2.1.2. Significant Impact Thresholds
For land use development projects in the City of Clovis that do not qualify for VMT screening exemptions, the City has adopted Vehicle Miles Traveled (VMT) significance thresholds based on long-range planning goals and regional greenhouse gas (GHG) reduction targets. In accordance with Senate Bill 743 and the technical guidance provided by the California Office of Planning and Research (OPR), the City uses thresholds that align with regional GHG goals set by the Fresno Council of Governments (Fresno COG), which has established a 13% per capita GHG emissions reduction target for 2035.
Accordingly, residential and office projects are evaluated using a threshold of 13% below the existing regional average VMT per capita or per employee, respectively. Retail projects are evaluated based on whether they generate a net increase in total VMT. Other land uses are assessed on a case-by-case basis, with metrics selected based on the nature and context of the project.
Table 2 summarizes the adopted thresholds:
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Residential: Significant if VMT per capita exceeds 14.1 (13% below Fresno County average of 16.1).
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Office: Significant if VMT per employee exceeds 22.3 (13% below Fresno County average of 25.6).
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Retail: Significant if the project results in a net increase in total VMT within the region.
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Other Land Uses: Evaluated case-by-case. Some uses, like R&D or industrial, may use VMT per employee; others, such as hotels or schools, may use net total VMT.
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Mixed-Use Projects: Each component is evaluated separately using the relevant threshold, or alternatively, the project may be assessed based on its dominant use.
2.1.3. VMT Analysis Methodology
Projects not exempt under the City’s screening criteria must undergo a detailed VMT analysis. VMT is evaluated using metrics derived from the Fresno COG activity-based travel demand model. This model simulates daily travel behavior based on demographic data and household travel surveys. It is calibrated to match observed traffic volumes and validated against regional data, including counts from the Highway Performance Monitoring System (HPMS).
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VMT per Capita includes all vehicle trips made by residents (excluding non-resident trips to homes and trips by non-automobile modes).
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VMT per Employee includes all work-related trips by employees, regardless of the trip origin, but excludes trips made by visitors to the site.
2.1.3.1. Regional Averages
The VMT thresholds for per capita and per employee metrics are based on regional averages produced by the Fresno COG model. These values are periodically updated to reflect evolving land use and travel behavior.
2.1.3.2. Applying VMT Metrics to a Project
Several methods are available for determining a project’s VMT:
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Use the latest available screening maps (Attachment B) to determine the VMT for the project’s location using the corresponding Traffic Analysis Zone (TAZ).
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If data for the TAZ is limited or anomalous, the City may allow averaging across adjacent TAZs.
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For large projects that significantly affect the local land use balance, the Fresno COG model should be rerun with the proposed project to recalculate VMT metrics.
2.1.3.3. Exclusion of Truck VMT
Consistent with CEQA Guidelines Section 15064.3, VMT analyses under SB 743 focus solely on automobile travel. Truck VMT is excluded from the transportation impact analysis, though it remains relevant for other CEQA topics such as air quality, GHG emissions, and noise. Projects generating substantial truck traffic must still evaluate operational impacts on the roadway network as discussed in later sections.
2.1.4. Redevelopment Projects
Redevelopment projects that result in a net reduction in VMT compared to existing land uses are presumed to have less-than-significant transportation impacts. However, if redevelopment leads to an overall increase in VMT, then the project must be evaluated using the thresholds applicable to the proposed land use. For mixed-use redevelopment, each component must be assessed separately.
2.1.5. Land Use Plans
For long-range land use planning documents—such as community plans, specific plans, and general plan updates—the City requires VMT comparisons between existing conditions and projected horizon-year conditions. If the proposed plan results in an increase in per capita or per employee VMT compared to the existing condition, the impact is considered significant. This approach is consistent with OPR guidance and ensures that land use plans support statewide and regional GHG reduction goals.
2.1.6. Cumulative Impacts
Cumulative VMT impacts are evaluated in accordance with CEQA Section 15064(h)(1). Cumulative impacts are determined based on whether the project’s VMT contributes to a significant regional effect. There are two approaches:
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Efficiency Metrics (VMT per Capita or per Employee): Projects below the efficiency thresholds are considered to have less-than-significant cumulative impacts, as they do not exceed regional norms.
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Total VMT: Projects evaluated based on total VMT (e.g., retail, hotel, and transportation facilities) must demonstrate consistency with the General Plan or the Regional Transportation Plan/Sustainable Communities Strategy (RTP/SCS). If a project is consistent, it is presumed to contribute to a cumulative condition that meets long-range transportation goals. Inconsistent projects may require further cumulative impact analysis to assess net increases in VMT.
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