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Local Guidelines for Implementing the <br />California Environmental Quality Act (2019) INITIAL STUDY <br /> <br /> <br />2019 City of Santa Ana Local Guidelines 5-9 ©Best Best & Krieger LLP <br />Table 1 <br />VMT Impact Thresholds <br />Methods Project Threshold Cumulative Threshold <br />• VMT analysis using <br />OCTAM forecast of total <br />daily VMT/SP. <br />A significant impact <br />would occur if the project <br />generates VMT/SP <br />above 15% below the <br />Countywide average. <br />A significant impact would occur if <br />the project is determined to be <br />inconsistent with the RTP/SCS. <br /> <br />A significant impact would occur if <br />the project causes total daily VMT <br />within the City to be higher than the <br />no project alternative under <br />cumulative conditions. This analysis <br />should be performed using the <br />‘project effect’ method. <br />Transportation Projects (thresholds may apply for SB 743 or GHG purposes) <br />• OCTAM forecast of total <br />citywide daily VMT1 <br />A significant impact <br />would occur if the project <br />increased the baseline <br />VMT within the City. <br />A significant impact would occur if <br />the project caused total daily VMT <br />within the City to be higher than the <br />no build alternative under <br />cumulative conditions. <br />• Consistency check with <br />SCAG RTP/SCS <br />NA <br /> <br />A significant impact would occur if <br />the project is determined to be <br />inconsistent with the RTP/SCS. <br /> <br />The thresholds of significance set forth in Table 1 should be considered when determining <br />a proposed project’s potential transportation impacts under Forms J and S of these Local CEQA <br />Guidelines. <br />5.10 MANDATORY FINDINGS OF SIGNIFICANT EFFECT. <br />Whenever there is substantial evidence, in light of the whole record, that any of the <br />conditions set forth below may occur, the Lead Agency shall find that the project may have a <br />significant effect on the environment and thereby shall require preparation of an EIR: <br />(a) The project has the potential to substantially degrade the quality of the environment, <br />substantially reduce the habitat of a fish or wildlife species, cause a fish or wildlife <br />population to drop below self-sustaining levels, threaten to eliminate a plant or animal <br />community, substantially reduce the number or restrict the range of a rare or endangered <br />plant or animal, or eliminate important examples of major periods of California history or <br />prehistory; <br /> <br />1 It is recommended that OCTAM is used to develop VMT estimates for transportation project impact assessment. <br />However, the analyst must verify the model results for sensitivity to changes in VMT. Alternatively, if the model is <br />not deemed appropriate, Robert Cevero’s research on lane-mile elasticity and its relationship to VMT can be <br />referenced. <br />3 -64