Cloverdale planning commission recommends council adopt updated circulation element and transportation EIR

CLOVERDALE, Calif. — The Cloverdale Planning Commission voted May 6 to recommend that the City Council certify a subsequent environmental impact report focused on transportation and adopt an updated circulation element to the city—s general plan.

The update responds to state changes that require vehicle miles traveled, or VMT, to be used in CEQA (California Environmental Quality Act) analyses instead of relying solely on level of service, a measure of traffic delay. The commission—s recommendation includes a mitigation monitoring and reporting program and new policies to integrate complete-streets principles and VMT screening and mitigation into future project review.

The circulation element is the portion of the general plan that guides how people and goods move through the city. Mary Bean, vice president at First Carbon Solutions, said SB 743 requires jurisdictions to evaluate transportation impacts using VMT and that the update does not propose physical improvements but rather changes to policies used to assess future projects. "SB 743 came into effect in 2020. It looks at average trip length per capita," Bean said. "The circulation element addresses that and updates policies where needed to affirm that the city is using VMT rather than LOS under CEQA."

Ian, a transportation consultant with Fehr & Peers, briefed the commission on how the updated element retains level-of-service (LOS) analysis for local operational review while shifting CEQA impact determinations to the VMT metric. "Level of service A through F is still useful for intersection operations," Ian said. "But the state has moved to the vehicle miles traveled metric for environmental review." He explained that LOS measurements typically use an AM and PM peak-hour analysis, while VMT evaluates average trip distance and encourages infill and transit-oriented development.

Consultants told commissioners the draft subsequent EIR finds the city meets the VMT reduction target on two of three metrics studied (residents, employees and total VMT), but not on one metric. That shortfall required the EIR to identify a "significant and unavoidable" impact for that metric. Bean described three mitigation approaches included in the document: (1) screening thresholds so some projects do not require detailed VMT analysis (for example, projects within a half-mile of a major transit stop or with a floor area ratio above 0.75); (2) transportation demand management (TDM) measures for projects that do not screen out, such as bike and pedestrian improvements, parking reductions and transit enhancements; and (3) payment into a regional VMT mitigation bank that the Sonoma County Transportation Authority (SCTA) is developing.

Commissioners discussed how the VMT approach affects small and rural jurisdictions that often have higher per-capita travel because residents commute outside town. Planning staff and the consultants said adopting the circulation element and disclosing a citywide significant and unavoidable VMT effect in the general-plan-level EIR provides a path for future projects consistent with the general plan to avoid having to complete separate, full EIRs for VMT impacts, while still requiring application of the document—s mitigation measures.

The commission also noted the project received one comment letter, from Caltrans, which required no changes to the draft EIR. Staff said the city is the CEQA lead agency and that the update was scoped to transportation topics only; other environmental topics were not analyzed in the subsequent EIR.

Motion and next steps: Commissioner Acey moved that the Planning Commission recommend City Council adopt the subsequent EIR and MMRP in connection with the circulation element and approve a general plan amendment to update the circulation element. Commissioner Kadel seconded the motion. The commission voted in favor and the motion passed. Staff will forward the recommendation, the final EIR and the mitigation monitoring and reporting program to the City Council for final action.

The item affects how the city evaluates future development applications under CEQA, especially projects seeking the state—s streamlining benefits. Consultants and staff advised applicants may still choose to perform project-specific VMT analyses; projects in areas with lower VMT can seek to demonstrate they meet the 15% reduction target and thus avoid certain mitigation requirements. The circulation element language adds city policies and implementation measures that list responsible departments, time frames and potential funding sources for implementation.

The commission—s recommendation does not itself adopt the circulation element; it forwards the city staff recommendation and the final EIR to City Council, which will consider certification and approval at a future meeting.