HomeMy WebLinkAboutAppendixE_Transportation........................................................................................................................
A P P E N DI X E :
T R AN SPO R TATION ANALYSIS
........................................................................................................................
PREPARED FOR
SJ23-2217
PLACEWORKS AND
CITY OF CUPERTINO
JANUARY 2024
Cupertino General Plan
and Zoning Updates:
Transportation
Analysis for the
Environmental
Review
Cupertino General Plan and
Zoning Updates:
Transportation Analysis for
the Environmental Review
Prepared for:
PlaceWorks and
City of Cupertino
January 2024
SJ23-2217
Table of Contents
Executive Summary ....................................................................................................................... 1
Project Description ...................................................................................................................................................................... 1
CEQA Impacts and Mitigation Measures ............................................................................................................................ 2
Plan Conflicts ......................................................................................................................................................................... 2
Vehicle Miles Traveled ....................................................................................................................................................... 3
1. Introduction and Project Description ..................................................................................... 8
1.1 Purpose ..................................................................................................................................................................................... 8
1.2 Project Description .............................................................................................................................................................10
1.2.1 Land Use Program ..................................................................................................................................................10
1.3 Recent Changes to CEQA Transportation Analysis ...............................................................................................13
1.4 Analysis Scenarios ...............................................................................................................................................................13
1.5 Report Organization ..........................................................................................................................................................14
2. VMT Approach and Analysis Methods .................................................................................. 15
2.1 Use of CEQA Prior to SB 743 ..........................................................................................................................................15
2.2 Overview of Senate Bill 743 and Legal Framework ...............................................................................................15
2.3 Approach ................................................................................................................................................................................17
2.3.1 Summary of VMT Methods Decisions ............................................................................................................19
2.4 VMT Accounting Methods ..............................................................................................................................................21
2.4.1 Total VMT ...................................................................................................................................................................22
2.4.2 Project’s Effect on VMT (Using Boundary VMT) .........................................................................................22
3. Summary of Relevant Regional Circulation and Transportation Plans ............................. 24
3.1 Metropolitan Transportation Commission’s (MTC) Regional Transportation Plan (Plan Bay Area) ...24
3.2 Santa Clara Valley Transportation Authority VTP 2040 Plan .............................................................................27
3.3 Santa Clara Countywide Bicycle Plan ..........................................................................................................................28
3.4 Congestion Management Program Monitoring and Conformance Report ................................................28
3.5 Cupertino General Plan – Community Vision 2015-2040 ...................................................................................28
3.6 City of Cupertino Climate Action Plan ........................................................................................................................29
3.7 City of Cupertino 2016 Bicycle Transportation Plan .............................................................................................30
3.8 City of Cupertino Pedestrian Transportation Plan .................................................................................................31
3.9 City of Cupertino Transportation Impact Fee (TIF) Nexus Study .....................................................................31
3.10 Cupertino Municipal Code Chapter 17.08 ..............................................................................................................32
3.11 City of Cupertino Transportation Study Guidelines ............................................................................................32
4. Significance Criteria ................................................................................................................ 33
4.1 Significance Criteria ...........................................................................................................................................................33
4.1.1 Plan Conflicts ............................................................................................................................................................33
4.1.2 VMT Impacts .............................................................................................................................................................34
5. Vehicle Miles Traveled Forecasts ........................................................................................... 37
5.1 Summary of VMT Forecasts Methods ........................................................................................................................37
5.2 Service Population ..............................................................................................................................................................37
5.3 Daily VMT Forecasts...........................................................................................................................................................38
5.3.1 Total Project Generated VMT Forecasts .........................................................................................................38
5.3.2 Boundary VMT Forecasts .....................................................................................................................................39
5.4 Santa Clara Valley Transportation Authority Travel Model ................................................................................40
5.4.1 VTA Travel Model Documentation ...................................................................................................................40
6. Environmental Impacts and Mitigation Assessment ........................................................... 42
6.1 Plan Conflict Analysis ........................................................................................................................................................42
6.1.1 Transit and Carpool Evaluation .........................................................................................................................42
6.1.2 Roadway Evaluation ...............................................................................................................................................44
6.1.3 Bicycle Evaluation ....................................................................................................................................................44
6.1.4 Pedestrian Evaluation ............................................................................................................................................44
6.2 VMT Analysis ........................................................................................................................................................................45
6.2.1 Project Generated VMT Analysis (Project Analysis) ...................................................................................45
6.2.2 Project’s Effect on VMT Analysis .......................................................................................................................52
6.2.3 Regional Transportation Plan/Sustainable Community Strategy Plan Consistency .....................53
Appendices
Appendix A: Transportation Analysis Zone Map
Appendix B: Regional Transportation Plan/Sustainable Community Strategy Plan Consistency
List of Figures
Figure 1: City of Cupertino Location ............................................................................................................................................ 9
Figure 2: Cupertino General Plan and Zoning Updates: Housing Opportunity Site Locations ......................... 12
Figure 3: Measuring Vehicle Miles Traveled .......................................................................................................................... 23
List of Tables
Table ES-1: Project Generated VMT Threshold ........................................................................................................................ 4
Table ES-2: Project Generated VMT Results under Existing Conditions ......................................................................... 4
Table ES-3: Total Project Generated VMT with Mitigations Assessment ....................................................................... 5
Table ES-4: Project’s Effect (Boundary) VMT Assessment under Existing Conditions ............................................... 6
Table ES-5: Project’s Effect (Boundary) VMT Assessment under Cumulative Conditions ....................................... 6
Table 1: Land Use Program ............................................................................................................................................................ 11
Table 2: VMT Significance Thresholds ....................................................................................................................................... 34
Table 3: Project Generated VMT Threshold ............................................................................................................................ 35
Table 4: Project’s Effect on VMT (Boundary VMT) Existing Threshold ......................................................................... 36
Table 5: Project’s Effect on VMT (Boundary VMT) Cumulative Threshold .................................................................. 36
Table 6: Service Population ........................................................................................................................................................... 38
Table 7: Total Project Generated VMT Forecasts .................................................................................................................. 39
Table 8: Boundary VMT Forecasts ............................................................................................................................................... 39
Table 9: Total Project Generated VMT Assessment ............................................................................................................. 45
Table 10: VMT Mitigation Measure Reduction Percentages ............................................................................................ 48
Table 11: Citywide VMT Reduction by VMT Type ................................................................................................................ 49
Table 12: Total Project Generated VMT with Mitigations Assessment ........................................................................ 52
Table 13: Project’s Effect (Boundary) VMT Assessment under Existing Conditions ................................................ 52
Table 14: Project’s Effect (Boundary) VMT Assessment under Cumulative Conditions ......................................... 53
Cupertino General Plan and Zoning Updates: Transportation Analysis for the Environmental Review
January 2024
1
Executive Summary
This report presents the results of the transportation analysis (TA) conducted to evaluate the
environmental effects of the proposed City of Cupertino General Plan 2040 and Zoning Code
Amendments (the Project). The purposes of the TA are to show compliance with the California
Environmental Quality Act (CEQA), including analysis of the Project’s vehicle miles traveled (VMT), and to
identify significant impacts and mitigation, where applicable, for inclusion in the Environmental Impact
Report (EIR).1 Project effects on the environment were evaluated following the CEQA guidelines along with
guidance from the City of Cupertino Transportation Study Guidelines (2021 Transportation Study
Guidelines, May 2021) and Caltrans. Figure 1 shows the City of Cupertino city limits boundary and the
City’s location within the surrounding transportation network.
Project Description
The proposed Project includes updates to the City of Cupertino’s General Plan and zoning to
accommodate additional residential development within the City of Cupertino. The Project identifies
specific sites appropriate for the development of residential dwelling units in Cupertino. The City would
rezone specified sites as necessary to meet the requirements of California state law. Based on the draft
Regional Housing Needs Assessment (RHNA), the City will need to plan for at least an additional 4,588
dwelling units plus a buffer of 1,428 dwelling units for a total of 6,016 dwelling units. This total of 6,016
dwelling units is for Housing Element planning purposes and is the combination of pipeline projects,
accessory dwelling units, and new opportunity sites. The City identified 2,119 dwelling units as “pipeline”
projects that are currently in the permitting or construction process. Pipeline projects are those that have
the highest likelihood of being constructed within the eight-year Housing Element cycle. Many of the
“pipeline” projects have already received entitlements and/or a building permit, and thus are not
considered “new” units for the purposes of this environmental analysis. Further accessory dwelling units
are allowed under the current General Plan and are presumed to be built over time, too. The purpose of
this environmental analysis is to evaluate the environmental effects of the “new” units associated with the
opportunity sites identified in this housing element due to higher residential densities as compared to the
City of Cupertino’s General Plan; therefore, this Project is evaluating the incremental effect of 3,317 new
dwelling units on the new opportunity sites, which are mostly in northeast areas of Cupertino along
Stevens Creek Boulevard and De Anza Boulevard.
1 VMT refers to “vehicle miles traveled,” a metric that accounts for the number of vehicle trips generated plus the
length or distance of those trips. This report uses total VMT and boundary VMT metrics for specific geographic
areas, which are defined in Chapter 2.
Cupertino General Plan and Zoning Updates: Transportation Analysis for the Environmental Review
January 2024
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CEQA Impacts and Mitigation Measures
The 2021 Transportation Study Guidelines provides guidance for the preparation of a CEQA-compliant
transportation impact analysis pursuant to SB 743. Examples of situations that could be considered
significant impacts are as follows:
• Plan Conflicts: The project would conflict with a program, plan, ordinance, or policy addressing
the circulation system, including transit, roadway, bicycle, and pedestrian facilities.
• VMT Impacts: The project would result in a VMT-related impact in accordance with the City of
Cupertino Transportation Study Guidelines based on the project’s direct impacts relative to total
VMT per service population evaluated under Existing Conditions, or based on the project’s effect
on VMT using boundary VMT per service population evaluated under Existing and
Cumulative Conditions.
• Hazard Impacts: The project would substantially increase hazards due to a geometric design
feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g.,
farm equipment).
• Emergency Access Impacts: The project would result in inadequate emergency vehicle access.
Each of these criteria is discussed further below.
Plan Conflicts
The Project’s consistency with relevant transportation programs, plans, ordinances, or policies, was
evaluated for each respective mode of travel—transit system, roadway system, bicycle system, and
pedestrian system—as listed below.
Transit System
Implementation of the proposed Project will not result in modifications to the transit network that would
disrupt existing facilities or services or interfere with the implementation of planned facilities/services
contained in adopted programs, plans, policies, or ordinances. Further, future developments will be
required to comply with VTA, city, state, and/or other design standards regarding transportation facilities.
The proposed Project would lead to increases in the residential population of Cupertino, which would
increase the demand for transit facilities and services and may cause transit vehicle delays. However, these
impacts would be accommodated by existing and planned improvements to the transit system. Therefore,
the impact relative to disruption of existing or planned transit or carpool facilities, or conflicts with transit
programs, plans, ordinances, or policies would be less-than-significant.
Roadway System
The Project does not include modifications to the roadway network and future developments will be
required to comply with city, state, and/or other design standards regarding transportation facilities. Thus,
Cupertino General Plan and Zoning Updates: Transportation Analysis for the Environmental Review
January 2024
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the Project would not be expected to interfere with existing roadway facilities nor conflict with planned
roadway facilities, adopted plans, guidelines, policies, or standards. Therefore, the impact relative to
disruption of existing or planned roadways or conflicts with programs, plans, ordinances, or policies
through the implementation of the proposed Project would be less-than-significant on roadway
facilities, and no mitigation would be required.
Bicycle System
The Project does not include modifications to the bicycle network and future developments will be
required to comply with city, state, and/or other design standards regarding transportation facilities. Thus,
the Project would not be expected to interfere with existing bicycle facilities nor conflict with planned
bicycle facilities, adopted plans, guidelines, policies, or standards. The Project is supportive of bicycle
usage by locating new residential developments in proximity to existing or planned bicycle paths,
bikeshare stations, and on-road bicycle facilities; and providing connections to existing and planned
bicycle facilities aligns with the overall goals and policies of the plans described in Chapter 3. This
promotion of bicycle usage is desired based on the General Plan goals and does not conflict with planned
bicycle facilities, adopted plans, guidelines, policies, or standards. Therefore, the impact relative to
disruption of existing or planned bicycle facilities or conflicts with programs, plans, ordinances, or policies
through the implementation of the proposed Project would be less-than-significant on bicycle facilities,
and no mitigation would be required.
Pedestrian System
The Project does not include modifications to the pedestrian network and future developments will be
required to comply with city, state, and/or other design standards regarding transportation facilities. Thus,
the Project would not be expected to interfere with existing pedestrian facilities nor conflict with planned
pedestrian facilities, adopted plans, guidelines, policies, or standards. The Project is supportive of walking
by locating new residential developments in proximity to existing or planned pedestrian facilities; and
providing connections to existing and planned pedestrian facilities aligns with the overall goals and
policies of the plans described in Chapter 3. Therefore, the impact relative to disruption of existing or
planned pedestrian facilities or conflicts with programs, plans, ordinances, or policies through the
implementation of the proposed Project would be less-than-significant on pedestrian facilities, and no
mitigation would be required.
Vehicle Miles Traveled
The VMT impact analysis presented in this report considers the Project’s direct (Project-generated)
impacts relative to the citywide total VMT per service population under Existing with Project Conditions as
well the Project’s long-term effect on VMT using boundary VMT per service population evaluated under
Existing and Cumulative Conditions. Based on this analysis, the Project would result in a Project direct
(Project-generated) VMT-related impact as described below.
Cupertino General Plan and Zoning Updates: Transportation Analysis for the Environmental Review
January 2024
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Project-Generated VMT (Existing Conditions)
The significance threshold for determining the Project’s direct impact is a total VMT per service
population rate that is 14.4% below the existing City of Cupertino total VMT per service population. The
current citywide total VMT per service population is 36.56, as shown in Table ES-1, and the significance
threshold is set at 14.4% below that value, or 31.30. Therefore, the Project would cause a significant
Project-generated VMT impact if the Project’s total VMT per service population under Existing with Project
Conditions is greater than 31.30.
Table ES-1: Project Generated VMT Threshold
Item Amount
Total Vehicle Miles Traveled (A)1 3,772,000
Service Population (B)1,2 103,170
Total VMT per Service Population (A/B = C) 36.56
Total VMT per Service Population Threshold (C*85.6% = D) 31.30
Notes:
1. Rounded service population and VMT to nearest 10.
2. Service population is defined as the sum of all residents and employees.
Source: Fehr & Peers, 2024.
As shown in Table ES-2, the Project would generate VMT at a rate of 34.80 miles per service population.
This value is higher than the VMT threshold of 31.30 total VMT per service population.
Table ES-2: Project Generated VMT Results under Existing Conditions
Item Amount
Project
Total Project Generated Vehicle Miles Traveled (A)1 3,927,390
Service Population (B)1,2 112,870
Total Project Generated VMT per Service Population (A/B = C) 34.80
Initial Impact Assessment
Total VMT per Service Population Threshold 31.30
(Initial Impact Conclusion) Potentially Significant
Notes:
1. Rounded service population and VMT to nearest 10.
2. Service population is defined as the sum of all residents and employees.
Source: Fehr & Peers, 2024
Cupertino General Plan and Zoning Updates: Transportation Analysis for the Environmental Review
January 2024
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Implementation of the Project would result in a total Project-generated VMT per service population under
Existing with Project Conditions that is higher than the applicable threshold. Therefore, the impact of the
Project total VMT rate would be potentially significant.
Project-Generated VMT Mitigation
The Project reduces VMT through the higher density residential development. However, in order to reduce
VMT to a less than significant level, the City must rely on additional assistance from regional and state-
level agencies to affect major changes in driving patterns and behaviors throughout the greater Bay Area
region. The biggest effects of VMT mitigation actions (and resultant emissions reductions) derive from
statewide or region-wide policies that increase the cost, or reduce the convenience, of using vehicles. The
City of Cupertino cannot effectively or practically implement statewide or region-wide policies, other than
to be supportive of and complementary to these efforts in the City’s General Plan, which the City has
done, as described above.
Table ES-3 presents the Project-generated total VMT per service population with VMT mitigations. There
are no additional feasible mitigation strategies available to the City to reduce this impact to a less than
significant level. Therefore, implementation of the proposed Project would result in a VMT impact that
would be considered significant-and-unavoidable.
Table ES-3: Total Project Generated VMT with Mitigations Assessment
Existing with Project
Conditions
Existing with Project
Conditions with
Mitigations
City of Cupertino
Total Project Generated Vehicle Miles Traveled (A)1 3,927,390 3,719,400
Service Population (B)1,2 112,870 112,870
Total Project Generated VMT per Service Population (A/B = C) 34.80 32.95
Initial Impact Assessment
Total VMT per Service Population Threshold 31.30 31.30
(Impact Conclusion) Potentially Significant Significant and
Unavoidable
Notes:
1. Rounded service population and VMT to nearest 10.
2. Service population is defined as the sum of all residents and employees.
Source: Fehr & Peers, 2024.
Project's Effect on VMT (Existing and Cumulative Conditions)
For the Project’s effect on overall VMT, the threshold is set as no increase in Countywide VMT per service
population (that is, no increase in the total amount of VMT occurring within the borders of Santa Clara
County divided by the total service population of the County). As shown in Table ES-4, under Existing
Cupertino General Plan and Zoning Updates: Transportation Analysis for the Environmental Review
January 2024
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Conditions the Countywide VMT per service population is 13.51, so that value is the threshold of
significance for the evaluation of Existing with Project Conditions. As shown in Table ES-5, under
cumulative conditions the Countywide VMT per service population is 12.53, so that value is the threshold
of significance for the evaluation of Cumulative with Project conditions.
To evaluate the Project’s effect on VMT, the boundary VMT for the region is divided by service population,
defined as the sum of all residents and employees in Santa Clara County.
Table ES-4: Project’s Effect (Boundary) VMT Assessment under Existing Conditions
Existing Conditions Existing with
Project Conditions
Santa Clara County
Boundary Vehicle Miles Traveled (A)1 39,258,000 39,318,000
Service Population (B)1,2 2,905,260 2,914,960
Boundary VMT per Service Population (A/B = C) 13.51 13.49
Boundary VMT per Service Population Threshold 13.51
(Initial Impact Conclusion) Less Than Significant
Notes:
1. Rounded service population and VMT to nearest 10.
2. Service population is defined as the sum of all residents and employees.
Source: Fehr & Peers, 2024
Table ES-5: Project’s Effect (Boundary) VMT Assessment under Cumulative Conditions
Cumulative Conditions Cumulative with
Project Conditions
Santa Clara County
Boundary Vehicle Miles Traveled (A)1 48,413,000 48,479,000
Service Population (B)1,2 3,864,050 3,873,750
Boundary VMT per Service Population (A/B = C) 12.53 12.51
Boundary VMT per Service Population Threshold 12.53
(Initial Impact Conclusion) Less Than Significant
Notes:
1. Rounded service population and VMT to nearest 10.
2. Service population is defined as the sum of all residents and employees.
Source: Fehr & Peers, 2024
Under Existing with Project Conditions the countywide boundary VMT per service population of 13.49 is
less than the applicable threshold of 13.51. Therefore, the impact of the Project’s effect on VMT under
Existing with Project Conditions would be less-than-significant.
Cupertino General Plan and Zoning Updates: Transportation Analysis for the Environmental Review
January 2024
7
Under Cumulative with Project Conditions the region boundary VMT per service population of 12.51 is
less than the applicable threshold of 12.53. Therefore, the impact of the Project’s effect on VMT under
Cumulative with Project Conditions would be less-than-significant.
Regional Transportation Plan/Sustainable Community Strategy Plan Consistency
California Environmental Quality Act, Section 15125(d), requires an EIR to discuss inconsistencies between
the proposed Project and applicable general and regional plans. This analysis discusses the proposed
Project’s consistency with the policies in the region’s Regional Transportation Plan/Sustainable Communities
Strategy (RTP/SCS), also known as Plan Bay Area 2050 (October 2021).2 The Metropolitan Transportation
Commission (MTC) and the Association of Bay Area Governments (ABAG) are the designated metropolitan
planning organizations and, as such, are mandated by the federal government to research and draw up
plans for transportation, growth management, hazardous waste management, and air quality.
The Project does not propose changes to the transit system that would impact the Plan Bay Area 2050
(2021) goals of expanding the role transit plays in meeting the region’s mobility needs such as investments
in bus rapid transit, expansion of local services, and planned rail projects. Internal circulation changes would
support core regional transit travel within the NBS Master Plan.
Overall, the proposed Project would not conflict with existing or planned transportation facilities because the
proposed street changes are additions of pedestrian and bicycle facilities with few, if any, reductions in
vehicle lanes. The proposed Project would not be expected to interfere with existing roadway facilities;
conflict with planned roadway facilities; or conflict with adopted transportation plans, guidelines, policies, or
standards. Therefore, the impact relative to disruption of existing or planned roadways or conflicts with
program, plan, ordinance, or policy would be less-than-significant.
2 Metropolitan Transportation Commission, 2021. Plan Bay Area 2040. Available online at Plan Bay Area 2050 | Plan
Bay Area.
Cupertino General Plan and Zoning Updates: Transportation Analysis for the Environmental Review
January 2024
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1. Introduction and
Project Description
This report presents the results of the transportation analysis (TA) conducted to evaluate the
environmental effects of the proposed City of Cupertino General Plan 2040 and Zoning Code
Amendments (the Project). The Project includes policy updates to the General Plan 2040 to bring the
Housing Element and Health and Safety Element up to date with state law. Subsequent updates to the
Mobility and Land Use, Community Character Elements, and Zoning Code are also required because of
updates to the Housing Element. The proposed Project is considered a policy/planning action. The trip
generation and vehicle miles traveled analysis presented in this report assumes the City of Cupertino will
increase its absolute vehicle trip generation but lower its vehicle trip rates due to the proposed land use
program and transportation demand management (TDM) policies. Figure 1 shows the City of Cupertino
city limits boundary and the City’s location within the surrounding transportation network.
This chapter outlines the report purpose, Project description, recent changes in the California
Environmental Quality Act (CEQA) regarding transportation analyses, the analysis scenarios, and
report organization.
1.1 Purpose
The primary purpose of this report is to present the transportation analysis for compliance with CEQA,
including identification of potential significant impacts and applicable recommended mitigation for
inclusion in the Environmental Impact Report (EIR). Specifically, this report conducts a plan conflict
analysis of the Project against the various regional, county, and local plans, and a vehicle miles traveled
(VMT) impact analysis. Project effects on the environment were evaluated following the CEQA guidelines.
Guidance from the City of Cupertino Transportation Study Guidelines (2021 Transportation Study
Guidelines, May 2021) and Caltrans were also considered.
·85
%&280
City of Cupertino Location
Figure 1
Cupertino City Limits
Cupertino Sphere of Influence
N:\Projects\_SJ23_Projects\SJ23_2217_Cupertino_GP_Rezone_CEQA\Graphics\ADOBE\Fig01_City of Cupertino Location.ai
Vallco Pkwy
Prospect Rd
Stevens Creek Blvd
McClellan Rd
Homestead Rd
Cupertino General Plan and Zoning Updates: Transportation Analysis for the Environmental Review
January 2024
10
1.2 Project Description
The proposed Project identifies specific sites appropriate for the development of residential dwelling units
in Cupertino. The City would rezone specified sites as necessary to meet the requirements of California
state law. Based on the draft Regional Housing Needs Assessment (RHNA), the City will need to plan for at
least an additional 4,588 dwelling units plus a buffer of 1,428 dwelling units for a total of 6,016 dwelling
units. This total of 6,016 dwelling units is for Housing Element planning purposes and is the combination
of pipeline projects, accessory dwelling units, and new opportunity sites. The City identified 2,119 dwelling
units as “pipeline” projects that are currently in the permitting or construction process. Pipeline projects
are those that have the highest likelihood of being constructed within the eight-year Housing Element
cycle. Many of the “pipeline” projects have already received entitlements and/or a building permit, and
thus are not considered “new” units for the purposes of this environmental analysis. Further accessory
dwelling units are allowed under the current General Plan and are presumed to be built over time, too.
The purpose of this environmental analysis is to evaluate the environmental effects of the “new” units
associated with the opportunity sites identified in this housing element due to higher residential densities
as compared to the City of Cupertino’s General Plan; therefore, this Project is evaluating the incremental
effect of 3,317 new dwelling units on the new opportunity sites, which are mostly in northeast areas of
Cupertino along Stevens Creek Boulevard and De Anza Boulevard. Figure 2 shows the City of Cupertino
General Plan and Zoning Updates housing site locations. Appendix A includes a map of the
transportation analysis zones.
1.2.1 Land Use Program
The proposed Project is evaluating the incremental effect of the 3,317 dwelling units associated with the
new opportunity sites identified in the housing element. The potential changes in land use and intensity
or density would be the primary changes from the current City of Cupertino General Plan (2015) that may
result in environmental impacts. Table 1 presents the Project land use program by transportation analysis
zone.
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January 2024
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Table 1: Land Use Program
Project
Transportation Analysis Zone Housing Units Service Population
86 666 1,973
89 147 439
91 155 462
94 485 1,442
98 332 895
99 295 795
101 49 132
110 19 52
111 211 641
112 167 454
113 357 1,067
116 7 21
119 77 234
120 37 117
123 7 22
126 230 724
129 76 229
Total 3,317 9,699
Note: Refer to Appendix A for a map of the VTA travel model transportation analysis zones in Cupertino.
Source: Fehr & Peers, 2024.
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Figure 2
Housing Opportunity Sites
Cupertino City Limits
Cupertino Sphere of Influence
New Housing Units Percent of Project
Net New Housing Units
N:\Projects\_SJ23_Projects\SJ23_2217_Cupertino_GP_Rezone_CEQA\Graphics\ADOBE\Fig02_Housing Opportunity Sites.ai
628
19%
1079
33%
313
9%246
7%419
13%
263
8%
237
7%
132
4%
XX
X%
Stevens Creek Blvd
Vallco Pkwy
Homestead Rd
Prospect Rd
McClellan Rd
Cupertino General Plan and Zoning Updates: Transportation Analysis for the Environmental Review
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1.3 Recent Changes to CEQA Transportation Analysis
Senate Bill (SB) 743 changed how transportation impacts under CEQA are analyzed. SB 743 removed the
use of automobile delay or traffic congestion for determining transportation impacts in environmental
review. The latest CEQA Statute & Guidelines now specify that VMT is the appropriate metric to evaluate
transportation impacts.3 In short, SB 743 changes the focus of transportation impact analysis in CEQA
from measuring impacts to drivers to measuring the impact of driving.
In February of 2021, the City of Cupertino adopted a set of VMT methods and procedures that apply to
land use projects in the City in conformance with SB 743. The City’s VMT methods and procedures are
outlined in the City of Cupertino Transportation Study Guidelines (TS Guidelines, May 2021). The TS
Guidelines provide a clear and consistent technical approach for evaluating the transportation effects
(adverse or beneficial) of projects on the City’s transportation system and services. The TS Guidelines
provide three primary purposes including guidance “[t]o evaluate significant impacts and mitigation
measures per the California Environmental Quality Act (CEQA).”
The proposed land use changes associated with the General Plan and zoning updates is a large project
that will modify and increase the residential land use supply with the City of Cupertino, and would
influence the total VMT within the City of Cupertino and nearby.
1.4 Analysis Scenarios
The VMT analysis includes the following study scenarios:
• Scenario 1: Existing Conditions – Existing (2019) travel characteristics.
• Scenario 2: Existing with Project Conditions – Scenario 1 travel characteristics plus the 3,317
dwelling units throughout the City of Cupertino.
• Scenario 3: Cumulative Conditions – Year 2040 travel behavior based on the 2040 travel model
and the 2013 Association of Bay Area Governments (ABAG) land use projections, and planned and
funded transportation system improvements in the Valley Transportation Plan (VTP) 2040. Within
Cupertino, this scenario reflects the cumulative land use growth.
• Scenario 4: Cumulative with Project Conditions – Scenario 3 travel characteristics plus the
3,317 dwelling units throughout the City of Cupertino.
3 On September 27, 2013, Governor Jerry Brown signed SB 743 into law and started a process intended to
fundamentally change transportation impact analysis as part of CEQA compliance. Following several years of draft
proposals and related public comments, OPR settled upon VMT as the preferred metric for assessing passenger
vehicle-related impacts and issued revised CEQA Statute & Guidelines in December 2018, along with a Technical
Advisory On Evaluating Transportation Impacts in CEQA (December 2018) to assist practitioners in implementing the
CEQA Statute & Guidelines revisions. Under the revised CEQA Statute & Guidelines, vehicle level of service (LOS) is
no longer to be used as a determinant of significant environmental impacts, and analysis of a project’s impacts will
now be based on assessment of VMT. As of July 1, 2020, all transportation analysis performed under CEQA must be
consistent with the revised CEQA Statute & Guidelines.
Cupertino General Plan and Zoning Updates: Transportation Analysis for the Environmental Review
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1.5 Report Organization
This report is divided into seven chapters:
• Chapter 1 – Introduction and Project Description includes the TA purpose, proposed Project
description, a description of recent changes to CEQA transportation analysis, a summary of the
analysis scenarios, and report organization.
• Chapter 2 – VMT Approach and Analysis Methods discusses the approach for a comprehensive
VMT assessment, and the forecasting methods used to estimate total VMT per service population
rate and the Project’s effect on VMT using boundary VMT per service population.
• Chapter 3 – Summary of Relevant Regional Circulation and Transportation Plans provides
background information to be used for the plan consistency evaluation.
• Chapter 4 – Significance Criteria lists the significance criteria used for the environmental
impact analysis.
• Chapter 5 – Vehicle Miles Traveled Forecasts summarizes the VMT forecast methods including
the daily trip generation, service population, and Santa Clara Valley Transportation Authority
(VTA)-City/County Association of Governments of San Mateo County (C/CAG) Bi-County travel
model (VTA Travel Model) overview.
• Chapter 6 – Environmental Impacts and Mitigation Assessment includes a plan conflict
analysis, a VMT analysis, hazards analysis, and an emergency access analysis.
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2. VMT Approach and
Analysis Methods
This chapter summarizes the use of CEQA prior to SB 743, an overview of SB 743 and legal framework, and
VMT assessment approach decisions and VMT analysis methods.
2.1 Use of CEQA Prior to SB 743
CEQA was enacted in 1970 with the goal of providing a mechanism for disclosing to the public the
environmental impacts of proposed actions. Before taking a discretionary action, lead agencies (such as
Cupertino) must determine if that action is subject to CEQA and conduct a review of the effects of that
action on the physical environment. The State Office of Planning and Research (OPR) prepares and
maintains guidelines to help agencies implement CEQA.
Under CEQA, lead agencies must determine whether a proposed project has the potential to cause
significant environmental impacts. This determination must be based, to the extent possible, on factual
data and scientific methods of analysis. A project’s effect on transportation is one of the 13 areas that
must be analyzed. For many years, many lead agencies have used vehicle level of service (LOS) as the
primary measure to evaluate a project’s effects and determine transportation impacts.
LOS is a qualitative description of vehicular traffic flow based on factors such as speed, travel time, delay,
and freedom to maneuver. Six levels are defined from LOS A, which reflects free-flow conditions where
there is very little interaction between vehicles, to LOS F, where vehicle demand exceeds capacity and high
levels of vehicle delay result. LOS E represents “at-capacity” operations.
Mitigating a LOS impact typically involves making changes to the physical transportation system to
accommodate additional vehicles and reduce delays. These mitigations may involve actions such as
installing traffic signals, adding turn lanes, widening roads, or contributing to the construction of
HOV/Express Lanes, among other options. The identification of necessary mitigations resulting from
project impacts has historically led to project sponsors identifying and funding these changes to the
transportation system (i.e., paying for or providing a “fair share” contribution toward funding a new traffic
signal or widening an existing roadway).
2.2 Overview of Senate Bill 743 and Legal Framework
On September 27, 2013, Governor Jerry Brown signed SB 743 into law and started a process intended to
fundamentally change transportation impact analysis as part of CEQA compliance. Specifically, the
legislation directed the State of California’s OPR to look at different metrics for identifying transportation
impacts and make corresponding revisions to the CEQA Statute & Guidelines. The initial bill included two
legislative intent statements (emphasis and bullets added):
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• New methodologies under the California Environmental Quality Act are needed for evaluating
transportation impacts that are better able to promote the state’s goals of reducing greenhouse
gas emissions and traffic-related air pollution, promoting the development of a multimodal
transportation system, and providing clean, efficient access to destinations.
• More appropriately balance 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.
These statements provide direction to OPR and to lead agencies. For OPR, the direction is about what the
new metrics should achieve. For lead agencies, the direction is about expected changes in transportation
analysis (and related technical areas) and what factors to consider for significance thresholds.
To implement this intent, SB 743 contains amendments to current congestion management law that allow
cities and counties to opt out of the LOS standards that would otherwise apply. SB 743 does not prevent a
lead agency from continuing to analyze delay or LOS as part of other plans (e.g., a general plan), fee
programs, or ongoing network monitoring. However, automobile delay as described by LOS is not
considered a significant impact on the environment for purposes of CEQA. Lead agencies may still
consider vehicle LOS outside of the CEQA process if they determine it is an important part of their
transportation planning process. The most common applications are jurisdictions wanting to use vehicle
LOS to plan roadways in their general plans or determine nexus relationships for their impact fee
programs. Jurisdictions can also continue to condition projects to build transportation improvements
through the entitlement process in a variety of ways.
Following several years of draft proposals and related public comments, OPR settled upon VMT as the
preferred metric for assessing passenger vehicle-related impacts and issued revised CEQA Statute &
Guidelines in December 2018, along with a Technical Advisory on Evaluating Transportation Impacts in
CEQA (December 2018) (OPR Technical Advisory) to assist practitioners in implementing the CEQA Statute
& Guidelines revisions. Under the revised CEQA Statute & Guidelines, vehicle LOS is no longer to be used
as a determinant of significant environmental impacts under CEQA, and analysis of a project’s impacts will
now be based on assessment of VMT.
The OPR Technical Advisory provides guidance and recommendations for SB 743 implementation.
However, lead agencies must still make their own specific decisions about metrics, methods, thresholds,
and mitigation. Further, the OPR guidance is primarily tied to statewide goals for greenhouse gas (GHG)
reduction and does not attempt to balance or resolve potential conflicts between state and lead agency
goals, such as those expressed in local agency general plans and/or climate action plans.
The use of VMT as a metric focuses on the total amount of driving, rather than the driving experience. This
new view presents an impact filter intended to promote the reduction of greenhouse gas emissions, the
development of multimodal transportation networks, and a diversity of land uses. VMT can help identify
how projects (land development and infrastructure) influence accessibility (i.e., access to places and
people), noise, and emissions; thus, its selection as a metric is aligned with the objectives of SB 743.
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Many jurisdictions find it useful to express VMT as an efficiency metric (e.g., VMT per person or VMT per
employee). This form of the metric is unrelated to the level of activity in a particular location and more
about how efficiently the people at that location travel. A project that contributes to a more efficient use
of the transportation system would reduce the total VMT per person as compared to a no-project
scenario. A commonly used efficiency metric is “total VMT per service population,” in which the
denominator called “service population” includes all the variables that generate vehicle trips in the models
that estimate VMT; in most instances this will be the total number of residents plus the number of
employees in the analysis area or project; however, it may also include other categories of people, such as
visitors or students, if those categories are used in the trip generation estimates in the model. Based on
the background context outlined above, the remainder of this chapter provides information about key
decisions the City of Cupertino staff made regarding VMT metrics, calculation methods, and
impact thresholds.
2.3 Approach
Under CEQA, agencies must decide what constitutes a significant environmental impact. The CEQA Statute
& Guidelines encourage local agencies to adopt thresholds of significance. The thresholds for VMT can be
quantitative (i.e., a measured value such as the concentration of greenhouse gas emissions in the
atmosphere) or qualitative performance standards (e.g., VMT on local streets) by which the agency can
measure the relative magnitude of an impact caused by a project to determine if the project’s impacts are
significant. In fact, the new CEQA Statute & Guidelines Section 15064.3(b)(4) establishes that the lead
agency has discretion to choose the most appropriate VMT methods for transportation impact analysis:
Methodology. A lead agency has discretion to choose the most appropriate methodology to evaluate
a project’s vehicle miles traveled, including whether to express the change in absolute terms, per
capita, per household, or in any other measure. A lead agency may use models to estimate a
project’s vehicle miles traveled and may revise those estimates to reflect professional judgment
based on substantial evidence. Any assumptions used to estimate vehicle miles traveled and any
revisions to model outputs should be documented and explained in the environmental document
prepared for the project. The standard of adequacy in Section 15151 shall apply to the analysis
described in this section.
After careful evaluation of the Technical Advisory on Evaluating Transportation Impacts in CEQA
(December 2018) (OPR Technical Advisory) and conducting its own SB 743 implementation to establish
VMT methods and thresholds (refer to the SB 743 Implementation Decisions for the City of Cupertino,
February 2021), the City of Cupertino adopted VMT thresholds in February 2021 and prepared the City of
Cupertino Transportation Study Guidelines (TS Guidelines, May 2021). The TS Guidelines provide guidance
for CEQA compliant transportation impact analysis pursuant to SB 743 for land development and
transportation projects in the City. Considering the information and options provided in the TS Guidelines,
City staff chose to prepare a comprehensive VMT assessment to evaluate the effect of this large land use
project. The comprehensive VMT assessment (i.e., VMT including all vehicle trips, vehicle types, and trip
purposes without separation by land use) presented in this report considers the Project’s direct and
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indirect impacts under cumulative conditions that considers the Project’s long-term effect on VMT.4 This
VMT approach was prepared by transportation engineers and support staff with a strong understanding
of CEQA practice and a focus on consistency and compliance with CEQA Statute & Guidelines.
The OPR Technical Advisory provides a blueprint for organizing key decisions regarding SB 743 methods:
the decisions listed later in this section follow the basic structure of the OPR Technical Advisory. The OPR
Technical Advisory recommends considering a project’s short-term, long-term, and cumulative effects on
VMT but provides limited recommendations on how to prepare a comprehensive VMT assessment for
large land use projects.
City staff considered the substantial evidence presented in the OPR Technical Advisory, the SB 743
Implementation Decisions for the City of Cupertino (February 2021), and the TS Guidelines to make key
decisions about the VMT forecasting model, VMT accounting methods, calculation of the baseline and
cumulative regional VMT estimates, and VMT thresholds required for a comprehensive analysis. The
SB 743 Implementation Decisions for the City of Cupertino includes substantial evidence examples with
specific citations of the following:
• Using total VMT and project’s effect on VMT (refer to the Retail Projects quote on page 45 of the
SB 743 Implementation Decisions for the City of Cupertino whitepaper, February 2021),
• not truncating trip lengths based on model or political boundaries (refer to the Consideration for
All Projects quote on page 45 of the SB 743 Implementation Decisions for the City of Cupertino
whitepaper, February 2021), and
• accounting for the cumulative effects of a project (refer to Cumulative Impacts quote on page
45 of the SB 743 Implementation Decisions for the City of Cupertino whitepaper) used to evaluate
consistency with adopted plans.
The inclusion of a project’s effects on VMT for retail projects in the OPR Technical Advisory is one of the
reasons the analysis presented here includes all trip purposes and vehicle types without separation of
VMT by land use, and an evaluation of a project’s effects on VMT (i.e., total project generated VMT per
service population and boundary VMT).
The expectations of a CEQA impact analysis to provide a complete picture of the VMT effects on the
environment are highlighted within the CEQA Guidelines in the following sections.
4 This is in contrast with the OPR Technical Advisory recommendation to use partial VMT for transportation impact
analysis (Governor’s Office of Planning and Research, Technical Advisory: On Evaluating Transportation Impacts in
CEQA, pages 15 and 16). Using partial VMT for project generated VMT screening may not tell the full story of the
project’s benefits. For example, mixed-use projects help reduce VMT by shortening vehicle trip lengths or reducing
vehicle trips because of the convenience of walking, bicycling, or using transit between project destinations. A
comprehensive VMT analysis is a more complete evaluation.
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• CEQA Guidelines – Expectations for Environmental Impact Analysis
◦ § 15003 (F) = fullest possible protection of the environment…
◦ § 15003 (I) = adequacy, completeness, and good-faith effort at full disclosure…
◦ § 15125 (C) = EIR must demonstrate that the significant environmental impacts of the
proposed project were adequately investigated…
◦ § 15144 = an agency must use its best efforts to find out and disclose…
◦ § 15151 = sufficient analysis to allow a decision which intelligently takes account of
environmental consequences…
All of these suggest that completeness and accuracy is important when judging an adequate analysis.
Furthermore, to understand the effects of a project, VMT inputs for air quality, GHG emissions, and energy
consumption already require a comprehensive analysis of total “project generated” VMT and “project’s
effect on VMT” using local or regional travel forecasting models:
• Total (project generated) VMT per service population (Direct/Project Impacts): The sum of
the “VMT from” and “VMT to” and within a specific geographic area are divided by the sum of the
number of residents and employees in the same geographic area.
• Project’s effects on VMT per service population (Cumulative Impacts): An evaluation of the
change in travel between With and Without Project Conditions on all roadways within a
geographic area divided by the sum of the number of residents and employees in the same
geographic area.
Both total VMT and the Project’s effects on VMT are needed to fully account for VMT effects that may
include changes to VMT generation from neighboring land uses. The importance of a comprehensive
analysis using all VMT per service population and that considers the Project’s effects on VMT is that land
use projects can influence the routing of existing trips and the VMT generation of surrounding land uses.5
2.3.1 Summary of VMT Methods Decisions
Implementation of a comprehensive VMT assessment requires certain methodology decisions. The
following steps were taken to establish SB 743 VMT thresholds:
• Select a VMT calculation tool
◦ Use the Santa Clara Valley Transportation Authority (VTA)-City/County Association of
Governments of San Mateo County (C/CAG) Bi-County travel model (VTA Travel Model).
5 Typical CEQA practice focuses on environmental effects that occur on a typical weekday, so all references to VMT in
this document are intended to mean VMT that occurs on a typical weekday.
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• Select the VMT accounting method(s)
◦ Total (project generated) VMT per service population (Direct/Project Impacts): The sum
of the VMT within the specified geographic area (internal-internal trips), “VMT from” the
specified geographic area (internal-external trips), and “VMT to” the specified geographic
area (external-internal trips), divided by the sum of the number of residents and employees in
the same geographic area.
◦ Project’s effects on VMT per service population: An evaluation of the change in travel
between With and Without Project Conditions on all roadways within a geographic area,
divided by the sum of the number of residents and employees in the same geographic area.
• Calculate the baseline and cumulative regional VMT estimates
◦ The analysis presented here uses VMT from all trip purposes and vehicle types (i.e., there is no
separation of VMT by land use) for the City (defined as the City of Cupertino city limits) for
total VMT per service population, and VMT on all roadways in Santa Clara County for Project’s
effect on VMT per service population (refer to the VMT Accounting Methods sections for
detailed descriptions).
• Set the VMT threshold(s)
◦ The threshold to be applied in assessing project-specific impacts is 14.4% below existing total
VMT per service population rate for the City. (Refer to Table 3 in Chapter 4 for additional
details about this threshold.)
◦ The threshold to be applied in assessing project’s effect on VMT is no change in the existing
(baseline) boundary VMT per service population for the County. (Refer to Table 4 in
Chapter 4 for additional details about this threshold.)
◦ The threshold to be applied in assessing cumulative impacts (project’s effect on VMT) is no
change in the cumulative conditions (future) boundary VMT per service population for the
County. (Refer to Table 5 in Chapter 4 for additional details about this threshold.)
For direct impacts, total VMT per service population is the metric used to evaluate how the Project VMT
changes (increases or decreases) between the Without Project and With Project scenarios, considering
both VMT increases due to growth and VMT reductions due to changes in travel behavior. Total VMT per
service population is used to evaluate if the VMT rate due to the Project (i.e., the direct impacts) is greater
than a specified VMT threshold; however, it does not evaluate a project’s effect on VMT on the entire
roadway system,6 which is evaluated separately.
6 An often-cited example of how a project can affect VMT is the addition of a grocery store in a food desert. Residents
of a neighborhood without a grocery store have to travel a great distance to an existing grocery store. Adding the
grocery store to that neighborhood will shorten many of the grocery shopping trips and reduce the VMT to/from
the neighborhood. This concept is likely to occur with the addition of housing and supporting retail uses in the City
of Cupertino.
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Regarding the cumulative Project’s effect on VMT analysis, the Project land use changes are small in the
context of the regional residential population and employment; therefore, it is to be expected that the
Project’s effect on VMT (cumulative impact) would have localized VMT effects. Furthermore, the Project is
likely to cause existing traffic to shift to active and transit modes as more residential infrastructure is built
in the City of Cupertino. Therefore, the Project’s effect on VMT, as evaluated by the cumulative effects of
the Project’s land use and transportation changes, compares the changes in boundary VMT per service
population7 between the Existing Condition and Existing with Project Condition, and Cumulative
Condition and the Cumulative with Project Condition. Each scenario is described in Chapter 1.
For the reasons listed above, the analysis presented in this report focuses on the VMT for all trip purposes
and vehicle types without separation of VMT by land use. For the Project analysis, the total Project
generated VMT threshold was developed using the Existing Conditions total VMT for the City and is used
to evaluate the Project’s direct impact. The boundary VMT baseline uses the countywide boundary VMT to
evaluate the Project’s effects on VMT because the Project effects are likely to be localized near the City of
Cupertino and within the County.
2.4 VMT Accounting Methods
To understand the VMT forecasts and VMT impact analysis, this section defines important VMT terms and
analysis methods. The VTA Travel Model was used to develop daily VMT forecasts for the
following metrics:
• Total VMT: The sum of the VMT associated with travel from, to, and within a project site.
• Project’s Effect on VMT (within a selected geographic boundary): An evaluation of the
change in total vehicle travel within a defined geographic area boundary, compared between the
Without Project and With Project conditions.
Total VMT per service population is the metric used to evaluate how the project VMT changes (increases
or decreases) between the Without Project and With Project scenarios, considering both VMT increases
due to growth and VMT reductions due to changes in travel behavior. As noted earlier, total VMT per
service population is used to evaluate if the VMT rate due to the project is greater than a specified VMT
threshold; however, it does not evaluate a project’s effect on VMT across an entire roadway system. The
Project’s effect on VMT compares the changes in boundary VMT per service population between the
without Project and with Project scenarios. The analysis presented in this report focuses on the VMT for all
trip purposes and vehicle types (i.e., there is no separation of VMT by land use).
7 Boundary VMT captures all VMT on a roadway network within a specified geographic area, including local trips plus
interregional travel, that does not have an origin or destination within the area.
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2.4.1 Total VMT
The total VMT is the VMT from all vehicle trips for all trip purposes and types caused by the residential
and employment population in a specific area. It is calculated by summing the VMT within the specified
geographic area (internal-internal trips), “VMT from” the geographic area (internal-external trips), and
“VMT to” the geographic area (external-internal trips), as follows:
𝑇𝑜𝑡𝑎𝑙 𝑉𝑀𝑇 ൌ ሺ𝐼𝐼 𝐼𝑋ሻ ሺ𝐼𝐼 𝑋𝐼ሻ ൌ 2 ∗𝐼𝐼𝐼𝑋𝑋𝐼
• Internal-internal (II): The full length of all trips made entirely within the specified geographic
study area limits.
• Internal-external (IX): The full length of all trips with an origin within the specified geographic
study area and destination outside of the area.
• External-internal (XI): The full length of all trips with an origin outside of the specified
geographic study area and destination within the area.
The intra-zonal VMT and VMT between traffic analysis zones, or TAZs, that are in the specified geographic
study area cause some double counting, an expected result when summing the trip end based VMT. To
ensure a VMT rate is expressed properly (i.e., that the numerator and denominator include the generators
of both trip ends of the VMT), the total VMT is divided by the service population (residential population,
and employment population)—the generator of both trip ends of the VMT. The VMT estimates are also
presented on a per service population basis to account for both the effects of population and/or
employment growth and the effects of changes in personal travel behavior. For example, population
growth may cause an increase in overall VMT, while travelers changing their behavior by using different
travel modes or decreasing their vehicle trip lengths would cause decreases in the amount of VMT that
each person generates.
2.4.2 Project’s Effect on VMT (Using Boundary VMT)
The Project’s effect on VMT is evaluated using the boundary VMT method, which captures all VMT on the
roadway network within a specified geographic area, including local trips plus interregional travel that
does not have an origin or destination within the study area. The geographical boundary method only
considers traffic within the physical limits of the selected study area and does not include the impact of
vehicles once they travel outside the area limits. The use of boundary VMT is a more comprehensive
evaluation of the potential effects of the Project because it captures the combined effect of new VMT,
shifts in existing VMT to/from other neighborhoods, and/or shifts in existing traffic to alternate travel
routes or modes. The boundary VMT is also divided by the service population (sum of residents and
employees) to account for the effects of population and/or employment growth and the effects of
changes in personal travel behavior within the specified geographic area.
Figure 3 presents a representation of both total VMT and boundary VMT. Both metrics are needed for a
comprehensive evaluation of a project’s VMT effects.
·82
·85
%&280
·82
·85
%&280
Cupertino City Limits and Sphere of Influence
Figure 1
N:\Projects\_SJ23_Projects\SJ23_2217_Cupertino_GP_Rezone_CEQA\Graphics\ADOBE\Fig03_Measuring Vehicle Miles Traveled.ai
Measuring Vehicle Miles Traveled (VMT) in Cupertino
with City Streets and City Limits
Figure 3
Project Generated VMT Project Effect on VMT
(Boundary VMT)
Legend:
= Cupertino City Limits
= Cupertino Sphere of Influence
= 2 x Internal to Internal (2 x II) VMT
= External to Internal (XI) VMT
= Internal to External (IX) VMT
= External to External (XX) VMT
2
3
1
4
Legend:
= Cupertino City Limits
= Cupertino Sphere of Influence
= Internal to Internal VMT
= External to Internal (XI) VMT
= Internal to External (IX) VMT
= External to External (XX) VMT
= Streets included in boundary
VMT calculation
1
2
3
4
Notes: External to External (XX) trips (shown as transparent arrow 4) are excluded from this
VMT metric. Adjustments to project generated VMT made to include the full length of
trips that leave the Cupertino to capture inter-city travel.
Notes: Boundary VMT is all the VMT within the Cupertino (city limits). Transparent portions of
arrows 2, 3 and 4 are not included in the VMT metric.
}85
3
22
4
3
1 1
}85
4
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3. Summary of Relevant
Regional Circulation and
Transportation Plans
This chapter provides a summary of regional circulation and transportation plans relevant to this Project.
The Metropolitan Transportation Commission’s (MTC) Regional Transportation Plan provides a roadmap for
accommodating projected household and employment growth in the nine-county Bay Area by 2050 as
well as a transportation investment strategy for the region. The Santa Clara Valley Transportation
Authority (VTA) VTP 2040 Plan describes all major projects in Santa Clara Valley over the next 20 years.
The Santa Clara Countywide Bicycle Plan’s primary goal was to make it easier and safer for people to bike
when traveling from one city to the next in Santa Clara County. The Congestion Management Program
Monitoring and Conformance Report sets state and federal funding priorities for transportation
improvements affecting the Santa Clara County Congestion Management Program (CMP)
transportation system.
Cupertino General Plan – Community Vision 2015-2040 includes mobility goals aimed to enhance travel by
all modes by encouraging use by non-auto modes and thus reduce vehicle trips. The City of Cupertino
Climate Action Plan quantifies and estimates community-wide and municipal GHG emissions between
2010 and 2050 with specific measures to reduce GHG emissions. The City of Cupertino 2016 Bicycle
Transportation Plan focuses on improving the safety and comfort of the bike network in Cupertino. The
City of Cupertino Pedestrian Transportation Plan focuses on improving the safety and comfort of the
pedestrian network in Cupertino. The City of Cupertino Transportation Fee (TIF) Nexus Study is an
implementation program that allows the City to collect a one-time fee from new developments to cover
the cost of vehicle and bicycle capital improvements that support land use growth in the City. Cupertino
Municipal Code Chapter 17.08 presents the standards for the use of vehicle miles traveled in
environmental impact analysis. The City of Cupertino Transportation Study Guidelines provide guidance for
conducting a transportation study in Cupertino.
3.1 Metropolitan Transportation Commission’s (MTC) Regional
Transportation Plan (Plan Bay Area)
Plan Bay Area 20508 is overseen by the Metropolitan Transportation Commission (MTC) and the
Association of Bay Area Governments (ABAG). It serves as the region’s Sustainable Communities Strategy
(SCS) pursuant to SB 375 and the 2040 RTP (preceded by Transportation 2035), integrating transportation
and land use strategies to manage greenhouse gas emissions and plan for future population growth. The
8 Metropolitan Transportation Commission, 2017. Plan Bay Area 2040. Available online at Plan Bay Area 2040 | Plan
Bay Areahttp://2040.planbayarea.org/.
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RTP and SCS include policies that call for shifting more travel demand to transit and accommodating
growth along transit corridors in “Priority Development Areas (PDAs).” In July 2013, Plan Bay Area 2040
was adopted by ABAG and the MTC.
Plan Bay Area 20509 is the update to Plan Bay Area 2040. It serves as the region’s Sustainable
Communities Strategy (SCS) pursuant to SB 375 and the 2050 RTP (preceded by Plan Bay Area 2040) and
integrates four elements (Housing, Economy, Transportation, and Environment) and five guiding principles
(affordable, connected, diverse, healthy, and vibrant) to manage GHG emissions and plan for future
population growth. Most of the investments are directed toward residents of Equity Priority Communities
or other systematically underserved communities. The plan envisions investment in affordable housing
production and preservation, a universal basic income to support residents’ essential needs, investments
in means-based transit fare discounts, and subsidies to protect homes and businesses from natural
hazards. The following strategies are included:
• Housing Strategies
◦ Protect and Preserve Affordable Housing
▪ H1. Further strengthen renter protections beyond state law
▪ H2. Preserve existing affordable housing
◦ Spur Housing Production for Residents of All Income Levels
▪ H3. Allow a greater mix of housing densities and types in Growth Geographies
▪ H4. Build adequate affordable housing to ensure homes for all
▪ H5. Integrate affordable housing into all major housing projects
▪ H6. Transform aging malls and office parks into neighborhoods
◦ Create Inclusive Communities
▪ H7. Provide targeted mortgage, rental, and small business assistance to Equity
Priority Communities
▪ H8. Accelerate reuse of public and community-owned land for mixed-income housing and
essential services
9 Metropolitan Transportation Commission, 2021. Plan Bay Area 2050. Available online at Plan Bay Area 2050 | Plan
Bay Areahttp://planbayarea.org/.
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• Economic Strategies
◦ Improve Economic Mobility
▪ EC1. Implement a statewide universal basic income
▪ EC2. Expand job training and incubator programs
▪ EC3. Invest in high-speed internet in underserved low-income communities
◦ Shift the Location of Jobs
▪ EC4. Allow greater commercial densities in Growth Geographies
▪ EC5. Provide incentives to employers to shift jobs to housing-rich areas well served
by transit
▪ EC6. Retain and invest in key industrial lands
• Transportation Strategies
◦ Maintain and Optimize the Existing System
▪ T1. Restore, operate, and maintain the existing system
▪ T2. Support community-led transportation enhancements in Equity Priority Communities
▪ T3. Enable a seamless mobility experience
▪ T4. Reform regional transit fare policy
▪ T5. Implement per-mile tolling on congested freeways with transit alternatives
▪ T6. Improve interchanges and address highway bottlenecks
▪ T7. Advance other regional programs and local priorities
◦ Create Healthy and Safe Streets
▪ T8. Build a Complete Streets network
▪ T9. Advance regional Vision Zero policy through street design and reduced speeds
◦ Build a Next-Generation Transit Network
▪ T10. Enhance local transit frequency, capacity, and reliability
▪ T11. Expand and modernize the regional rail network
▪ T12. Build an integrated regional express lanes and express bus network
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• Environmental Strategies
◦ Reduce Risk from Hazards
▪ EN1. Adapt to a sea level rise
▪ EN2. Provide means-based financial support to retrofit existing residential buildings
▪ EN3. Fund energy upgrades to enable carbon neutrality in all existing commercial and
public buildings
◦ Expand Access to Parks and Open Space
▪ EN4. Maintain urban growth boundaries
▪ EN5. Protect and manage high-value conservation lands
▪ EN6. Modernize and expand parks, trails, and recreation facilities
◦ Reduce Climate Emissions
▪ EN7. Expand commute trip reduction programs at major employers
▪ EN8. Expand clean vehicle initiatives
▪ EN9. Expand transportation demand management incentives
Major transit projects included in Plan Bay Area 2050 include a BART extension to San José/Santa Clara,
Caltrain electrification, enhanced service along the Amtrak Capitol Corridor, and improvements to local
and express bus services.
3.2 Santa Clara Valley Transportation Authority VTP 2040 Plan
Santa Clara Valley Transportation Authority (VTA), the countywide transportation authority, has adopted
the Valley Transportation Plan (VTP) 2040 (adopted in October 2014) that describes all major projects and
initiatives expected to occur in the next 20 years. It prioritizes complete streets, express lanes, light rail
effectiveness upgrades, bus rapid transit, and bicycle/pedestrian improvements.
Most recently, the Phase 3 of the US 101 and State Route (SR) 85 Express Lanes Project converted the
existing single carpool lanes to express lanes on US 101 from near SR 237 to SR 85 in Mountain View and
SR 85 from SR 237/Grant Road to the US 101/SR 85 interchange. Also, the existing double carpool lane on
US 101 between the San Mateo County line to the US 101/SR 85 interchange was converted to double
express lanes. The VTA 2040 Plan also includes a package of projects in the North Bayshore Precise Plan
area including the electrification of Caltrain, express lane projects along US 101, SR 237 and SR 85, US 101
southbound improvements from San Antonio Road to Rengstorff Avenue, Permanente Creek Trail grade
separation at Charleston Road, and extensions of Permanente Creek Trail to Middlefield Road.
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3.3 Santa Clara Countywide Bicycle Plan
The Santa Clara Countywide Bicycle Plan’s primary goal is to make it easier and safer for people to bike
when traveling from one city to the next in Santa Clara County. The plan establishes a network of Cross
County Bikeway Corridors that will provide continuous, complete bike connections across the county. The
plan also identifies locations where new and improved bicycle connections are needed across freeways,
rail lines, and creeks. Lastly, the plan identifies ways to make it easier for people to use their bicycle with
transit, including bicycle access to major transit stops, bicycle parking at stops, and bicycle
accommodations onboard.
3.4 Congestion Management Program Monitoring and
Conformance Report
As the county’s Congestion Management Agency (CMA), VTA is responsible for managing the county’s
blueprint to reduce congestion and improve air quality. VTA is authorized to set state and federal funding
priorities for transportation improvements affecting the Santa Clara County CMP transportation system.
CMP-designated transportation system components in Cupertino include a regional roadway network, a
transit network, and a bicycle network. The CMP regional roadway network in Cupertino includes all state
highways, county expressways, and some principal arterials, while the transit network includes rail service
and selected bus service. The bicycle network focuses on the Cross County Bicycle Corridors, which is a
network of 57 routes identified in the Santa Clara Countywide Bicycle Plan (summer 2018). The long-range
countywide transportation plan and how projects compete for funding and prioritization are documented
in the Valley Transportation Plan (VTP) 2040 (adopted in October 2014).
The Citywide Multimodal Improvement Plan (MIP), also referred to as the Deficiency Plan per state’s CMP
legislation, is a planning document that identifies measures to improve transportation conditions on the
CMP network instead of making physical traffic capacity expansions such as widening an intersection or
roadway. The MIP is based on the VTA Deficiency Plan Requirements, which describe the required
content, actions, and implementation standards to assist member agencies with deficiency plan
preparation and responsibilities.
3.5 Cupertino General Plan – Community Vision 2015‐2040
The Land Use and Community Design Element, and Mobility Element of the Cupertino General Plan –
Community Vision 2015-2040 (2015) states the community’s land use and transportation goals, policies,
and strategies for land use growth and multimodal travel. The General Plan emphasizes land use growth
along major mixed-use corridors and mixed-use nodes, and an enhancement of the connectivity and
quality of the multimodal transportation system to support economic vitality, air quality and greenhouse
goals, and urban design amenities. The Mobility Element goals are listed below for reference:
• Goal M-1: Actively participate in regional planning processes to coordinate local planning and to
advocate for decisions that meet and complement the needs of Cupertino.
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• Goal M-2: Promote improvements to City streets that safely accommodate all transportation
modes and persons of all abilities.
• Goal M-3: Support a safe pedestrian and bicycle street network for people of all ages and abilities.
• Goal M-4: Promote local and regional transit that is efficient, frequent, convenient, and reduces
traffic impacts.
• Goal M-5: Ensure safe and efficient pedestrian and bicycle access to schools while working to
reduce school-related congestion.
• Goal M-6: Promote innovative strategies to provide efficient and adequate vehicle parking.
• Goal M-7: Review and update TIA policies and guidelines that allow for adequate consideration
for all modes of transportation, including automobiles, walking, bicycles, and transit.
• Goal M-8: Promote policies to help achieve state, regional, and local air quality and greenhouse
gas emission reduction targets.
• Goal M-9: Promote effective and efficient use of the city's transportation network and services.
• Goal M-10: Ensure that the city's transportation infrastructure is well-maintained for all modes of
transportation and that projects are prioritized on their ability to meet the City's mobility goals.
The General Plan policies and strategies provide additional detail regarding the underlying expectations of
how population and employment will be supported and how the community will travel. Additionally, the
General Plan describes modal priorities in its street typology and circulation network figure by indicating
which modes individual streets and street types will be designed for. While Policy M-1.210 states the City’s
vehicle level of service policy, General Plan Goal M-7 indicates that the City will review and update its
Transportation Impact Analysis (TIA) policies and guidelines with Policies M-7.111 and M-7.2,12.
3.6 City of Cupertino Climate Action Plan
Over the past 10 years, the State of California has adopted legislation to address climate change and
streamline CEQA evaluation (including AB 32, SB 375, SB 743, and AB 1358). Specifically, with the passage
of Assembly Bill (AB) 32, the Global Warming Solutions Act of 2006, the State of California committed
10 Policy M-1.2: Transportation Impact Analysis: Participate in the development of new multi-modal analysis methods
and impact thresholds as required by Senate Bill 743. However, until such impact thresholds are developed, continue
to optimize mobility for all modes of transportation while striving to maintain the following intersection Levels of
Service (LOS) at a.m. and p.m. peak traffic hours:
Major intersections: LOS D
Stevens Creek Boulevard and De Anza Boulevard: LOS E+
Stevens Creek Boulevard and Stelling Road: LOS E+
De Anza Boulevard and Bollinger Road: LOS E+
11 Policy M-7.1: Multi-Modal Transportation Impact Analysis: Follow guidelines set by the VTA related to
transportation impact analyses, while conforming to State goals for multi-modal performance targets.
12 Policy M-7.2: Protected Intersections: Consider adopting a Protected Intersection policy, which would identify
intersections where improvements would not be considered, which would degrade levels of service for non-
vehicular modes of transportation. Potential locations include intersections in Priority Development Areas (PDAs)
and other areas where non-vehicular transportation is a key consideration, such as, near shopping districts, schools,
parks and senior citizen developments.
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itself to reducing GHG emissions to 1990 levels by 2020. SB 375 provides guidance on how curbing
emissions from cars and light trucks can help the state comply with AB 32. In response to this state
legislation and its community values to reduce greenhouse gas emissions, Cupertino prepared the City of
Cupertino Climate Action Plan (2015). The Climate Action Plan quantifies and estimates community-wide
and municipal GHG emissions between 2010 and 2050 with specific measures to reduce GHG emissions.
The transportation sector represents the second largest community-wide GHG emissions sector (34%).
The transportation measures include the following:
• Measure C-T-1 Bicycle & Pedestrian Environment Enhancements – Continue to encourage
multimodal transportation, including walking and biking, through safety and comfort
enhancements in the bicycle and pedestrian environment.
• Measure C-T-2 Bikeshare Program – Explore feasibility of developing local bikeshare program.
• Measure C-T-3 Transportation Demand Management – Provide informational resources to local
business subject to SB 1339 transportation demand management program requirements and
encourage additional voluntary participation in the program.
• Measure C-T-4 Transit Route Expansion – Explore options to develop local community shuttle or
community-wide car sharing to fill gaps in existing transit network.
• Measure C-T-5 Transit Priority – Improve transit service reliability and speed.
• Measure C-T-6 Transit-Oriented Development – Continue to encourage development that takes
advantage of its location near local transit options (e.g., major bus stops) through higher densities
and intensities to increase ridership potential.
• Measure C-T-7 Community-Wide Alternative Fuel Vehicles – Encourage community-wide use of
alternative fuel vehicles through expansion of alternative vehicle refueling infrastructure.
The CAP assumes that 85% of the estimated reduction in the transportation sector GHG emissions will
come from low carbon fuels and increased vehicle efficiency, while Transportation Demand Management
will account for the remaining 15% (the reduction associated with other measures was not modeled
because they were considered to be supportive measures to the built environment characteristics and
TDM in Cupertino).
3.7 City of Cupertino 2016 Bicycle Transportation Plan
The City of Cupertino 2016 Bicycle Transportation Plan (June 2016) summarizes goals for improving the
bicycle network, existing and proposed facilities, and programs involving education, enforcement, and
promotion. The Bicycle Plan was developed in conformance with several other plans including the
Cupertino General Plan, the Santa Clara Valley Transportation Authority Countywide Bicycle Plan, the
Metropolitan Transportation Commission Regional Bicycle Plan, the Santa Clara County Trails Master Plan,
and the Caltrans Streets and Highways Code Section 891.2. Goals of the Bicycle Plan are as follows:
• Goal 1 – Programs: Increase awareness and value of bicycling through encouragement, education,
enforcement, and evaluation programs.
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• Goal 2 – Safety: Improve bicyclist safety through the design and maintenance of
roadway improvements.
• Goal 3 – Mobility: Increase and improve bicycle access to community destinations across the City
of Cupertino for all ages and abilities.
3.8 City of Cupertino Pedestrian Transportation Plan
The City of Cupertino Pedestrian Transportation Plan (February 2018) summarizes goals for the pedestrian
network, existing and proposed facilities, and priority of pedestrian improvements. The Pedestrian Plan
was developed in conformance with the Cupertino General Plan and other City guidance documents.
Goals of the Pedestrian Plan are as follows:
• Goal 1 – Safety: Improve pedestrian safety and reduce the number and severity of pedestrian-
related collisions, injuries, and fatalities.
• Goal 2 – Access: Increase and improve pedestrian access to community destinations across the
City of Cupertino for people of all ages and abilities.
• Goal 3 – Connectivity: Continue to develop a connected pedestrian network that fosters an
enjoyable walking experience.
3.9 City of Cupertino Transportation Impact Fee (TIF) Nexus Study
The City of Cupertino Transportation Impact Fee (TIF) Nexus Study (2017) is an implementation program
that allows the City to collect a one-time fee from new developments to cover the cost of vehicle and
bicycle capital improvements determined to be necessary to support land use growth in the City. A “nexus
study” is used to establish the nexus (or relationship) between new development that occurs in a
jurisdiction and the need for new and expanded transportation facilities. After establishing the nexus, the
study calculates the development impact fees to be levied for each land use type in the areas of benefit,
based on the proportionate share of the total facility use for each type of development. A nexus study
identifies the maximum allowable fee, but does not determine a particular fee level; the relevant policy-
making body (in this case, the City Council) has the authority to decide specifically what fees will be
charged within the framework provided by the nexus study.
In general, the relevant state legislation governing fee programs (the Mitigation Fee Act, California
Government Code sections 66000 et seq.) require that a nexus study address the following topics:
• Identify the purpose of the fee.
• Identify how the fee is to be used.
• Determine how a reasonable relationship exists between the fee's use and the type of
development project on which the fee is imposed.
• Determine how a reasonable relationship exists between the need for the public facility and the
type of development project on which the fee is imposed.
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• Demonstrate a reasonable relationship between the amount of the fee and the cost of the public
facility, or portion of the public facility, attributable to the development on which the fee
is imposed.
The City’s transportation fee project list includes a combination of freeway interchange, street, and
intersection improvements focused on localized vehicle operations and bicycle improvements focused on
improving the connectivity and quality of the bicycle network.
3.10 Cupertino Municipal Code Chapter 17.08
On February 16, 2021, Cupertino City Council adopted Ordinance #21-2223 that adds Cupertino Municipal
Code Chapter 17.08 with standards for the use of vehicle miles traveled (VMT) in environmental impact
analysis review to implement SB 743 in environmental review of land use or transportation projects. The
municipal code provides standards relating to VMT screening and VMT significance thresholds for
projects in Cupertino.
3.11 City of Cupertino Transportation Study Guidelines
The City of Cupertino developed guidance for transportation impact analysis metrics and thresholds of
significance in the City of Cupertino Transportation Study Guidelines (2021). The guidelines are used to
evaluate projects in Cupertino for consistency with the City’s General Plan, for consistency with the Santa
Clara County Congestion Management Program (CMP), and for significant impacts and mitigation for
environmental impact analysis. City staff use these guidelines to establish a clear and consistent technical
approach for performing local transportation analysis (LTA), transportation analysis (non-CEQA), and
transportation analysis for analyzing and determining impacts under CEQA. The resulting reports provide
essential information on effects (adverse and beneficial) on the transportation system and services for
decision-makers and the public when evaluating individual development and transportation
infrastructure projects.
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4. Significance Criteria
The detailed impact criteria for VMT and other transportation-related items are described below. The
Project’s potential impacts are presented in Chapter 6.
4.1 Significance Criteria
The City of Cupertino Transportation Study Guidelines (TS Guidelines, May 2021) provides guidance for the
preparation of CEQA-compliant transportation impact analysis pursuant to SB 743. The significance
criteria from the TS Guidelines are presented below.
4.1.1 Plan Conflicts
To determine the proposed Project’s consistency with relevant transportation programs, plans, ordinances
or policies, the following significance thresholds were applied to each respective mode of travel—transit
system, roadway system, bicycle system, and pedestrian system as listed below.
4.1.1.1 Transit System
Analysis of transit-related impacts encompasses two components: (1) transit capacity, and (2) a project’s
consistency with local transit plans. For transit capacity, a significant impact would occur if the Project
creates demand for public transit above the capacity which is provided or planned.
To determine the Project’s consistency with local transit plans, significant impacts would occur if the
Project or any part of the Project:
• Disrupts existing transit services or facilities;13 or
• Conflicts with an existing or planned transit facility; or
• Conflicts with transit policies adopted by the City of Cupertino, or the Santa Clara Valley
Transportation Authority for their respective facilities in the study area.
4.1.1.2 Roadway System
To determine the proposed Project’s consistency with local roadway plans, significant impacts would
occur if the Project or any part of the Project:
• Disrupts existing or planned roadway facilities or conflicts with applicable program, plan,
ordinance or policy.
13 This includes disruptions caused by the Project relative to transit street operations and transit stops/shelters; or
impacts to transit operations from traffic improvements proposed or resulting from the Project.
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4.1.1.3 Bicycle System
The proposed Project would create a significant impact related to the bicycle system if the Project or any
part of the Project:
• Disrupts existing bicycle facilities;
• Interferes with planned bicycle facilities; or,
• Conflicts with applicable bicycle system plans, guidelines, policies, or standards.
4.1.1.4 Pedestrian System
The proposed Project would create a significant impact related to the pedestrian system if the Project or
any part of the Project:
• Disrupts existing pedestrian facilities; or
• Interferes with planned pedestrian facilities; or
• Conflicts with applicable pedestrian system plans, guidelines, policies, or standards.
4.1.2 VMT Impacts
The VMT impact analysis presented in this report considers the Project’s direct impacts relative to total
VMT per service population as well as the Project’s long-term effect on VMT using boundary VMT per
service population. Per the Cupertino Municipal Code “Chapter 17.08: Evaluation of Transportation
Impacts under the California Environmental Quality Act” as of March 2021, the Project would result in a
VMT-related impact as described below in Table 2.
Table 2: VMT Significance Thresholds
Impact Category Significance Threshold Calculated Numeric Threshold for Project
Under Existing (Baseline) Conditions
Project Impact
A significant impact would occur if the total
project generated VMT per service
population for the project would exceed a
level of 14.4% below the citywide baseline
VMT rate.
The project would result in a significant
project-specific impact if the Project total
VMT per service population under Existing
with Project Conditions is greater than 31.30
miles.
Project Effect
A significant impact would occur if the project
increases total (boundary) countywide VMT
compared to baseline conditions.
The project would result in a significant
project effect impact if it causes the existing
countywide daily boundary VMT per service
population to be greater than 13.51 miles.
Under Cumulative Conditions
Project Effect
A significant impact would occur if the project
increases total (boundary) countywide VMT
compared to cumulative no project
conditions.
The project would result in a significant
cumulative impact if it causes the cumulative
countywide daily boundary VMT per service
population to be greater than 12.53 miles.
Source: Fehr & Peers, 2024.
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4.1.2.1 Project Generated VMT Impact Thresholds and Impact Criteria
As discussed in the VMT Approach and Analysis Methods chapter (Chapter 2), the significance threshold
for determining the Project’s direct impact is a total VMT per service population rate that is 14.4% below
the Existing Conditions total VMT per service population for the City of Cupertino. The threshold applied
in this analysis is 14.4% below the existing total VMT per service population of 36.56, which, as shown in
Table 3, is the existing total VMT of 3,772,000 divided by the service population of 103,170. This results in
a total VMT per service population threshold of 31.30 miles (36.56 miles * 85.6% = 31.30 miles).
Table 3: Project Generated VMT Threshold
Item Amount
Total Vehicle Miles Traveled (A)1 3,772,000
Service Population (B)1,2 103,170
Total VMT per Service Population (A/B = C) 36.56
Total VMT per Service Population Threshold (C*85.6% = D) 31.30
Notes:
1. Rounded service population and VMT to nearest 10.
2. Service population is defined as the sum of all residents and employees.
Source: Fehr & Peers, 2024.
Therefore, the Project would cause a significant Project-generated VMT impact if the Project total VMT
per service population under Existing with Project Conditions is greater than 31.30 miles.
4.1.2.2 Project’s Effect on VMT Thresholds and Impact Criteria
For the Project’s effect on overall VMT, the threshold is set as no increase in Countywide VMT per service
population (that is, no increase in the total amount of VMT occurring within the borders of Santa Clara
County divided by the total service population of the County). As shown in Table 4, under Existing
Conditions the Countywide VMT per service population is 13.51, so that value is the threshold of
significance for the evaluation of Existing with Project Conditions. The cumulative conditions impact
threshold for the Project’s effect on VMT is the Santa Clara County boundary VMT per service population,
or 12.53 miles (refer to Table 5).
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Table 4: Project’s Effect on VMT (Boundary VMT) Existing Threshold
Item Amount
Boundary Vehicle Miles Traveled (A)1 39,258,000
Service Population (B)1,2 2,905,260
Boundary VMT per Service Population (A/B = C) 13.51
Boundary VMT per Service Population Threshold (C = D) 13.51
Notes:
1. Rounded service population and VMT to nearest 10.
2. Service population is defined as the sum of all residents and employees.
Source: Fehr & Peers, 2024.
Table 5: Project’s Effect on VMT (Boundary VMT) Cumulative Threshold
Item Amount
Boundary Vehicle Miles Traveled (A)1 48,479,000
Service Population (B)1,2 3,873,750
Boundary VMT per Service Population (A/B = C) 12.53
Boundary VMT per Service Population Threshold (C = D) 12.53
Notes:
1. Rounded service population and VMT to nearest 10.
2. Service population is defined as the sum of all residents and employees.
Source: Fehr & Peers, 2024.
Therefore, the Project’s effect on VMT would result in a significant existing impact if it causes the existing
countywide daily boundary VMT per service population to be greater than 13.51 miles.
The Project’s effect on VMT would result in a significant cumulative impact if it causes the cumulative
countywide daily boundary VMT per service population to be greater than 12.53 miles.
4.1.2.3 Plan Consistency
CEQA, Section 15125(d), also requires an EIR to discuss inconsistencies between the proposed Project and
applicable general and regional plans; therefore, a significant impact would occur if the Project were
inconsistent with the Regional Transportation Plan/Sustainable Community Strategy Plan (Plan Bay Area).
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5. Vehicle Miles Traveled Forecasts
The Santa Clara Valley Transportation Authority (VTA)-City/County Association of Governments of San
Mateo County (C/CAG) Bi-County travel model (VTA Travel Model) was used to develop daily VMT and
traffic forecasts for the City of Cupertino and the Project sites. VMT forecasts were prepared for the
SB 743 VMT assessment, as well as for use as inputs for the air quality, greenhouse gas (GHG), and
noise analysis.
5.1 Summary of VMT Forecasts Methods
The VMT assessment calculates VMT using the following steps and methods consistent with the VTA
Travel Model:
• Service Population: The residential and employee populations are from the VTA Travel Model.
• Vehicle Miles Traveled: The total VMT and boundary VMT were developed using the VTA Travel
Model. The VMT estimates are also presented on a per service population basis to distinguish the
effects of population and/or employment growth from the effects of changes in personal travel
behavior.14 (The total VMT metric and calculation methods and the project's effect on VMT using
boundary VMT are described in Chapter 2 and illustrated in Figure 3.)
5.2 Service Population
VMT is the result of the land use and transportation network inputs for a given model year. The land use
input for this VMT analysis is the service population that generates the VMT. The service population is the
sum of the number of employees plus residents. Table 6 shows the service populations used in the VMT
metrics for the City of Cupertino and Santa Clara County.
14 For example, population growth may cause an increase in total VMT, but if travelers change their behavior by using
different travel modes or decreasing their trip lengths, then the VMT per service population metric could decrease.
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Table 6: Service Population
Land Use Existing
Conditions3
Existing with
Project
Conditions
Cumulative
Conditions4
Cumulative
with Project
Conditions
City of Cupertino1
Residents (A) 59,680 69,380 72,740 82,440
Employees (B) 43,490 43,490 52,720 52,720
Service Population (A+B = C) 103,170 112,870 125,460 135,160
Santa Clara County2
Residents (A) 1,856,250 1,865,950 2,553,720 2,563,420
Employees (B) 1,049,010 1,049,010 1,310,330 1,310,330
Service Population (A+B = C) 2,905,260 2,914,960 3,864,050 3,873,750
Notes: Population values rounded to nearest 10.
1. TAZs included in this summary 86-94, 97-103, 105-136, and 204.
2. TAZs included in this summary 1-1490.
3. Existing Conditions represent 2019 conditions.
4. Cumulative Conditions represent 2040 conditions.
Source: VTA Travel Model land use summary prepared by Fehr & Peers, 2024.
The service population is expected to increase by 21.6 percent (((125,460 / 103,170) – 1)*100 = 21.6%) in
Cupertino and 33.0 percent (((3,864,050 / 2,905,260) – 1)*100) for Santa Clara County between existing
and cumulative conditions.
5.3 Daily VMT Forecasts
This section summarizes the total VMT and boundary VMT forecasts for the City of Cupertino under the
four study scenarios.
5.3.1 Total Project Generated VMT Forecasts
The total project generated VMT City trip generation is presented in Table 7. Because the City’s project
generated VMT is expected to grow at a slower rate than its service population, the City of Cupertino total
VMT per service population rate is expected to decrease over time.
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Table 7: Total Project Generated VMT Forecasts
Land Use Existing Conditions2 Existing with Project
Conditions
City of Cupertino1
Total Project Generated VMT (A) 3,772,000 3,927,390
Service Population (B) 103,170 112,870
Total VMT per Service Population (A/B = C) 36.56 34.80
Notes: Population values rounded to nearest 10.
1. TAZs included in this summary 86-94, 97-103, 105-136, and 204.
2. Existing Conditions represent 2019 conditions.
3. Cumulative Conditions represent 2040 conditions.
Source: VTA Travel Model summary prepared by Fehr & Peers, 2024.
5.3.2 Boundary VMT Forecasts
Boundary VMT is a VMT metric that measures the VMT on a jurisdictions roadway system – refer to
Table 8. The countywide boundary VMT on local streets and freeways is expected to grow at a slower rate
than the countywide service population, which means that Santa Clara County’s boundary VMT per service
population is expected to decrease over time.
Table 8: Boundary VMT Forecasts
Land Use Existing
Conditions2
Existing with
Project
Conditions
Cumulative
Conditions3
Cumulative
with Project
Conditions
Santa Clara County1
Boundary Vehicle Miles Traveled (A) 39,258,000 39,318,000 48,413,000 48,479,000
Service Population (B) 2,905,260 2,914,960 3,864,050 3,873,750
Boundary VMT per Service Population (A/B = C) 13.51 13.49 12.53 12.51
Notes: Population values rounded to nearest 10.
1. TAZs included in this summary 1-1490.
2. Existing Conditions represent 2019 conditions.
3. Cumulative Conditions represent 2040 conditions.
Source: VTA Travel Model summary prepared by Fehr & Peers, 2024.
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5.4 Santa Clara Valley Transportation Authority Travel Model
The VTA Travel Model was used to develop the VMT forecasts for this study. A description of the VTA
travel model, land use inputs, and transportation network inputs are discussed in the following sections.
5.4.1 VTA Travel Model Documentation
A comparison of the available travel forecasting models for the City of Cupertino was conducted and
documented in Chapter 4 and Appendix C of the SB 743 Implementation Decisions for the City of
Cupertino (Fehr & Peers, February 2021). As noted in Chapter 2, the VTA Travel Model was selected to
establish VMT thresholds and conduct VMT assessments in Cupertino. This version of the VTA Travel
Model uses 2015 as its base year, and 2040 as its cumulative horizon year. Updates to the land use in
Cupertino were made to reflect 2019 conditions.
The VTA Model includes the regional roadways and major arterials of the nine-county Bay Area, the
Association of Monterey Bay Area Governments (AMBAG) region (Santa Cruz County, Monterey County,
and San Benito County), and portions of the San Joaquin (Central) Valley. There are additional
transportation network details and refined transportation analysis zones (TAZs)15 in San Mateo County
and Santa Clara County. The VTA Model land use inputs are based on Association of Bay Area
Governments (ABAG) 2017 land use projections (Plan Bay Area 2040 land use projections), 2010 Census
socio-economic data (with some additional refinements in 2019), and a future regional transportation
infrastructure consistent with Plan Bay Area 2040 (July 2017). The VTA Model has a 2040 horizon year.
The TAZ size influences the types of streets vehicle traffic is typically assigned to. For the VTA Model, an
arterial or minor arterial is the lowest street level that traffic is assigned to because the TAZ structure in
Cupertino has moderate detail. The VTA Model has a mode share model that can be used to express
changes in mode share.
The future year VTA Model is used to develop forecasts for Cumulative (2040) Conditions and includes
projected growth to Year 2040. The future roadway network was developed based on planned and funded
improvements identified in the financially constrained roadway improvement project list from the Valley
Transportation Plan (VTP) 2040 published by the VTA (October 2014), and the City’s 2040 General Plan
Infrastructure Element. This roadway network used the Future Year (2030) scenario and the regional
roadway improvements within Cupertino are summarized below (with VTP 2040 project numbers
in parentheses).
15 Transportation analysis zones, also referred to as TAZs, are small geographic areas within the VTA Model. As
defined by NCHRP Report 716, Travel Demand Forecasting: Parameters and Techniques, TRB, 2012, “TAZ boundaries
are usually major roadways, jurisdictional borders, and geographic boundaries and are defined by homogeneous
land uses to the extent possible.”
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• SR 85 HOV/express lanes from South San Jose to Mountain View (H1)
• I-280 express lanes from Leland Avenue to Magdalena Avenue (H11)
• I-280 northbound second exit lane to Foothill Expressway (H35)
• I-280 northbound braided ramps between Foothill Expressway and SR 85 (H45)
• Lawrence Expressway expand to eight lanes from Moorpark Avenue to South of Calvert
Drive (X10)
• McClellan Road widening and bike lanes between Foothill Boulevard and Byrne Avenue and
between Stelling Road and De Anza Boulevard (R2)
The VTA Model has four time periods to address travel during congested morning and evening peak
periods and uncongested mid-day and midnight time periods. During congested times, the average trip
length and speed of travel change.
5.4.1.1 Model Input Adjustments
For the purpose of this VMT analysis, the baseline (2015) VTA Model land use, population, and roadway
network inputs were updated for the entire planning area to reflect current (Year 2019) development
conditions in the City of Cupertino. The major changes were centered around the 2019 conditions of the
Apple campus and Vallco projects. In addition, the Year 2040 VTA Model was updated to reflect the full
definition of the approved Apple campus and Vallco projects.
The VMT forecasts are based on recent model runs as of November 2023 with adjustments made to
include travel outside of the model area (an adjustment that adds three to five percent to the geographic
VMT values—refer to Appendix F of the SB 743 Implementation Decisions for the City of Cupertino report
for the external station adjustments).
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6. Environmental Impacts and
Mitigation Assessment
This section describes the analysis methods, assumptions, and results used to identify potential significant
impacts of the proposed Project on the transportation system per the significance criteria described in
Chapter 4. Transportation/traffic impacts are described and assessed, and mitigation measures are
recommended for impacts identified as significant.
6.1 Plan Conflict Analysis
This section provides an overview of the transit, roadway, bicycle, and pedestrian evaluations and
identifications of potential impacts.
6.1.1 Transit and Carpool Evaluation
Implementation of the proposed Project will not result in modifications to the transit network that would
disrupt existing facilities or services, or interfere with the implementation of planned facilities/services
contained in adopted programs, plans, policies, or ordinances. Further, future developments will be
required to comply with VTA, city, state, and/or other design standards regarding transportation facilities.
However, the proposed Project would lead to increases in the City’s residential population in Cupertino,
which would increase the demand for transit facilities and services, and would cause additional roadway
traffic congestion that may affect several transit corridors by increasing travel times and decreasing
headway reliability for transit vehicles. Potential increases in transit vehicle delay would occur as a result of
buses operating in mixed-flow lanes with other vehicles.
The VTA operates the bus and light rail transit system in Cupertino and in partnership with Cupertino and
other member agencies will make service changes over time based on the equitable distribution of the
following performance measures (VTA's Title VI: System-Wide Service Standards and Policies, OPS-PL-
0059; November 2013):
• Vehicle Load
• Vehicle Headways
• On-Time Performance
• Service Availability
• Ridership Productivity
The increase in demand for transit service and transit vehicle delay caused by the proposed Project would
be accommodated by existing and planned improvements to the transit system, such as improving access
to transit for local residents and employees (e.g., transit stop enhancements, sidewalk widening, etc.), and
improving how transit vehicles move in and around the City of Cupertino (e.g., new and more frequent
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bus services, expansion of the VTA system, provision of transit-focused facilities, etc.). This effort to
increase or modify transit service capacity and operations would be approved by a publicly appointed
decision body (like the VTA board).
The proposed Project includes General Plan and zoning updates to accommodate the additional
residential housing in Cupertino required by the City’s 6th Cycle Housing Element (2023-2031). The City’s
General Plan includes goals to enhance access to transit and increase connections between land uses and
the transportation system.
• Goal M-1: Actively participate in regional planning processes to coordinate local planning and to
advocate for decisions that meet and complement the needs of Cupertino.
• Goal M-2: Promote improvements to city streets that safely accommodate all transportation
modes and persons of all abilities.
• Goal M-4: Promote local and regional transit that is efficient, frequent, convenient, and reduces
traffic impacts.
• Goal M-5: Ensure safe and efficient pedestrian and bicycle access to schools while working to
reduce school-related congestion.
• Goal M-8: Promote policies to help achieve state, regional, and local air quality and greenhouse
gas emission reduction targets.
• Goal M-9: Promote effective and efficient use of the city's transportation network and services.
• Goal M-10: Ensure that the city's transportation infrastructure is well-maintained for all modes of
transportation and that projects are prioritized on their ability to meet the City's mobility goals.
The General Plan policies and strategies provide additional detail regarding the underlying expectations of
how population and employment will be supported and how the community will travel.
To meet the desired outcomes stated above, the multimodal improvements would need to address transit
ridership trends16 and include access to transit and access by transit improvements, such as transit stop
enhancements, direct bicycle and pedestrian network enhancements to transit stops, and street
operational improvements (e.g., signal coordination, transit vehicle preemption, etc.) that enhance transit
reliability and travel time.
The Project is supportive of the transit use and goals summarized in Chapter 3. Therefore, the impact
relative to disruption of existing or planned transit or carpool facilities or conflicts with transit programs,
plans, ordinances, or policies would be less-than-significant.
16 Santa Clara Valley Transportation Authority. Annual Report 2019. Available online at
https://www.vta.org/sites/default/files/2020-04/AnnualReport2019_Accessible.pdf
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6.1.2 Roadway Evaluation
The Project does not include modifications to the roadway network and future developments will be
required to comply with city, state, and/or other design standards regarding transportation facilities. Thus,
the Project would not be expected to interfere with existing roadway facilities nor conflict with planned
roadway facilities, adopted plans, guidelines, policies, or standards. Therefore, the impact relative to
disruption of existing or planned roadways or conflicts with programs, plans, ordinances, or policies
through the implementation of the proposed Project would be less-than-significant on roadway
facilities, and no mitigation would be required.
6.1.3 Bicycle Evaluation
The Project does not include modifications to the bicycle network and future developments will be
required to comply with city, state, and/or other design standards regarding transportation facilities. Thus,
the Project would not be expected to interfere with existing bicycle facilities nor conflict with planned
bicycle facilities, adopted plans, guidelines, policies, or standards. The Project is supportive of bicycle
usage by locating new residential developments in proximity to existing or planned bicycle paths,
bikeshare stations, and on-road bicycle facilities; and providing connections to existing and planned
bicycle facilities aligns with the overall goals and policies of the plans described in Chapter 3. This
promotion of bicycle usage is desired based on the General Plan goals and does not conflict with planned
bicycle facilities or conflict with adopted plans, guidelines, policies, or standards. Therefore, the impact
relative to disruption of existing or planned bicycle facilities or conflicts with programs, plans, ordinances,
or policies through the implementation of the proposed Project would be less-than-significant on
bicycle facilities, and no mitigation would be required.
6.1.4 Pedestrian Evaluation
The Project does not include modifications to the pedestrian network and future developments will be
required to comply with city, state, and/or other design standards regarding transportation facilities. Thus,
the Project would not be expected to interfere with existing pedestrian facilities nor conflict with planned
pedestrian facilities, adopted plans, guidelines, policies, or standards. The Project is supportive of walking
by locating new residential developments in proximity to existing or planned pedestrian facilities; and
providing connections to existing and planned pedestrian facilities aligns with the overall goals and
policies of the plans described in Chapter 3. Therefore, the impact relative to disruption of existing or
planned pedestrian facilities or conflicts with programs, plans, ordinances, or policies through the
implementation of the proposed Project would be less-than-significant on pedestrian facilities, and no
mitigation would be required.
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6.2 VMT Analysis
This section presents an analysis of the Project’s impacts relative to VMT. Both Project-generated and
Project’s effect on VMT impacts were evaluated. Direct VMT impacts were evaluated using the citywide
total VMT per service population under Existing with Project Conditions. The Project’s effects on VMT
impacts were evaluated using countywide boundary VMT per service population under Existing with
Project Conditions and Cumulative with Project Conditions. The results of the Project-generated VMT and
Project’s effect on VMT analyses are presented in Table 9, Table 13, and Table 14.
6.2.1 Project Generated VMT Analysis (Project Analysis)
Below is a description of the Project-generated VMT impact analysis and the associated VMT mitigation.
6.2.1.1 Total Project Generated VMT Assessment
As shown in Table 9, the Project would generate 3,927,390 daily total VMT, or 34.80 miles on a per service
population basis. This value would be approximately 11% greater than the VMT threshold (31.30 total
VMT per service population). Implementation of the Project would result in a total Project-generated VMT
per service population under Existing with Project Conditions that is higher than the applicable threshold.
Therefore, the impact of the Project total VMT rate would be potentially significant.
Table 9: Total Project Generated VMT Assessment
Existing Conditions Existing with Project
Conditions
City of Cupertino
Total Project Generated Vehicle Miles Traveled (A)1 3,772,000 3,927,390
Service Population (B)1,2 103,170 112,870
Total Project Generated VMT per Service Population (A/B = C) 36.56 34.80
Initial Impact Assessment
Total VMT per Service Population Threshold 31.30 31.30
(Initial Impact Conclusion) Potentially Significant
Notes:
1. Rounded service population and VMT to nearest 10.
2. Service population is defined as the sum of all residents and employees.
Source: Fehr & Peers, 2024.
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6.2.1.2 Total Project Generated VMT Mitigation
This analysis concludes that the total Project-generated VMT rate will be more than the applicable
threshold. The Cupertino General Plan and Rezoning total Project-generated VMT rate is the result of the
local land use context and land use changes throughout the Bay Area region, Santa Clara County, and
within the City of Cupertino. The Project can include VMT mitigation measures to reduce the total Project-
generated VMT by implementing a transportation demand management (TDM) plan, physical site design
elements, or policies and infrastructure for location efficiency.
TDM refers to strategies that incentivize alternatives to automobile travel, either through financial
incentives for walking, biking, and riding transit, or through additional costs to automobile use at project
sites. The current standard for calculating VMT reduction efficacy from TDM strategies is the California Air
Pollution Control Officers Association (CAPCOA) 2021 Handbook for Analyzing GHG Emission Reductions,
Assessing Climate Vulnerabilities, and Advancing Health and Equity. The handbook quantifies the effects of
numerous land use and design strategies including travel incentives and disincentives.
The effectiveness of different TDM strategies varies widely based on local context, scale of intervention,
and availability of non-automotive transportation. TDM strategies are most effective when implemented
in a policy environment that encourages land use location efficiency and infrastructure investments that
support transit, walking, and bicycling. Measures that more typically come to mind when considering
TDM, such as building-specific subsidy and marketing programs for transit or other non-drive-alone
modes, or installation of bicycle racks, tend to be less effective than community-wide strategies and
investments. Furthermore, programs tied to individual projects or buildings may vary in efficacy based
solely on the final building tenants.
VMT mitigation measures evaluated for the Project are listed below, noting the maximum VMT reduction
observed in literature. The effectiveness of TDM strategies varies based on local context, scale of
intervention, and availability of non-automotive transportation. As a function of these factors, the
effectiveness of the listed measures does not reach the maximum reduction for the Project.
• Project-Level Measures
◦ Limit parking supply: When combined with companion TDM measures, reduced parking
supply discourages driving by limiting easy and convenient parking options. Implementation
of this strategy may require reducing (or removing) minimum parking requirements and
allowing developers to use shared parking strategies. (Reduction range: 0 to 13.7%)
◦ Unbundle parking costs: Unbundling separates parking costs from property cost, for
instance by not including a parking space in a residential unit’s rent, or by requiring
employers to lease each parking space separately from the building owner. This strategy
ensures that the user understands that the cost of driving includes parking and can
encourage people to use an alternative mode to save money. (Reduction range: 0 to 15.7%)
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◦ Employ marketing and encouragement strategies to promote non-drive-alone travel:
This strategy encompasses the aspects of typical TDM programs that rely on providing
customized information and incentives to encourage use of transportation alternatives in
place of single occupancy vehicles. The process is typically a residential-based approach for
each community. (Reduction range: 0 to 2.3%)
• Community-Level Measures
◦ Provide ride-sharing programs: This strategy focuses on encouraging carpooling and
vanpooling by project site/building tenants and has similar limitations to strategy (2) above.
The City of Cupertino is currently served by Silicon Valley Hopper, an on-demand rideshare
shuttle through Via Transportation, that provides pickup and drop-off transportation services
anywhere within the city service area. (Reduction range: 0 to 8%)
◦ Implement car-sharing program: This strategy reduces the need to own a vehicle or
reduces the number of vehicles owned by a household by making it convenient to access a
shared vehicle for those trips where vehicle use is essential. Examples include programs such
as ZipCar, Car2Go, and Gig. (Reduction range: 0 to 0.15%)
◦ Implement Bikeshare, Electric Bikeshare, and Scootershare Program: This strategy will
establish a bikeshare and scootershare program. The projects provide users with on-demand
access to bicycles, electric pedal assist bicycles, and electric scooters for short-term rentals.
They encourage mode shift from vehicles to bicycles and scooters, displacing VMT and thus
reducing GHG emissions. (Reduction range: 0 to 1%)
◦ Implement on-street market pricing for parking: This strategy focuses on implementing a
pricing strategy for parking by pricing all on-street parking in central business districts,
employment centers, and retail centers. Priced parking would encourage “park once” behavior
and may also result in area-wide mode shifts. (Reduction range: 0 to 30%)
• County/Region-Level Measures
◦ Increase transit service frequency and speed: This strategy focuses on improving transit
service convenience and travel time competitiveness with driving. Given existing land use
density in Cupertino, this strategy may be limited to traditional commuter transit where trips
can be pooled at the start and end locations, or it may require new forms of demand-
responsive transit service. A demand-responsive service could be provided as subsidized trips
by contracting to private TNCs or taxi companies. Alternatively, a public transit operator could
provide the subsidized service but would need to improve on traditional cost effectiveness.
Note that implementation of this strategy would require regional or local agency
implementation, substantial changes to current transit practices, and would not likely be
applicable for individual development projects. (Reduction range: 0 to 4.6%)
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The VMT reductions research is based on three VMT types:
household VMT
commute VMT
total VMT
The VTA travel model is a trip-based travel model that categorizes these VMT types as:
home-based-other VMT: Any VMT other than work with one end at the household (e.g. going to
the grocery store from home).
home-based-work VMT: Only VMT from home to work or vice versa.
non-home-based VMT: Any VMT that does not start or end at a household (e.g. going out to
lunch at work).
The project-level, community-level, and county/region-level mitigation measure reductions were applied
by VMT type (e.g., Home-based other, home-based work, and non-home based VMT). Table 10 presents
the VMT reduction percentages categorized by VMT type, and at the project area and citywide level.
Project Area reduction percentages are the reductions for just the project sites and presented for
informational purposes. However, the total VMT is evaluated at the citywide level, and thus the VMT
reductions are converted to total citywide VMT reductions so that a total citywide VMT per service
population reduction can be calculated.
Table 10: VMT Mitigation Measure Reduction Percentages
Measure Type
Home-Based Other
VMT
Home-Based Work
VMT
Non Home-Based
VMT
Project
Area
Citywide Project
Area
Citywide Project
Area
Citywide
Project-Level TDM Measures 6.0% 0.3% 6.0% 0.3% 4.9% 0.2%
Community-Level TDM Measures 3.9% 3.9% 5.8% 5.8% 3.9% 3.9%
County/Region-Level Measures 0.5% 0.5% 0.5% 0.5% 0.5% 0.5%
Total (including Multiplicative
Dampening1) 10.1% 4.7% 11.9% 6.5% 9.1% 4.6%
Notes:
1. Because many strategies are complementary, the estimated totals are dampened to account for overlap in their impacts.
Detailed guidance for combining the VMT reduction effects of TDM strategies is provided in Chapter 3 of the Handbook
for Analyzing GHG Emission Reductions, Assessing Climate Vulnerabilities, and Advancing Health and Equity (CAPCOA,
2021). As a result, the total reduction is less than the sum of the project-level measures, community-level measures, and
county/region-level mitigation measures.
Source: CAPCOA 2021, Fehr & Peers, 2024
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Table 11 presents citywide reduction percentages applied to citywide VMT. The calculations show a
resulting 5.3% total VMT reduction.
Table 11: Citywide VMT Reduction by VMT Type
VMT Type
Total VMT
Without TDM
Reductions (A)
TDM Reduction
Percentages (B)
VMT Reductions
(C)
Total VMT With
TDM Reductions
(A+C = D)
Home-Based Other VMT 1,686,460 -4.7% -79,260 1,303,760
Home-Based Work VMT 1,349,670 -6.5% -87,730 881,170
Non Home-Based VMT 891,260 -4.6% -41,000 1,534,470
Total VMT 3,927,390 -5.3% -207,990 3,719,400
Source: Fehr & Peers, 2024
Overall, CAPCOA indicates that projects in suburban areas may be able to achieve up to a 15% reduction
in VMT. However, achieving this level of reduction requires that the project implement many individual
project-level strategies (such as TDM and site design strategies) and be sited in an efficient, transit-
adjacent location. These traits may not be feasible in all locations within Cupertino. In addition, project-
level TDM strategies are often implemented by individual building tenants so their use requires ongoing
monitoring and adjusting to account for changes in tenants and their travel behavior.
Due to these project-specific implementation barriers, ad-hoc project-by-project mitigation is less
effective for reducing VMT compared with larger scale program-based approaches, such as an impact fee
program that funds transit expansion, or land use and zoning changes at a citywide level. The emergence
of these new mitigation concepts presents opportunities to reduce VMT at a citywide or regional scale,
though the measured effects of these programs (and their ability to reach desired long-term land use
outcomes) are largely unknown.
When making a VMT impact determination, other available evidence related to VMT trends in California
was considered; specifically, CARB’s 2017 Climate Change Scoping Plan Update17 and 2022 Scoping Plan
Update,18 which assumes that all of the regions in the state will meet the GHG reduction targets set in
their Regional Transportation Plans and Sustainable Communities Strategies (RTP/SCS). Thus far, there is
indication that not all regions are meeting those targets, and vehicular travel in California (at least prior to
the COVID-19 pandemic) has been increasing rather than decreasing over the past several years (see
CARB’s Improved Program Measurement Would Help California Work More Strategically to Meet Its Climate
Change Goals, February 2021, and CARB’s 2018 Progress Report: California’s Sustainable Community and
17 California Air Resources Board’s 2017 Climate Change Scoping Plan Update: The Strategy for Achieving California’s
2030 Greenhouse Gas Target (January 2019)
18 California Air Resources Board’s 2022 Scoping Plan Update (November 2022)
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Climate Protection Act, November 2018). The 2020 Mobile Source Strategy (California Air Resources Board
2021) also acknowledges the challenge of VMT reduction and states, “Without additional policy
intervention, VMT may continue to rise.”
The Scoping Plan reviews California’s progress for meeting GHG reduction goals and sets forth strategies
to achieve those goals based on past performance. The plan acknowledges that the state is not meeting
its VMT reduction objectives and that VMT growth is returning after COVID-19 pandemic effects diminish.
After a significant pandemic-induced reduction in VMT during 2020, passenger VMT has steadily
climbed back up and is now closing in on pre-pandemic levels. Driving alone with no passengers
remains the primary mode of travel in California, amounting to 75 percent of the mode share for
daily commute trips. Conversely, transit ridership, which was also heavily affected during the
lockdown months, has not recovered at the same pace as VMT, and roughly averages two-thirds of
pre-pandemic levels of ridership.19
This evidence demonstrates the challenge of reducing VMT when background macro-level conditions are
contributing to higher VMT generation rates.
Additionally, declining transit ridership trends20 in Santa Clara County (at least prior to the COVID-19
pandemic) suggest that the supportive polices at all levels may not be effective at increasing transit
ridership and decreasing VMT. This is because limited facilities exist that prioritize travel by high
occupancy vehicles and many of the vehicles (i.e., private vehicles and public transit) on the regional
streets in Santa Clara County have limited capacity because streets are routinely filled up during peak
periods by vehicles with poor seat utilization. Therefore, public transit in Santa Clara County often
experiences inefficiencies or deficiencies, which contributes to lower transit demand and higher demand
for vehicle use contributing to higher VMT.
Further, this VMT analysis does not account for any future increases in the use of TNCs (such as Uber and
Lyft) or commercial delivery services, nor does it envision the potential for development of autonomous
vehicles or any other emerging transportation innovations. These emerging transportation innovations
will alter the effectiveness of VMT mitigation action, some increasing VMT reduction effectiveness while
others decreasing VMT reduction effectiveness.
In summary, the Project prioritizes higher residential densities than those currently allowed in Cupertino.
From a land use planning perspective, the City has been very proactive in promoting a land use pattern
that provides convenient access to transit, places, jobs, services, and housing in close proximity, and
establishes residential densities that provide for dense and walkable neighborhoods. These land use
strategies represent some of the most effective tools available to Cupertino to reduce VMT through sound
land use planning.
19 https://ww2.arb.ca.gov/sites/default/files/2022-05/2022-draft-sp.pdf (page 155)
20 Santa Clara Valley Transportation Authority. Annual Report 2019. Available online at
https://www.vta.org/sites/default/files/2020-04/AnnualReport2019_Accessible.pdf
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The proposed Project, land use forecasts, and targeted areas for growth are the result of an extensive
outreach process among staff, policymakers, and the public to arrive at a solution that balances
competing concerns about accommodating housing growth, jobs growth, and quality of life. The Project
achieves meaningful reductions in VMT generated by land uses within the City. However, as previously
discussed, major reductions in VMT would be required to achieve the threshold. The City at this time
cannot demonstrate that VMT will be reduced to the degree that is needed to meet these thresholds.
VMT reduction also depends on several factors such as demographic change, household preferences for
housing types and locations, the cost of fuel, and the competitiveness of regional transit relative to
driving. Improving regional transit relative to driving relates to congestion along vehicular commute
routes that are not under the City’s jurisdiction, as well as transit provided by agencies other than the City.
Additionally, no county-wide or region-wide VMT mitigation programs currently exist.
As described above, the Project reduces VMT through the higher density residential development.
However, in order to reduce VMT to a less than significant level, the City must rely on additional
assistance from regional and state-level agencies to affect major changes in driving patterns and
behaviors throughout the greater Bay Area region. The biggest effects of VMT mitigation actions (and
resultant emissions reductions) derive from statewide or region-wide policies that increase the cost, or
reduce the convenience, of using vehicles. The City of Cupertino cannot effectively or practically
implement statewide or region-wide policies, other than to be supportive of and complementary to these
efforts in the City’s General Plan, which the City has done, as described above.
Table 12 presents the Project-generated total VMT per service population that includes the mitigations
calculated above in Table 11. There are no additional feasible mitigation strategies available to the City to
reduce this impact to a less than significant level. Therefore, implementation of the proposed Project
would result in a VMT impact that would be considered significant-and-unavoidable.
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Table 12: Total Project Generated VMT with Mitigations Assessment
Existing with Project
Conditions
Existing with Project
Conditions with
Mitigations
City of Cupertino
Total Project Generated Vehicle Miles Traveled (A)1 3,927,390 3,719,400
Service Population (B)1,2 112,870 112,870
Total Project Generated VMT per Service Population (A/B = C) 34.80 32.95
Initial Impact Assessment
Total VMT per Service Population Threshold 31.30 31.30
(Initial Impact Conclusion) Potentially Significant Significant and
Unavoidable
Notes:
1. Rounded service population and VMT to nearest 10.
2. Service population is defined as the sum of all residents and employees.
Source: Fehr & Peers, 2024.
6.2.2 Project’s Effect on VMT Analysis
As shown in Table 13, under Existing with Project Conditions the countywide boundary VMT per service
population of 13.49 is less than the applicable threshold of 13.51. Therefore, the impact of the Project’s
effect on VMT under Existing with Project Conditions would be less-than-significant.
As shown in Table 14, under Cumulative with Project Conditions the region boundary VMT per service
population of 12.51 is less than the applicable threshold of 12.53. Therefore, the impact of the Project’s
effect on VMT under Cumulative with Project Conditions would be less-than-significant.
Table 13: Project’s Effect (Boundary) VMT Assessment under Existing Conditions
Existing Conditions Existing with
Project Conditions
Santa Clara County
Boundary Vehicle Miles Traveled (A)1 39,258,000 39,318,000
Service Population (B)1,2 2,905,260 2,914,960
Boundary VMT per Service Population (A/B = C) 13.51 13.49
Boundary VMT per Service Population Threshold 13.51
(Initial Impact Conclusion) Less Than Significant
Notes:
1. Rounded service population and VMT to nearest 10.
2. Service population is defined as the sum of all residents and employees.
Source: Fehr & Peers, 2024.
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Table 14: Project’s Effect (Boundary) VMT Assessment under Cumulative Conditions
Cumulative Conditions Cumulative with
Project Conditions
Santa Clara County
Boundary Vehicle Miles Traveled (A)1 48,413,000 48,479,000
Service Population (B)1,2 3,864,050 3,873,750
Boundary VMT per Service Population (A/B = C) 12.53 12.51
Boundary VMT per Service Population Threshold 12.53
(Initial Impact Conclusion) Less Than Significant
Notes:
1. Rounded service population and VMT to nearest 10.
2. Service population is defined as the sum of all residents and employees.
Source: Fehr & Peers, 2024.
6.2.3 Regional Transportation Plan/Sustainable Community Strategy Plan Consistency
The purpose of this section is to discuss the proposed Project’s consistency with the policies in the
region’s Regional Transportation Plan/Sustainable Communities Strategy (RTP/SCS), also known as Plan
Bay Area 2050 (July 2021),21 and to provide an analysis of the proposed Project’s impacts on
transportation policies for the region. The Metropolitan Transportation Commission (MTC) and the
Association of Bay Area Governments (ABAG) are the designated metropolitan planning organizations
and, as such, are mandated by the federal government to research and draw up plans for transportation,
growth management, hazardous waste management, and air quality. This analysis considers each Plan Bay
Area 2050 strategy (i.e., Housing, Economic, Transportation, and Environmental) listed in Section 4.1. The
Project does not conflict with the goals or policies in Plan Bay Area 2050. Appendix B includes the goals
included in Plan Bay Area 2050 and demonstrates the Project’s consistency with the plan.
The Project does not propose changes to the transit system that would impact the Plan Bay Area 2050
(2021) goals of expanding the role transit plays in meeting the region’s mobility needs such as
investments in bus rapid transit, expansion of local services, and planned rail projects.
Overall, the proposed Project would not conflict with existing or planned transportation facilities because
the proposed Project is to update general plan land use designations and zoning updates. The proposed
Project would not be expected to interfere with existing roadway facilities; conflict with planned roadway
facilities; or conflict with adopted transportation plans, guidelines, policies, or standards. Further, as show
in Appendix B, the Project supports or does not obstruct the Plan Bay Area strategies. Therefore, the
impact relative to disruption of existing or planned roadways or conflicts with programs, plans,
ordinances, or policies would be less-than-significant.
21 Metropolitan Transportation Commission, 2021. Plan Bay Area 2050. Available online at Plan Bay Area 2050 | Plan
Bay Area.
Appendix A:
Transportation Analysis Zone Map
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VTA Transportation Analysis Zones in Cupertino
Cupertino City Limits
VTA TAZs in Cupertino
Figure 1
1Mile
Appendix B:
Regional Transportation
Plan/Sustainable Community Strategy
Plan Consistency
Table B-1: Plan Bay Area 2050 Consistency Evaluation
Plan Bay Area 2050 Strategy
Consistency Evaluation
Explanation Supports Obstructs Does not
Obstruct
Housing Strategies
H1
Further strengthen renter protections
beyond state law. Building upon recent
tenant protection laws, limit annual rent
increases to the rate of inflation, while
exempting units less than 10 years old.
X
Project policies do not affect
renter protections. The Project
will increase the available
affordable housing, which is
supportive of managing rent.
H2
Preserve existing affordable housing.
Acquire homes currently affordable to low
and middle-income residents for
preservation as permanently deed-
restricted affordable housing.
X
The Project is designed to
provide adequate inventory of
housing sites to meet the
required Regional Housing
Needs Allocation (RHNA). Any
affordable housing that is
demolished will be rebuilt.
H3
Allow a greater mix of housing
densities and types in Growth
Geographies. Allow a variety of housing
types at a range of densities to be built in
Priority Development Areas, select Transit-
Rich Areas, and select High-Resource
Areas.
X
The Project will allow the
addition of a variety of
housing types in the City of
Cupertino at levels required by
the RHNA.
H4
Build adequate affordable housing to
ensure homes for all. Construct enough
deed restricted affordable homes to fill
the existing gap in housing for the
unhoused community and to meet the
needs of low-income households.
X The Project will accommodate
additional affordable housing.
H5
Integrate affordable housing into all
major housing projects. Require a
baseline of 10-20% of new market-rate
housing developments of five units or
more to be affordable to low-income
households.
X The Project will accommodate
additional affordable housing.
H6
Transform aging malls and office parks
into neighborhoods. Permit and promote
the reuse of shopping malls and office
parks with limited commercial viability as
neighborhoods with housing for residents
at all income levels.
X The Project will not affect this
policy.
Plan Bay Area 2050 Strategy
Consistency Evaluation
Explanation Supports Obstructs Does not
Obstruct
H7
Provide targeted mortgage, rental and
small business assistance to Equity
Priority Communities. Provide assistance
to low-income communities and
communities of color to address the
legacy of exclusion and predatory lending,
while helping to grow locally owned
businesses.
X The Project will not affect this
policy.
H8
Accelerate reuse of public and
community-owned land for mixed-
income housing and essential services.
Help public agencies, community land
trusts and other non-profit landowners
accelerate the development of mixed-
income affordable housing.
X The Project will not affect this
policy.
Economic Strategies
EC1
Implement a statewide universal basic
income. Provide an average $500 per
month payment to all Bay Area
households to improve family stability,
promote economic mobility and increase
consumer spending.
X The Project does not affect this
policy.
EC2
Expand job training and incubator
programs. Fund assistance programs for
establishing new businesses, as well as job
training programs, primarily in historically
disinvested communities.
X The Project does not directly
affect this policy.
EC3
Invest in high-speed internet in
underserved low-income communities.
Provide direct subsidies and construct
public infrastructure to ensure all
communities have affordable access to
high-speed internet.
X The Project does not affect this
policy.
Plan Bay Area 2050 Strategy
Consistency Evaluation
Explanation Supports Obstructs Does not
Obstruct
EC4
Allow greater commercial densities in
Growth Geographies. Allow greater
densities for new commercial
development in select Priority
Development Areas and Transit-Rich
Areas to encourage more jobs to locate
near public transit.
X The Project will not affect this
policy.
EC5
Provide incentives to employers to shift
jobs to housing-rich areas well served
by transit. Provide subsidies to encourage
employers to relocate off ices to housing-
rich areas near regional rail stations.
X The Project will not directly
affect this policy.
EC6
Retain and invest in key industrial
lands. Implement local land use policies
to protect key industrial lands, identified
as Priority Production Areas, while funding
key infrastructure improvements in these
areas.
X The Project will not affect this
policy.
EN7
Expand commute trip reduction
programs at major employers. Set a
sustainable commute target for major
employers as part of an expanded Bay
Area Commuter Benefits Program, with
employers responsible for funding
incentives and disincentives to shift auto
commuters to any combination of
telecommuting, transit, walking and/or
bicycling.
X The Project will not affect this
policy.
EN8
Expand clean vehicle initiatives. Expand
investments in clean vehicles, including
more fuel-efficient vehicles and electric
vehicle subsidies and chargers.
X The Project will not affect this
policy.
EN9
Expand transportation demand
management initiatives. Expand
investments in programs like vanpools,
bikeshare, carshare and parking fees to
discourage solo driving.
X The Project will not affect this
policy.
Plan Bay Area 2050 Strategy
Consistency Evaluation
Explanation Supports Obstructs Does not
Obstruct
Transportation Strategies
T1
Restore, operate, and maintain the
existing system. Commit to operate and
maintain the Bay Area’s roads and transit
infrastructure while overseeing pandemic-
related cuts to total transit service hours.
X The Project will not
significantly affect the existing
system.
T2
Support community-led transportation
enhancements in Equity Priority
Communities. Provide direct funding to
historically marginalized communities for
locally identified transportation needs.
X The Project will not affect this
policy.
T3
Enable a seamless mobility experience.
Eliminate barriers to multi-operator transit
trips by streamlining fare payment and
trip planning while requiring schedule
coordination at timed transfer hubs.
X The Project will not affect this
policy.
T4
Reform regional transit fare policy.
Streamline fare payment and replace
existing operator specific discounted fare
programs with an integrated fare structure
across all transit operators.
X The Project will not affect this
policy.
T5
Implement per-mile tolling on
congested freeways with transit
alternatives. Apply a per-mile charge on
auto travel on select congested freeway
corridors where transit alternatives exist,
with discounts for carpoolers, low-income
residents, and off-peak travel; and reinvest
excess revenues into transit alternatives in
the corridor.
X The Project will not affect this
policy.
T6
Improve interchanges and address
highway bottlenecks. Rebuild
interchanges and widen key highway
bottlenecks to achieve short- to medium-
term congestion relief.
X The Project will not directly
affect this policy.
Plan Bay Area 2050 Strategy
Consistency Evaluation
Explanation Supports Obstructs Does not
Obstruct
T7
Advance other regional programs and
local priorities. Fund regional programs
like motorist aid and 511 while supporting
local transportation investments on
arterials and local streets.
X The Project will not affect this
policy.
T8
Build a Complete Streets network.
Enhance streets to promote walking,
biking and other micro-mobility through
sidewalk improvements, car-free slow
streets, and 10,000 miles of bike lanes or
multi-use paths.
X The Project will not affect this
policy.
T9
Advance regional Vision Zero policy
through street design and reduced
speeds. Reduce speed limits to between
20 and 35 miles per hour on local streets
and 55 miles per hour on freeways, relying
on design elements on local streets and
automated speed enforcement on
freeways.
X The Project will not affect this
policy.
T10
Enhance local transit frequency,
capacity and reliability. Improve the
quality and availability of local bus and
light rail service, with new bus rapid transit
lines, South Bay light rail extensions, and
frequency increases focused in lower-
income communities.
X The Project will not affect this
policy.
T11
Expand and modernize the regional rail
network. Better connect communities
while increasing frequencies by advancing
the Link21 new transbay rail crossing,
BART to Silicon Valley Phase 2, Valley Link,
Caltrain Downtown Rail Extension and
Caltrain/High-Speed Rail grade
separations, among other projects.
X The Project will not affect this
policy.
Plan Bay Area 2050 Strategy
Consistency Evaluation
Explanation Supports Obstructs Does not
Obstruct
T12
Build an integrated regional express
lanes and express bus network.
Complete the buildout of the regional
express lanes network to provide
uncongested freeway lanes for new and
improved express bus services, carpools,
and toll-paying solo drivers.
X The Project will not affect this
policy.
Environmental Strategies
EN1
Adapt to sea level rise. Protect shoreline
communities affected by sea level rise,
prioritizing low-cost, high-benefit
solutions, and providing additional
support to vulnerable populations.
X The Project does not affect this
policy.
EN2
Provide means-based financial support
to retrofit existing residential buildings.
Adopt building ordinances and incentivize
retrofits to existing buildings to meet
higher seismic, wildfire, water, and energy
standards, providing means-based
subsidies to offset associated costs.
X The Project will not affect this
policy.
EN3
Fund energy upgrades to enable carbon
neutrality in all existing commercial
and public buildings. Support
electrification and resilient power system
upgrades in all public and commercial
buildings.
X The Project will not affect this
policy.
EN4
Maintain urban growth boundaries.
Using urban growth boundaries and other
existing environmental protections, focus
new development within the existing
urban footprint or areas otherwise suitable
for growth, as established by local
jurisdictions.
X The Project focuses growth
within the Project area.
Plan Bay Area 2050 Strategy
Consistency Evaluation
Explanation Supports Obstructs Does not
Obstruct
EN5
Protect and manage high-value
conservation lands. Provide strategic
matching funds to help conserve and
maintain high-priority natural and
agricultural lands, including but not
limited to, Priority Conservation Areas and
wildland-urban interface areas.
X The Project will not affect
high-value conservation lands.
EN6
Modernize and expand parks, trails,
and recreation facilities. Invest in quality
parks, trails and open spaces that provide
inclusive recreation opportunities for
people of all backgrounds, abilities, and
ages to enjoy.
X The Project will not affect
existing parks.
EN7
Expand commute trip reduction
programs at major employers. Set a
sustainable commute target for major
employers as part of an expanded Bay
Area Commuter Benefits Program, with
employers responsible for funding
incentives and disincentives to shift auto
commuters to any combination of
telecommuting, transit, walking and/or
bicycling.
X The Project will not affect this
policy.
EN8
Expand clean vehicle initiatives. Expand
investments in clean vehicles, including
more fuel-efficient vehicles and electric
vehicle subsidies and chargers.
X The Project will not affect this
policy.
EN9
Expand transportation demand
management initiatives. Expand
investments in programs like vanpools,
bikeshare, carshare and parking fees to
discourage solo driving.
X The Project will not affect this
policy.
Source: MTC Plan Bay Area 2050 Consistency Checklist, 2023; Fehr & Peers, 2024.