in this VMT-
efficient location and would further the legislative intent of SB 743. City staff determined
that this most closely aligns with the local goals, vision, and values of the City of Grand
Terrace. The adopted threshold will result in less than significant transportation
impacts.
ATTACHMENTS:
Exhibit A_Resolution 2020-26 (PDF)
Exhibit B Guidelines_TIA -2020 (PDF)
APPROVALS:
Steven Weiss Completed 09/10/2020 10:28 AM
City Attorney Completed 09/10/2020 11:34 AM
Steven Weiss Completed 09/10/2020 2:06 PM
Planning Commission/Site And Architectural Review Board Pending 09/17/2020 6:30
PM
Packet Pg. 10
D.1.a
Attachment: Exhibit A_Resolution 2020-26 (Vehicle Miles Traveled (VMT) Presentation)
Packet Pg. 11
D.1.a
Attachment: Exhibit A_Resolution 2020-26 (Vehicle Miles Traveled (VMT) Presentation)
Packet Pg. 12
D.1.a
Attachment: Exhibit A_Resolution 2020-26 (Vehicle Miles Traveled (VMT) Presentation)
Packet Pg. 13
D.1.a
Attachment: Exhibit A_Resolution 2020-26 (Vehicle Miles Traveled (VMT) Presentation)
Packet Pg. 14
D.1.a
Attachment: Exhibit A_Resolution 2020-26 (Vehicle Miles Traveled (VMT) Presentation)
Packet Pg. 15
This page left intentionally blank.
D.1.b
City of Grand Terrace Traffic Impact
Analysis(Guidelines
July2020
1
Packet Pg. 16
D.1.b
Table of Contents
Background Error! Bookmark not defined.
Background Information ................................................................................................................................................... 4
Guidelines Organization.................................................................................................................................................... 6
Introduction Error! Bookmark not defined.
CEQA Changes ......................................................................................................... Error! Bookmark not defined.
Need for Level of Service Analysis 7
CEQA Assessment - VMT Analysis 20
Analysis Methodology .....................................................................................................................................................21
CEQA VMT Impact Thresholds .....................................................................................................................................25
VMT Mitigation Measures ..............................................................................................................................................26
CEQA Assessment - Active Transportation and Public Transit Analysis 28
Transportation Impact Analysis Format ....................................................................................................................30
Attachments 33
Detailed VMT Forecasting Information .....................................................................................................................34
Attachment: Exhibit B Guidelines_TIA -2020 (Vehicle Miles Traveled (VMT) Presentation)
2
Packet Pg. 17
D.1.b
Grand Terrace TIA Guidelines
June 2020
Introduction
Attachment: Exhibit B Guidelines_TIA -2020 (Vehicle Miles Traveled (VMT) Presentation)
3
Packet Pg. 18
D.1.b
Grand Terrace TIA Guidelines
July 2020
One of the fundamental roles of government agencies is the construction and maintenance of
public infrastructure facilities including roadways, rail and bus facilities, bicycle and pedestrian
infrastructure, water lines, sanitary sewer lines, stormwater treatment facilities, parks, and other
public facilities.
When private development occurs, it is the responsibility of government to ensure that there are
adequate public facilities to serve incremental population and employment growth. For the
transportation system, one way to address this issue is the preparation of a Traffic Impact Analysis
(TIA).
For the past several decades, the preparation of a TIA was integrated into the CEQA process, in
s under CEQA. However, with the
passage of SB 743, changes to the TIA process are necessary. Specifically, a TIA may be needed as
a stand-alone document which is a requirement of project approval and will include information
for the decision makers that is not required as part of the CEQA process.
The purpose of Transportation Impact Analysis (TIA) Guidelines is to provide general instructions
for analyzing the potential transportation impacts of proposed development projects. These
guidelines present the recommended format and methodology that should generally be utilized in
the preparation of TIAs. These recommendations are general guidelines and the City has the
discretion to modify the TIA requirements based on the unique characteristics of a particular
project.
Background Information
SB 743, signed by the Governor in 2013, is changing the way transportation impacts are identified.
Specifically, the legislation has directed the Office of Planning and Research (OPR) to look at
different metrics for identifying transportation as a CEQA impact. The Final OPR guidelines were
released in December 2018 and identified vehicle miles of travel (VMT) as the preferred metric
moving forward. The Natural Resources Agency completed the rule making process to modify the
CEQA guidelines in December of 2018. The CEQA Guidelines identify that, by July of 2020 all lead
agencies must use VMT as the new transportation metric for identifying impacts for land use
project.
In anticipation of the change to VMT, the City of Grand Terrace recently completed a SB 743
Implementation Study in partnership with SBCTA in support of agencies throughout the county.
Attachment: Exhibit B Guidelines_TIA -2020 (Vehicle Miles Traveled (VMT) Presentation)
This regional approach focuses on important implementation questions about the methodology,
thresholds, and mitigation approaches for VMT impact analysis. The regional approach includes
the following main components.
Thresholds Evaluation Memorandum Potential thresholds agencies could consider when
establishing thresholds of significance for VMT assessment
Sample Projects Memorandum Types of VMT that could be considered for impact
assessment and how project assessment could be performed.
4
Packet Pg. 19
D.1.b
Grand Terrace TIA Guidelines
July 2020
Tools Evaluation Memorandum Types of tools that could be used to estimate VMT and
the pros/cons associated with each tool
Mitigation Memorandum Types of mitigation that can be considered for VMT
VMT Screening Tool An on-line GIS tool that can be used for VMT screening. This tool is
currently under development but will be available for all SBCTA member agencies to use.
As noted in CEQA Guidelines Section 15064.7(b) below, lead agencies are encouraged to formally
adopt their significance thresholds and this is key part of the SB 743 implementation process.
(b) 9ğĭŷ ƦǒĬƌźĭ ğŭĻƓĭǤ źƭ ĻƓĭƚǒƩğŭĻķ Ʒƚ ķĻǝĻƌƚƦ ğƓķ ƦǒĬƌźƭŷ ƷŷƩĻƭŷƚƌķƭ ƚŅ ƭźŭƓźŅźĭğƓĭĻ ƷŷğƷ ƷŷĻ ğŭĻƓĭǤ ǒƭĻƭ
źƓ ƷŷĻ ķĻƷĻƩƒźƓğƷźƚƓ ƚŅ ƷŷĻ ƭźŭƓźŅźĭğƓĭĻ ƚŅ ĻƓǝźƩƚƓƒĻƓƷğƌ ĻŅŅĻĭƷƭ͵ ŷƩĻƭŷƚƌķƭ ƚŅ ƭźŭƓźŅźĭğƓĭĻ Ʒƚ ĬĻ ğķƚƦƷĻķ ŅƚƩ
ƚĭĻƭƭ ƒǒƭƷ ĬĻ ğķƚƦƷĻķ ĬǤ ƚƩķźƓğƓĭĻͲ
ƩĻƭƚƌǒƷźƚƓͲ ƩǒƌĻͲ ƚƩ ƩĻŭǒƌğƷźƚƓͲ ğƓķ ķĻǝĻƌƚƦĻķ ƷŷƩƚǒŭŷ ğ ƦǒĬƌźĭ ƩĻǝźĻǞ ƦƩƚĭĻƭƭ ğƓķ ĬĻ ƭǒƦƦƚƩƷĻķ ĬǤ ƭǒĬƭƷğƓƷźğƌ
ĻǝźķĻƓĭĻ͵ \[Ļğķ ğŭĻƓĭźĻƭ ƒğǤ ğƌƭƚ ǒƭĻ ƷŷƩĻƭŷƚƌķƭ ƚƓ ğ ĭğƭĻΏĬǤΏĭğƭĻ Ĭğƭźƭ ğƭ ƦƩƚǝźķĻķ źƓ {ĻĭƷźƚƓ ЊЎЉЏЍΛĬΜΛЋΜ͵
Is Level of Service (LOS) Still Important?
The City has adopted vehicle LOS policies that set standards for which local agency infrastructure
will strive to maintain. These policies are contained in the General Plan and therefore apply to
discretionary approvals of new land use and transportation projects. Therefore, these guidelines
also include instructions for vehicle LOS analysis consistent with General Plan requirements. The
LOS guidelines are largely based on the SBCTA Congestion Management Plan (CMP) guidelines
that were updated in 2016 and reflect state of the practice.
CEQA Changes
Since the last CMP TIA Guidelines update, SB 743 was finalized through the rule making process. A
key element of this law is the elimination of auto delay, level of service (LOS), and other similar
measures of vehicular capacity or traffic congestion as a basis for determining significant impacts.
This change is intended to assist in balancing the needs of congestion management with statewide
goals related to infill development, promotion of public health through active transportation, and
reduction of greenhouse gas emissions.
SB 743 contains amendments to current congestion management law that allows cities and
counties to effectively opt-out of the LOS standards that would otherwise apply in areas where
Congestion Management Plans (CMPs) are still used (including San Bernardino County). Further, SB
Attachment: Exhibit B Guidelines_TIA -2020 (Vehicle Miles Traveled (VMT) Presentation)
and establish criteria for determining the significance of transportation impacts. In December 2018,
OPR released their final recommended guidelines based on feedback with the public, public
agencies, and various organizations and individuals. OPR recommended Vehicle Miles Traveled
(VMT) as the most appropriate measure of project transportation impacts for land use projects and
land use plans. For transportation projects, lead agencies may select their own preferred metric
but must support their decision with substantial evidence that complies with CEQA expectations.
SB 743 does not prevent a city or county from continuing to analyze delay or LOS outside of CEQA
5
Packet Pg. 20
D.1.b
Grand Terrace TIA Guidelines
July 2020
review for other transportation planning or analysis purposes (i.e., general plans, impact fee
programs, corridor studies, congestion mitigation, or ongoing network monitoring); but these
metrics may no longer constitute the sole basis for CEQA impacts.
These updated TIA Guidelines have been designed to comply with the new CEQA Guidelines
expectations and build on the infor
Guidelines Organization
The remainder of this guidelines document is organized as follows. We have attempted to organize
this memorandum to provide background information, assessment for congestion management/
General Plan Consistency (e.g. LOS analysis), and CEQA assessment (e.g. VMT analysis).
1. Introduction
2. Need for Level of Service Analysis
3. CEQA Assessment - VMT Analysis
4. CEQA Assessment - Active Transportation and Public Transit Analysis
5. Transportation Impact Analysis Format
Attachment: Exhibit B Guidelines_TIA -2020 (Vehicle Miles Traveled (VMT) Presentation)
6
Packet Pg. 21
D.1.b
Grand Terrace TIA Guidelines
July 2020
Need for Level of Service
Analysis
Attachment: Exhibit B Guidelines_TIA -2020 (Vehicle Miles Traveled (VMT) Presentation)
7
Packet Pg. 22
D.1.b
Grand Terrace TIA Guidelines
July 2020
These guidelines describe the key elements required for preparing Traffic Impact Analysis Reports
(TIA Reports) consistent with the countywide goals toward the Congestion Management Program
(CMP) in San Bernardino County.
TIA Reports shall be prepared by applicants for land use projects when local criteria and thresholds
indicate they are necessary. However, TIA Reports must be prepared to satisfy CMP requirements,
when a proposed change in land use, development project, or at local discretion, a group of projects
are forecast to equal or exceed the CMP threshold of 250 two-way peak hour trips generated, based
on trip generation rates published for the applicable use or uses in the Institute of Transportation
Engineers' Trip Generation or other CMA-approved data source. Pass-by trips shall not be
considered in the threshold determination. However, industrial, warehousing and truck projects
(although, for intersection assessment,
the report could appropriately adjust the highway capacity manual capacity factors to reflect the
increase in heavy vehicles).
A TIA which includes LOS analysis shall be required for a proposed project that meets any of the
following criteria:
When either the AM or PM peak hour trip generation is expected to exceed 100 vehicle
trips from the proposed development.
Projects that will add 51 or more trips during either the AM or PM peak hours to any
intersection.
Any project where variations from the standards and guidelines provided in this manual
are being proposed.
When determined by the City Traffic Engineer that existing or proposed traffic conditions
in the project vicinity have unique characteristics that warrant evaluation.
TIA Report Content for Level of Service Analysis
The TIA Report may be contained within other similar documents (e.g. an EIR prepared under
CEQA), or it may be an independent document. The intent is to address all CMP concerns without
duplication of other work. In some jurisdictions, the TIA Report may be prepared by the developer
or developer's consultant. In other jurisdictions, the TIA Report may be prepared by the jurisdiction
or jurisdiction's consultant. In either case, it is in the interest of all parties that the participants fully
understand and come to agreement on the assumptions and methodology prior to conducting the
actual analysis. This is particularly important when considering using assumptions that vary from
the norm. The City may request a meeting with the developer and/or preparer of the TIA Report to
Attachment: Exhibit B Guidelines_TIA -2020 (Vehicle Miles Traveled (VMT) Presentation)
discuss the methodology prior to the initiation of work on the analysis. A meeting with the CMA
and/or Caltrans, where applicable, is also encouraged to address issues associated with large or
extraordinary projects.
The following outline and commentary represent the recommended structure for the TIA Report.
8
Packet Pg. 23
D.1.b
Grand Terrace TIA Guidelines
July 2020
I. Introduction
Set the stage for the analysis, providing background information necessary for the unfamiliar reader
to understand the magnitude of the project, location of the project and special characteristics.
Project, general plan, or specific plan description
The description must include project size by land use type, location of project, approximate location
of proposed access points to the local and regional roadway system and movements from adjacent
streets allowed into and out of the project. This should be shown in a site diagram. Special
characteristics of the site, such as unusual daily or seasonal peaking characteristics or heavy
involvement of truck traffic, should be mentioned. If the description is included in another part of
a more comprehensive document, that is acceptable.
Analysis methodology
Provide a general description (overview) of the process used to analyze the project. Analysis years
should be specified and the approach to the modeling/traffic forecasting process should be
explained. The sources of information should be identified. The study area and method for LOS
analysis for the various roadway types should be identified. At a minimum, the study area must
include all freeway links with 100 or more peak-hour project trips (two-way) and other CMP
roadways with 50 or more peak-hour project trips (two-way). The study area does not end with a
city or county boundary. The study area is defined by the magnitude of project trips alone. In most
cases, the analysis need not extend more than five miles beyond the project site, even if there are
more than 50 project trips on an arterial and 100 project trips on a freeway. However, analysis of
projects in isolated areas with few access routes should be continued until the 100 or 50-trip
threshold is met. Within the defined study area, all "key intersections," as listed in the most current
CMP, must be analyzed. Key intersections represent intersections of CMP roadways plus those
additional intersections recognized by local jurisdictions and/or SBCTA to be important to mobility
on CMP roadways. At a minimum, key intersections will include signalized intersections operating
at LOS D or below. The distribution of traffic must be shown for all roadways on which project trips
occur (except those for internal circulation), whether they are on the CMP network.
The analysis of traffic operations and LOS is to be provided for the following conditions and is to
include an assessment of required traffic improvements for project opening day and future
conditions.
Attachment: Exhibit B Guidelines_TIA -2020 (Vehicle Miles Traveled (VMT) Presentation)
1. Existing conditions the conditions at the time of TIA preparation without the inclusion
of the project generated trips. Existing deficiencies should be identified, but analysis of
improvements is not required. The existing conditions analysis must include the full project
effect area as defined above.
2. Project opening day conditions - the conditions on the opening day of the project for
two scenarios: 1) excluding the project traffic and 2) including the project traffic. Assume
full trip generation effect of the site. Full improvement analysis is to be performed for
9
Packet Pg. 24
D.1.b
Grand Terrace TIA Guidelines
July 2020
project opening day conditions. If it is deemed more appropriate because of the nature of
the project, another intermediate scenario may be included to focus on the access
requirements and/or immediate area surrounding the project, subject to a request by the
City of Grand Terrace. The methodology used for distribution of project traffic at project
opening day conditions is at the discretion of the City.
3. Future conditions - the conditions for two model forecast year scenarios: 1) excluding
the project traffic and 2) including the project traffic. Full improvement analysis is to be
performed for future conditions. In addition, a staging analysis of improvements may be
required for large projects constructed over a long time period. The need for a staging
analysis will be determined by the City.
The analysis of the project opening day and future condition shall be based on, at a minimum, the
PM peak-hour of the adjacent street traffic. An analysis of the AM peak hour of the adjacent street
traffic is also required for developments containing residential land uses and may be required for
other types of development at local discretion. Analysis may be required for peak-hours other than
the AM and PM peak for some land uses. This determination will be made by the local jurisdiction.
The peak traffic generation hour of the development, if different from peak AM and PM hours, must
also be identified and the total vehicle trips during the peak-hour of the generator must be
estimated. This will facilitate a decision regarding the need to evaluate time periods other than the
peak-hours of the adjacent streets.
II. Existing conditions
Existing roadway system
Provide a map and brief written description of the roadway network. The number and type of lanes
on freeways, principal arterials and other affected roadways should be identified. Signalized
intersections and plans for signalization should be identified. The existing number of lanes at key
CMP intersections should be clearly identified on a graphic or in conjunction with the LOS analysis
output. Maps of the CMP network are available in the Congestion Management Program
documentation, available from the CMA. Also describe the relevant portions of the future network
as specified with officially approved funding sources.
Existing volumes
Existing average weekday daily traffic (AWDT) should be identified for the CMP links in the study
Attachment: Exhibit B Guidelines_TIA -2020 (Vehicle Miles Traveled (VMT) Presentation)
area. Historic volume growth trends in the study area should be shown. Consult the local
jurisdiction, Caltrans and San Bernardino County for additional information.
Existing LOS
A LOS analysis must be conducted on all existing segments and intersections on the CMP network
potentially affected by the project or plan (as defined by the thresholds in Section I. B). Urban
segments (i.e., segments on roadways that are generally signalized with spacing less than 2 miles)
10
Packet Pg. 25
D.1.b
Grand Terrace TIA Guidelines
July 2020
do not require segment analysis. Segment requirements can normally be determined by the analysis
of lane requirements at intersections. Freeway mainline must be analyzed and ramp/weaving
analysis may be required at local discretion if a ramp or weaving problem is anticipated. Several
software packages are available for conducting LOS analysis for signalized intersections, freeways
and other types of roadways. The software package and version used must be identified. Normally,
the existing LOS analysis for intersections will be run using optimized signal timing, since the future
analysis will normally need to be run using optimized timing. Signal timing optimization should
consider pedestrian safety and signal coordination requirements. Minimum times should be no less
than 10 seconds.
Saturation flow rates are considered as average field measured saturation flow rates and in no case
shall the adjusted saturation flow rates of the 2000 Highway Capacity Software be allowed to go
lower than the specified saturation flow rates listed on page C-13 of the CMP, when field data are
not available. However, there shall be no restriction on minimum saturation flow rates if actual
saturation flow rates are available.
Default lost time is two seconds per phase and a clearance signal time of three seconds. Without
local data to show otherwise, a peak-hour factor of 0.95 may be assumed for existing and full
generation scenarios. Variations from these values must be documented and justified. LOS analyses
should be field verified so that the results are reasonably consistent with observation and errors in
the analysis are more likely to be caught. A brief commentary on existing problem areas must be
included in this section, bringing existing problems to the attention of the readers.
Only project opening day and future scenarios with project require that traffic operational problems
be addressed to provide LOS E or better operation. If the lead agency or an affected adjacent
jurisdiction requires improvements to a higher LOS, this takes precedence over the CMP
requirements. The LOS threshold for State highway facilities will be the same as the jurisdiction
where the facility is located but no greater than a 45 second average delay per vehicle in the peak
not always be feasible and
recommends that the lead agency consult with Caltrans to determine the appropriate target LOS.
If an existing State highway facility is operating at less than the appropriate target LOS, the existing
LOS should be maintained.
Related general plan issues
The relationship to the general plan may be identified. This section should provide general
background information from the Traffic Circulation Element of the General Plan, including plans
Attachment: Exhibit B Guidelines_TIA -2020 (Vehicle Miles Traveled (VMT) Presentation)
for the ultimate number of lanes, new roadways planned for the future and other information that
provides a context for how the proposed project interrelates with the future planned transportation
system.
11
Packet Pg. 26
D.1.b
Grand Terrace TIA Guidelines
July 2020
III. Future conditions
Traffic forecasts
One of the primary products of the TIA is the comparison of future traffic conditions with and
without the project. The primary forecasts will be for the CMP forecast year (consult the CMA for
the most currently applicable forecast years). If a project is phased over a development period past
the CMP forecast year, a buildout forecast with forecast background traffic must also be provided.
There are two components of the forecast that need to be considered: background traffic and
project traffic. Acceptable methodologies for these forecasts are described below.
Project Traffic Forecasts
Two basic alternatives are available for forecasting project traffic:
Manual method - Generate project trips using rates from the ITE Trip Generation report.
Distribute and assign the trips based on the location of the project relative to the remainder of
the urban area and on the type of land use. Rather than relying on pure judgment to develop
the distribution of project traffic, the future year CMP model select zone needs to be obtained
from SCAG to determine the distribution pattern. The percentage distribution should be
reasonably related to the location of and the number of trips generated by zones surrounding
the project. Computer-assisted trip distribution and assignment methods may be used as long
as they reasonably represent the travel characteristics of the area in which the project is located.
It should be noted that the model does not forecast project trucks. Therefore, distribution needs
to be made in a reasonable manner.
Use of local model - Create a zone or zones that represent the project (if not already contained
in the local model). The CMP model may be used if new zones are created to represent the
project (it is unlikely that the CMP model will already have zones small enough to represent the
project). The zone or zones should include the exact representation of driveway locations with
centroid connectors. It is important that the driveway representations be exact to produce
acceptable turning movement volumes. Some adjustments to the turning movement volumes
may be needed, depending on the adequacy of this representation.
The above methodologies may produce different results, both in the generation of trips and the
distribution of trips. However, both methods will have application, depending on the jurisdiction
and on the type and size of project. It should be noted that a model select zone run shall be used
for distribution and ITE trip generation rates for project trips.
Attachment: Exhibit B Guidelines_TIA -2020 (Vehicle Miles Traveled (VMT) Presentation)
Background Traffic Forecasts
Background traffic refers to all traffic other than the traffic associated with the project itself. The
background traffic shall include intersection turning movement and segment truck volumes by
classification (converted to PCE's) as shown on page C-12 on arterial streets of the CMP, interchange
ramps and mainline freeway lanes. Future scenarios shall use the truck model (converted to PCEs)
or 150 percent of the existing truck volume for arterials and freeway ramps and 160 percent for
12
Packet Pg. 27
D.1.b
Grand Terrace TIA Guidelines
July 2020
mainline freeway lanes in a special generator area such as found in the City of Fontana (between I-
15 and Citrus Avenue and between San Bernardino Avenue and Jurupa Avenue).
Several alternatives for forecasting background traffic are:
For project opening day analysis - Use accepted growth rates provided by the jurisdictions in
which the analysis is to take place. Each jurisdiction's growth rates should be used for
intersections and segments within that jurisdiction. A table of growth rates may be available
from the jurisdictions.
For horizon year - The traffic passenger vehicle and truck classification (in PCEs) models will
provide the needed forecasts and if requested, passenger vehicle background plus project
forecasts. Local models may also be used to generate intersection and segment forecasts, if a
traffic refinement process is properly applied to maximize the quality and reasonableness of
the forecasts. Alternatively, the CMP model may be used to generate growth factors by subarea,
which may be applied to existing intersection and segment volumes. The separate forecasting
of background traffic by each TIA Report preparer is redundant, will only create conflict among
reports and should be avoided by the city/county providing an acceptable background forecast
for use by all TIA Report preparers. Ideally, cities and/or the County should establish the
background forecasts annually for use by project applicants. Until the city/county is in a position
to produce these forecasts on a routine basis, they may wish to use the results of the
background forecasts from prior acceptable TIA Reports as the basis for background forecasts
for other TIA Reports. The availability of such forecasts should be established before initiating
the preparation of a TIA Report. If the CMP model is being used as the basis for the forecast,
assume that the project is not included in the CMP model forecast (unless it can be definitively
proven otherwise). If a local model is being used, the background traffic will be derived by
subtracting the project traffic from the forecast where the project is already represented in the
model. Where the project is not represented in the model, the background traffic can be directly
derived from the model (with appropriate refinement to maintain quality and reasonableness
of the forecasts).
A Note on Methodology for General Plans and Specific Plans:
In the case of analysis of general plan revisions/updates or specific plans, the same approach is
applied as above. However, the "project" to be analyzed shall consist of the proposed land use. For
threshold determination use the difference between the previously approved general plan and the
proposed revision to the general plan. Unless otherwise agreed by the City, the analysis must
Attachment: Exhibit B Guidelines_TIA -2020 (Vehicle Miles Traveled (VMT) Presentation)
assume the maximum intensity of land uses allowed (i.e., worst case) on the parcels to which the
revision applies. All new specific plans must be analyzed based on worst case assumptions.
Although general plans may not identify specific access locations, the analysis must assume access
locations that are reasonable, based on the location and size of the plan.
A. Traffic added by project, general plan revision/update, or specific plan
13
Packet Pg. 28
D.1.b
Grand Terrace TIA Guidelines
July 2020
The methods for generating and distributing project trips must be consistent with the appropriate
methodology listed above. The total number of trips generated by the project must be specified
by land use. The source of the trip generation rates must be documented. Project trips (inbound
and outbound) must be identified on a graphic map for both the peak hour or hours being studied.
Any assumed reductions in trip generation rates, such as internal trips and transit/TDM reductions
must be documented. Pass-by trips may be allowed only for retail uses and fast-food restaurants.
The pass-by and internal trip percentages and methodology must be consistent with the estimates
and methodology contained in the latest ITE Trip Generation handbook. The internal trip
percentage must be justified by having a mixed-use development of sufficient size. In special cases,
larger reductions may be allowed; but these must be documented and justified. Reductions for
transit or TDM must be accompanied by an explanation of how the strategies will actually be
implemented and may require a monitoring program.
Industrial and warehouse truck uses must also show the estimated number and distribution of
the same hours. The methodology utilized to obtain trip generation rates
and truck percentages applied in traffic impact analyses for industrial and warehouse (including
-latest edition
City.
B. Transit and TDM considerations
Transit and travel demand management strategies are a consideration in many development
projects. Requirements within each jurisdiction are contained in the local TDM ordinance, to be
adopted by each local jurisdiction as part of the CMP requirements. Examples of items to include
are location of transit stops in relationship to the proposed project, designation of ridesharing
coordinator, posting of information on transit routes and ridesharing information, provision of
transit passes, etc.
C. Traffic model forecasts
Provide a map showing link volumes by direction. All CMP arterial links with 50 or more peak-hour
project trips (two-way) and freeway links with 100 or more peak-hour project trips (two-way) must
be shown. The factor to derive a peak-hour from the three-hour AM peak period is 0.38. The factor
to derive a peak-hour from the four-hour PM peak is 0.28. All model forecasts shall be post
processed. Appendix E in the CMP documentation contains guidelines for model post processing.
Attachment: Exhibit B Guidelines_TIA -2020 (Vehicle Miles Traveled (VMT) Presentation)
D. Future LOS
Compute levels of service for CMP segments and intersections based on the procedures in the
latest Highway Capacity Manual. Refer to the procedures adopted in Chapter 2 of the CMP and the
assumptions specified in section II.C of this appendix. Copies of the volumes, intersection
geometry, capacity analysis worksheets and all relevant assumptions must be included as
appendices to the TIA Report. It should be noted that the v/c ratio and implied LOS that can be
14
Packet Pg. 29
D.1.b
Grand Terrace TIA Guidelines
July 2020
output by travel demand models are different from the LOS analysis prescribed in this section. The
capacities used in the model are not typically the same capacities as used in the capacity analysis.
Intersections and segments on State highway facilities should be analyzed as a coordinated system.
Left turn, through and right turn lane queuing analysis is highly desirable to validate an
intersection's LOS. This more detailed analysis is meant to ensure the various movements do not
overflow and impede adjacent movements and is left to the discretion of the City.
E. Description of projected LOS problems
Identify resulting levels of service for intersections and segments, as appropriate, on a map for
applicable peak-hours. Describe in the text the nature of expected LOS problems. Describe any
other effects that the project may also have on the CMP roadway network, particularly access
requirements.
F. Project contribution to total new volumes (forecast minus existing) on analyzed links
Compute the ratio of traffic generated by the proposed development to the total new traffic
(including project traffic) generated between the existing condition and forecast year for each
analyzed link or intersection. The purpose of this calculation is to identify the proportion of volume
increase that can be attributed to the proposed project. This will be a necessary component of any
deficiency plans prepared under the CMP at a later date. The calculations are to be conducted for
all applicable peak hours. The results may be shown on a map or in a table by percentages to the
nearest tenth of a percent.
IV. Project Deficiencies.
The improvement of project deficiencies is designed to identify potential LOS problems and to
address them before they occur. This will also provide a framework for negotiations between the
local jurisdiction and the project developer. The CMA will not be involved in these negotiations
unless requested by a local jurisdiction. Deficiencies beyond the boundaries of the jurisdiction must
be identified in the same fashion as effects within the jurisdictional boundary. Affected local
agencies outside the boundary will be provided an opportunity for review of the TIA Report.
Negotiations with these outside jurisdictions and with Caltrans are a possible outcome, depending
on the magnitude and nature of the effects.
For the CMP, the improvements must bring the roadway into conformance with the LOS standards
established for the CMP. However, local agencies may require conformance to higher standards,
Attachment: Exhibit B Guidelines_TIA -2020 (Vehicle Miles Traveled (VMT) Presentation)
and these must be considered in consultation with the local jurisdiction. Measures to address local
needs that are independent from the CMP network should be included in the TIA Report for
continuity purposes. Consult the local jurisdiction to determine requirements which may be beyond
the requirements of the CMP. The information required in this part of the TIA Report is described
below.
15
Packet Pg. 30
D.1.b
Grand Terrace TIA Guidelines
July 2020
Other transportation improvements already programmed and fully funded
Only transportation improvements that are fully funded should be assumed in forecast.
Roadway improvements needed to maintain CMP LOS standard
These should include an evaluation of intersection turn lanes, signalization, signal coordination and
link lane additions, at a minimum. If a freeway is involved, lane requirements and ramp treatments
to solve LOS deficiencies must be examined. Prior studies on the same sections may be furnished
to the preparer of the TIA and such studies may be referenced if they do, in fact, provide the
necessary improvement for the proposed project. However, the calculation of percentage of
contribution of the project to the growth in traffic must still be provided for the appropriate peak-
hours, as described earlier. If the physical or environmental constraints make improvements
unlikely, then the contribution may be used to improve LOS elsewhere on the system or another
location that would relieve the effect. The point of referencing a previously conducted study is to
avoid unnecessary duplication of effort on the same sections of roadway. Copies of previously
conducted relevant studies in the area may be obtained from the local jurisdictions or the CMA,
including any plans resulting from the annual modeling runs for the CMP.
Other improvements needed to maintain the LOS standard
In some cases, additional transit and TDM strategies beyond what was in the original assumptions
may be necessary to provide an adequate LOS. These must be described and the method for
implementation must be discussed.
LOS with improvements
The LOS with improvements must be computed and shown on a map or table along with the traffic
LOS without improvements. Delay values, freeway volume/capacity ratios, or other measures of
LOS must be included in the results (could be in an appendix) along with the letter designation.
Cost estimates
The costs of improving deficiencies must be estimated for deficiencies that occur either within or
outside the boundaries of the jurisdiction. The costs must be identified separately for each
jurisdiction and for Caltrans roadways. Prior studies and cost estimates by SANBAG, Caltrans and
other jurisdictions may be referenced. Used together with the analysis conducted in Section III.G,
this will provide an approximation of project contribution to the needed improvements. This
Attachment: Exhibit B Guidelines_TIA -2020 (Vehicle Miles Traveled (VMT) Presentation)
estimate is prepared for discussion purposes with the local jurisdiction and with neighboring
jurisdictions and Caltrans. It does not imply any legal responsibility or formula for contributions to
improvements. If an improvement is identified as necessary to bring a deficiency into conformance
with the LOS standard, but physical or environmental constraints make the improvement
impractical, an equivalent contribution should be considered to improve the LOS elsewhere on the
system or another location providing direct relief. F. Relationship to other elements While the
measures required to address air quality problems are not required for the TIA Report, they may
16
Packet Pg. 31
D.1.b
Grand Terrace TIA Guidelines
July 2020
be required as part of a CEQA review. The TIA Report may be integrated with environmental
documents prepared for CEQA requirements. This is at the discretion of the local jurisdiction.
V. Conclusions and recommendations
Summary of proposed improvements and costs
Provide a summary of the deficiencies, proposed improvements and the costs of the
improvements. A cost estimate for the proposed improvements must be included. Generalized unit
costs will be available from either Caltrans or the local jurisdiction. The source of the unit cost
estimates used must be specified in the TIA Report.
Other recommendations
List any other recommendations that should be brought to the attention of the local jurisdiction,
the CMA, or Caltrans. This may include anticipated problems beyond the forecast year or on
portions of the network not analyzed.
Summary List of Typical Figures and Tables to Be Included in a TIA Report:
Project location and 5-mile limit study area (map)
Project size by land use (table)
Trips generated by land use for AM and PM weekday peak-hours of adjacent street traffic
and for daily traffic inbound and outbound (table) and other applicable peak-hours
List of other planned transportation improvements affecting the project
Existing intersection and link volumes and levels of service (map)
Distribution and assignment of project trips (map)
Forecast traffic without project and with project for applicable peak-hours (map or table)
LImprovements required to address
project opening day and forecast year scenario effects (map and/or table)
Ratio of project traffic to new traffic (new traffic means the difference between existing
and forecast) on analyzed links or intersections (map or
jurisdiction and for Caltrans roadways
Summary of Analysis Assumptions for the TIA:
LOS Analysis Procedures and Assumptions
Attachment: Exhibit B Guidelines_TIA -2020 (Vehicle Miles Traveled (VMT) Presentation)
Intersections
Current HCM operational analysis.
Optimized signal timing/phasing for future signal analysis, unless assumed to be in a
coordinated system, in which case estimated actual cycle length is used. The maximum
cycle length for a single signalized intersection or system should be 130 seconds.
10 second minimum phase time, including change interval.
17
Packet Pg. 32
D.1.b
Grand Terrace TIA Guidelines
July 2020
Average arrivals unless
(12 feet).
"Required" solution if analysis by Webster.
Exclusive right turn lane is assumed to exist if pavement is wide enough to permit a
separate right turn, even if it is not striped. (Minimum 20' from curb line to lane stripe).
2 second lost time/phase.
A full saturation flow rate can be assumed for an extra lane provided on the upstream of
the intersection only if this lane also extends at least 600 feet downstream of the
intersection (or to the next downstream intersection).
PHF = 0.95 for future analysis.
The lane utilization factor may also be set at 1.00 when the v/c ratio for the lane group
approaches 1.0, as lanes tend to be more equally utilized in such situations.
of 1.5. For medium duty trucks with 3 axles use a PCE of 2.0. For heavy duty trucks with 4
axles, use a PCE of 3.0.
Industrial, warehousing and other Projects with high truck percentages should convert to
When field saturation flow rates and any special intersection characteristics are not
available, the following field adjusted saturation flow rates are recommended for analysis.
Existing and Opening Day Scenarios
Exclusive thru: 1,800 vehicles per hour green per lane (vphgpl)
Exclusive left: 1,700 vphgpl
Exclusive right: 1,800 vphgpl
Exclusive double le
Future Scenarios
Exclusive right: 1,900 vphgpl
Exclusive double right: 1,800 vphgpl
Exclusive double left: 1,700 vphgpl
Exclusive triple left: 1,600 vphgpl or less
Note: Existing field saturation flow rates should be used if they are available and any special
traffic or geometric characteristics should also be taken into account if known to affect
Attachment: Exhibit B Guidelines_TIA -2020 (Vehicle Miles Traveled (VMT) Presentation)
traffic flow.
Freeways
Capacity of 2,200 vehicles/hour/lane (1,600/hr/lane/HOV)
Use Caltrans truck percentages (includes trucks, buses and RV's)
Peak-hour factor of 0.98 for congested areas and 0.95 for less congested areas
18
Packet Pg. 33
D.1.b
Grand Terrace TIA Guidelines
July 2020
Directional distribution of 55% and 45%, if using non-directional volumes from Caltrans
volume book
Design speed of 70 mph
Stop Controlled Intersections
Current HCM for 2-way and 4-way stops
Project-Related Assumptions
Use the latest ITE Trip Generation handbook for mixed use internal trip percentages. Higher
percentages must be fully justified.
Pass by trips - Retail uses and fast food restaurants only
Use ITE procedures to estimate percentage
For analysis at entry points into site, driveway volume is not reduced (i.e., trip generation
rate is still the same). Rather, trips are redistributed based on the assumed prevalent
directions of pass-by trips (see recommended ITE procedure).
Reductions for transit or TDM are a maximum of 10% unless higher can be
justified. Other
If a new traffic generating development project (other than a single family
residential unit) within a federally designated urbanized area abuts a state highway
or abuts a highway that intersects a State highway within 500 feet of that
intersection, the local jurisdiction in which the development occurs must notify
Caltrans and the CMA.
The TIA procedures will be reviewed biannually. Forward comments to the CMA.
Industrial warehouse and truck projects may distribute only truck trips by hand.
(Employee trip distribution shall be modeled.)
exceeds 1.0, even if the LOS defined by the delay value is above the defined LOS
standard.
All the computer-generated traffic forecasts need to be refined for use in TIA
reports to provide the best estimate of future volumes possible. Traffic forecasts
should be post processed by us
another approved methodology. However, the post processing of turning
movements is restricted to local models only.
Attachment: Exhibit B Guidelines_TIA -2020 (Vehicle Miles Traveled (VMT) Presentation)
19
Packet Pg. 34
D.1.b
Grand Terrace TIA Guidelines
July 2020
CEQA Assessment - VMT
Analysis
Attachment: Exhibit B Guidelines_TIA -2020 (Vehicle Miles Traveled (VMT) Presentation)
20
Packet Pg. 35
D.1.b
Grand Terrace TIA Guidelines
July 2020
A key element of SB 743, signed in 2013, is the elimination of automobile delay and LOS as the sole
basis of determining CEQA impacts. The most recent CEQA guidelines, released in December 2018,
recommend VMT as the most appropriate measure of project transportation impacts. However, SB
743 does not prevent a city or county from continuing to analyze delay or LOS as part of other
plans (i.e., the General Plan), studies, or ongoing network monitoring.
The following recommendations assist in determining VMT impact thresholds and mitigation
TIAs.
Analysis Methodology
For purposes of SB 743 compliance, a VMT analysis should be conducted for land use projects as
deemed necessary by the Engineering Services Department and would apply to projects that have
the potential to increase the average VMT per service population (e.g., population plus
employment) compared to the City boundary. Normalizing VMT per service population essentially
provides a transportation efficiency metric that the analysis is based on. Using this efficiency metric
allows the user to compare the project to the remainder of the City for purposes of identifying
transportation impacts.
Project Screening
There are three types of screening that lead agencies can apply to effectively screen projects from
project-level assessment. These screening steps are summarized below, and the project needs only
to satisfy one of the potential screening steps:
Step 1: Transit Priority Area (TPA) Screening
1
Projects located within a TPA may be presumed to have a less than significant impact absent
substantial evidence to the contrary. This presumption may NOT be appropriate if the project:
1. Has a Floor Area Ratio (FAR) of less than 0.75;
1
A TPA is defined as a half mile area around an existing major transit stop or an existing stop along a high-
quality transit corridor per the definitions below.
Attachment: Exhibit B Guidelines_TIA -2020 (Vehicle Miles Traveled (VMT) Presentation)
Pub. Resources Code, § 21064.3 - transit station,
a ferry terminal served by either a bus or rail transit service, or the intersection of two or more major bus
routes with a frequency of service interval of 15 minutes or less during the morning and afternoon peak
commute periods.
Pub. Resources Code, § 21155 - -
corridor with fixed route bus service with service intervals no longer than 15 minutes during peak commute
hours.
21
Packet Pg. 36
D.1.b
Grand Terrace TIA Guidelines
July 2020
2. Includes more parking for use by residents, customers, or employees of the project than
required by the City (if the City requires the project to supply parking);
3. Is inconsistent with the applicable Sustainable Communities Strategy (as determined by
the lead agency, with input from the Metropolitan Planning Organization); or
4. Replaces affordable residential units with a smaller number of moderate- or high-income
residential units.
Step 2: Low VMT Area Screening
Residential and office projects located within a low VMT-generating area may be presumed to have
a less than significant impact absent substantial evidence to the contrary. In addition, other
employment-related and mixed-use land use projects may qualify for the use of screening if the
project can reasonably be expected to generate VMT per resident, per worker, or per service
population that is similar to the existing land uses in the low VMT area. A low VMT area is defined
as an individual traffic analysis zone (TAZ) where total daily Origin/Destination VMT per service
population is lower than the City average total daily Origin/Destination VMT per service population.
To identify if the project is in a low VMT-generating area, the analyst may review the SBCTA
screening tool and apply the appropriate threshold (identified later in this chapter) within the tool.
Additionally, as noted above, the analyst must identify if the project is consistent with the existing
3
land use within that traffic analysis zone (TAZ) and use professional judgement to determine that
there is nothing unique about the project that would otherwise be mis-represented utilizing the
data from the travel demand model.
The SBCTA screening tool can be accessed at the following location:
https://devapps.fehrandpeers.com/sbctavmt/
Alternative data sources can be reviewed to further refine low-
commercially available VMT data (e.g. big data). This data source could also be reviewed to
determine if it is in a low VMT area instead of the SBCTA screening tool data.
For low VMT screening to be satisfied, the analyst mush verify that the project land uses would not
alter the existing built environment in such a way as to increase the rate or length of vehicle trips
(e.g., the proposed project is consistent with existing land use in the area, the project would be
expected to contribute VMT consistent with existing land use in the area, and the project would not
significantly alter travel patterns in the area).
Attachment: Exhibit B Guidelines_TIA -2020 (Vehicle Miles Traveled (VMT) Presentation)
Step 3: Project Type Screening
3
TAZs are geographic polygons like Census block groups used to represent areas of homogenous travel
behavior. Service population is population plus employment. Used with VMT, it provides a normalized
standard unit for comparison purposes while accounting for the population and/or employment in a given
area.
22
Packet Pg. 37
D.1.b
Grand Terrace TIA Guidelines
July 2020
Local serving retail projects less than 50,000 square feet may be presumed to have a less than
significant impact absent substantial evidence to the contrary. Local serving retail generally
improves the convenience of shopping close to home and has the effect of reducing vehicle travel.
In addition to local serving retail, the following uses may, at the discretion of the City, be presumed
to have a less than significant impact as their uses are often local serving in nature:
Local parks
Day care centers
Local-serving retail uses less than 50,000 square feet, including:
o Gas stations
o Banks
o Restaurants
o Shopping Center
Student housing projects on or adjacent to college campuses
Local-serving assembly uses (places of worship, community organizations)
Community institutions (Public libraries, fire stations, local government)
Local serving community colleges that are consistent with the assumptions noted in the
RTP/SCS
Hotels (non-destination or resort; no banquet or special event space)
4
Affordable or supportive housing
Assisted living facilities
Senior housing (as defined by HUD)
5
Projects generating less than 110 daily vehicle trips
o This generally corresponds to the
11 single family housing units
16 multi-family, condominiums, or townhouse housing units
10,000 sq. ft. of office
4
The project must provide 100% of residential units as affordable or supportive housing
Attachment: Exhibit B Guidelines_TIA -2020 (Vehicle Miles Traveled (VMT) Presentation)
5
This threshold ties directly to the OPR technical advisory and notes that CEQA provides a categorical
exemption for existing facilities, including additions to existing structures of up to 10,000 square feet, so
long as the project is in an area where public infrastructure is available to allow for maximum planned
development and the project is not in an environmentally sensitive area. (CEQA Guidelines, § 15301, subd.
(e)(2).) Typical project types for which trip generation increases relatively linearly with building footprint
(i.e., general office building, single tenant office building, office park, and business park) generate or attract
an additional 110-124 trips per 10,000 square feet. Therefore, absent substantial evidence otherwise, it is
reasonable to conclude that the addition of 110 or fewer trips could be considered not to lead to a
significant impact.
23
Packet Pg. 38
D.1.b
Grand Terrace TIA Guidelines
July 2020
6
15,000 sq. ft. of light industrial
7
63,000 sq. ft. of warehousing
7
79,000 sq. ft. of high cube transload and short-term storage warehouse
-will be required
users (employees, customers, visitors) would be existing within the community. As such, the project
would not generthe land use meets existing
demand that would shorten the distance that residents, employees, customers, or visitors would
otherwise travel.
VMT Assessment for Non-Screened Development
Projects not screened through the steps above or exempt under CEQA will be required to complete
a VMT analysis and forecasting through the SBTAM model to determine if they have a significant
VMT impact. This analysis is to
estimates for the project TAZ (or TAZs) under the following scenarios:
Baseline conditions - This data is already available in the web screening map.
Baseline plus project for the project - The project land use would be added to the project
TAZ or a separate TAZ would be created to contain the project land uses. A full base year
model run would be performed and VMT changes would be isolated for the project TAZ
and across the full model network. The model output must include reasonableness checks
of the production and attraction balancing to ensure the project effect is accurately
captured. If this scenario results in a less-than-significant impact, then additional
cumulative scenario analysis may not be required (more information about this outcome
can be found in the Thresholds Evaluation discussion later in this chapter).
Cumulative no project - This data is available from SBCTA.
Cumulative plus project - The project land use would either be added to the project TAZ
or a separate TAZ would be created to contain the project land uses. The addition of
project land uses should be accompanied by a reallocation of a similar amount of land
use from other TAZs; especially if the proposed project is significant in size such that it
Attachment: Exhibit B Guidelines_TIA -2020 (Vehicle Miles Traveled (VMT) Presentation)
would change other future developments. Land use projects will generally not change
the cumulative no project control totals for population and employment growth. Instead,
they will influence the land use supply through changes in general plan land use
designations and zoning. If project land uses are simply added to the cumulative no
6
Threshold may be higher depending on the tenant and the use of the site. This number was estimated
24
Packet Pg. 39
D.1.b
Grand Terrace TIA Guidelines
July 2020
project scenario, then the analysis should reflect this limitation in the methodology and
The model output should include total VMT, which includes all vehicle trips and trip purposes, and
VMT per service population (population plus employment). Total VMT (by speed bin) is needed as
an input for air quality, greenhouse gas (GHG), and energy impact analysis while total VMT per
7
service population is recommended for transportation impact analysis.
will summarize two types of VMT: (1) project generated
VMT per service population and comparing it back to the appropriate benchmark noted in the
thresholds of significance, and (2) the project effect on VMT, comparing how the project changes
8
VMT on the network looking at Citywide VMT per service population or a sub-regional VMT per
service population and comparing it to the no project condition.
The analyst should clearly document the VMT methods used for the project-generated VMT and
the project effect on VMT.
Project-generated VMT shall be extracted from the travel demand forecasting model using the
origin-destination trip matrix and shall multiply that matrix by the final assignment skims. The
project-effect on VMT shall be estimated using a sub-regional boundary (such as a City limit or
County line) and extracting the total link-level VMT for both the no project and with project
condition.
A detailed description of this process is attached to these guidelines.
CEQA VMT Impact Thresholds
The City of Grand Terrace has selected a threshold based on the baseline VMT performance in the
City.
VMT Impacts
An example of how VMT thresholds would be applied to determine potential VMT impacts is
provided below.
Attachment: Exhibit B Guidelines_TIA -2020 (Vehicle Miles Traveled (VMT) Presentation)
7
The VMT produced for the air quality, greenhouse gas (GHG), and energy impact analysis should use the
same methodology (origin/destination) as the transportation impact analysis. However, the VMT presented
in the transportation chapter will be presented as total VMT per service population, while the VMT presented
in the other chapter will be as total VMT by speed bin.
8
Network-based VMT is also referred to as boundary method VMT. For most projects, boundary method for
the City should be adequate. For projects located near the City limit, an alternative boundary should be
considered that captures the true effect the project has on local traffic. This could be determined using
average trip length to/from the site or other approach to completely capture changes in VMT.
25
Packet Pg. 40
D.1.b
Grand Terrace TIA Guidelines
July 2020
A project would result in a significant project-generated VMT impact if either of the
following conditions:
1. The baseline project-generated VMT per service population exceeds the County of
San Bernardino baseline VMT per service population, or
2. The cumulative project-generated VMT per service population exceeds County of
San Bernardino baseline VMT per service population.
e considered significant if it resulted in either of the
following conditions:
1. The cumulative link-level boundary VMT per service population within the City of
9
Grand Terrace increases under the plus project condition compared to the no
project condition).
Please note that the cumulative no project shall reflect the adopted RTP/SCS; as such, if a project is
consistent with the regional RTP/SCS, then the cumulative impacts shall be considered less than
significant subject to consideration of other substantial evidence.
VMT Mitigation Measures
To mitigate VMT impacts, the following choices are available to the applicant:
1. Modify the -built environment characteristics to reduce VMT generated by the
project.
2. Implement transportation demand management (TDM) measures to reduce VMT
generated by the project.
3. Participate in a VMT fee program and/or VMT mitigation exchange/banking program (if
they exist) to reduce VMT from the project or other land uses to achieve acceptable levels
As part of the SBCTA Implementation Study, key TDM measures that are appropriate to the region
were identified.
Measures appropriate for most of the SBCTA region are summarized in Attachment B of the TDM
Strategies Evaluation Memorandum and available from SBCTA. It should be noted that the
availability, applicability, and effectiveness of VMT mitigation measures is evolving and this
memorandum may be out of date. Evaluation of VMT reductions should be evaluated using state-
Attachment: Exhibit B Guidelines_TIA -2020 (Vehicle Miles Traveled (VMT) Presentation)
of-the-practice methodologies recognizing that many of the TDM strategies are dependent on
9
Please note, that for most projects establishing a boundary of the City limits should be sufficient. However,
for larger projects or projects located near the City limit, a larger boundary should be applied to ensure
that the true project effect is not truncated. Typically, doubling the average trip length to/from the site
could establish an appropriate boundary if the City limit is not appropriate.
26
Packet Pg. 41
D.1.b
Grand Terrace TIA Guidelines
July 2020
building tenant performance over time. As such, actual VMT reduction cannot be reliably predicted
and monitoring may be necessary to gauge performance related to mitigation expectations.
Attachment: Exhibit B Guidelines_TIA -2020 (Vehicle Miles Traveled (VMT) Presentation)
27
Packet Pg. 42
D.1.b
Grand Terrace TIA Guidelines
July 2020
CEQA Assessment - Active
Transportation and Public
Transit Analysis
Attachment: Exhibit B Guidelines_TIA -2020 (Vehicle Miles Traveled (VMT) Presentation)
28
Packet Pg. 43
D.1.b
Grand Terrace TIA Guidelines
July 2020
Potential impacts to public transit, pedestrian facilities and travel, and bicycle facilities and travel
can be evaluated using the following criteria.
A significant impact occurs if the project conflicts with adopted policies, plans, or programs
regarding public transit, bicycle, or pedestrian facilities, or otherwise decreases the
performance or safety of such facilities.
Therefore, the TIA shall include analysis of a project to examine if it is inconsistent with adopted
policies, plans, or programs regarding active transportation or public transit facilities, or otherwise
decreases the performance or safety of such facilities and make a determination as to whether it
has the potential to conflict with existing or proposed facilities supporting these travel modes.
Attachment: Exhibit B Guidelines_TIA -2020 (Vehicle Miles Traveled (VMT) Presentation)
29
Packet Pg. 44
D.1.b
Grand Terrace TIA Guidelines
July 2020
Transportation Impact Analysis
Format
Attachment: Exhibit B Guidelines_TIA -2020 (Vehicle Miles Traveled (VMT) Presentation)
30
Packet Pg. 45
D.1.b
Grand Terrace TIA Guidelines
July 2020
The recommended TIA format including both LOS and VMT analysis is as follows:
1. Executive Summary
a. Table summarizing significant impacts and mitigation measures
b. Table summarizing LOS deficiencies and proposed improvements
2. Introduction
a. Purpose of the TIA and study objective
b. Project location and vicinity map (Exhibit)
c. Project size and description
d. Existing and proposed land use and zoning
e. Site plan and proposed project (Exhibit)
f. Proposed project opening year and analysis scenarios
3. Methodology, LOS Thresholds and CEQA Significant Impact Thresholds
4. Existing Conditions
a. Existing roadway network
b. Existing traffic control and intersection geometrics (Exhibit)
c. Existing traffic volumes AM and PM peak hour and ADT (Exhibit)
d. Existing level of service (LOS) at intersections (Table)
e. Existing bicycle facilities (Exhibit)
f. Existing transit facilities (Exhibit)
g. Existing pedestrian facilities
5. Project Traffic
a. Trip generation (Table)
b. Trip distribution and assignment (Exhibit)
c. Project peak hour (or other required hours) turning movements and ADT (Exhibit)
6. Background Conditions (Opening Year) Analysis
a. No Project analysis
i. Committed (funded) roadway improvements
ii. Approved project trip generation (Table, if required)
iii. Approved project trip assignment and distribution (Exhibit, if required)
Attachment: Exhibit B Guidelines_TIA -2020 (Vehicle Miles Traveled (VMT) Presentation)
iv. Peak turning movement and ADT (Exhibit)
v. Intersection level of service (Table)
vi. Roadway segment level of service (Table)
b. Plus Project analysis
i. Plus Project peak turning movement and ADT (Exhibit)
ii. Intersection level of service (Table)
31
Packet Pg. 46
D.1.b
Grand Terrace TIA Guidelines
July 2020
iii. Roadway segment level of service (Table)
iv. Identification of intersection and roadway segment deficiencies
7. Cumulative Year Analysis
a. No Project analysis
i. Committed (funded) roadway improvements
ii. Pending projects and verification of how they are included in the travel
demand forecasting model
iii. Cumulative Year peak turning movement and ADT (Exhibit)
iv. Intersection level of service (Table)
v. Roadway segment level of service (Table)
b. Plus Project Analysis
i. Plus Project peak turning movement and ADT (Exhibit)
ii. Intersection level of service (Table)
iii. Roadway segment level of service (Table)
iv. Identification of intersection and roadway segment deficiencies
8. Traffic Signal Warrant Analysis
9. Site Access Analysis
10. Safety and Operation Improvement Analysis
11. Active Transportation and Public Transit Analysis
12. Improvements and Recommendations
a. Proposed improvements at intersections
b. Proposed improvements at roadway segments
c. Recommended Improvements categorized by whether they are included in fee
plan or not. (Identify if these improvements are included in an adopted fee
program)
13. Vehicle Miles Traveled (VMT) Analysis
a. Project VMT per person/employee for all analysis scenarios
b. Project effect on VMT for all analysis scenarios
c. Identification of VMT impacts
d. Proposed VMT Mitigation Measures
Attachment: Exhibit B Guidelines_TIA -2020 (Vehicle Miles Traveled (VMT) Presentation)
14. Appendix
a. Approved scope of work
b. Traffic counts
c. Intersection analysis worksheets
d. VMT and TDM calculations
e. VMT and TDM mitigation calculations
32
Packet Pg. 47
D.1.b
Grand Terrace TIA Guidelines
July 2020
f. Signal warrant worksheets
Attachments
Attachment: Exhibit B Guidelines_TIA -2020 (Vehicle Miles Traveled (VMT) Presentation)
33
Packet Pg. 48
D.1.b
Grand Terrace TIA Guidelines
July 2020
Detailed VMT Forecasting Information
Most trip-based models generate daily person trip-ends for each TAZ across various trip purposes
(home-based-work, home-based-other, and non-home-based, for example) based on population,
household, and employment variables. This may create challenges for complying with the VMT
guidance because trip generation is not directly tied to specific land use categories. The following
methodology addresses this particular challenge among others.
Production and attraction trip-ends are separately calculated for each zone, and generally:
production trip-ends are generated by residential land uses and attraction trip-ends are generated
by non-residential land uses. OPR's guidance addresses residential, office, and retail land uses.
Focusing on residential and office land uses, the first step to forecasting VMT requires translating
the land use into model terms, the closest approximations are:
Residential: home-based production trips
Office: home-based work attraction trips
Note that this excludes all non-home-based trips including work-based other and other-based
other trips.
The challenges with computing VMT for these two types of trips in a trip-based model are 1)
production and attraction trip-ends are not distinguishable after the PA to OD conversion process
and 2) trip purposes are not maintained after the mode choice step. For these reasons, it not
possible to use the VMT results from the standard vehicle assignment (even using a select zone re-
assignment). A separate post-process must be developed to re-estimate VMT for each zone that
includes trip-end types and trip purposes.
To calculate VMT:
Re-skim final loaded congested networks for each mode and time period
Run a custom PA to OD process that replicates actual model steps, but:
o Keeps departure and return trips separate
o Keeps trip purpose and mode separate
o Converts person trips to vehicle trips based on auto occupancy rates and isolates
automobile trips
Attachment: Exhibit B Guidelines_TIA -2020 (Vehicle Miles Traveled (VMT) Presentation)
o Factors vehicle trips into assignment time periods
Multiply appropriate distance skim matrices by custom OD matrices to estimate VMT
Sum matrices by time, mode, and trip purpose to calculate daily automobile VMT
Calculate automobile VMT for individual TAZs using marginal totals:
o Residential (home-based) - row of departure matrix plus column of return matrix
o Office (home-based work) - column of departure matrix plus row of return matrix
34
Packet Pg. 49
D.1.b
Grand Terrace TIA Guidelines
July 2020
Appropriateness Checks
Regardless of which method is used, the number of vehicle trips from the custom PA to OD process
and the total VMT should match as closely as possible with the results from the traditional model
process. The estimated results should be checked against the results from a full model run to
understand the degree of accuracy. Note that depending on how each model is setup, these custom
10
processes may or may not include IX/XI trips, truck trips, or special generator trips (airport,
seaport, stadium, etc.).
When calculating VMT for comparison at the study area, citywide, or regional geography, the same
methodology that was used to estimate project specific VMT should be used. The VMT for these
comparisons can be easily calculated by aggregating the row or column totals for all zones that are
within the desired geography.
Attachment: Exhibit B Guidelines_TIA -2020 (Vehicle Miles Traveled (VMT) Presentation)
10
IX/XI trips refer to trips that start inside the model boundary and end outside of it (IX), and trips that start
outside the model boundary and end inside it (XI).
35
Packet Pg. 50