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VMT
Mitigation

Approaches and Examples

 

VMT Mitigation Approaches

The SB 743 Implementation Assistance Project considered different ways to mitigate the additional vehicle miles traveled (VMT) that would be generated by the case study projects.  The project organized a series of workshops to explore and compare VMT mitigation strategies, drawing on established practices in impact mitigation. Approaches included:

1. Project-level mitigation 

This refers to actions/programs that could be carried out by a lead agency within its authority. Two workshops in 2017 - one in Los Angeles and one in Sacramento - offered sessions where participants devised project-level mitigation proposals for different case studies. To help participants identify effective mitigation strategies, a simple spreadsheet was developed based on a 2010 paper prepared for CAPCOA (California Pollution Control Officers Association) which summarizes and quantifies different methods for reducing VMT - such as by tolling freeway lanes, or initiating parking charges. The spreadsheet and other materials from these workshops can be found below. (A 2017 technical memorandum by Fehr & Peers assesses and summarizes new research - since release of the 2010 CAPCOA paper - on the effectiveness of transportation demand management (TDM) for reducing VMT.) 

2. Tiering

Another mitigation approach under CEQA (see Pub. Resources Code sections 21093–21094), tiering is carried out by developing a general broad analysis and mitigation strategy for a plan, program, ordinance or range of activities, then using that analysis and mitigation strategy to cover the impacts of a specific project implementing that plan or program. This strategy was not specifically examined as part of the case studies, although it was noted if the project being studied was a beneficiary of tiering. 

3. Regional-level mitigation  

Regional mitigation strategies provide a means for mitigating impacts that are beyond the boundaries or jurisdiction of the responsible agency and thus beyond its ability to implement.  An example of such a strategy would be a fee paid by each project within a region (or state) into a common pool that can then be used to pay for mitigation throughout the region (or state). Such fees are common when wetlands are developed, and are used to create replacement wetlands elsewhere. A white paper (listed below) by Neil Peacock, commissioned by the SB 743 project’s Leadership Team, describes the many and interesting precedents for regional-level VMT mitigation.

4. VMT offset exchanges 

The VMT offset exchange concept was explored in two workshops in 2018, one in Los Angeles and one in San Jose. An offset exchange system would match VMT-generating projects with VMT-reducing projects, facilitated by a payment or other exchange.  The approach draws on concepts from cap-and-trade and transfer-of-development-rights (TDR) programs, as well as regional-level VMT mitigation precedents described in a white paper below. This approach is transactional and scalable and does not require establishing a uniform regional fee.  A white paper (listed below) by Robert Liberty, prepared for the workshop, discusses the VMT exchange concept in detail.

 
 
 

VMT Mitigation Concepts and Examples

White Papers from Workshops

Workshop Presentations on VMT Exchange Concept 

Each paper and accompanying slide presentation describes a potential VMT exchange program/project, its VMT reduction effects, and the estimated cost of executing or expanding the program. Programs could be carried out by government, nonprofit, or for-profit entities.

Other Workshop Materials and VMT Mitigation Resources

  • Pasadena VMT Experience - Mike Bagheri describes Pasadena’s project-level mitigation level efforts. The city has chosen to apply VMT reduction impact standards to road projects as well as land use projects. Presented at SB 743 Project’s professional education event in L.A. (3/1/19), now available online for credit.

  • VMT Exchange Working Group (no website yet) -  this group was established to develop VMT exchange systems within California to address mitigation needs. The group meets bimonthly to discuss ongoing work around the state on the set up of exchanges and similar broad VMT mitigation strategies. Members come from many levels of government including state, MPO, and city, as well as consultants who are working to explore and implement these types of programs. To join the group contact Ramses Madou, Division Manager, Planning, Policy, and Sustainability, Department of Transportation, City of San Jose, ramses.madou@sanjoseca.gov | desk:408-975-3283 | cell:650-924-1237.

CEQA and Mitigation

CEQA requires public agencies to consider feasible alternatives and mitigation measures that would substantially reduce any significant adverse environmental impacts a proposed project would have on the environment.  To learn more about mitigation under CEQA, see the relevant sections, listed below, from the CEQA Guidelines and CEQA Statute:

Guidelines:

  • § 15021. “Duty to Minimize Environmental Damage and Balance Competing Public Objectives”

  • § 15370. “Mitigation.” (Includes a list of general mitigation strategies.) 

Statute:

  • § 21001. “Additional Legislative Intent”

  • § 21002. “Approval of Projects; Feasible Alternative or Mitigation Measures” 

  • § 21002.1. “Use of Environmental Impact Reports; Policy” 

  • § 21081. “Necessary Findings Where Environmental Impact Report Identifies Effects” 

  • § 21100. “Environmental Impact Report On Proposed State Projects; Significant Effect; Cumulative Impact Analysis” (See especially 21100[c])