Transportation Projects – VMT Analysis and Mitigation in the City of Clovis
This section outlines the City of Clovis’s approach to evaluating transportation projects with respect to Vehicle Miles Traveled (VMT) impacts. It establishes when a detailed VMT analysis is required, the methodology to be used, applicable thresholds, and potential mitigation strategies. These guidelines support compliance with California Environmental Quality Act (CEQA) requirements and the intent of Senate Bill 743 (SB 743) to prioritize environmental review on projects that may increase driving and vehicle emissions.
2.2.1. Determining the Need for a Detailed VMT Analysis
The City of Clovis requires a VMT analysis for transportation projects that are expected to result in a net increase in vehicle travel, particularly those that encourage single-occupancy vehicle use. Projects that expand roadway capacity, such as adding through travel lanes, are likely candidates for a detailed VMT analysis, as these improvements may induce additional vehicle trips and increase citywide VMT over time.
However, not all transportation projects necessitate such analysis. Projects that have already undergone review as part of a broader citywide plan—such as the Clovis General Plan or a regional transportation plan—may be exempt from additional project-level VMT evaluation. This exemption is granted if the plan-level analysis has already accounted for the project’s VMT impacts and identified any necessary mitigation measures.
On the other hand, transportation projects that are unlikely to significantly increase VMT, especially those designed to improve safety, maintain infrastructure, or promote non-automobile modes of travel, are generally not subject to a VMT analysis. Examples of projects that typically do not require a detailed analysis include:
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Roadway maintenance and rehabilitation
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Traffic safety improvements
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Auxiliary lanes under one mile in length
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New or improved turning lanes
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Conversion of existing lanes to managed or transit-only lanes
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Road diets that reduce the number of travel lanes
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Parking removal or relocation
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New pedestrian, bicycle, or transit infrastructure
A full list of projects that may be exempt from detailed VMT review is provided in Attachment C of the Clovis Transportation Impact Analysis Guidelines. This exemption framework is consistent with the goals of SB 743, which aims to streamline environmentally beneficial transportation projects while ensuring that VMT-increasing projects are properly assessed and mitigated.
2.2.2. Thresholds for Transportation Projects
Transportation projects that have been previously included in and evaluated by a citywide planning document—such as the Clovis General Plan or the Fresno Council of Governments Regional Transportation Plan/Sustainable Communities Strategy (RTP/SCS)—are presumed to have a less-than-significant VMT impact. These projects benefit from the environmental clearance provided by their inclusion in long-range planning efforts.
Projects that are new, modified, or not previously analyzed in citywide plans are subject to further scrutiny. If a transportation project causes a net increase in VMT, it may be considered to have a significant environmental impact under CEQA. Conversely, if a project replaces a previously planned project and would result in a net decrease in VMT compared to the original, it may be found to have a less-than-significant impact.
Determining whether a project results in a net increase or decrease in VMT is essential to assessing whether mitigation is required and what level of environmental review is appropriate.
2.2.3. VMT Analysis Methodology and Tools
For transportation projects that require detailed VMT analysis—such as those that increase vehicular capacity or are not included in existing plans—the City of Clovis requires the use of the most current travel demand model available, typically the Fresno COG regional travel model. This model estimates changes in citywide VMT, including rerouted or induced vehicle trips that may result from project implementation.
To account for induced demand effects from increased capacity, the following formula should be applied:
[% increase in lane miles] × [existing VMT] × [elasticity] = [VMT increase from project]
The City’s standard metric is total VMT within city limits. A project is considered to have a significant impact if it results in any increase in total citywide VMT when analyzed over the long-range planning horizon (typically 20 years from project completion). This policy supports long-term sustainability by discouraging roadway expansions that contribute to induced travel demand and elevated greenhouse gas emissions.
2.2.4. Mitigation Measures for Transportation Projects
If a transportation project is found to result in a significant VMT increase, the City of Clovis will require implementation of feasible mitigation measures to reduce the impact to a less-than-significant level. The goal is to discourage increased reliance on single-occupancy vehicle travel and promote more efficient, sustainable transportation modes.
Example mitigation strategies for transportation projects may include:
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Tolling of new travel lanes to incentivize carpooling and generate funding for transit service
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Conversion of general-purpose lanes to High-Occupancy Vehicle (HOV) or High-Occupancy Toll (HOT) lanes
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Funding or implementation of off-site Transportation Demand Management (TDM) programs
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Deployment of Intelligent Transportation Systems (ITS) to enhance the efficiency of existing infrastructure and reduce unnecessary trips
The City may also consider other mitigation measures, provided they are supported by substantial evidence demonstrating their effectiveness in reducing VMT. These strategies align with regional sustainability goals and the City’s broader commitment to managing transportation impacts responsibly and in accordance with CEQA.
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