4. LEVEL OF ENVIRONMENTAL REVIEW
The City of Clovis has adopted procedures to ensure that the level of environmental review for land use development projects remains consistent with the standards in place prior to the implementation of SB 743. The intent is to avoid increasing the burden of environmental documentation while still addressing transportation-related impacts under CEQA. This section outlines the appropriate environmental review and transportation analysis requirements based on different project scenarios, with a focus on Vehicle Miles Traveled (VMT) under SB 743, and how they relate to consistency with the City’s General Plan.
4.1. General Plan Circulation Element Update
In 2022, Clovis conducted a focused update to the Circulation Element of its 2014 General Plan. This update added new policies designed to reduce VMT through planning measures such as promoting compact development, enhancing transit options, and supporting active transportation. As part of this update, the City prepared a Supplemental Environmental Impact Report (SEIR) to assess the potential VMT-related impacts of implementing the General Plan.
The SEIR concluded that, despite mitigation efforts, some land uses consistent with the General Plan may still exceed the City’s VMT thresholds. These significant and unavoidable impacts remain due to the inability to confirm that policy-based mitigation would sufficiently reduce VMT levels. However, the SEIR provides a framework for tiering the environmental review of future projects that align with the General Plan. Projects consistent with the General Plan can reference the SEIR rather than preparing new environmental documents disclosing the same impacts. These projects may still be required to implement VMT mitigation measures that align with the Circulation Element policies.
4.2. Environmental Review Scenarios
The type and extent of environmental documentation required for a project will depend on whether it generates transportation or other environmental impacts, and whether it aligns with the General Plan and meets VMT screening criteria. Regardless of whether a project is subject to VMT analysis under CEQA, other transportation-related criteria—such as consistency with transportation policies, hazards, and emergency access—must still be evaluated. A Local Transportation Analysis (LTA) may also be required for operational and safety assessments.
4.2.1. Project Has Non-Transportation Environmental Impacts
If a project is anticipated to result in significant environmental impacts unrelated to transportation—such as air quality, biological resources, or cultural resources—an Environmental Impact Report (EIR) will typically be required. Even if the project qualifies for VMT screening exemption, it may still be required to prepare a TIA that includes a Local Transportation Analysis to address operational and safety concerns.
Likely Environmental Review:
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Environmental Impact Report (EIR)
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Supporting TIA (Local Transportation Analysis may suffice)
4.2.2. Project Has Transportation Impacts Only
For projects where transportation is the only area of potential environmental impact, the level of review depends on whether the project meets the VMT screening criteria and the outcome of any required VMT analysis.
4.2.2.1. Project Meets VMT Screening Criteria
Projects that meet the VMT screening criteria outlined in Section 2.1.1 may be exempt from CEQA VMT analysis. However, even when exempt from VMT analysis, the project must still address other CEQA transportation criteria and conduct a Local Transportation Analysis.
Note: Screening for low-VMT areas must be based on the base year (2019) maps in Attachment B. Future VMT conditions may not be used for screening purposes.
Likely Environmental Review:
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Mitigated Negative Declaration (MND)
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Supporting TIA (may be limited to Local Transportation Analysis)
4.2.2.2. Project Does Not Meet VMT Screening Criteria, But VMT Is Below Threshold
If a project is not eligible for screening, a project-specific VMT analysis must be conducted using the Fresno COG travel demand model to determine the actual VMT impacts. If this analysis demonstrates that the project’s VMT is below applicable thresholds, then no CEQA VMT impact finding is required.
Likely Environmental Review:
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Mitigated Negative Declaration (MND)
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Supporting TIA including Project-Specific VMT Analysis and Local Transportation Analysis
4.2.2.3. Project Does Not Meet Screening Criteria, VMT Above Threshold, Project Consistent with General Plan
If a project fails screening and generates VMT above applicable thresholds, it must identify and implement feasible mitigation. When mitigation cannot reduce impacts below the threshold, a significant and unavoidable impact must be reported. However, if the project is consistent with the General Plan, and its VMT impacts were already disclosed in the SEIR, a less intensive environmental document (e.g., MND) may still be appropriate, provided mitigation measures consistent with General Plan policies are implemented.
Likely Environmental Review:
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Mitigated Negative Declaration (MND) with VMT Mitigation
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Supporting TIA with Project-Specific VMT Analysis and Local Transportation Analysis
4.2.2.4. Project Does Not Meet Screening Criteria, VMT Above Threshold, Not Consistent with General Plan
For projects not consistent with the General Plan, such as General Plan Amendments, the ability to tier from the General Plan SEIR is limited. If a project-specific VMT analysis shows that thresholds are exceeded, mitigation must be identified. If mitigation cannot reduce VMT below the threshold, and the City cannot demonstrate equivalency or improvements relative to pre-project conditions, an EIR will likely be required.
However, if substantial evidence supports the claim that VMT impacts from the project are equivalent to or less than those of the existing conditions, the City may determine the impacts have already been disclosed and documented under the SEIR.
Likely Environmental Review:
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Environmental Impact Report (EIR) with VMT Mitigation and Findings of Overriding Considerations
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Supporting TIA with Project-Specific VMT Analysis and Local Transportation Analysis
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