2. CEQA Analysis Requirements
This section outlines the requirements for conducting transportation analyses for projects subject to environmental review under the California Environmental Quality Act (CEQA), particularly in accordance with Senate Bill (SB) 743. Under CEQA, lead agencies such as the City of Clovis have the authority to establish their own significance thresholds and analytical methodologies, provided these are supported by substantial evidence. This flexibility allows each jurisdiction to align its CEQA transportation analysis approach with local development patterns, policy goals, and unique context.
SB 743 mandates the use of Vehicle Miles Traveled (VMT) as the primary metric for evaluating transportation impacts under CEQA, replacing Level of Service (LOS) in determining environmental significance. The CEQA Appendix G Environmental Checklist identifies four key areas of potential transportation-related impacts:
a) Would the project conflict with a program, plan, ordinance, or policy addressing the circulation system, including transit, roadway, bicycle, and pedestrian facilities?
b) Would the project conflict with or be inconsistent with CEQA Guidelines Section 15064.3(b), which requires the use of VMT?
c) Would the project substantially increase hazards due to a design feature (e.g., sharp curves or dangerous intersections) or incompatible uses?
d) Would the project result in inadequate emergency access?
In accordance with CEQA Guidelines Section 15064.3, the City of Clovis has adopted VMT-based thresholds of significance to determine whether a proposed project will result in a significant transportation impact. Additionally, the City has developed project screening criteria to streamline the VMT analysis process for certain projects, which are described in Section 2.1.1.
2.1. Land Use Projects
This section addresses the process for evaluating land use projects to determine whether a detailed VMT analysis is required. Figure 1 (not included here) provides a visual representation of the decision-making flowchart for land use projects under the City’s VMT analysis framework.
2.1.1. Project Screening
Projects are presumed to result in a less-than-significant VMT impact—and therefore may be exempt from a detailed VMT analysis—if they meet at least one of the five screening criteria established by the City of Clovis:
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Small Projects
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Affordable Housing
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Local-Serving Retail and Public Facilities
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High-Quality Transit Area (HQTA) Location
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Location in a Low VMT Area
2.1.1.1. Small Projects
Projects generating fewer than 500 vehicle trips per day are presumed to have a less-than-significant impact on VMT. These thresholds are based on trip generation rates from the Institute of Transportation Engineers (ITE) Trip Generation Manual (10th Edition). For example, a project with up to 53 single-family homes, 68 townhomes, 13,250 square feet of retail space, or 100,800 square feet of light industrial space would typically fall within this category.
2.1.1.2. Affordable Housing
Affordable housing developments, especially those located in High-Quality Transit Areas (HQTAs), may be presumed to have a less-than-significant VMT impact. This presumption only applies if the project is well-served by pedestrian and bicycle infrastructure and located near employment and retail opportunities. If a project includes a mix of market-rate and affordable units, only the affordable portion may be screened out from detailed VMT analysis.
2.1.1.3. Local-Serving Retail and Public Facilities
Retail developments that serve a local market and are 100,000 square feet or less in gross floor area are presumed to generate minimal regional VMT. The City may require a market analysis to confirm that the project primarily serves local needs based on location, size, and the types of goods and services provided. Typical examples include grocery stores, pharmacies, casual dining, fitness centers, and beauty services. In mixed-use projects, the retail portion should be assessed independently for screening.
Similarly, public facilities such as fire and police stations, public utilities, and neighborhood parks are generally presumed to have a less-than-significant impact, as these uses are designed to support local populations. However, this presumption may not apply if the facility is sited in a remote area, causing long-distance travel for employees or users.
2.1.1.4. High-Quality Transit Area (HQTA)
Projects located within a HQTA—defined as areas within one-half mile of a major transit stop or corridor with frequent service—may be exempt from detailed VMT analysis. However, this exemption does not apply if the project:
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Has a floor area ratio (FAR) below 0.75
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Provides more parking than required under City Code (Section 9.32.040), which may discourage transit and active transportation use
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Is inconsistent with the Fresno Council of Governments’ (COG) Sustainable Communities Strategy (SCS)
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Replaces affordable housing units with a reduced number of moderate- or high-income units
Maps identifying HQTA boundaries in Clovis are provided in Attachment A.
2.1.1.5. Low VMT Area Screening
Projects located in areas with below-average VMT may also be exempt from detailed analysis. Screening maps based on Fresno COG’s travel demand model and Traffic Analysis Zones (TAZs) help identify such areas. Projects that qualify include:
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Residential projects in TAZs with VMT per capita at least 13% below the countywide average
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Office or employment uses with VMT per employee at least 13% below the baseline
These TAZs are illustrated in green on the screening maps found in Attachment B.
2.1.1.6. Consistency with RTP/SCS
Projects that are inconsistent with the Fresno COG’s adopted Regional Transportation Plan/Sustainable Communities Strategy (RTP/SCS) may not qualify for VMT screening. In such cases, the City will evaluate whether the inconsistency could result in a significant transportation impact. Projects must demonstrate alignment with regional planning goals to benefit from screening criteria.
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