Type: Law Bulletins
Date: 06/30/2023

Chicago Announces Interim Travel Demand Study and Management Guidelines For New Construction Development Projects In Transit Served Locations

On June 16, 2023, the Chicago Department of Transportation (CDOT) announced interim travel demand study and management guidelines for projects located in transit-served locations (the “TDM Guidelines”).

In 2022, the City of Chicago adopted the Connected Communities Ordinance (CCO), amending the Chicago Zoning Ordinance and expanding provisions for transit-served locations. CDOT was granted rulemaking authority to issue Travel Demand Study and Management Rules in line with the CCO. The TDM Guidelines will function as a pilot program for approximately one year before being officially codified into formal rules. The TDM Guidelines became effective on June 16, 2023.

Defining Travel Demand Management and Distinction from Standard Traffic Study

Travel Demand Management (TDM) involves implementing strategies to decrease reliance on motor vehicle transportation and promote active transportation and the use of public transit. To compensate for and balance the parking reductions allowed by the CCO, TDM plans will offer residents and users of new construction projects various transportation alternatives through project-specific programmatic or design strategies.

Unlike a traffic impact study (TIS), which assesses the impact of a development on the surrounding transportation network, projecting traffic volumes and analyzing their effects on capacity, safety, and congestion, a TDM study or plan focuses on reducing vehicular travel generated by a development. In contrast to a focus on traffic engineering considerations, a TDM study or plan proposes strategies to encourage alternative modes of transportation such as public transit, walking, biking, carpooling, and telecommuting.

Projects Covered by Interim Guidelines

The TDM Guidelines now apply to new construction projects in the Business (B), Commercial (C), and Downtown (D) zoning districts that are within a half mile radius of CTA and Metra rail stations. CDOT determines the scope of TDM compliance through a case-by-case assessment following a preliminary review by CDOT’s Plan Review Committee, in accordance with the latest CDOT Plan Review Committee (PRC) submittal guidelines.   

Unless a project is exempt from TDM compliance as a Tier 0 project as explained below, projects generally fall into one of three “tiers” based on their size and scope. Each tier establishes corresponding TDM requirements. All projects subject to TDM compliance must ultimately obtain a CDOT-stamped site plan prior to the issuance of a building permit or before a Plan Commission hearing if the project undergoes Chicago Plan Commission review.

Exemption from TDM Requirements – Tier 0: Tier 0 projects include new construction projects with fewer than 20 dwelling units, less than 10,000 square feet of proposed retail space, less than 30,000 square feet of non-retail commercial space, or less than 50,000 square feet of industrial space. In cases where a mix of uses is proposed, the non-residential square footage is converted into an “equivalent” number of dwelling units to determine whether the project triggers Tier 1, Tier 2, or Tier 3 review. Tier 0 projects generally do not undergo CDOT review or require TDM compliance, unless additional zoning review and approval is triggered, such as special use approval or air quality site plan review.

Tier 1 – CDOT PRC Review Required: Tier 1 projects are those consisting of either 20-50 dwelling units, 10,000-30,000 square feet of retail space, 30,000-50,000 square feet of commercial space, or greater than 50,001 square feet of industrial space. Tier 1 projects must submit a site plan and project narrative to CDOT’s PRC. CDOT PRC evaluates whether further study or TDM requirements will apply on a project-by-project basis.

Tier 2 – CDOT PRC and TDM Memo Required: Tier 2 projects are those consisting of either 51-175 dwelling units, 30,001-75,000 square feet of retail space, or 50,001-150,000 square feet of commercial space. These projects must submit a site plan and project narrative to CDOT PRC. The PRC evaluates the project and determines whether a TDM study and plan will be required, with this decision made on a project-by-project basis.

Tier 3 – TDM Study and Plan Likely Required: Tier 3 projects are those proposing either greater than 175 dwelling units, over 75,000 square feet of retail space, or greater than 150,000 square feet of commercial, non-retail space. A TDM study and plan are likely required for Tier 3 projects.

Following preliminary review by CDOT PRC, new construction projects falling under Tiers 1, 2, or 3 may be directed to provide CDOT with a TDM memo, TDM study, and/or a TDM plan.

  • TDM Memo: A concise memo created by the development team or attorney/consultant outlining pedestrian-oriented design best practices, transportation-related improvements, or other TDM strategies to be incorporated into the development.
  • TDM Study: A comprehensive study, typically prepared by an urban planning or transportation engineering/planning professional, incorporating information and analysis typically found in a TIS, focusing on the specific site location, intended users, and recommendations for optimal TDM practices.
  • TDM Plan: A plan offering recommendations for transportation improvements or strategies specific to a proposed development, detailing the necessary actions to implement these recommendations. The TDM plan is typically integrated into or accompanied by the travel demand study. It also describes ongoing outreach and engagement efforts aimed at informing the public, residents, or tenants about the TDM plan.
  • Ongoing Reporting and Monitoring: CDOT requires ongoing monitoring and reporting related to a TDM plan, including participation in an annual survey that reports project occupancy, parking count, parking utilization, current mode split, and TDM strategy participation.
  • TDM Strategies: The TDM guidelines do not prescribe specific strategies, but CDOT offers a menu of programmatic and design options available here.

Implementation of Guidelines

The interim TDM Guidelines came into effect on June 16, 2023. Projects requiring planned development or special use approval will include TDM review in the standard review processes. “As of right” developments should contact CDOT PRC for guidance on TDM compliance.

CDOT plans to publish draft rules for public comment in Q1 2024, and the formal TDM rules are expected to take effect by the summer of 2024.

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