Introduction to the Transportation Impact Analysis Guidelines
The Transportation Impact Analysis (TIA) Guidelines are intended to serve as a comprehensive reference for the City of Clovis staff, project applicants, and consultants. These guidelines clarify the requirements for evaluating transportation impacts associated with land development projects, infrastructure improvements, and planning efforts, particularly in the context of the California Environmental Quality Act (CEQA). This document outlines a consistent framework to assess how proposed projects may affect the local and regional transportation system, ensuring compliance with both State mandates and local policies.
The TIA Guidelines are structured to achieve the following objectives:
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Ensure compliance with relevant City, State, and regional transportation regulations.
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Support consistent, legally defensible evaluations in accordance with CEQA requirements.
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Establish uniform methodology and report formats to be used by consultants and applicants.
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Provide predictability and transparency for reviewers, decision-makers, and the public.
While the Guidelines aim to be as comprehensive as possible, transportation conditions and project circumstances vary. Therefore, City staff maintain the discretion to modify the scope or methodology of a transportation analysis based on the context of a specific project. Exemptions or refinements to the standard requirements may be applied at the discretion of the City Engineer or other designated reviewers during project application or environmental review.
Guideline Structure and Overview
The TIA Guidelines are organized into the following major sections:
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Section 1 – Introduction: Describes the purpose of the Guidelines, general applicability, and overview of CEQA and local analysis requirements.
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Section 2 – CEQA Transportation Analysis Requirements: Focuses on the implementation of Senate Bill (SB) 743 and associated CEQA guidance, particularly the use of Vehicle Miles Traveled (VMT) as the key metric for assessing environmental impacts.
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Section 3 – Local Transportation Analysis Requirements: Addresses operational and safety assessments that are not part of the CEQA process but are essential for compliance with the City’s General Plan policies and development standards.
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Section 4 – Environmental Review Process: Summarizes the types of environmental documentation and levels of analysis required for different project types based on anticipated transportation impacts.
Together, these sections form a complete roadmap for determining the transportation impact review obligations of a project and defining appropriate analysis approaches.
State-Mandated Transportation Analysis (SB 743 Requirements)
Senate Bill 743, enacted in 2013 and effective statewide as of July 1, 2020, introduced a fundamental change in how transportation impacts are evaluated under CEQA. Previously, projects were analyzed primarily based on Level of Service (LOS), which measured traffic congestion and delay at intersections and roadways. However, LOS-based impact analysis often led to road-widening and intersection expansions that conflict with broader environmental and community goals such as reducing greenhouse gas (GHG) emissions, improving public health, and supporting infill development.
To address these concerns, SB 743 requires that automobile delay and congestion no longer constitute a significant impact under CEQA. Instead, transportation impact analysis must now focus on Vehicle Miles Traveled (VMT) — a metric that quantifies the amount and distance of automobile travel associated with a project. This shift is intended to promote:
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Reduction of GHG emissions;
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Development of multimodal transportation networks; and
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Efficient land use patterns that reduce the need for long-distance vehicle trips.
As a result, LOS and similar metrics are no longer valid for CEQA transportation impact determinations. However, the City of Clovis may still evaluate LOS outside of CEQA to ensure compliance with General Plan goals and to address site-specific operational and safety concerns.
Local Transportation Analysis Requirements
Although VMT is the standard for CEQA impact analysis, local jurisdictions, including Clovis, retain the authority to apply additional transportation review criteria under their planning and entitlement processes. These local requirements are implemented through municipal codes, general plan policies, conditions of approval, and development standards. For example, the City’s 2014 General Plan Circulation Element includes LOS-based performance measures for roadways and intersections.
As part of the City’s land use entitlement process, a Local Transportation Analysis (LTA) may be required to assess:
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Site access and circulation adequacy;
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Intersection and roadway capacity relative to LOS targets;
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Safety concerns for all transportation modes (vehicles, bikes, pedestrians);
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Impacts to emergency vehicle access and public transit operations.
The City Engineer may request a LOS analysis to determine whether mitigation, such as roadway improvements or traffic control modifications, is necessary to maintain consistency with General Plan policies. These requirements apply regardless of a project’s CEQA status and may result in conditions of approval to be implemented during project design or construction.
Transportation Impact Analysis Report Structure
Depending on project type, location, and size, a full Transportation Impact Analysis (TIA) may include both CEQA and Local Transportation components. In general, the TIA may be composed of the following:
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CEQA VMT Analysis: Required for projects that may result in a significant increase in regional or local VMT. The analysis must follow methodologies consistent with SB 743, including appropriate screening criteria, baseline assumptions, and significance thresholds.
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Local Transportation Analysis (LTA): Required when projects may create operational or safety impacts at the local level, regardless of CEQA applicability.
Not all projects will require both components. For example, projects located within Transit Priority Areas (TPAs) or low-VMT zones may be screened from detailed VMT analysis, while still needing a local circulation study. Conversely, a project with significant VMT impacts may be exempt from LTA requirements if it does not materially affect nearby intersections or roadways.
Conclusion
The City of Clovis Transportation Impact Analysis Guidelines are intended to facilitate transparent, consistent, and efficient review of transportation impacts for proposed developments. By aligning with CEQA mandates (SB 743) and retaining local authority over operational concerns, the City can promote balanced land use decisions that support long-term environmental, economic, and mobility objectives. Applicants are encouraged to consult with City staff early in the development process to confirm the scope of transportation analysis required for their project.
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