2.1.7. Mitigation of Significant VMT Impacts
Under CEQA, when a project is determined to have significant transportation impacts due to excessive Vehicle Miles Traveled (VMT), feasible mitigation measures must be implemented to reduce these impacts. CEQA defines mitigation broadly to include a variety of strategies, including:
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Avoiding the impact entirely by altering or eliminating part of the project;
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Minimizing the impact by limiting its magnitude or scope;
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Rectifying the impact through restoration or rehabilitation of the affected environment;
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Reducing the impact over time via preservation or maintenance activities;
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Compensating for the impact by substituting or replacing lost environmental functions, potentially through conservation easements or similar long-term protections.
VMT Mitigation Strategies
To reduce VMT-related impacts, projects should implement a combination of measures that decrease the number of automobile trips, shorten travel distances, and promote the use of alternative transportation modes. These can include strategies related to project design, multimodal infrastructure improvements, parking policies, and—most effectively—Transportation Demand Management (TDM) programs.
TDM focuses on shifting travel behavior away from single-occupancy vehicle (SOV) use and peak-period travel. The goal is to reduce reliance on automobile trips and instead encourage more sustainable modes like walking, biking, transit, and carpooling. TDM strategies often involve behavioral incentives and supportive infrastructure. Common TDM measures include:
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Free or subsidized transit passes
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Rideshare or vanpool programs
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Parking cash-out programs
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Guaranteed ride home services for employees
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On-site amenities that support biking and walking
When properly implemented, these measures can reduce VMT, alleviate traffic congestion, lessen parking demand, and increase use of active transportation.
Sources for VMT Reduction Measures
Numerous agencies and organizations have developed tools and methodologies to help estimate and validate the effectiveness of VMT mitigation strategies. The City of Clovis recommends project applicants refer to the following sources for selecting appropriate mitigation measures and estimating potential VMT reductions:
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California Air Resources Board (CARB) – Transportation and land use strategies for reducing GHG emissions
https://ww3.arb.ca.gov/cc/sb375/policies/policies.htm -
California Air Pollution Control Officers Association (CAPCOA) – Handbook for Analyzing Greenhouse Gas Emission Reductions, Assessing Climate Vulnerabilities, and Advancing Health and Equity (2021)
https://www.airquality.org/ClimateChange/Documents/Final%20Handbook_AB434.pdf -
San Diego Association of Governments (SANDAG) – VMT Reduction Calculator Tool
https://www.icommutesd.com/docs/default-source/planning/vmt-reduction-calculatortool_final.xlsx?sfvrsn=4b21b67b_4
Documentation and Approval of Mitigation
Applicants of projects with significant VMT impacts must identify mitigation strategies and estimate the percentage reduction in VMT those strategies will achieve. These estimates must be supported by substantial evidence. The City will evaluate the proposed measures and the calculations used to demonstrate VMT reduction. If the adjusted project VMT falls below the applicable threshold of significance, the impact will be considered mitigated to a less-than-significant level under CEQA.
Mitigation documentation should clearly show:
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Baseline VMT without mitigation
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Projected VMT reduction percentage for each measure
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Total adjusted VMT after mitigation
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Comparison with the threshold of significance
Future Options for VMT Mitigation
The City of Clovis recognizes that site-specific mitigation may not always be feasible—particularly in high-VMT areas where land use or location constraints limit options for meaningful reductions. To address this, the City may explore broader mitigation frameworks such as:
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VMT mitigation fees – Collected from developers and pooled to fund regional transportation improvements
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Mitigation banks – Centralized programs that implement large-scale VMT-reducing projects, allowing developers to buy mitigation credits
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VMT exchange programs – Enabling mitigation in one location to offset impacts from another
These mechanisms allow for flexible, program-level mitigation approaches that can be implemented citywide or regionally. However, these systems require upfront planning, legal frameworks, and funding mechanisms. As a first step, the City will need to assess feasible strategies and determine the physical and operational viability of projects and programs that could serve as effective regional mitigations—such as investments in bicycle, pedestrian, and transit infrastructure.
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