Mountain View staff present draft citywide TDM ordinance; commissioners press for clearer monitoring and proportional penalties

City transportation staff presented a draft citywide transportation demand management ordinance framework to the Environmental Planning Commission on Feb. 5, 2025, proposing to screen new development by average daily trips and to require TDM plans and post‑occupancy monitoring for projects estimated to generate more than 200 average daily trips.

The proposal is intended to replace a piecemeal approach that the city has used for TDM requirements and align Mountain View with state and regional policy, staff said. Ben Pacho, transportation planner, said the draft ties screening and mitigation to the city’s VMT analysis and the multimodal handbook and would require a TDM plan before entitlement and annual reporting after occupancy. “If proposed projects generate upwards of 200 average daily trips, they will be required to mitigate vehicle trips by adopting a TDM plan,” Pacho said.

Commissioners and staff framed the framework around three policy areas: applicability (who must comply), requirements (what performance targets and strategies apply) and monitoring and enforcement. Under the draft, trip‑reduction targets would scale with project size: about 30% ADT reduction for small projects (roughly 200–499 ADT), 40% for medium projects (500–999 ADT) and 50% for large projects (1,000+ ADT). Projects would choose from mandatory, core and auxiliary strategies; staff provided a toolkit estimating the relative effectiveness of each strategy. The draft also proposes annual reporting and a penalty structure calibrated to project size, while noting small projects would not initially face monetary penalties for missing targets but would still need to submit reports.

Staff said the shift to average daily trips (ADT) reflects state policy changes such as SB 743 and the city’s VMT policy, and can better capture trips beyond peak periods and total VMT. Ria Hootabarat Lowe, transportation manager, said the ADT approach is “more consistent with that policy and some of the state laws that led to it.” Staff also described ongoing coordination with county and regional efforts, including a potential VTA county program described as similar to “a VMT bank” that could provide off‑site mitigation options if and when it is implemented.

Commissioners raised technical and policy questions throughout a long discussion. Several asked for clearer guidance on how ADT is estimated and how post‑occupancy sampling would be done; staff said ITE trip‑generation rates are used for estimates and driveway counts or pneumatic tube counts are common for sampling, with an agreed sampling period to yield an ADT. Commissioner Hank Dempsey warned that driveway counts can miss trips that park on nearby streets and said, “a large number of the vehicle traffic is just not gonna be counted under that method. That’s deeply concerning to me.” Commissioners suggested broadening sampling to include neighborhood counts where spillover parking occurs.

Other recurring comments: several commissioners asked that peak‑hour or operational metrics be kept as an informative measure (even if ADT is the compliance metric) so the city can better address congestion and neighborhood cut‑through traffic; commissioners also urged better monitoring infrastructure, potentially a shared platform or TMA‑supported service to reduce costs for smaller properties. Multiple commissioners and staff said smaller projects could pool resources through the Mountain View Transportation Management Association for monitoring and other services.

Several commissioners urged staff to revisit the penalty structure and scaling. Commissioners expressed support for a carrot‑first enforcement approach — reporting periods and an opportunity to cure before penalties — but asked staff to develop a proportionate monetary mechanism so small projects are not exempt from any enforcement while avoiding disproportionate fines for minor noncompliance. Staff said practice to date has focused on voluntary correction and that penalties are used rarely; the draft ties penalties to project size with further work planned on per‑trip cost calculations.

Next steps: staff said they will finalize the framework elements and present recommendations to the City Transportation Commission next month, followed by a City Council study session in June and ordinance drafting for potential council adoption in late 2025. The commission asked staff to preserve peak‑hour and operational data as an informative complement to ADT, strengthen sampling guidance to reduce undercounting, and return with a clearer, proportional penalty structure.

Commissioners, staff and consultants indicated broad support for standardizing TDM across projects but highlighted monitoring, sampling and penalty proportionality as the principal issues to resolve before drafting ordinance language.

Looking ahead, staff directed the public and stakeholders to upcoming committee and council briefings where the framework will be refined and to the city’s project webpage for additional materials.