VMT Mitigation Q & A
Sustainability and the SB 743 Management Team have fielded many questions related to the potential mitigation of VMT impacts for transportation projects on the State Highway System (SHS). Several of the most common questions are addressed below. However, it is important to note that more definitive and detailed guidance can be found in the implementation document, "Transportation Analysis Under CEQA" (Appendix C).
Another topic that is applicable to VMT mitigation is the concept of "additionality". This refers to the assurance that a mitigation investment provides additional resources that otherwise would not have been provided or providing the additional resources substantially earlier than they otherwise would have been available. Our Bulletin on "VMT Mitigation Funding Status and Additionality" addresses this concept.
In addition, a "Mitigation Playbook," detailing specific mitigation measures and means for evaluating them, is under development and review and will be posted once completed in the spring of 2022.
VMT Mitigation: Q & A
Q: What about the proximity of VMT mitigation strategies - how far away can they be from the project?
A: While there is not specific distance or geographic area to point to, generally, the more proximate the mitigation is to the impact, the better. For example, if an impact is identified for a particular community, the benefits of the mitigation should be equitably shared by that community. However, given the broad impacts of increasing VMT, VMT mitigation that has a larger geographic reach that the project corridor can still be considered, as long as the equity considerations are addressed.
Q: Doesn't VMT mitigation have to involve only transportation projects, programs, and stakeholders?
A: No. There are several programs and strategies that have been shown to reduce VMT that are not directly related to improvements to the highway system. For example, denser or more affordable housing can lessen the need for driving in the future, as can expansion of transportation demand management programs. Including support for these kinds of land uses and programs can be an effective method of lowering VMT and can constitute mitigation under CEQA. These kinds of strategies require outreach and the establishment of partnerships that go beyond the "usual" transportation project stakeholders. Forming these types of partnerships has occurred in the past for other transportation project impacts, such as encroachment into sensitive natural habits.
Q: Shouldn't all VMT mitigation features that are considered for a transportation project be biddable and buildable, just like the project's design plans?
A: Not necessarily. If specific multimodal features are included in a project's design (such as bicycle or transit facilities), then they need to be properly incorporated into the plans, whether the design is done by Caltrans or other partner agencies. However, there are many non-capital strategies that reduce VMT (such as demand management programs) that can be included in the scope of a highway project to address the induced VMT impacts. CEQA does require that these be "enforceable", meaning firmly committed to by the relevant parties.
Q: How can transportation funds be used for non-transportation VMT mitigation expenditures?
A: In the same way that transportation funds are used for mitigation of other non-transportation impacts (sensitive habitats, cultural resources, etc.), funds can appropriately be added into highway project budgets to mitigate VMT impacts, which are recognized under the California Environmental Quality Act (CEQA). For example, just as Article 19 (gas tax) funds can be used to acquire off-project land for wetland remediation, they could be used for off-system housing, TDM, or transit support, including transit operating expenses.