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Local Guidelines for Implementing the <br />California Environmental Ouality Act (2019) INITIAL STUDY <br />proximity to other destinations, etc. For many projects, a qualitative analysis of <br />construction traffic may be appropriate. <br />(4) Methodology. A lead agency has discretion to choose the most appropriate <br />methodology to evaluate a project's vehicle miles traveled, including whether to <br />express the change in absolute terms, per capita, per household or in any other <br />measure. A lead agency may use models to estimate a project's vehicle miles <br />traveled, and may revise those estimates to reflect professional judgment based on <br />substantial evidence. Any assumptions used to estimate vehicle miles traveled and <br />any revisions to model outputs should be documented and explained in the <br />environmental document prepared for the project. The standard of adequacy in <br />Section 15151 shall apply to the analysis described in this section. <br />(c) Applicability. <br />The provisions of this section shall apply prospectively as described in section <br />15007. A lead agency may elect to be governed by the provisions of this section <br />immediately. Beginning on July 1, 2020, the provisions of this section shall apply <br />statewide. <br />Consistent with State CEQA Guidelines section 15064.3, the City has adopted the <br />thresholds of significance set forth in Table 1 below to guide when the City will normally <br />determine that a project will have a significant transportation impact. <br />Table 1 <br />VMT Impact Thresholds <br />Methods <br />Project Threshold <br />I Cumulative Threshold <br />Land Use Plans (such as General Plans and Specific Plans) <br />• Orange County Traffic <br />A significant impact <br />A significant impact would occur if <br />Analysis Model <br />would occur if the <br />the project caused total daily VMT <br />(OCTAM) forecast of <br />project VMT/SP (for the <br />within the City to be higher than the <br />total daily vehicle miles <br />land use plan) exceeds <br />no project alternative under <br />traveled per service <br />15% below the <br />cumulative conditions. <br />population (VMT/SP). <br />Countywide average. <br />To capture project <br />effect, the same <br />cumulative year <br />population and <br />employment growth <br />totals should be used. <br />The `project' only <br />influences land use <br />allocation. <br />2019 City of Santa Ana Local Guidelines <br />011est Best & Krieger LLP <br />75D-68 <br />