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The proposed project satisfies none of these categories. It is predominantly a housing project, i.e., not local -serving retail or a school. The Revised Traffic Circulation Analysis estimates that the project would generate 2,751 daily trips after an adjustment for internal capture, and 875 more daily trips than the existing land use on the project site, i.e., much more than 110 daily trips. (Table 5-1, p. 19) As the project fails to satisfy any of the City's three VMT screens, the City's Resolution requires a VMT analysis with the Orange County Transportation Analysis Model ("OCTAM"). This OCTAM analysis is required for this project and has not been done. A Significant VMT Impact Must Be Mitigated The Resolution states: A Significant impact would occur if the project causes total daily VMT within the City to be higher than the no project alternative under cumulative conditions. This analysis should be performed using the 'project effect' method. The Guidelines attached to the Resolution state: Once a significant impact is identified, the project's VMT per capita should be mitigated to be at or less than 15% below the existing Countywide VMT/SP. Mitigation should consist of Transportation Demand Management (TDM) measures analyzed under a VMT-reduction methodology consistent with Chapter 7 of the California Air Pollution Control Officers Association (CAPCOA) Quantifying Greenhouse Gas Mitigation Measures (August 2010) and approved by the City's Traffic Engineering Division. Since the City's Guidelines were adopted, CAPCOA has updated its guidance with the publication of its Handbook for Analyzing Greenhouse Gas Emission Reductions, Assessing Climate Vulnerabilities, and Advancing Health and Equity: Designed for Local Governments, Communities, and Project Developers (Final Draft, December 2021). This newer publication states: The Handbook builds on CAPCOA's previous efforts to provide accurate and reliable quantification measures. In 2010, CAPCOA published Quantifying Greenhouse Gas Mitigation Measures: A Resource for Local Government to Assess Emissions Reductions from Greenhouse Gas Mitigation Measures (hereafter referred to as the "2010 Handbook"). Since that time, climate science has evolved and GHG reduction practices have advanced in sophistication. New priorities have also arisen, such as strengthening climate resilience and infusing health and equity into integrated planning efforts. Therefore, CAPCOA decided it was time to develop an updated and expanded resource to provide the latest data and methods to quantify GHG emissions reductions, climate change vulnerability reductions, and equity improvements in a single resource: The Handbook. (p. 2-3) The City's VMT Guidelines are best followed by applying the updated CALCOA Handbook. Achieving significant VMT mitigation at this project site may be impossible. The Handbook includes 14 quantified VMT reduction measures at the Project/Site scale (p. 63). 9 of the 14 measures involve trip reduction projects that are not applicable to the predominantly residential character of the proposed project. The other 5 measures include 3 land use measures and 2 parking measures. 5